IR 05000266/1989022

Insp Repts 50-266/89-22 & 50-301/89-21 on 890725-0824. Violations Noted.Major Areas Inspected:Radiation Protection Program,Organization & Mgt Controls,Staffing,External & Internal Exposure Controls & Control of Radioactive Matls

ML20246K969
Person / Time
Site:	Point Beach
Issue date:	08/29/1989
From:	Gill C, Paul R, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246K966	List: IR 05000266/1989021 IR 05000266/1989022
References
TASK-2.B.3, TASK-3.D.3.3, TASK-TM 50-266-89-22, 50-301-89-21, NUDOCS 8909060186
Download: ML20246K969 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Repo 's No. 50-266/89022(DRSS); 50-301/89021(DRSS)

Docket Nos. 50-266; 50-301 Licenses No. DPR-24; DPR-27 ,

Licensee: Wisconsin Electric Power Company 231 West' Michigan Street - P379 Milwaukee, WI 53201 l Facility Name: Point Beach Nuclear Plant (PBNP)

Inspection At: PBNP; Units I and 2, Two Rivers, Wisconsin Inspection Conducted: July 25 through August 24, 1989 Inspectors: M f(

R. A/. Paul Dats

1. [' d /

i G.9.2nd C. F. Gill skh9 Date

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Approved By: 0,[. 41 7 2h8T '

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W. G. Snell, Chiefd Dat'e Radiological Controls and ,

Emergency Preparedness Section Inspection Summary Inspection on July 25 through August 24,1989 (Reports No. 50-266/89022(DRSS); i l

50-301/89021(DRSS))

Areas Inspected: Routine, unannounced inspection of the radiation protection )

program (IP 83750), including: organization and management controls; staffing;

- external and internal expost re controls; control of radioactive materials and contamination; audits and appraisals; and the ALARA program. Also reviewed were I several recent incidents regarding degradation and breaching of high radiation i area (HRA) barriers (IP 93702) and compliance with certain TMI Action Plan Items I (TI 2515/65).

Results: Although the licensee's radiation protection program generally ';

continues to be effective in protecting occupational workers, the inspectors-perceived weaknesses in the keyway (reactor cavity pit) entry control policy (Section 5), the personal contamination control program (Section 7), and 'he ALARA program (Section 9). One procedural violation with three examples ,<as identified (failure to suitably barricade a HRA on two occasions and failure to follow requirements for entry into another HRA~,-Section 10). The violation )

is indicative of a significant recurrent programmatic problem regarding HRA entry control. Followup of previously identified problems concerning inability to meet TMI Action Items II.B.3 and III.D.3.3 during an exercise identified two i potential violations for f ailure to comply with TMI Action Plan Confirmatory I Orders (Section 3). An enforcement conference will be held to determine appropriate enforcement action.

l 8909060186 890s30 i

PDR ADOCK 05000266

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DETAILS

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1. 1. . Persons Contacted ,

1. M. Baumann,' Project Engineer, Radiological'l Design

1. R. Bredvad, Plant Health Physicist ..  !

1. W.7Doolittle, Nuclear Specialist (Health Physicist) i

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• F Flentje, Administrative Specialist, Regulatory Services

1. T. Fredrics, Superintendent, Chemistry l

1. • D.~ Johnson, Superintendent, Health Physics i

1. • J. Knorr., Regulatory Engineer i

• G. Maxfield, General Sup'erintendent, Operations j

• J. Zach, Plant Manager

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• J. Gadzala, NRC Resident Inspector J

The inspectors also contacted.Other licensee employee )

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• Denotes those present at the onsite exit meeting on July 28, 1989.

-# Denotes those contacted by telephone during the period July 31

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through August 24, 198 . General

. This inspection was conducted to review the radiation protection .

program. The inspectioW included tours of'the onsite facilities, I s' observation of work in' progress, review of records, and discussions  !

'with licensee personnel.

' Licensee Action on Previous Inspection Findinos (Closed) Open Item (266/89003-01; 303/89003-01): Use of alpha activity results from air samples and smears performed in the fuel transfer ,

cana Two procedures involving the alpha analysis program have been revised to require alpha analysis of air samples taken from the reactor cavity and fuel transfer canal. About 15-20 percent of all snear swipes

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taken from the transfer canal are analyzed for alpha activit .

