IR 05000255/1990019
| ML18057A835 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/29/1991 |
| From: | Markley A, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A833 | List: |
| References | |
| 50-255-90-19-01, 50-255-90-19-1, NUDOCS 9104090031 | |
| Download: ML18057A835 (17) | |
Text
U.S; NUCLEAR REGULATORY COMMISStON
- REGION III Report No. 50-255/90019(DRSS)
Docket No. 50-255 Licensee:
Consumers Power Company 1945 West Parnall Road Jack~on, MI 49201 Facility Name:
Palisades Nuclear Generating Plant
- Inspection At:
Palisad~s *site, Covert, Michig~n Inspection Inspector:
w~~
Approved By:
William Snell, Chief Radiologica~ Coritrols and Emergency PreparednessSection I'nspection Summary License No. DPR-20 3-21-91 Date Date Inspection on March 4**through 8, 1991 (Report No. 50-255/90019(DRSS))
Areas Inspected:
Routine~ unannounced inspection of.the radiation protection pro~ram including:
organiz~tion, management controls and training, audits arid appraisals, external exposure control, ihternal exposure c6ntrol, control of radioactive materials, contamination, and surveys; and maintaining occupational exposures A~ARA (IP 83750).
Also, ~eviewed were open items from past identified concerns (83750).
.
Resulti:
During this inspection~ one vio1ation was identified for a failure to control, calibrate arid operationally check health physics instrumentation*
(Section 8~a). A violation ~as identified for a failure to control vendor *
manuals* (Section 8.a).
A non-cited violation was identified for a failure to implement adequate corrective ~ctions (Secti-0n ~.b}~
Weaknesses were identified in the areas of management review of personnel.
qualifications (Section 4.a); training weaknesses associated with poor radiological work practices (Section 4.b); inadequacies of the radiation ~
work permit system (Section 9); methodologies utilized to assess skin dose ciue to hot particle exposures (Section 6.b); and the poO.r performance of contract radiation protection technicians (Sections 4.c, 5.a, and 8.b).
Strength~ were ideniified in the areas of SGRP radiation protection -
performance, operational ALARA planning and.in the field management of radiation protection (Section 9).
Strengths were also identified in the 9104090031 9~855~55 PDR ADOCK 0 PDR ()
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plant side outage* performanc A notable area of strength was in the perfo~mance of refueling activitiei (Section 9).
Improvemehts were rioted in the area of quality assurance surveillances in *the radiat-ion protectio and radwaste management (Section 5.a) and in timeliness of corre~tiv~ action implementation for concerns identified in radiation incident and deficiency reports.
- DETAILS Persons Contacted
- R. Brzezinski, Instrumentation and Controls Supefintendent
- English~ Corporate Health Physicist
- J. Fontaine, Senior Health Physicist
- K. Haas, Radiological Services Manager
- C. Hillman, Plant Licensing
- L. Kenaga, Health Physics Superintendent
- J. Kuemin, Licensing Administratcir
- M. Lesinski, SGRP Radiation Protection Manager
- D. Malone, Project Engineering Supervisor M. Mennucci, Senior Health Physicist
- R. Mccaleb, Quality Assurance Director
- T. Neal, Radioa~tive Materials Administrator
- G. Slade, Plant General Manager
- R. Vincent, Plant Safety Engineerir:g Administrator
- J. _Werner, SGRP Qua 1 i ty Assurance
- J. Heller, Senior Resident Inspector
- R. Bywater, Reactor Engineer The inspectors also interviewed ether Licensee and contractor personnel during the course of the inspection.
- Denotes those present at the exit meeting on March 8, 1991.
- Denotes personnel contacted by telephone on March 26, 199.
Genera 1 The inspection was conducted to review aspects of the licensee's radiation protection progra Included in this inspection was a follow-up of outstanding items in the areas of radiation protection and radioactive waste managemen The inspection included tours of radiation controlled areas, auxiliary building, radwaste facilities, observations of licensee activities, review of representative records and discussions with licensee personne.
