IR 05000255/1988021
| ML18054A481 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/03/1989 |
| From: | Gill C, Greger L, Michael Kunowski, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054A479 | List: |
| References | |
| 50-255-88-21, NUDOCS 8901120497 | |
| Download: ML18054A481 (31) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report N /880-2-1{.D'*RS~S--+)-----
Docket No. 50-255 Licensee:
Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, Michigan Inspection Conducted:
September 6 through December 8, 1988 Inspectors:
Approved By:
w.~~,
W. ~." Slawinski
/'I. tl, l_* ~
.
M. A. Kunowski
~
L. Robert Greger, Chief Emergency Preparedness and Radiological Protection Branch Inspection Summary License No. DPR-20 11/(JQ/frf Date
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Date Date Inspection on September 6 through December 8, 1988 (Report No. 50-255/88021(DRSS))
Areas Inspected:
Special, announced team inspection of the operational radiation protection program during an outag Areas inspected included:
organization and management controls (IP 83750, 83722); training and qualifications (IP 83750, 83723, 81"729); external exposure controls (IP 83750, 83724); internal exposure controls (IP 83750, 83725); control of radioactive materials and contamination (IP 83750, 83726); facilities and equipment (IP 83750, 83727); ALARA (IP 83750, 83728); outage exposure controls (IP 83750, 83729); licensee actions on previous inspection findings; questions raised by members of a contractor work group; and licensee actions taken regarding several recent event q901120497 890103
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ADOCK 05000255 J.. 1'
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Results:
The organizational structure, management controls, staffing levels, and upper management support appear adequate to establish and maintain a quality radiation protection progra One violation was identified-failure to provide locked doors to prevent unauthorized entry into high radiation areas in which the radiation level is greater than 1000 mR/hour (Section 14).
Also, programmatic weaknesses were identified in the personn_eJ__c_o_1Jt.a=m~in~a~t~i~o~n~~~~~~-i control (Section 12) and ALARA programs (Section 13).
DETAILS Persons Contacted
- C. Axtell, Hea-1-th-Physics Superintendent
- W. Beckman, Radiological Services Manager
- K. Berry, Director, Nuclear Licensing
- K. Block, Training Instructor
- E. Bogue, ALARA Coordinator
- J. Brunet, Licensing Analyst N. Campbell, Senior Health Physicist A. Clark, General Health Physicist J. Cole, Plant Facilities Manager M. Dickson, Radiological Safety Supervisor
- G. Ellis, Radiological Safety Supervisor
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- R. English, Corporate Health Physicist
- R. Fenech, Operations Superintendent
- J. Hadl, Quality Assurance Consultant
- G. Heins, Senior Vice President
- D. Henry, Radiological Safety Supervisor C. Hillman, Plant Chemical Engineer
- D. Hoffman, Vice President, Nuclear Operations
- L. Kenaga, Staff Health Physicist C. Kozup, Technical Engineer
- J. Lewis, Technical Director G. List, Engineering Supervisor
- D. Malone, Licensing Analyst M. Mennucci, Radiological Safety Supervisor
- R. McCaleb, Quality Assurance Director E. Polk, Radiation Materials Control Supervisor R. Rice, Operations Manager P. Ri gozzi, Supervisory Instructor, Trai.ni ng Department
- D. Rogers, Training Administrator
- G. Slade, Plant General Manager H. Tawney, Mechanical Maintenance Superintendent
- A. Davis, NRC/Region III, Regional Administrator
- .. ****.*
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--~--~--~-*--**--*~-*----*-- *-*
- C. Norelius, NRC/Region III, Director, Division of Radiation Safety and Safeguards
- L. Robert Greger, NRC/Region I II, Chief, Emergency Preparedness and Radiological Protection Branch
- B. Burgess, NRC/Region III, Chief, Reactor Projects Section 2A
- E. Swarrson, NRC Senior Resident Inspector
- J. Heller, NRC Resident Inspector The inspectors also contacted other licensee employee *Denotes those present at the onsite exit meeting on November 22, 1988
- Denotes those present at the meeting in the Region III Office on December 8, 198 * General This special team inspection was conducted to review the operational radiation protection progra One team member was onsite intermittently in September and October; the full team was onsite for a week and a half in Novembe Tours of licensee facilities were made to review postings, labeling, access and contamination controls, and to observe radiation protection aspects of work in progres Programmatic weaknesses were noted in the personnel contamination control (Section 12), ALARA (Section 13), and very high radiation area access control (Section 14) program.
Licensee Action on Previous Inspection Findings (IP 83750, 92701)
(Closed) Open Item (255/87032-0l(DRP)):
Review method for revising the ALARA plan and briefing workers about the revisio The licensee's review indicated that (for the job reviewed by the NRC inspector) the required ALARA briefing was conducted when a change in job scope occurred; however, because of a paper-work mixup, a copy of the briefing summary was not attached to the Radiation Work Permit (RWP).
Instead, a copy of the briefing summary for the job as originally planned was still attache The licensee has reemphasized to the radiation protection staff the necessity of maintaining current documentatio This matter is considered close (Closed) Unresolved Item (255/87005-lO(DRSS)):
Review licensee's study showing that monitoring for whole-body dose is adequate to determine dose to the lens of eye, as required by 10 CFR 20, Form NRC-The study has been reviewed by NRC (RIII and NRR); the whole-body dose monitoring system is adequat *
(Closed) Open Item (255/87005-ll(DRSS)):
Licensee should reevaluate the feasibility of establishing additional friskers, with or without shielded bQoths, in more convenient location As a result of the licensee's reevaluation, several additional friskers have been located in the auxi*l i ary buildin However, because of high background and floor loading limitations, placing additional friskers and shielded booths on the stairwell leading from the East and West Safeguards Rooms is reportedly not feasibl The licensee plans to position one shielded booth on the spent fuel pool deck elevation, and one each in the north and south radioactive material storage building.
Organization and Management Controls (IP 83750, 83722)
The inspectors reviewed the licensee's organization and management controls for the Radiation Protection Program including the organizational structure and staffing, staff stability, effectiveness of procedures and other management techniques used to implement the program, and experience concerning self-identification and correction of program implementation weaknesse The HP. Superintendent (HP Operations Group), the Staff HP (HP Support Services Group), the Radioactive Material Control (RMC) Administrator
- ,,,
(Radwaste Group), and a Senior Health Physicist (Industrial Hygiene)
report directly to the Radiological Services Department (RSD) Manage The Senior Health Physicist (Industrial Hygiene) is assisted by a Nuclear Operations Analys Two Radiation Safety Supervisors, the Senior Nuclear Plant_ Emerge.ncy Planning Coordinator, e General Nuclear Erner enc P-lanner, the General Health Physicist, a Senior HP Clerk, an HP Specialist, and two Radiation Protection Technicians (RPTs) report to the Staff H The RMC Supervisor (shipping), the Rad/Chem Supervisor, a Senior Engineering Technician, a Nuclear Operations Analyst, five RPTs, five Radwaste Handlers, and six advanced unskilled workers report to the RMC Administrato The HP Operations Group consists of the HP Superintendent, an HP Specialist, the ALARA Coordinator, a Senior HP, two Radiation Safety Supervisors, and 16 RPTs._ Jhe licensee is hiring three experienced, ANSI 18.1-1971 qua l ifi eaRPTSTir-*nn *ttrree recent openings due to internal transfers/promotions; with this addition, 22 of the 26 RPTs will be ANSI qualifie The inspectors s~lectively reviewed RPT qualification documeAtation; no problems were note Because of the low staff turnover rate and incre.ased RPT qualification/experience level, the licensee does not plan to augment the staff with contract RPTs after the current outag Management involvement in radiation protection is evident in that the weakness correction programs delineated in Inspection Report No. 50-255/87030 are still receiving strong management support and new proposed improvement programs are generally receiving appropriate management attentio One apparent exception is the program to improve radiation worker practices. * This plant-wide effort involves corrective action to be taken by all plant. departments with most of the primary
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actions to be taken by the Radiological Services and Training Department Many of the problems were identified by plant workers and first-line supervisors during worker group discussions with RSD representatives and radiation worker practice inspections conducted jointly by RSD representatives and other departments* first-line supervisor Major actions taken/planned by the Training Department include upgrading the observation training program, elimination of NGET-requalification practical factors waivers, increasing RSD step-off-pad (SOP) coaching skills, improving OJT for plant workers and contractors, and improving RPT continuing trainin The RSD plans to be more involved in supervisory work activity observations, increase decontamination/laundry efforts and the use of SOP coaches, and make facility change The licensee had planned to have this program well implemented before the current outage; however, the unexpected early start of the outage, the need to quickly obtain and train contract workers, and (perhaps) a shortage of contract RPTs resulted in radiation workers less well-qualified and RP supervised than desirabl This likely contributed to the large number of personnel contamination events (PCEs) during this outag If the existing radiation worker practices improvement program is fully implemented as now scheduled during 1989, it is expected that the frequency of PCEs will be significantly reduced.