(Closed) 0)en Item (266/89003-02; 301/89003-02): Use of CAMS in the

. auxiliary )uilding during fuel transfer canal work and fuel handlin The licensee is currently using alarming CAMS on the auxiliary building refueling floor during outage conditions to alert workers of changing condition (Closed) Open Item (266/89003-03; 301/89003-03): Weaknesses associated'  !

with the use of rops barriers for HRA control The licensee is

' attempting to replace all rope barriers and has installed permanen swinging barriers to replace most rope barriers in the Unit I containment; the rope barriers'used in Unit 2 containment will be '

replaced during the 1989 (all outag ,

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(Closed) Open Item (266/89015-03; 301/89014-03): Corrective action l to prevent recurrence.of an unplanned extremity exposure event. An )

inspector reviewed the adequa'cy of the licensee's corrective actions to' - l prevent recurrence; no problems were noted. -The corrective actions are  !

, ' delineated in Section'4 of Inspection Reports No. 50-266/89015(DRP); R -No. 50-301/89014(DRP). ,

(Closed) Violation-(266/88013-02): Failure' to follow HP Procedure 3.2, Posting of_ Radiological Areas. The corrective actions outlined in the licensee's response dated June 17, 1988 were reviewed; no problems were note ,

J (Closed) Open Item (266/88022-03'; 301/88020-03): Lack'of an audit program to perform periodic surveillance of liquid and gaseous  !

radwaste activities including audits to ensure performance of required .!

surveillance tests'of effluent monitoring systems. The inspectors-verified that tne'1989 Quality Assurance Project Plan included an audit

. of the liquid'and gaseous radwaste effluent activities (scheduled' for -

late.1989) and T/S Surveillance Requirements for the effluent monitoring l systems were audited,as part of T/S Long Frequency Surveillance Audit j (No. A-TS-89-02) during the period from March 20 through May 19, 198 This matter is close )

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(Closed) Open Item (266/89088-06N During the March 15, 1989 emergency

,' preparedness exercise, the licentee demonstrated an inability to obtain

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and analyze a~ containment.atmosp'nere sample when predicted containment pressure exceeded 5 psig. .The technical and procedural problems and

' proposed corrective actions are discussed in Subsection 2.j of Inspection

' Reports No. 50-266/89023(DRSS); 50-301/89022(DRSS). The regulatory significance of the licensee's failure is discussed belo i On March 14, 1983, the Commission issued an Order confirming the licensee's commitments on certain Post-TMI related issues. The Order states,.in part, that the licensee shallsimplement and maintain the i specific items described as complete in the attachments tn the Orde !

, Attachment 1 to the Order described as complete the licensee's commitment 1 to install upgraded post-accident sampling capability for NUREG-0737, j Item II.B.3, ' Post-accident Sampling." -NUREG-0737, " Clarification of 1 TMI Action Plan Requirements," states, in part, that the licensee must  !

I provide capability to remove grab samples of containment atmosphere within an allowed combined time of.three hours or less for sampling

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and analysis. Figure 14.3.4-7 of the licensee's FSAR indicates that i under predicted accident conditions the containment pressure would .l H' not decline to 5 psig until greater than three hours post-acciden j Plant Procedure No. EPIP 7.3.3,, Post-Accident Sampling of Containment

. Atmosphere, Revision 20, October 10, 1988, Step 4.1.2.d states that ,

the sample pump seals are rated for 5 psig and to prevent an inadvertent  !'

airborne release, the containment pressure must be less than 5 psig before proceeding. As discussed in Subsection 2.j of the aforementioned inspection reports, the pump seals are not at risk at 5 psig; however, a glass drain trap collection bowl in the system does have a pressure j

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limitation of.5 psig. Therefore, although the procedural' reason for the , 4

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fpressure limitation is erroneous, the limitation value of 5 psig appears h valid.. (According toithe licensee personnel, the pump seals.have:a .

15 psig' limitation.) According to the licensee, the 5 psig pressure: .

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. limitation'was added to EPIP 7.3.3 in Revision 5, July 1, 1983,.after the

'. containmenttatmosphere sampling subsystem was modified. The licensee's P .;

failure to. maintain. the post-accident sampling system's capability to

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obtain grab samples of containment-atmosphere under predicated accident

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conditions within an allowed time of three hours or lessifor sampling L< and analysis is an apparent violation of 10 CFR 50.54(h) which states, in i e part, that the licensee shall be subject to"the provisions of. the orders of the Commission. Because the resolution of this matter will be tracked:

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as an apparent violation, this item'is closed,(Violation 266/89022-01;-

301/89021-01).

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(Closed) Open Item (266/89008-07):. During the March 15, 1989 emergenc >

preparedness exercise, it was noted that the licensee lacked a procedure for counting an inplant air sample which had a predicated high level of-

, radiciodine,present. Proposed corrective actions are discussed in-Subsection 2.k of Inspection ReporM.No. 50-266/89023(DRSS);.