Licensee Action on Previous Inspection Findings (IP 83750, 84750)
(Closed) Open Item No. 255/89025-02:
Request for 10 CFR 20.302 approval for in situ retention of contaminated soil adjacent to the south radwaste building. Since this request is currently in review and will be dispositioned by the Office of Nuclear Reactor Regulation (TAC No. 467408), it will no longer be administratively tracked by Region II (Closed)~ Item No. 255/89025-05:
Evaluate the apparent need to conductan acceptability evo.luation of the steam generator and condenser hotwell release progra The licensee has revised Administrative Procedure 4.00, Operations Organization, Responsibilities and Conduc This revision delineated the responsibilities to ensure that plant effluents from a.11 sources are evaluated for regulatory complianc.
(Closed) Op~n Item No. 255/90019-03:
Evaluate the implementation of the expanded qua 1 ity assurance survei 11 ance program i"n radiation protection and radwaste management program Surveillances since the last inspection and surveillance plans for 1991 were reviewe Implementation is acceptab1 This item i~ close (Closed) Violation No. 255/90019-05:
Willful violation of high radiation area (HRA) access control Corrective actions and disciplinary actions taken to prevent recurrence were reviewe Corrective actions implemented are appropriat This _violation is close (Closed) Unresolved Item No. 255/90028-04:
Evaluate apparent'
overexposure to the skin of the whole body due to a hot particl The inspector reviewed the methodologies, calculations and documentation of the skin dose assessmen No exposure in excess of regulatory limits occurre This item is close :
Organizational, Management Controls and Training (IP 83750)
- The irispectors reviewed the licensee 1s organization and management controls for the iadwaste and shipping and transportation programs, including:
organizational structure, staffing, delineation of authority and management techniques used to implemeht the program and. ~xperience concerning self identification and correction of program implementation weaknesses. Organization.and Qualifications The inspector reviewed changes in the licensee's organizatio The licensee has nearly completed the Steam Generator Replacement Project and is reassigning some 'management p_ersonne The former dosimetry supervi.sor has been reassigned to the instrumentation and respi r-atory supervisor positio The RMC supervisor has. been reassigned to the ALARA projects coordinator positio The nuclear operations analyst has been reassigned to the dosimetry supervisor positio The rad decontamination supervisor resigned to take a position ~ith a nuclear services vendo The individual selected to replace the rad decontamination sµpervisor ha~ significaht experience in radiation protection and appears t6 be well qualified for the positio The ALARA supervisor was promoted to a corporate industry liaison positio The individual selected to replace the ALARA supervisor appears to marginally meet the requirements of ANSI NlS.1-197 The inspector interviewed the selected ALARA supervisor regarding his knowledge of and plans for the ALARA progra The inspector concluded that no safety concerns exist regarding the selection of this ~andidate for the ALARA
supervisor positio The inspector subsequently reviewed the qualifications of all management personnel in the Radiological Services_ Departmen Other personnel within this department_ met the requirements of ANSI Nl8.l-197 Further discussion with licensee management and licensing personnel indicated that the
- ANSI requirements for the position were not considered in the selection proces Discussions with the licensee also indicated that ANSI requirement~ were not routinely considered in the selection of personnel in other department Although no problems were identified ~s a re~ult of not routinely considering th~ ANSI
.requirements in the positions reviewed, the-licensee.1s program should benefit if the ANSI requirements were included in the selection proces Training The in.specter reviewed the training program requirements for radiation protection *cRP) technician training.* The 'inspector.;;-_
reviewed course requirements, timing of training and promotional requirement Training.on plant systems and system
interrelationships were not evaluated at thi.s time. * While actual course content w~s not reviewed~ di~cussions with licensee personnel and reviews of procedure requirements _indicated that the license does provide an adequate amount of radiation protection training to the RP technician The inspector reviewed radiation incident reports, deficiency reports and qua 1 i ty assurance survei 11 ances for i ndiC:at io.ns of training weaknesse Some weaknesses were identified in the areas of use of electronic dosimetry and.radiological work
. practice With respect to* electronic dosimetry*,. several incidents wer~ identified i.n which personnel failed to l~~ve the radiological cri~trolled area (RCA) after their dosimeters began alarming. *Numer.ous incidents were identified in which workers*
knowledge of RCA access requirements,* radiation work permit requi~ements, proper wearing of protective clothing and contamination control practices were weak.* These were confirmed by observations made by Palisades and SGRP quality assurance (QA)
personne This appears to indicate that improvements are warranted in the general employee training program and worker attitudes regarding the importance of good radiological work practices~
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Coritract RP Technician Performance The inspector conducted interviews with. RP operations management, SGRP RP managemeht, SGRP QA personnel, refueling engineering management and with RP technical personnel to revi*ew contract RP technician.performanc Radiation iricident reports, radiation deficiency reports, deviation reports and quality assurance surveillance reports were revie~ed for indications of good and poor performanc The inspector did note that there were a number of contract RP technicians that were very good performer However, the overa 11 performance of the contract RP techni c1 ans was poo The nature, types and numbers of incidents and observations made by management, *QA and NRC personne~ indicate that a lack of initiative and professionalism characterize the contract radiation protection.technician work forc Numerous examples