- No violations or deviations were identifie.
Changes (IP 83750, 83729)
The inspectors reviewed changes in organizational, personnel, facilities, equipment, programs, and procedures that cm1ld affect the outage._.,1...;ra~d~iu:a~t~i~onu._ ___ _
protection progra During this outage, the station RPTs and crewleaders are providing continuous coverage, seven days per week, by working twelve-hour days, five days per wee Two Radiation Safety Supervisors during the weekdays and other RSD supervisory personnel during the weekend days split the Duty Health Physicist function to provide 24-hour continuous coverag Evidence of contract RPT oversight is exhibited by the 1icensee 1 s po 1 icy-*-*----.c of appointing station RPTs as crewleaders, with contract RPTs as alternate crewleader This scheme, combined with tours by Radiological Safety Supervisors, heal th physicists, and the A LARA Coordinator, *appears to provide adequate oversight of contract RPT activitie No violations or deviations were identifie.
Audits and Appraisals (IP 83750)
The inspectors reviewed* reports of audits and appraisals conducted by the licensee including audits required by technical specification Also reviewed were management techniques used to implement the audit program, and experience concerning identification and correction of programmatic weaknesse As noted in Section 12, the licensee's QA group has been conducting monthly personnel contamination and radiation worker practice surveillances since January 198 These surveillances were initiated at the request of plant management and consist of personnel contamination report and data trending review and tours of radiologically controlled areas (RCAs) to observe radiation worker practices and housekeepin The surveillances, which appear to be thorough and well documented, indicate the licensee continues to experience significant problems in these area Numerous specific examples of poor radiation worker and contamination control practices are repeatedly noted in the surveillance report Additionally, Radiological Incident Report (RIR) No.88-024, generated during the outage, exemplifies what may be a plant-wide indifferent attitude toward proper work practices and contamination control To date, efforts to improve these problems appear to have lacked the aggressiveness and necessary plant and corporate management support to be fully successfu Similar concerns have been previously expressed (Inspection Reports No. 50-255/87030 and 50-255/88006).
The licensee intends to continue these monthly surveillance The report of the last annual QA audit of the Health Physics and Packaging/Shipping of Radioac1ive Material programs, conducted on October 3-7, 1988, was reviewed by the inspector The audit resulted in
three observations that are all considered adverse to quality and require corrective actions; these actions are pendin The observations consisted of (1) failure to require nasal smears and whole body counts for individuals contaminated in excess of 1000 cpm above the neck;
- --** -*.. - -(2} the need.. to develop acceptance criteria for verifying waste classification and characteristics, and (3) the need to remove chipped and peeling paint inside containment and evaluate its effect on fouling sump strainer The auditors also noted that twelve of twenty-nine RIRs generated during the first nine months of 1988 were attributable to poor radiation worker practices including worker disregard for health physics instructions and inattentiveness of RPT The audit report indicated that the level of corrective and disciplinary action for certain practices lacked. the appropriate worker sanctj9ns and was not commensurate with the ___ grarny**-ortfie-tfrob l e Othe*r *a:udi tor concerns included two RIRs involving unlocked lR/hr doors (five similar examples were noted in the 1987 audit report (Inspection Report No. 50-255/88006)).
Inspector concerns regarding access controls to > lR/hr areas are described in Section 1 The QA audit and appraisal program appears good; thorough radiation protection program area audits/surveillances were performed in 198 No violations or deviations were identified by the inspector.
Planning Preparation (IP 83750, 83729)
The inspectors reviewed the outage planning and preparation performed by the licensee, including:
additional staffing, sp_ecial training, increased equipment supplies, and job-related health physics consideration During the outage, the plant 1s HP Operations Group has been augmented with up to approximately 80 contract RPTs, consisting of about 70 senior
. and 10 junior technician The original RSD request was for approximately 100 contract RPTs; reportedly, the reduction in staff was made by management for budgetary reason The inspectors-conducted plant tours and interviewed utility and contract RPTs, as well as utility supervisory and management personnel, to determine if the redtiction in requested contract RPT staff had a significant negative effect on the. outage radiological safety progra It appears that, at times, the RPT staff was barely able to provide adequate job coverage to support scheduled outage activiti~s; some personnel indicated that outage tasks were sometimes delayed until RPTs were available for job coverag Some utility crewleaders/RPTs indicated that the reduced percentage of contract RPT returnees (30% this outage compared to 85% last outage)
required more detailed oversight by plant personnel of contract RPTs because of lower contract RPT plant familiarity than during previous outage However, overall it appears that the RPT job coverage was adequat One highly visible aspect of the licensee 1s radiation protection program, personnel contamination, appears *to have been negatively impacted by the strained outage resources and planning (see Section 12).
Overall the supplies of portable survey instruments, portable ventilation equipment, respiratory protection equipment, and protective clothing
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appeared adequate for the outag Licensee representatives stated that on several occasions during the outage, the supply of telescoping high-range G-M meters and portable HEPA-equipped vacuum cleaners was insufficien ~~~~---;-;-No~v~i~o'l-a7 t7 io_n_s~o-r--;-d-ev-1'*a~t*i-o_n_s_w_e_r_e--;-i'de-n~t~i~f~i-e~a-.~~~~~~~~~--~--
- Training and Qualifications of Personnel (IP 83750, 83723, 83729)
The inspectors reviewed the training and qualifications aspects of the licensee's radiation protection, radwaste, and transportation programs including:
changes in responsibilities, policies, programs and methods; qualifications of newly-hired or promoted radiation--protection personnel; and provisions for appropriate radiation protection, radwaste and transportation training for station personne Also reviewed were management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse The inspectors reviewed the education and experience qualifications of contract radiation protection personnel and training provided to the Observations and conclusions discussed in Section 7 of Inspection Report No. 50-255/87002 are still vali No problems were note The inspectors _reviewed the training programs for RPT qualification and continuing training, NGET, basic radiation workers, and radioactive waste, handler qualification; no significant problems were note The inspectors also *reviewed the Advanced Radiation Worker Training Program which is *part of the qualification requirements for members of the Operations Department to allow self-monitoring in designated high radiation areas (HRAs).
Interviews with licensee representatives and review of lesson plans, qualification requirements, OJT, practical factors, and selected examination records indicate that this qualification program should be adequate to permit members of the operations department to
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provide sufficient self-monitoring in designated HRAs under proper RSD oversigh The inspectors discussed with RSD supervisory and managerial personnel the importance of maintaining adequate RSD oversight of this program and the desirability of taking appropriate action if the privilege of self-monitoring is abuse As noted in Section 4 above, the Training Department has been assigned a major role in the licensee's program to improve radiation worker practice However, the delays in implementing the program and the early outage resulted in radiation workers being less well trained than planned and appear to have contributed to the large number of PCEs which occurred during the outag No violations or deviations were identified.