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50-301/89022(DRSS). The regulatory significance of the licensee's' >

l failure is discussed belo On July 10, 1981, the Commission issued an Order confirming the licensee's commitments on certain Post-TMI related issues. The

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Order states, in part, that the licensee shall satisfy the' specific

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requirements described in the Attachment to the Order no later than'

60 days after the effective date of the Order. The Attachment to the Order requires the licensee for NUREG-0737 Item Ill.D.3.3, " Improved Inplant Iodine Monitoring," to.have available means to accurately'

measure airborne radiciodine inplant during an accident. NUREG-0737,

" Clarification of TMI Action Plant Requirements," states-that these means shall include procedure As discussed in Inspection Reports No. 50-266/80019; 50-301/80019, the licensee initially intended to use the analytical ability of a single channel iodine spectrophotometer to accurately measure airborne

.radioiodine inplant during an accident. Use of this instrument for this purpose was specified in Health Physics Administrative Control Policies and Procedures Manual Se:: tion HP 17.5.5, Revision 0, October 24,'198 According to the licensee, tnis procedure was incorporated into an~

Emergency Preparedness Implementation Procedurc (EPIP) circa 1982-1983, was cancelled in 1984 when the single channel analyzer was removed from service, and was not replaced by a new procedure. The licensee's failure to maintain the procedural means to accurately measure airborne o radiciodine inplant during predicated accident conditions is an

' apparent violation of 10 CFR 50.54(h) which states, in part, that the licensee shall'be subject to the provisions of the orders of the Commissio Because the resolution of this matter will be tracked as an apparent violation, this open item is closed (Violation (266/89022-02; 301/89021-02).

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4 .- Organization, Management Controls, 'and Staffing (IP 83750)

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The inspectors' reviewed the licensee's organization and management j controls for radiation protection,< including changes.in the organizational i

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structure and staffing, effectiveness of procedures and other management l techniques'used to. implement the program, and experience concerning l

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self-identification and correction of program implementation weaknesse l 3 i The organization structure for the Health' Physics Group remains the  !

same as discussed in Inspection Reports No. 50-266/88003(DRSS);- 1

No. 50-301/88003(DRSS), except that the Radiation Control Operator .  !

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(RCO) positions are now designated'as Health Physics Technologist (HPT) j

1. < positions. Currently, all 20 HPT positions are. filled and HPT staffing j remains. generally stable withltwo replacements in 1988 and three to dat .i

'in 1989. The licensee's policy to usually. hire replacement HPTs with 0 health physics associate degrees and/or several years applied experience

aids in assuring.the maintenance of an experienced and technically competent staff. Regardless of the educational and experience background

"of.new HFT hirees, they are designated as trainees who must complete a-rigorous qualification program (usually two years) before they may be o promoted to HPTs; six of the HPT staff have not yet completed the j qualification program. The inspectors reviewed tha qualification program u and the continuing education program for qualified HPTs; no problems were a

noted. The supervisory and professional HP staffing (10, members) has remained stable over the past two years. The inspectors selectively

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reviewed tho education and experience background of these staff members; j i

their qualifications, generally, are goo Upper management support for the radiation protection' program appears good, with the exceptions due '

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mainly to budgetary constraint No violations or deviations were identifie . External Exposure Control and Personal Dosimetry (IP 83750)

The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities, equipment, l personnel, and procedures; adequacy of the dosimetry program to mee .I routine needs; required records, reports, and notifications; effectiveness '!

of management techniques used to implement these programs; and experience i concerning self-identification and correction of progrt.m implementation

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l The licensee's estimated 1989 total dose of 400 person rem compares 1

! well with previous annual doses. Through June 1989 the total (station) l exposure was about 185 person-rem which includes a major refueling / 1 maintenance outage. No ex'posures greater than 10 CFR 20.101 limits  !

were noted,'no individual exceeded the' licensee's; administrative quarterly whole body limit of 2500 mre ' Portable instruments are typically calibrated quarterly. The inspectors reviewed records of recent calibrations of selected portable instruments; i no significant problems were noted. The licensee's inventory, control

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j and calibration programs appear adequat l l

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&# - (The inspectors reviewed;the,. licensee *s, N ., reactor cavily, pit entry control) 3 hf Q f~ ' policy-(Draft Guideline.No; HPGD;16; Routine Keyway ~ Entry Guideline) and

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j discussed their. resultant. concerns.with appropriate members of thel

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i E N R* f . ;1icensee's staff; The inspectors: expressed concerns regarding?the; '

(j 7 - lack of a unique:HRA, lock for the entrywayL(any liRALkey may be used on l the keyway lock),-questioned the.needifortAuxiliary Operators (A0s) to-

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. have keys for the keyway lock,, andinoted;that there;were no specific-w . instructions:to the Duty Shift Supervisor (DSS)iorith'e A0 to; inform .