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of poor radiological work control were documente Interviews with RP operations management indicated that only one third of the contract technicians could be relied upon to perform properly during high risk evolution RP operations management also indicated that there were problems with poor contract RP technician attitudes, lack of initiative and that a significant proportion of the management tim~ was expended in providing detailed direction to contract RP technician *
In.tervi ews with refueling engi neeri.ng management.indicated that problems experienced with cohtract ~p technicians included poor attitudes, inconsistent turnover, an unwillingness to perform surveys, inconsistent quality and detail-in surveys performed, and a lack of knowledge of the activities involved in the refueling evolutio Refueling engineering management also
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indicated that the initial lack of dedicated coverage, assignment of contract RP technicians to refueling who had not participated in pre-job briefings, and aforementioned concerns resulted in the providing of funds for an ALARA specialist on the refueling staf Reportedly, this was done to ensure a knowledgeable, consistent level of radiological suppor Refueling engineering management indicated that the consistency of radiological coverage did improve in the latter part of the outag SGRP RP management indicated that problems were experienced with lack of initiative and poor attitude Reportedly, this was addressed by ensuring an assertive, in the field RP management presence and by weeding out problem personne The SGRP management indicated that a number of good performers (RP technicians) helped ensure that proper radiological controls were implemente Interviews with SGRP QA personnel and reviews of QA surveillances and plant tour reports provided further evidence of poor contract RP technician performanc Problems with attitude and initiative were note QA surveillances indicated that the RP technicians had a high tolerance for poor work practice When poor work practices were observed by RP personnel (and frequently the job supervisor) actions were not always taken to provide instruction to correct the observed practic Area status sheets and radiological postings were not always maintained in a timely, accurate or informative manne Contract RP technicians were observed to allow:
burping of bags of contaminated trash in clean areas; an engineer to remove a tool from a contaminated box, to carry the tool across a clean area without bagging and to hand the tool to another worker across a contaminated area boundary; a supervisor hand a* key to a worker across a contaminated area boundary, then receive the key from the worker (who had removed his glove) and place the key back in his pocket without frisking the key; groups of workers to stand around in containment; and workers touch/rub their faces with their contaminated outer gloves o A refusal to perform radiological surveys under the plant 1 s confined spaces entry
procedure versus a contractor's procedure because the plant's procedures were too much bothe Contract RP technicians were frequently observed not wearing required safety equipment, such as safety glasses and hard hat While there were some good performers amon~ the contract radiation protectipn technician work force, the overall performance of this group was poo No violations or deviations were identifie Three weaknesses were identifie.
Audits, Surveillances and Self Assessments (IP 83750, 84750)
The inspectors reviewed the results of Quality Assurance audits and surveillances conducted by the licensee since the last inspectio Also reviewed were the extent and thoroughness of the audits and surveillance Audits and Surveillances The inspector reviewed SGRP QA audits, surveillances and plant tour reports of various SGRP activitie These included an audit of engineering modifications and associated ALARA of implementation activities, surveillances of thermal shield decontamination and removal, decontamination of steam generator B cold leg, contamination control, SGRP radiological program implementation, control of radiography, radioactive material control, and dosqmetry/exposure trackin As noted previously, problems with poor radiological work practices and contamination controls were identifie These involved both radiological workers and RP technician Good performance was noted with management involvement, coordination, and radiological performance in the thermal shield removal, decontamination of the steam generator B cold leg, control of radiography and the SGRP dose alert/red tag syste The inspector reviewed surveillances of health physics work practices, contamination control and radiation worker practices, ALARA planning and implementation for CK-ES3116 valve repair and the spent fuel pool heat exchanger repai Problems associated with contract RP technician performance were discussed in Section Additional concerns including adequacy of the radiation work permit (RWP) system, poor radiological work practices, poor quality, control and maintenance of survey and sampling records, knowledge among RP personnel of special processes requirements, proper wearing of dosimetry and some instances of work coordination were identifie The QA surveillances also identified significant items of good performanc These included ALARA planning, pre-job briefings, control and maintenance of calibration and respiratory documents, spent fuel pool heat exchanger work, and the CK-ES3116 valve repair job.