9. *
External Exposure Control and Personal Dosimetry (IP 83750, 83724)
The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including:
changes in facilities, equipment, personnel, and procedures; adequacy of tb_e___d_Qsimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks; required records, reports, and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse The inspectors reviewed the licensee's personal dosimetry programs *far
_coinplj_ance with 10 CFR 20.202 concerning National Voluntary Laboratory
---AtcY*ea*fratiLon Pr-C>gram (NVLAP) retjlifrements for dosimetry processor The licensee's self-administerd dosimetry program employs a Teledyne TLD system that is NVLAP accredited for ANSI-Nl3.ll Test Categories II, IV, V, VII, and VII The licensee is not NVLAP accredited for Categories I, III, and VI, corresponding to low-energy photons and high/low energy photon mixture The low-energy photons are characteristic of x-ray emissions in the 20-70 keV energy rang According to preliminary results of a study performed at the station, characteristic x-rays produced from system radioactivity (primarily Fe-55 activation product contamination)
do not contribute significantly to either deep or skin dos Although the licensee is not NVLAP accredited for determining exposure for low-energy photons, they contend that any such exposures are conservatively determined due to the inherent overresponse of calcium-based TL materials to photon energies less than 100 ke However, due to replacement part availability and other concerns, the licensee. is considering discontinuance of their current TLD system and evaluating another vendor's equipmen The licensee plans to initiate NVLAP accreditation performance testing for a self-administered Panasonic system within the next few month As of November 1, 1988, the licensee instituted the use of a single-chip ring badge for hand exposure monitorin The ring contains one LiB04 thermoluminescent chip, and replaces the 4-chip dosimeter (containing 2 Li804 chips and 2 CaS04 chips) formerly used for hand monitorin The licensee continues to use the 4-chip dosimeter as the secondary whole-body dosimete Both monitoring devices, the single chip ring and the 4-chip dosimeter, are provided to the licensee by the same vendor (Panas'onic).
While there is a reduction of dosimetry information as a.result of switching from the 4-chip dosimeter to a I-chip dosimeter, the omitted information is not required for regulatory purpose The inspectors reviewed selected dose records for 1988; no problems were note As discussed in Section 12, contamination levels associated with the recent high number of personal contaminations have been low, and 10 CFR 20 limits for whole-body skin dose have not been approached as a result of contamination on any worker While most of the contamination found on workers is low-level and dispersed over the body, the licensee has identified some contamination in the form of relatively high-activity,
localized particles (hot particles).
Licensee representatives reported that 48 hot particles have been found on workers in 198 Isotopic analyses of these particles typically have indicated the presence of only Co-6 Skin dose calculation for hot particles and for contaminations of at least 10,000 counts per minute as measured with a pancake probe is performed with a me.:tb.qd also used at the Big Reek--plant (see Inspection Report No. 50-155/88004 for a description of this method).
Skin dose calculations for several hot particle contamination events were reviewed by the inspector For one of these events, involving a hot particle found on the heel of a worker, the licensee calculated a dose of 6.9 rem to the foot of the worker (compared to the 10 CFR 20 dose limit of 18.75 rem).
For another event, involving a hot particle found on the shoulder of a diver, the license~-determined that for the five minutes the particle was apparently on the diver's shoulder, 329 mrem dose accrued to the skin of the whole bod However, the licensee later determined that the particle probably was on the diver's right thumb for about one hour during the dive, and was transferred to the shoulder when the diver removed his diving suit and protective clothing after completing the div (The licensee found a pin-hole leak in the right thumb of the diver's diving suit.) Radiation protection personnel covering the dive reportedly observed the diver touch his shoulder with his right hand while removing his clothing after the div The licensee calculated that the diver's thumb received approximately 4 rem from the particl In another contamination event (on October 7, 1988), a diver was contaminated over a large portion of the body with low-levels of radioactive materia Apparently the diver had informed his supervisor via a communication line early in the dive that the diving suit was leaking; however, contrary to station policy, the supervisor instructed the diver to stay in the water and complete the div Licensee representative stated to the inspectors that after learning of these facts, they revoked the dive supervisor's access to the plant and have modified the diving communication line to allow RP personnel to listen i This matter will be reviewed further at a future inspection (Open Item 255/88021-09).
Inspector review of the licensee's skin, extremity, and whole-body dose determinations for these events identified no problem No violations or deviations were identifie.
Internal Exposure Control (IP 83750, 83725)
The inspectors reviewed the licensee's internal exposure control and assessment programs, including:
changes to facilities, equipment, and procedures affecting internal exposure control and personal exposure assessment; determination whether respiratory equipment, and assessment of individual intakes meet regulatory requirements; required records, reports, and notifications; effectiveness of management techniques used to impl~ment these programs, and experience concerning self-identification and correction of program implementation weaknesse d
- Respiratory Protection Program Selected aspects of the licensee's respiratory protection program were reviewed, including respirator selection, issuance and accountabili
- g and maintenance, fit testing, training, and provisions for MPC-hour determinations; results of the review are discussed.belo Implementation of the licensee's respiratory protection program is governed by 10 CFR 20 requirements, Station Procedure No. HP 7.0, and a corporate policy statement on respirator usag Personnel whose duties may require the use of respiratory protection equipment are required to complete initial training and periodic retraining in the
- use*arttie equipment, a biennial fit test and an annual medical exam and/or pulmonary function tes Respiratory protection training is provided by the station's training department as a supplement to NGET and includes an annual requalificatio The inspectors discussed the respiratory protection training program with a training instructor; no significant problems were note However, although respirator selection and usage is discussed in the training course and practiced to some extent during the fit testing process, it appears desirable for each trainee to physically demonstrate proper respirator usage (donning, removal, etc.) as part of the training clas Respiratory fit testing is.accomplished in the station's fit test booth employing a smoke or corn oil atmospher The fit test equipment is periodically checked, calibrated, and routine mirintenance performed as necessar No problems were note To obtain a respirator, workers report to the access control desk where training, fit testing, medical qualifications and equipment approval data are maintained on compute The inspectors reviewed respirator qualification/training documentation for several plant and contractor personnel; no problems were identifie The computer database appears to be properly maintained and includes relevant and current informatio After approval is verified, the appropriate respirator is issued by the RPT manning the des After use, respirators are individually bagged and deposited in a 55-gallon drum located near access contro No method is inplace for worker-respirator accountability/traceability nor for smearing used and returned respirators prior to cleanin According to the licensee, lack of a respirator survey and accountability program has not posed significant problems and does not appear necessary at this tim If accountability and/or respiratory equipment related contamination control problems arise in the future, such a program should be considere This matter was discussed at the exit meeting.
During the outage, used respirators were machine washed by contract workers and inspected by RPT A check of respirators ready for issuance indicated that adequate attention is given to inspection and maintenanc No unattended respirators were observed in the plan i-------.---Tn.....--n----;;----~----- Hour Accountability and Tracking MPC-hour accountability methods, procedures, and documentation were reviewe MPC-hours are tracked, at the discretion-of the duty health physicist, when the possibility exists that a worker 1s uptake could approach 40 MPC-hours in seven days as indicated by air sample results, or if tracking is prerequired by the RW If required by RWP-,-job coverage RPTs are responsible for air sampling and recording worker area entry/exit times and other necessary information on MPC-hour log sheet Normally, MPC-hours are calculated and assigned at the discretion of the duty HP based on review of (computer-tracked) air sample results, area occupancy, and other relevant factor The evaluation performed by the duty HP is based on available information, subjective health physics judgement, and is not dictated by procedure or specific mechanism, nor is the evaluation documented for further/future revie If MPC-hour tracking is deemed appropriate, pertinent information is recorded on the previously referenced 11MPC-hour log 11 sheets._ The desirability to standardize the MPC-hour evaluation methods and document the outcome was
_discussed with the license The licensee is attempting to devise a generic evaluation form for this purpos No problems were noted with the methods and practices employed for job specific (RWP) air activity determinatio Air samples are collected by RPTs and results reviewed by the duty HP at least shiftl Whole-Body Count Evaluation Methods The inspectors reviewed the lic~nsee 1 s methods and practices for evaluating levels of internally deposited radioactivity CMPC-hours)
based on investigation of whole-body count result The licensee computes MPC-hours from acute and chronic intakes using whole-body count results and methods delineated in Station Procedure No. HP 8.2, Whole-Body Count Evaluation Procedur The procedure, however, is based primarily on ICRP-2 methodology and consequently attempts to utilize biologic models derived for chronic intakes to estimate actual acute intake The use of ICRP-30 methodology would be more appropriate in most nuclear power plant intake incident Use of ICRP-2 derived values could result in MPC-hour under-estimation, particularly when the acute intake is from an isotope with a relatively short effective half-life (with little or no long-term component) and
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sufficient whole-body count data is unavailabl This matter was discussed with radiation protection supervision during the inspection and by telephone on December 6, 198 This matter will be reviewed further during a future inspection (Open Item 255/88021-01).
No violations or d~viations were identifie Control of Radioactive Materials and Contamination (IP 83750, 83726)
The inspectors reviewed the licensee 1s program for control of radioactive materials and contaminatjon, including:
changes in instrumentation, equipment, and procedures; effectiveness of survey methods, practices, equipment, and procedures; effectiveness of methods of control of
- radioactive-and contaminated materials; management techniques used to implement the program; and experience concerning self-identification and correction of program implementation weaknesse Personnel Monitoring Methods and Controls The station 1s sole ingress/egress control point for the radiologically controlled area (RCA) is on the 607 1 level of the auxiliary building adjacent to the RPT access control des Three PCM-18 whole-body contamination monitors, which became operational in April 1988, are located at the egress point and can be readily observed by RPTs who continuously man the des Calibration and testing of these monitors is described in Section 1 The contamination monitors are physically positioned side-by-side and share a single common ingress and. egress route which poses the potential for personnel cross contaminatio Separate monitor egress routes would reduce the probability of cross contamination and tracking contamination into clean (non-RCA) area The desirability to reposition the monitors was discussed with the licensee during the inspection and at the exit meetin This matter will be reviewed further during a future inspection (Open Item 255/88021-02).
Conventional (hand-held) friskers are stationed in various locations in the RCA and personnel are required to perform frisks at the nearest frisking station after removing protective clothing at step-off-pads or exiting a contaminated are As noted in Section 6, previously identified worker frisking (Inspection Report No. 50-255/87005) and contamination control weaknesses continu A final personal contamination survey is made prior to leaving th~ site with portal (walk-through) monitors located in the gatehous Personnel Contamination Reports Procedure No. HP 2.18, Personnel Decontamination, requires that personnel contamination reports (PCRs) be completed when personnel frisks yield greater than 100 cpm above backgroun PCRs are evaluated and findings summarized in reports issued to the Health Physics Superintenden The reports address the number and type of
personnel contamination events, the plant location where the contamination is believed to have occurred, and the apparent cause as identified by the RPT completing the ~epor In 1988, the licensee experienced a significant (four-fold) increase
~~~~~~--~11in-personnel contamination events (PCEs).
The new whole-body contamination monitors detected most of these event Approximately 1360 PCEs have been reported in 1988 through November 8; the majority (about 88%) were identified during the three-month maintenance/
refueling outage, which commenced in early August 1988 and was nearing completion during this inspectio The station averaged about 345 PCEs annually from 1985 through 198 An extensive evaluation of the outage contamination events was conducted by the licensee and is documented in a draft licensee repor Further licensee evaluation is continuin Pertinent information noted by the inspectors and/or extracted from the licensee 1s study is delineated below:
Contaminations were attributed primarily (77%) to discrete particles of low-to-moderate activity (100-2000 cpm);
5% involved activities greater than 10,000 cpm and triggered skin dose calculation if the contamination was on the ski *
Approximately 27% of the contamination events were attributed to contaminated clean areas; 35% to contaminated protective clothing; and 33% to poor radiation worker practice *
The contamination rate for certain jobs performed primarily by contractors was excessive and contributed a relatively high percentage to the overall total *
75 individuals were contaminated four or more times and amounted to 32% of all the contamination * *:. 37% of the skin contaminations.were to the hea *
The night shift contamination rate was nearly double the day shift rat *
Laundry and related work accounted for 10% of all contamination *
As the outage progressed, the ratio of contaminations from Co-58 to contaminations from Co-60 increase While contaminant particulate size appeared to ra.nge from two to 100 microns, other preliminary evidence suggests that contaminants may be colloidal crud in the sub-micron rang These and related issues are further discussed in Section 12.
The licensee's policy on skin dose determination from hot particles is defined in Section VI of the corporate Radiation Safety Pla The plan requires a skin dose determination if skin contamination levels greater than 10,000 cpm are observed regardless of the area over which the contamination is spread or the uniformity of contaminatio To calculate skin dose, the licensee uses measured values from Eberline Model R02/R02A dose rate or-count rate meters employing Model HP210/260 probes; the Radiation Safety *Plan was recently revised to require that dose calcul~tions from discrete particles be averaged over 1 cm2 in keeping with NRC guidance.
. In 1988, to date, the licensee calculated 38 skin doses (to 36 individuals) resulting from personnel contamination event The licensee's dose calculation methodology described in Station Procedure No. HP 2.42 was reviewed by the inspectors along with dose assessments for selected events (see Section 9)-~no significant problems were note Skin dose calculations performed by the licensee showed that no regulatory or licensee administrative dose limits were exceeded as a result of these contamination event The skin doses for the vast majority of the contaminations were less than one percent of the NRC limit Area Survey Program Routine area surveys are performed to assess general radiation and contamination levels and to evaluate the effectiveness of general radiological controls and housekeepin Routine radiological survey requirements are described in Section Procedure No. HP 2.14 and include routine daily and monthly external radiation and smearable contamination survey Additionally, contractor personnel perform daily large area masslinn smears in various auxiliary building areas and in selected clean (non-RCA) area Masslinn smears exhibiting greater than 100 cpm warrant area cleanu The inspectors selectively reviewed records of routine area surveys performed in 1988 to date; no significant problems were noted with the survey methods or frequenc Efforts to reduce auxiliary building contamination continue (see Inspection Report No. 50-255/87005).
The percentage of contaminated auxiliary building areas has remained fairly constant during non-outage periods in 1988 (about 40%) and increased to about 50%
during peak outage activities in September 198 Similar values were reported for 1987 (Inspection Report No. 50-255/87030).
The station goal, initially established in 1987, i~ to maintain the percent of contaminated auxiliary building area to 22%; the contamination baseline is 11%.
Jhe continued failure to meet the auxiliary building contamination goal appears to represent a weakness and is undoubtedly a contributing factor to the recurrent personnel contamination problem Staffing devoted to the decontamination program is described in Section 1.
- Radioactive Material Container Marking and Labeling During inspector to"rs of the RCA, numerous yellow plastic bags containing various equipment/parts (hoses, cables and metal components) were observed to be umarked/unlabeled as to the radiological conditions (dose rate and contamination levels)
of their content The licensee uses such bags to store contaminated (or potentially contaminated) materia With limited exceptions, yellow bagged material (non-trash or laundry) observed during the inspection was not marked or labeled to indicate if removable contamination was present on the content Proper marking/labeling is desirable to inform personnel of the potential hazard associated with handling or unpackaging the material. While the bags appear to be exempt from regulatory labeling requirements because of the limited amount of radioactive material present, failure to properly mark/label the bags is considered a poor health physics practice. Station procedures do not prohibit this practic This concern was previously identified by the NRC (Inspection Report No. 50-255/88006) and in numerous licensee monthly QA surveillances (Section 12.c). Other Region III plants with similar practices have experienced worker external and internal contamination problems when bagged equipment with unspecified radiological conditions was handle The continued failure to properly label bags of contaminated items is a weakness in the contamination control progra This matter was discussed at the exit meeting and will be reviewed further during a future inspection (Open Item 255/88021-03).
No violations or deviations were identified by the inspector Personnel Contamination Events (PCEs)
As previously noted (Section 11), the licensee experienced a significant (approximately four-fold) increase in PCEs in 198 The majority occurring during the refueling/maintenance outage that began in early Augus The thorough frisk capability and increased sensitivity of the new whole-body contamination monitor (alleviating individual frisking variances associated with conventional hand-held units) has dramatically improved the licensee's ability to identify low levels of personnel contaminatio Although it is not uncommon for the number of identified PCEs to increase significantly when such state-of-the-art monitors are made operational, the magnitude of the increase and its continuance throughout the outage is unusual and appears indicative of weaknesses in the personnel contamination control progra Based on licensee, INPO, and NRC evaluations, causal factors contributing to the contamination problem include protective clothing and laundry, radiation worker practices, and contamination in clean areas. Primary system particulate radioactivity buildup and accumul~tion_over several cycles, coupled with its release and possible unique chemical and physical properties, appear to be the source of the proble The underlying source and contributing factors are detailed below:
16 Protective Clothing and Laundry The licensee attributes approximately 35% of the outage contamination events to cross-contamination and leaching from protective clothing (PC).