- Event Identification ~nd'Cotrective Actions The inspector teviewed plant deviatiori reports, radiological incident reports and radiological deficiency report Also reviewed were the records of tracking, corrective action*
implementation-and closeout of identified c.oncerns. * In general, event identi.fication was consistent with regulatqry and
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procedural requirements. The deter:-nii nation< of appropriate,.
corrective actions was ~sually adequat The licensee has made significant progress. in closing out outstanding.r.adiologi,,cal.,. <,
incident reports and implementing corrective actions.*
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Performance with regard to timeliness in this area appears to
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have" improve However, it appears the adequacy of correcti'v'e",;. *
. actions as noted in Section 8 of this report could still be improve * Self Assessment Corrective Action Progress The inspector discussed the status of corrective action implementation for findings thqt resulted from the self**
assessment performed in the area of radiological control The licensee indicated that 144 of 522 items have been closed and that 100 items (approximately 15%) are overdue. *Improvements made to date have fo~used -0n procedures, methods and improvements in qualit The licensee indica't;ed that the next phase of improvements will. include worker responsibilities,. training program impro~ements, such as* advanced radiation wo~ker training*
- and contamination controls for workers and supervisors, and integration of ALARA and radiological controls into the work planning proces The inspector indicated that specific, identified corrective actions would be reviewed during a future inspection; No violations or 'deviations were identified.
. External Exposure Control (IP 83750):
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The inspector reviewed the licensee's external *exposure control and**
personal dosimetry program, including:
changes. in the program, use
- of dosimetry to determine whether requirements were met, planning and prepp.rationfor maintenance and refueling outage tasks includingALARA considerations and required records, reports and notification *Personnel Dosimetry Program Personnel ~xposur~ records for current and past licensee and contractor employees were selectively reviewed for completeness, accuracy and inconsistencie In addition, reporting of information was reviewed for timelines No problems were note The licensee's dosimetry organization is consists of a*
supervisor; a clerk/specialist, and two RP technicians with contractor staff augmentation, as require This group is
'responsible for both external and internal dosimetry program.
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The licensee's primary themoluminescent device (TLD) dosimetry system is National Voluntary Laboratory Accredited Program (NVLAP) certified in all eight areas of concerr The licensee also uses a secondary TLD system for multi-badging purpose This secondary TLD system is not NVLAP cert_ifi e TLDs are processed in the licensee's corporate office in Jackson, Michiga Discrepancies in TLD versus electronic dosimetry are--
evaluated by comparisons of the TLD chip readings, work history evaluations and dose assessment Experience with the.
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Merlin'-Gerin electronic dosimetry system indfcated *that th electronic dosimeters tended to under respond for dose accumulations of less than 1~000 mrem and to over respond for*/:
dose accumulations greater than 1,000 mre The licensee indicated that individuals who had experienced the under response had normally made hundreds of entries into the RC The electronic dosimetry tracks dose at one tenth of a millire Reportedly, the problem was with the computer up1oading of dose informatio The program accepted dose readings in whole integers and clipped the decimal reading The licensee revised the computer software to include a rounding function for the tenth of a millirem to ensure a more accurate dose recordin This change was made in the later part of January 199 It is too early to determine whether this action will resolve the response problem.
The TLD QA program utilizes a*blind spiking methodology for its primary TLD syste Gamma spiking is performed on-site and beta and neutron spiking are performed by a vendo The TLDs are then sent to the corporate processing center for readou The results of the corporate readout are then transmitted to the site for
- evaluatio Hot Particle Dose Assessment The inspector selectively reviewed skin dose assessments due to hot particle exposure This included an earlier apparent skin overexposure that was identified as an unresolved item in the last inspection report (50-255/90028(DRSS)).