During the outage, PCs were laundered using an in-plant wet wash system and a vendor-supplied dry cleane Highly contaminated PCs were dry cleaned during1nitial outage-st--age-s--bttt---ta-ter--wet -----
washed when the licensee discovered it was more effective in particulate remova Early in the outage, contamination was identified on numerous workers exiting the RCA and in the PC dress*
area (The PC storage and dress area is located in the service building (clean area) along with offices and lunch rooms).
The *
source was determined to be perspiration induced leaching of contamination from PCs and contamination on laundered PCs stored in the dress are Accord-i-ng to the licensee, contamination was not adequately controlled in the fuel pool tilt-pit drain line -
replacement job and highly contaminated PCs (particularly duck feet)
on that job were not segregated and consequently cross contaminated other PCs during the laundering proces (The licensee was not able to monitor all laundered items in their automated laundry frisker (ALF) early in the outage due to the increase in PC processing requirements).
Failure to segregate and specially launder PCs used in high contamination jobs, and the establishment of the PC dress and storage area in a 11clean 11 non-RCA are considered poor practices, the latter increasing the probability of spreading contamination into offices and eating/drinking area The inspectors also noted that PC dress requirements and donning methods were not c]early delineated, changed throughout the outage, and varied from worker to worke The licensee 1s wet-wash system is somewhat antiquated in that it has only two water changes per wash cycle compared to about seven in newer unit Additionally, the wash water is hard and the station 1s NPDES permit severely limits the amount of detergent and additives in the water discharged from the wash syste Colloidal corrosion products (see Section 12.d) could apparently further hamper the effectiveness of the existing laundry facilit During mid and later stages of the outage, a degreaser and acid solution were added to improve wash capability; the latter was discontinued as ineffectiv To correct laundry and related problems, the licensee tentatively plans to contract the services of an offsite laundry vendor and is considering the purchase~of new polyester/cotton blend PC This blend reportedly facilitates contaminant removal during launderin The use of.hospital scrubs will continue (as a PC undergarment) and their effectiveness further evaluate Radiation Worker Practices The licensee attributes about 33% of the outage contamination events to poor radiation worker practices. Approximately 37% (roughly 160 events) of outage skin contaminations were to the head, which
typically result from improper worker practice The station's QA group continues to conduct monthly PCE and radiation worker/
contamination control surveillance These surveillances, which began in January 1987, have continually identified instances of poor radiation worker practices exhibited by plant and contract workers, including members of the radiation protection grou The problems escalate during outage Similar problems have been noted during INPO visits and by NRC inspectors (Inspection Reports No. 50-255/87030 and 50-255/88006).
Inspection Report
No. 50-255/87030 describes a poor worker practice that contributed
to an apparent radioactive material ingestion/inhalation inciden Although station management involvement to improve worker practices
exists, a radiation worker practice task force was formed in early
1988, it dose not appear to have been very aggressive or effective
to date (see Section 4).
Personnel contamination rates have generally reflected the area
contamination levels except. for steam generator pl at form worker These workers have relatively lower personnel contamination rates
apparently because their activities are closely scrutinized and
they are assisted in PC removal by RPT Experience ievels and
qualifications of these workers also tends to be somewhat greater
than other radiation worker Monitors (or coaches) stationed at
the fuel pool area SOPs to instruct/assist worker in PC removal
proved to be beneficia On the night shift, which reportedly did
not utilize SOP monitors to the same extent as the day shift, nearly
a double contamination incident rate was experience This*
information appears to imply radiation worker training deficiencies;
however, the INPO and station QA auditors noted improved practices
when workers knew they were being observed and degraded practices
when unaware they were under observatio As previously *noted
(Section 11.b), about 75 workers were contaminated four or more times
and accounted for 32% of all outage PCE If management continues to
tolerate apparent worker indifference towards proper work practices
and contamination controls, the excessive number of contamination
incidents due to poor radiation worker practices may remain a
significant programmatic weaknes A disciplinary action program
for personnel that continue to demonstrate improper practices may be
necessar Enhanced radiation worker training, continued SOP
coaching, and a program for expanded management oversight of radiation
work may also be appropriat Corrective actions taken or under consideration by the licensee to
improve worker. practices include the following (also see Section 4):
Periodic supervisory/management RCA tour *
Evaluate revising con.tract~ (as necessary) to penali.ze
contractors for poor work practice *
Evaluate the necessity for added training of contractor
personnel or the increased use of technicians to monitor work
practice ***-***--.. -..
_-~*-=--*=--.=-.-'-'--'-~~~---~~~~~-~~-~~~~--------------------'
For future outages, use dedicated control-point monitors at
high traffic SOPs.
Evaluate the use of video monitors at multiple SOPs.
Provide technicians to assist personnel in undressing at high
contamination boundar+e *
Improve contamination area boundary demarcatio Contamination in Clean Areas
The licensee attributes about 27% of the outage PCEs to contaminated
clean area Several sources appear to contribute to this problem
and include lack of sufficient decontamination resources,
contamination spread caused by improper radi'ation-warker-and plant
contamination control practices, lack of a formal leak
identification and reduction program, and inadequate ventilation
flow Previously referenced monthly QA surveillances repeatedly identified
examples of poor worker practices and improper plant contamination
controls contributing to contamination in clean area Similar
examples were noted by INPO during an October 1988 visit and by NRC
inspectors during this inspection, including:
Lack of sufficient marking/posting of contamination area
boundaries resulting in inadvertent entry into such area *
Unsleeved and unmarked cords/hoses across contamination
boundarie *
Material/equipment partially inside contamination areas;
Worker congestion (due to space limitation) in certain SOP
change_area *
Unlabeled/unmarked yellow bagged material and equipmen The licensee continues to experience numerous shoe contaminations
involving individuals who enter the RCA but do not enter any posted
contaminated are Although the rate of shoe (to other)
con1aminations dropped in mid-1988, the data could be misleading
because of the substantial increase in skin and clothing
contamination The PCM-lBs are presumably identifying low-level
skin and clothing contaminations that previously were not detected
using the conventional hand-held friskers; this may be less true for
shoe contaminations because shoes are typically thoroughly surveyed
with hand-held frisker Although the station has devoted additional
efforts to auxiliary building survey and cleanup (Inspection Report
No. 50-255/87030), the station has not met area contamination goals
(during both outage and non-outage periods-Section 11.d). While the
surface contamination levels were reportedly not greater during the
1988 refueling outage than in past outages, RSD management was
generally dissatisfied with decontamination progress early in the
outag The outage commenced earlier and was more extensive than
anticipated and the licensee was not adequately staffed with a
qualified decontamination cre Additional deconners and laundry -
workers were added at various times during the outag Because known
contaminated areas, laundry operations, and other emergent work
received priority attention, clean areas of the auxiliary building
may not have received appropriate attentio Budgetary constraints
also limited decontamination staff overtime and weekend coverag Ventilation flow could be a contributor, spreading contamination
from potentially contaminated to clean area During inspector
plant tours, strong air currents from the open laundry area into
the adjacent clean hallway were eviden According to a licensee
representative, a similar situation exists in the spent fuel pool
heat exchanger room to the hallway outside that roo The lack of a formal leak identification, control, and reduction
program may also contribute to the proble The inspectors noted
numerous plant areas with leakage directed into floor drains by
tygon tubing or leaking directly onto floor area No formal
mechanism currently exists to identify plant leaks and track
their statu Correction actions planned and/or under licensee consideration
to reduce contamination in clear areas are described below:
Increase decontamination efforts to quickly restore
contaminated work areas to clean status, and increase
frequency of cleaning in high traffic area *
Increase the use of vacuum cleaners to remove debris/dust
throughout the RC *
Continue to explore alternative locations for PC dress-out
areas so that clean area transit by personnel wearing PCs
is minimize A modification has been requested to move
the change area into the RCA space vacated by the laundr (The budget authorization for this request is pending.)
When laundry processing is moved off-site, additional
support should be available to address decontamination
need *
Additional contract deconners will be planned for future
..outages as necessary to ensure.that surface area
contamination is maintained at acceptable level *
d.