The inspector reviewed the methodologies utilized, the calculations performed and documentation of these selected hot particle exposure Although the licensee's evaluation failed to account for the gamma component of the skin exposure, the inspector concurred with the licensee's determination that an over exposure had not occurre The licensee had contracted with a consultant to perform an independent evaluation of the e~posure. The irispector noted several differences between the consultant 1 s and licensee's methodologie First, different values were used for the activity of the particl The licensee's value was 0.744 uCi and the consultant's value was 0.69 uC The licensee's value for particle thickness was assumed to be 30 um with varying actual thickneses of 20-60 u The consultant used values of 74% at
40 um thickness and 26% at 60 um thicknes The differences in thickness and activity affect the resultant credit*that can be taken for self shielding and the resultant dose to the ski The consultant's report also identified a gamma component of exposure of approximately 10% while the licensee did not identify any dose due to the gamma componen The licensee'i estimated dose to the skin was 4.215 re The consultant's esti~at~ was approximately 3.98 re The results of other skin dose assessments did not ~valuate the contribution to dose due to the ga~ma compo~ent. The lf~ense~
acknowledged the inspectors concerns and committed to reevaluate their skin dose methodology and the dose"'iassessments performed that involved significant exposure. (Open*Item N /91006~01)
No violations or deviations were identifie One open item was identifie.
Internal Exposure Control (IP 83750)
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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 implement these programs; and experience concerning self identification and correction of program implementation weaknesse The inspector selectively reviewed the results of the licensee 1s whole body counting efforts since the last inspectio No significant incidences of uptake of radioactive materials were identifie The licensee utilizes a Canbera Fastscan and a Helgeson bed counte The Fastscan is normally used for incoming, termination and screening whole body count Reportedly, the bed counter is used for longer investigative count During the SGRP, a mobile Fastscan whole body counter was rented and setup at the training cente This helped process the large numbers of personnel required by the SGR The inspector reviewed the results of recent calibrations of each whole body counter syste Some minor scattering of efficiency was noted in the mobile Fastscan for energies less than 200 keV for: whole body (#12), lung (#11), and bare source (#10).
Some minor efficiency scattering was noted in the licensee's Fastscan for energies less than 200 keV for bare source (#9).
This was discussed with and acknowledged by the license No additional problems were note No violations or deviations were identifie Control of Radioactive Material (IP 83750)
The inspector reviewed the licensee's program for control of radioactive materials and contamination, including:
adequacy of iupply, maintenance and calibration of contamination survey and
monitoring equipment; effectiveness of survey methods, practices, equipment and procedures; adequacy of review and dissemination.of survey data; effectiveness of radioactive and contaminated materiai control *
- Portable Survey Instruments The inspector reviewed tha status Qf the licensee's portable *
survey instrument progra This review was accomplished by *
discussions with licensee personnel; r~views of.selected ca"libration and maintenance records, to"ur of.plant areas where survey instruments were in use, and a tour of the calibration and repai.r facilities.. The licensee has :acquired a large number of..
portable survey instruments and PCM-lBs that were procured for the SGRP. * Plans have yet to be finaliz~d regarding the number of instruments to be maintained and the number to be placed in storage.. Reportedly, the portal monitor located at the security gate hou~e will be replaced with an Eberline model that uses
- plastic scihtillation detectors to improve sensitivit During a tour of the instrumentation and-controls (I&C) shop, the inspector observed a portable frisker, Ludlum Model 177, sitting on a shelf with an.HP 260 probe velcro attached to the shelf fram The inspector found that this frisker did not h.ave a serial number, calibration sticker, nor operational daily chec The "I&C supervisor was.questioned as to the status of.this instrument.. The I&C supervisor stated that this instrument was used to check instruments for internal contamination upon.*
disassembly and had used this instrument himself to perform these contamination checks.. The inspector reviewed the calibration and operational -check records and could find no evidence tha thi~ instrume~t ha~ been calibrated, op~rationally checked or otherwise existe Administrative procedure 7.01, Health Physics Portable Instrumentation Program, requires that all health physics instrumentation shall be calibrated, have operational che~ks performed once per day, sha 11 be* serialized, and sha 11 have calibration stickers placed Upon the This inst~ument clearly did not meet these requirement In addition, on March 4, 1991, the inspector identified a p6rtable RADECO air sampler (# 7241) in room C-54 that had not been operationally checked since February 16, 1991.. These are violations of administrative.*
procedure 7.0 (Violation 255/91006-02)
- During the same tour of the l&C shop, the inspector identified numerous vendor manuals for portable survey instrumentatjon and a dete.ctor for an installed area monitor located in file drawers at the radiation instrument repair benc The inspector found that the following vendor m~nuals did not have control numbers,
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- uq 11/"Non-Q 11 designations, and that. the Record of Revision Sheet and Vendor Manual Review/Approval Sheet were not inserted into these manual None of the following manuals were marked as
"Reference Onli 1 *.