Source Term Considerations
The unit's primary system particulate activity source term has
apparently built-up and accumulated over several cycles; its
subsequent release into the primary coolant system may have been
triggered by a crud burst or other as yet unknown even ~~------A*>+dttedt+i-T-t"'t-1ion-a-1-ty-,-p-re-H-mi-na-ry licensee studies suggest that a possible
chemical and/or physical reaction prior to shutdown may have
caused primary system contaminants to be in. a chemical and physical
form that compounded problems with effectively controlling the
contamination after its release from process system These matters
are explored below:
Following shutdown, the plant experienced an unexpected increase
(about two orders of magnitude) in coolant activity after flooding
of the reactor cavity. * This-p-roduced-elevated radiation levels
particularly in the safeguards equipment and piping, reactor cavity,
and spent fuel pool tilt pit. This increase was initially thought
to be caused by corrosion product suspension possibly produced by a
crud burs Although not totally discounted by the licensee, the
curd burst theory has not held=up after coolant sample filtration
and chemical analysi Subsequent coolant chemical analyses revealed
that contaminants were in a dissolved ionic state presumably created
by an unknown oxidizing environmen Other licensee analyses appear
to indicate that the contaminants may be colloidal crud (sub-micron
particles). Since the PCs used by the licensee are permeable to
sub-micron particulates, many of the PCEs may have resulted from this
sub-micron contaminatio The licensee is continuing to investigate
the possibility of a crud burst and to characterize the contaminatio The licensee's past maintenance/operational practices *may have
introduced undesirable quantities of base metal into the primary
coolant system and allowed them to accumulate over numerous cycle This practice would negatively impact the ALARA and contamination
control program Primary coolant system filtration and/or other
primary system decontamination/cleanup techniques have apparently
not been extensively employed by the licensee until recently
(Section 13). It appears desirable to consider the various
options available for additional primary coolant system
decon/cleanup and source term reductio The contamination control programmatic weaknesses delineated in the
subsections above were discussed at the onsite exit meeting, at the
December 8, 1988 meeting in the NRC/Region III office, and will be
reviewed further during a future inspection (Open Item 255/88021-04).
No violations or deviations were identified; however, a significant
programmatic weakness was identified.
The inspectors reviewed the licensee 1 s program for maintaining
occupational exposures ALARA, including changes in ALARA policy and
procedures; ALARA considerations for maintenance and refueling outage;
and establishment of goals and objectives, and effectiveness in meeting
the Al so reviewed were management techniques used* to*-,-m*plemerit the
program and experience concerning self-identification and correction of
programmatic weaknesse NRC inspections since 1986 (Inspection Reports No. 50-255/86012,
50-255/87002, 50-255/87005, 50-255/87030, 50-255/88006, and 50-255/88020)
have determined that the licensee has apparently learned well from past
outage and operating experiences and has realized significant dose
savings through a strong and continually developing ALARA progra A-
review of the ALARA program during the current inspection corroborated
these earlier observations. Temporary shielding is used liberally; work
orders, proposed modifications, and work group procedures receive
generally good review by the ALARA group; job coverage by the radiation
protection (RP) group appears adequate; and plant ~pper management in the
operations, maintenance, and engineering groups appear to be sincerely
involved in ALARA effort As of mid-November 1988, final dose totals for approximately 72% of
the 330 currently inactive radiation work permits (RWPs) written for
calendar year 1988 job activities wer~ Withi~ the projetted*dose*
total For the approximately 105 currently active RWPs, dose totals
for 65% were within the projected totals. A review of selected RWPs
indicated that overall, the initial dose estimates were reasonable and
not inflate Although the initial estimate of 404 person-rem for the
current refueling outage and the estimate of 550 person-rem for the
calendar year 1988 will be exceeded, the licensee appears to have made
a good effort to limit dos The licensee incurred much of the dose
on unanticipated outage work and on unusually extensive or first-time
modification or maintenance activitie (However, some dose appears
to have been incurred because of poor planning or poor maintenance.)
Licensee representatives stated that several jobs in containment and
the East and West Safeguards Rooms had higher than expected dose totals
because of the relatively high radiation field created by the apparent
crud burst (see Section 12.d). This apparent crud burst resulted in
exposure rate readings of 250 mR/hr at the surface of the refueling
cavity pool (with readings in the pool as high as 1 R/hr) and general
area readings of 70 mR/hr in the East and West Safeguards Room Several of the jobs that had relatively high final dose totals were
reviewed by the inspectors and are discussed belo Unanticipated" outage activities that incurred significant dose included
steam generator work (approximately 90 person-rem incurred on "eddy
current testing, plugging 34 tubes, reinstalling plugs in 11 other tubes,
and support activities for the work); examination of all (45 total)
control rod drive seal housings (Inspection Report No. 50-255/88025);
and repairs to the fuel transfer cart. Anticipated outage activities
that resulted in a significant dose total increment included the complete
core offload, the extensive valve work in the East and West Safeguards
Rooms and in the
11 rat 1 s nesV1 area of containment, preparation for and
conducting of reactor head work, installation of excore dosimetry, the
extensive work on the safety injection and refueling water tank (SIRW
tank), and the hydrolasing of the reactor cavity, spent fuel pool tilt
1Ti-t-;-- and-s~l-ected auxiliary building drain lines. Accardi ng to licensee
representatives, during the current outage a dose-total reduction program
for reactor head work was initially implemente This program culminated
the two-year efforts of an engineer hired by the licensee to develop the
program to increase reactor head work efficiency and save dos This
program reportedly resulted in dose-savings of 40 person-rem this outag In addition, licensee representatives stated that the work on the SIRW
tank included cleaning of the inside of the tank, which had not been done
since initial plant startup. This cleaning is expected to reduce the
plant source term-.--- --
Apparently poorly planned or performed job activities that resulted
in increased dose included scaffold erection in containment (twice the
projected person-hours and four times the projected 10 person-rem dose),
and insulation removal and replacement in support-of acoustic monitoring
in containment (seven times the projected person-hours and five times the
projected 2.8 person-rem dose).
In addition to these two examples, the
inspectors noted that the licensee incurred unnecessary dose because
the maintenance performed on valve SFP-126 on September 20, 1988, was
inadequate and the valve required extensive rewor In addition, valve
position verification performed on this valve for red tagging purpose
after the initial repair was inadequate and resulted in the unintentional
pumping of 5400 gallons of spent fuel pool water out through disassembled
valves in the Safeguards Rooms (Inspection Report No. 50-255/88023(DRP)).
The spill required several days of cleanup efforts and resulted in
unnecessary exposure of deconner Because of initial poor plant system design and previous poor operational
and maintenance activities, the plant has been plagued with hot spots and
relatively high general area radiation field In the past two years, the
licensee has developed and been implementing a plan for radioactive source
term reductio Licensee representatives estimated that the recent removal
of five hot spots, including a 900 R/hr hot spot in a shutdown heat
exchanger and a 2000 R/hr hot spot in the spent fuel pool tilt pit drain
line, will reduce annual dose totals by 6.5 person-re (However, during
the present outage, a 500 R/hr hot spot developed in the reactor cavity
drain line, a 25 R/hr hot spot developed in a shutdown heat exchanger, and
a 200 R/hr hot spot developed in the spent fuel pool drain line.) Other
hot spots have been catalogued and are slated to be removed i~ the futur Licensee representatives indicated that preliminary consideration has
been given to periodically flush and/or hydrolaze systems and components
with recurrent hot spots, such as the tilt pits, the shutdown heat
exchangers, and the low-pressure safeti injection punip For the heat
exchangers, the flushing would require a formal jumper, link, and bypass
review and could be done during each refueling outag For the injection
pumps, the flushing could be done during one of the monthly operational
surveillances of these pump Licensee representatives also indicated
that preliminary discussion had been held on formally requiring system
engineers to institute maintenance, modification, or operational
activities to reduce the source _terms of their assigned system In addition to the hot spot reduct-ion efforts, the licensee instituted
this outage, for the first time, extensive use of temporary filtering
systems to improve water clarity and reduce the activity of the refueling
cavity and spent fuel pool water.. Three submerged filter/pump systems
were installed in the cavity and provided for filtering of the cavity
pool water in 6-8 hour Two other systems, equipped with a skimmer,
have also been purchased:
one system was used during the ~efueling
outage in the spent fuel poo In addition to the in-pool filtering
systems, modifications have been made to allow inline filtering of the
spent fuel pool tilt pit and the reactor cavity drain line While the above described actions of the licensee, and other actions
reviewed during this inspection and previous inspections indicate that
the licensee is putting forth effort to control worker exposure, the
fact that the plant's dose total for 1988 will probably be twice the
national PWR average, and the fact that the plant has almost consistently
exceeded the national average over the past 11 years, indicate a weakness
in the ALARA program that should be aggressively and expeditiously
correcte Much additional effort appears needed to remove radioactive
material from the primary system. * -The* licensee's proposed actions to
correct this weakness were discussed at the onsite exit meeting, at the
December 8, 1988 meeting at the NRC/Region III office, and will be.
reviewed further during a future inspection (Open Item 255/88021-05).
No violations or deviations were identified; however, a significant
program weakness was identifie.
Access Control for Areas with Radiation Levels >1 R/hr
The inspectors reviewed the licensee's actions to satisfy Technical
Specification (tech spec) 6.12.2, which in addition to requiring the use
of a radiation monitoring device for entries into areas with radiation
intensity greater than 1000 mrem/hr*(>l R/hr areas), requires that
locked doors be provided to prevent unauthorized entries into these
area Keys to these locks are to be maintained under the administrative
control of the Shift Supervisor on duty and/or the Plant Health Physicis Station Procedure No. HP 2.5, Entry Control for High Radiation Areas
Over lR/hr, establishes requirements for entries into >1 R/hr area In
addition to reiterating the requirements of the tech spec, the procedure
lists additional constraint For example, entries into areas with
extremely high radiation levels or the potential for such levels must
be made by at least two persons, one of which must be an RP These
areas include containment with the reactor critical, under the reactor
vessel, the purification and fuel pool demineralizer rooms, the
- purification filter room, and the spent resin storage tank area Entries into other >l R/hr areas can be made by one individual, if that
individual is an RPT, or an operator trained in the use of a dose rate
meter (a list of operators qualified to make these entries is maintained
at the HP desk at access control).
The licensee maintains at the HP desk
at access control five copies of the key to the locks for one-person
>l R/hr areas and two copies of the key to the locks for two-person
>l R/hr area The keys are distributed by the HP crewleader assigned to
the desk and the names of individuals who are given the keys are entered
in a lo When the keys are returned to the desk, a notation is made in
the lo The shift supervisor also maintains two copies of the one-person
>l R/hr key and one copy of the two-person >l R/hr key, for emergency us At a previous inspection (NRC Inspection Report No. 50-255/87005), the
inspector reported a weakness in the licensee 1s controls over access/
egress from >1 R/hr area The inspection report described two instances
in 1986 where individuals were locked in areas controlled as >1 R/hr
areas, and one instance in 1986 where two individuals worked without
RP coverage in a >1 R/hr area, contrary to procedur The licensee 1s
corrective actions for these events have apparently been adequat However, discussions with personnel during the current inspection and a
review of RIRs indicated that in 1987 and 1988, the licensee has continued
to have problems with tech spec-required controls over >1 R/hr area On
June 10, 1987, as described in RIR 87-021, the door to a >1 R/hr area
(around tank T-60) was found by the licensee to be unlocke On
September 30, 1987, as described in RIR 87-029, the NRC Senior Resident
Inspector found a door to a >1 R/hr area (602 1 pipeway) that was ope On
December 17, 1987, as described in RIR 87-037, the door to the spent fuel
pool heat exchanger room, a 1> R/hr area, was found to be ope Similarly,
on September 5, 1988 as described in RIR 88-028, and on September 7, 1988
as described in RIR 88-027, the door to the spent fuel pool heat exchanger
room was found to be unlocke (The inspectors note that the last three
instances, all involving the spent fuel pool heat exchanger room occurred
during successive outages.)
While the three instances in 1987 apparently can be partially attributed
to hardware problems with the doors or locks, the root cause of these
events, as well as the two events in 1988, is the failure of plant
personnel to lock or close the doors to these area Apparently, after
each event, the licensee has reemphasized to workers the requirements
for entering and leaving these areas; however, this action and other
procedural changes made have not been adequate to preclude recurrenc The failures on June 10, September 30, and December 17, 1987, and on
September 5 and 7, 1988, to maintain locked doors to prevent unauthorized
access to areas >l R/hr is a violation of Technical Specification 6.1 (Violation 255/88021-06).
Although these violations were predominantly
licensee-identified, licensee corrective measures to date have not been
adequate to preclude recurrenc One violation and no deviations were identified.
15.
I~~-
Facilities/Equipment and Equipment Calibration
The inspectors toured radiation protection facilities, observed equipment
in use, and discussed future plans for program improvement Laundry
facility weaknesses and the desirability to relocate the PC storage and
dress area and reposition the PCM-lBs were previously discussed
(Sections-l-L;-a---anct-11. a).
-
The inspectors reviewed records and relevant procedures for operation
and calibration of the Eberline Model PCM-18 whole-body frisker The
station maintains three such friskers at access control and plans to
calibrate each monitor on a semiannual basi Initial calibrations
were performed in April 1988 and repeated in August using nominal
100 nCi cesium-137 plate sources (100 cm2 area).
Detector efficiencies
for the ces:ium-137 standard-*are typically about 12%; frisker alarms are
set at 95 dps (about 2.5 nCi).
Daily monitor operational checks are
performed using a 2 nCi cesium check sourc The inspectors reviewed
calibration records for the monitors; no problems were note The licensee purchased an automated laundry monitor utilizing gas flow
proportional detectors (of about 345 cm2 area) located above and below
and traversing the width of a moving conveyor mes In July 1988, the
monitor was installed, voltage plateaus determined, and detectors
calibrated using the cesium-137 (100 cm2 ) plate sources; detector
efficiencies are about 12%.
Monitor alarms were initially set at
120 cps, corresponding to about 30 nCi over the detector surface
area (8 E-5 uCi/cm2 ). After the initial surge in PCEs in early August,
the monitor alarm setpoint was reduced to 60 cp An additional similar
monitor was leased, calibrated, and put into service in early Septembe Procedures have been developed for monitor operation/calibration and
include daily operational checks using a licensee fabricated cobalt-60
point sourc The procedure and calibration records for the leased
monitor were reviewed; no problems were note The licensee 1s whole-body counting program remains as previously
described (Inspection Report No. 50-255/87030).
During the inspection,
the procedure for operating the whole body counter (WBC) was available
at the counting facilit The WBC operator was interviewed and was aware
of the procedural requirements for whole body counting and reporting
criteria. The inspectors reviewed tne operation of the WBCs including
calibration, functional check, and maintenance activities. Station
Procedure No. HP 8.5 outlines operations of the unit Calibrations,
functional/operational checks, and maintenance activities are performed
by or dictated by the vendo The licensee does not perform routine
functional or operational checks on the WBC and relies on the equipment
vendor to inform them of any problem (Shortly after a count is
performed, the data obtained during the count is transmitted to the
vendor for further evaluation and refinement.) The licensee is notified
if problems are noted and minor adjustments are necessar To better
evaluate counter operation and performance, the licensee should consider
L
implementing a routine operational check program including the
maintenance of related logs and operational trending informatio This
matter was discussed at the exit meeting and will be reviewed further
during a future inspection (Open Item 255/88021-07).
The inspectors reviewed the latest annual calibrations of the WBC The calibration methods remain as previously described (Inspection
Report 50-255/87030); no problems were identified by the inspector The licensee has budgeted for a new WBC system and intends to purchase a
standup Fastscan counter and related hardware and have it operational in
early-mid 198 One of the existing lay-down counters will be maintained
as a backup and for its locational detection capabilities. A vendor will
continue to analyze WBC results until alternate methods are develope No violations or deviations were identifie.
Tours and Observations (IP 83750, 83729)
l The inspectors conducted several auxiliary and fuel building tours and
a guided tour of containmen Although auxiliary and fuel building
housekeeping was generally good, contamination control and containment
housekeeping concerns were noted and include the following:
Graffiti-laden surfaces in numerous areas of containmen The
graffiti was in areas exhibiting radiation levels up to 20 mR/h *
Plant process system leaks (Section 12.c).