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Vendor Eberlin(;!
Eberline*
Eberline Eberline Victoreen Vi~toreen
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Horizon Ecology Company Ludlum Instrument Technical Manual Model E-530 (count rate meter)
Model MS-2 (mini scaler)
RM-15 (count rate meter)
R0-2A (dose rate meter)
Model 843-30 (scintillation detector for installed area monitor)
8080.-2 VAMP (portable area monitor)
Model 5997-20 (pH contrc)ller)
Model 177 (count rate meter)
One vendor manua 1 for a Model* PMC-4B Consol e/PMP-4C Porta 1 was found stamped 11Controlled - I&C 11 and marked.with control number 11 E76 Sh. 5 11 *. The inspector questioned the I&C supervisor*
regarding the use of th~se vendor manual The I&C supervisor indicated that these manuals were used as references during repair and maintenance of the above named instrument Upon discovery of the Victoreen Model 843-30 manual, the I&C supervisor stamped the manual 11Controlled - I&C 11 *
The other*
manuals were not stamped and were left in the file drawer Administrativ~ procedure 10.45, Vendor Manual Control,*
establish~s the controls for new vendor manuals and revisions to existing vendor m~nuals to ensure that only the latest plant.
approved revisions of these manuals are made available to support plant activitie This procedure defines vendor manuals as technical information supplied by equipment manuf~cturers that address instailation, operation, and maintenance of equipment.
. This. includes drawings, parts lists, ~and other information in the
- manua *
Administrative procedure 10.45 requires that vendor manuals be identified, approved for use, revision thereto controlled and distribution controlled~. Failure to identify, approve and control the use of the aforementioned vendor manuals are violations of Admin~strative procedure 10.45. (Violation 255/91006-:03)
Further discussions wi.th I&C personnel indicated that I&C provides maintenance support for health physics instrumentation, limited support for chemistry instrumentation and full support*.
for installed plant equipmen The I&C supervisor indicated that normal practice has been to engage the services of a contractor *
to perform maintenance on health physics instrumentatio The services of the most recent contractor were terminated upon completion of t~e SGR Reportedly, no specific ttaining is provided to licensee personnel regarding maintenance and rep~i of health physics instrumentation.
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- Control of Radi,olOgical Work*
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.As noted previously in this report, numerous examples bf poor radiological work control associated with contract RP technician performance were identifie Several other.events are a)so cause for concer On December 5, *1990, a crew consisting of a senior RP technician, a maintenance supervisor and an auxiliary operator. (AO) arrived at. the locked gate for access to the 602 1 south pjpe way to verify work order tags. * This area was posted a:s 11Hi gh Radiation Area >1 R/hr 11
The RP technician unlocked the gate and allowed the AO and the mai ntena:nce supervisor to enter the pipe way. * The AO had a dose rate meter and was qualified for self monitoring but could not provide radiological coverag The RP technician di~ not enter the area to evaluate dose rates.. Rather, the RP technician remained at the access point.within sight of the maintenance supervisor and AO; However, the licensee indicated**
the RP 1echnician had been in the area earlier*that day, and was knowledgeable of the dose rate This level ~f coverage di~ not meet the direct coverage requirements of HP 2.5, Entry Control for High Radiation Areas over 1 R/h No significant radiation exposures occurred. 'This event was licensee identifie The licensee held a meeting with the involv~d.RP technician) the RP crew leader and the duty health physicist with the health physics superintendent in attendance.. The 1 i censee *i dent ifi ed the root cause of this event as a lack of understanding ~f direct versus line of sigh~ cov~rage. The corrective actions taken included requiring all RP ctihtractors to read and ackriowledge understanding of procedure HP 2.5... This was completed by
- January 10, 199 This was followed up by crew meetings to.
discuss the 11pros and cons 11 of this procedure when using it in the field; This action was completed by December 7, 199 *On February 11, 1991, a *contract RP technician, *1&c* technician
.and an AO (who did not have a dose rate meter) arrived at the*
locked door ~o the east safeguards room (T-60): The RP te~hnician arrived on the job in street clothes and a teletecto This room was posted as High Radiation Area >l R/hr
- Within this room, most of the areas were posted as contaminated areas.* The RP*
techni~iah advised the AO of the dose r~tes in the areas to be.*
entere The I&C technician could not recall being advised of
.the dose rate informatio The RP t~chriician did not enter the room td evaluate the radiological conditibn The latest survey for this room was* dated February 7, 199 The workers in the room did wear electronic dosimeters which continuously integrated exposure received and had preset alarm This level of coverage_
did not meet the direct coverage requirements of HP 2.5, Entry Control for High Radiation.Areas over 1 R/hr~ No significant
~adiation ~xpos~r~s occurred.
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The licensee 1 s corrective actions were essentially the same as the December 5, 1990 even A me~ting was conducted with the involved technician and the RP technicians were required to read and acknowledge an understanding of HP 2.5, Entry Control for High Radiation Areas over 1 R/h This event was licensee identifie *
This event occurred approximately two months after.,the almost identical, previous even The licensee 1 s corrective actions we.re not adequate to preclude recurrence.. High.radiatio_o. area.. '.- control and RP coverage were discussed at iength."wfth license~~,-~~-.\\
RP managemen The licensee is continuing to evaluate 'methods to improve HRA access control 'and radiologiC:al coverage.** Fa;illfre to take adequate corrective actions is a violation of 10 CFR 50, Appendix B, Criterion XV This appears to be an isolated even This Severity Level V violation is not being cited since the*
criteria specified in Section V.A of the Enforcement Policy were me The NRC expects its licensees to take timely and effective corrective actions to preclude recu~rence. (NCV 255/91006-04)
Two violations and one non-cited violation were identifie Maintaining Occupational Exposures ALARA (IP 83750):
The inspector reviewed the licensee 1 s program for maintaining occupational exposures ALARA, including:
ALARA group staffing and qualification; changes in ALARA policy and procedures, and their*.
implementation; ALARA considerations for planned, maintenance and refueling outages; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting the Also reviewed management techni~ues, program experience and correction of self identified program weaknesse The replacement ALARA supervisor was interviewed regarding changes to and plans for the ALARA progra The licensee indicated that as of January 1, 1991 ALARA dose performance goals have been added to the performance evaluation criteria for all plant persorine Department management ALARA goals have now been factored into the executive bonus progra These goals are formalized and are reviewed quarterl The licensee indicated that management efforts would be focused on identifying and motivating the informal leaders among plant personnel to support the ALARA progra Included in this would be enhanced visibility for contributors to the ALARA progra Plans also include an expansion of the ALARA staf Movement toward proceduralization of cobalt reduction efforts and the hot spot reduction progra Reportedly, the licensee intends to make the hot spot reduction program more pro-activ This would include evaluations of the nature, characteristics and causes of the hot spot The licensee indicated that Pb-Shield software has been acquired to perform pipe loading evaluations for shielding purpose Acquisition of Microshield and Micro Skyshine for ALARA evaluations and shielding design is planne Acquisition of a reactor head shield and
installation of permanent shielding around the regenerative heat exchanger is also planned'.
The licensee indicated that a new modification planning process is being implemente This would marry the three year modification planning efforts with the five year ALARA project planning proces Modification procedures would be revised to strengthen ALARA impl~mentation. Reportedly financial support has been provided to sOpport planned improvements, participation in the Combustion Engineering Owners Group and the Brookhaven National Laboratory ALARA'.
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database and initiative The inspector reviewed numerous ALARA review packages and post job review Included in these were the following activities:
reactor coolant pump seal breakdown and replacement; safety injection refueling water storage tank repairs; spent fuel pool heat excha~ger maintenance; control rod drive seal housing maintenance; reactor cavity decontamination; shielding reviews; restoration of pri'mary coolant system cold leg drain valves; neutron monitor source checks; and*
purification filter valve lineu ALARA reviews we~e usually well documented, specified pertinent dose reduction measures and captured.
lessons learne The licensee is ~urrently in the process of upgrading the ALARA job history file Although the backlog of work in this area following the SGRP/refueling outage appears to be significant, this area appears to be performing very well.