Unmarked/unlabeled yellow bagged material (Section 11.d).
Unsleeved/unmarked cords and hoses across contamination boundaries
and other material partially inside contamination control
boundarie *
Lack of sufficient space to properly doff PCs at the containment
manway SO *
Lack of sufficient contamination control boundary demarcation-
to reduce inadvertent entr *
One of two ingress points to a
11clean
11 area in the auxiliary
building posted as a contamination are The inspectors performed direct radiation and smear surveys of selected
11clean
11 equipment and areas in the auxiliary building; no significant
problems were identifie Contractor*worker 1s Information Requests*
On September 16, 1988, a contractor employee contacted the NRC Resident 1s
Office requesting confirmation of certain statements made to the employee
and others in his work group by members of the licensee 1s radiation
protection staff. Subsequently, an NRC Radiation Specialist and the
Senior Resident Inspector met with a group of approximately 20 contractor
employees to listen to their concern Two questions from the workers,
one involving asbestos removal requirements and the other involving
verification of proper scaffold construction, were referred to the
licensee because they concerned industrial safety matters not within the
NRC jurisdiction. -Four other questions or concerns about the validity
of statements made by the radiation protection staff, were reviewed by
NRC Radiation Specialists. The questions/concerns and the results of
the review are discussed belo *
RP staff have stated orally and in memoranda that the designation of
11dedicated
11 RPT coverage on an RWP does not mean that the RPT
assigned to a job must remain in
11 line-of-sight
11 of the workers on
that job; however, several contractor workers remember being told in
General Employee Training (GET) that
11dedicated
11 coverage meant that
the RPT must remain in
11 of the worker During a previous inspection (Inspection Report No. 50-255/87005),
the inspector expressed a concern about the definition of
11dedicated
11 radiation protection coverag In response, the
licensee clarified the definition, as stated in Administrative
Procedure No. 7.03, Radiation Work Permi The definition does not
require RPTs to remain in
11 line-of-sight
11 of workers unless there is
a good potential for a sudden increase in radiological hazard However, discussions with licensee personnel, in response to the
contractor concerns, indicated that some individuals need to be
apprised of the definitio The lead GET instructor and several
RPTs stated that
11dedicated
11 coverage did require RPTs to remain
in line-of-sight of worker Whereas this interpretation is
conservative, it may not be in keeping with good ALARA practices and
may confuse workers on what is actually required by dedicated RP job
coverag The inspectors informed RP management.of the discrepancy
and the need to correct it. The licensee agreed to resolve the
situatio The success of the resolution will.be reviewed during a
future inspection (Open Item 50-255/88021-10).
There are not enough deconner RP staff stated there were enoug *
The NRC inspectors discussed deconner staffing levels wit~ RP
management (see Section 12.d).
They conceded that staffing level
was less than desirable early in the refuel outage because of the
sudden, unanticipated onset of the outage; however, after several
weeks, staffing was increased up to the desired leve Respirator requirements appear inconsistent, e.g., on one shift for
a particular job respirators may be required, yet on a subsequent
shift, for the same job, and with no apparent change in radiological
conditions, respirators may not be required.
- A review of WBC records indicated that the licensee 1s internal
exposure control program has been successful to limit uptake of
radioactive materia A review of air sample records indicated that
typically airborne radioactivity is less than 1-2 MP As with most
other utilities, Palisades guidelines for requiring the use of
respirators are conservativ Discussion with RP staff indicated
that early in the outage, respirator requirements,. as well as
protective clothing requirements, did change more often than usual
for some jobs, as the RP staff tried to compensate for the
relatively high air temperature and humidity, lower than desirable
deconner staffing level, arid the relatively high number of personal
contamination Based on the results of the WBCs, the NRC inspectors
identified no problems with the licensee 1s establishment of respirator
requirements; however, it is noted that the licensee needs to take
stronger informational action to resolve the inevitable confusion
that will arise in workers because of changing radiological
protection requirement *
Protective clothing is responsible for contaminating worker RP management readily concedes that so-called
11clean
11 protective
clothing has been the cause of a fair number of personal
contamination Apparently the licensee has been trying to correct
this problem throughout the outag The licensee 1s corrective
actions for this concern are discussed in Section 1 During the initial review of these issues by the* NRC, the licensee 1s RP
management met with the contractor group to discuss these issues and
other Discussions with licensee representatives after the meeting
and a review of a written summary of the discussions at that meeting
indicated that the meeting was a worthwhile airing of concerns for both
groups and a good exchange of informatio The inspectors noted that
similar meetings might be considered for future outages to ensure a
better working relationshi No violations or deviations were identifie.
Review of Radiological Protection Considerations Taken During Rec~nt Events
The inspectors reviewed radiological protection considerations taken
during several recent event These events, involving potentially high
radiation and/or contamination levels, were (1) the freeing of a stuck
fuel assembly from the upper guide structure, (see Inspection Report
No. 50-255/88018); (2) repair of the fuel transfer cart prior to core
offloading; (3) cleanup and decontamination of the East and West
Safeguards Rooms after 5400 gallons of water from the spent fuel pool
were pumped into the rooms (see Inspection Report No. 50-255/88023); and
(4) removal of a 2000 R/hr hot spot in the spent fuel pool heat exchanger
room.
- Radiological protection considerations taken by the licensee during
events 1 through 3 appeared adequat Overall, doses received by workers
appeared to have been kept as low as practicabl One exception to
this involved a diver who was assisting in the repair of the fuel
transfer car Because of a leak in the diving suit, the diver became
contaminated with a hot particle, which resulted in a dose to his
-
thumb of approximately 4 re The dose to the diver from the
contamination is discussed further in Section.
Regarding Event (4), as discussed in Inspection Report No. 255/88006(DRSS),
and in Section 13 of this report, a 2000 R/hr hot spot developed in and
was eventually removed from the drain line for the spent fuel pool tilt
pit. A review of the completed work packages for removal of the hot spot
indicated that, overall, job activities were well planned and execute In view of this, Open Item No. 255/88006-01 is close Notwithstanding
the overall good effort, the inspectors did note that for the initial
entry, on January 6, 1988, an RPT received a whole-body dose of
approximately 650 mrem, a radiation protection supervisor accompanying
the RPT received approximately 300 mrem,and an auxiliary operator
received approximately 170 mre The workers entered the area to open
several valves on the drain line, to attach a high-range radiation probe
to the drain line, and to hang temporary shielding around the hot spo The workers were in the area for approximately 25 minute The dose
received by the RPT was the highest dose incurred by any individual
during the hot spot remova Considering that another entry was made on
the next shift to perform a survey (partially to provide information for
a shielding evaluation), the dose received by the RPT appears excessiv Doses received by workers during subsequent evolutions were reasonabl The inspectors' review of the job also included a review of selected
engineering evaluations conducted for temporary shielding hung around
the hot spo Licensee representatives stated that no evaluation was
done for the shielding that was hung during the initial entr Station
Procedure No. HP 1.6, Revision 1, Control and Use of Shielding and
Associated Equipment, the procedure on shielding that was in effect at
the time of entry, required an-engineering evaluation be conducted prior
to installing any shielding equipmen This apparent discrepancy will be
reviewed further at a future inspection (Unresolved Item 255/88021-08).
No violations or deviations were identified; however, one unresolved item
was identifie Exit Meeting
The inspectors met with the licensee representatives (denoted in
Section 1) at the conclusion of the onsite inspection on November 22,
1988, and at the NRG/Region III office on De~ember 8, 198 Further
discussions were conducted by telephone from November 23 through
December 7, 198 The inspectors summarized the scope and findings of
the inspectio The inspectors also discussed the likely informational
content of the inspection report with regard to documents and processes
reviewed by the inspectors during the inspectio The licensee did not
identify any such documents or processes as proprietar The following
matters were discussed specifically by the inspectors:
... The violation of the tech spec requirement to provide adequate access
controls for high radiation areas greater than 1000 mR/h (Section 14) The weaknesses in the personnel contamination control and ALARA
program (Section 12 and 13) The apparent need to improve.marking/labeling of RAM bags, MPC-hr
methodology, and the PCM-18 location (Sections 10 and 11) Inspector concerns regarding the apparent lack of an adequate
engineering evaluation before shielding installatio (Section 18)
31