The results 6f QA reviews, interviews with licensee and contractor personnel indicate that the licensee 1s operational ALARA program has matured significantly over the past yea This is evidenced by continued incremental breakdown of jobs into smaller tasks for evaluation for dose reduction implementatio Unfortunately, the licensee 1 s radiation work permit (RWP) system has not kept pace with the development of the ALARA progra As a result of this breakdown of tasks, significantly increased numbers of RWPs have been writte This
. has had some negative impact upon the licensee 1 s progra Resistance from workers was experienced regarding the numbers of RWPs that had to be remembered and referred to in order to complete job assignment This was further evidenced by observations made during QA survei 11 ances and plant tour report Refueling engineering management also indicated some resistance from its work force due to the increased numbers of RWP Support from the workers must b.e maintained for the ALARA program to be successfu The inspector discussed the RWP program weaknesses at length with licensee RP managemen The inspector reviewed the results of the SGRP/refueling outag Many aspects of this significant project have been discussed in previous inspection reports and in other sections of this repor Although the dose totals were not finalized by the conclusion of this inspection, the exposure performance for this SGRP has been the best in the industry to dat The operational ALARA planning and in the field management support were successful in minimizing the usual difficulties experienced during an outage of this magnitude as well as problems presented by the poor performance of the contract radiation protection technician Overall, the radiation protection portion of this project was well planned, ~ell manag~d and well i~plemente **
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The plant side of this project was. also successfu Operational ALARA planning and in the field management support played key*roles in minimizing outage difficulties and contract radiation protection technician performance problem Although refueling contamination control performance could have been improved, exposure and outage time reduction performance was excellent; The exposure goal*for refueling was 60 person-rem.. Actual exposure expended was approximately 53 person-re This was a significant improvement over the. last refueling outage which expended approxim~tely 75 person-rem for refuelin Outage :time utilized for refueling decreased from 16 'l;o 15 d?y Included in this reduction ~ere performanc~ improvements:i~-fuel ciff load/reload. *Formerly, this require_d 8 days/10 days, respectively..
During this outage, -off load required **4.5 days and *reload required day *
No violations or deviations wer~ identified.*
1 Plant Tours (IP 83750, 84750)
The inspector performed sever~l* tours of radiologically controlled area These included walk downs of the auxiliary building, radwaste facilities and spent fuel pool facilitie The inspector observed the fo 11 owing:
0 Radiation workers access and egress from the RCA; personnel use of frisking stations and portal monitors were acceptabl Contamination monitoring, portable survey, area radiation*
monitoring instrumentation in use throughout the plant~ with the exceptions noted earlier in this report~ instrumentation observed had been recently source checked and had current calibrations~ as appropriat Posting and labeling for radiation, high radiation; cont'amiriated and radioactive material storage areas; posting and labeling, with the exception noted below, were in accordance. with
.
regulatory requi rem~nts and approved stat ion procedure Housekeeping and material conditions were generally goo Problems were noted in some contaminated areas in the auxiliary building and the outside storage building Within those areas, accumulations of debris and used protective clothing and
- materials that extended through the contaminated area boundary -
were foun *
During the tour of the outside facilities, the inspector found a radiation area rope on the ground with the information side of the -
postings face down on the groun The inspector and the licensee's accompanying RP technician checked the dose rates in and around the affected are No dose rates were found that would have required*
posting as a radiation are This area was located on the east side of the north radioactive materials storage buildin This area is generally accessible and is used as a *walkway between trailer office The licen$ee must.remain vigilant to ensure that areas are properly
posted to preclude inadvertent radiation exposur No other examples of imprriper posting and barricading restricted areas ~ere ideritifie The licensee commenced investigations and implemented corrective actions td resolve identified concerns priot to the completion of the inspectio *
No violations or deviations were identifie. Exit Interview (IP 30703)
The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on March 8, 1991, to discuss the scope and findings of the inspectio Du~ing the exit interview, the inspectors discussed the likely informational content of the inspectioh report with regard to *
documents or processes reviewed by the inspectors during th inspection. * Licensee representatives did not identify any such documents or processes as proprietar The following matters were specifically discusse The apparent violations (Section 8.a) Inspector concerns regarding the effectiven~ss of corrective actions associated HRA radiatioh protection coverage. (Section 8. b),
Inspector concerns regarding the management review of personnel qualificatiohs (Section 4.a); trainin~ weaknesses (Section 4.b)
and the RWP system. (Section 9)
In~pector concerns regarding the poor performarice of contract radiation protection technicians. (Sectipns 4.c, 5.a, and 8.b) Inspector concerns regarding the methodology utilized to assess
~kin dose due to hot particles. (Section 6.b)
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