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.,y o y ;the.HP group prior to keyway entry;iUpon notificatiori of the -inspector- <

concerns,1the HP Superintendent = stated that serious consideration.woul ' '

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"be given to apparent' need to establish more stringent keyway entry ' . '

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s < controls. "This' matter was' difcussed at the[ exit' meeting and will be'- "; l Jreviewed further'during a1 future inspection (0 pen Item 266/89022-04;

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~ No violations or deriationsiere identified.I kF .6.~ InternalExposureControl'andAss$ssment'(IP83750)-

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The insp~ect. ors reviewed selected aspects of the licensee's internal r ' exposure control and assessment' programs, including: 'deterntnatio .

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whether-engineering controls, respiratory equipment; and assessment ,

of intakes meet regulatory requirements;eand planning and preparation '

> , . for' maintenance) tasks' including ALARA consideration '

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Air sample data wereTselectively reviewed. Air samples appear to be ,

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taken,. counted, and evaluated in accordance with procedural. requirements.-

.The procedures appear adequate for use in determining. air sample results,; i

- placement,;and.typei 'Special' air samples are collected to establish RWP 1 requirements'and'iob' conditions, and it' appears the licensee adequately =l '

uses air samplef t-esults.to establish RWP requirements for.use of respirator and protective clothing-

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s The licensee's whole-body count'and calibration program is discussed 1 in Inspection Reports No. '50-266/89003(DRSS); No.: 50-301/89003(DRSS); l

.no significant changes have been made:to the program. Review of . licensee: .

records indicated that no intakes in excess ~ of the 40 MPC-hour control

> , ' measure occurred in 1986 or 1989 to 5te. The WBC was calibrated by the vendor.in March 1989; a standarr i asonite phantom and NBS' traceable -l sources were used. The inspectors T J ewed the calibration results; no problems were identifie a

' No violations or deviations were identifie " . Control of Radioactive' Materials and Contamination (IP 83750)

s lhe inspectors reviewed the licensee's program for control of radioactive :

. materials and; contamination, including: adequacy of supply, maintenance, I'

and calibration of contamination,-survey, and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review'and dissemination.of survey data; and effectiveness

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of methods of control of radioactive and contaminated material s 6 i

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g, . . Whole Body Frisker Calibration' Program The inspectors reviewed recoras'and relevant calibration procedures 1 for the 'Eberline Model PCM-1B whole body frisker (WBF). Calibrations of'the WBFs are performed a6nually using nominal 100-nanocurie 01 ,

cesium-137 (100-cm2 area) standards. Detector efficiencies are about 11%;.the efficiency for the foot portion of the WBF is'about

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,16L Frisker alarms are nominally set at two nanocuries. _ A g two-nanocurie cesium standard is used monthly on all zones, and a' ten-nanocurie' technetium check, source is used daily on one zone to ensure the detectors alarm at the established'setpoin The inspectors reviewed calibration. records for. selected monitors, and'using the' vendors technical manual,' verified the vendars

. calculation _to determine alarm set values for each ' unit; no E problems were note Personal ~Cohtamina' tion Events StationHealthPhysicsProcedureHP2.1.1requiresiallpersonal e '(skin or. clothing) contaminations cetected as a result of hand-held frisking to be reported.on Form CHP-39(a). 'Similarly, HP 1.11 requires reporting of contamination initially detected by portal  ;

monitors on CHP-39(a). All personal contamination reports are i

entered 'in a computerized Personal Contamination Tracking System which identifies several parameters, including detection method, location of contamination, and probable cause, and allows tracking /

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trending, Through the second quarter of 1989, there were 164 personal l contaminations identified, about 40 percent of which were below the  !

INPO reporting criteria of 100 cpm abov_e background with a hand-held frisker and detected on skin or clothin During 1988 there were-  ;

. 645 personal contamination- events, about 40 ' percent of which were also below the INPD reparting criteria. < Although there appears' to be a significant' decrease of contamination eveots in 1989, the number of events seems inordinately high for a station with a stro contamination control ' progra , improve this condition, the q licensee : initiated special training classes emphasizing acceptable .l

work practices and use of proper protective clothing and survey technique In additi A % -lKensee pm; on using longer rubber 7.na eM pMMtithg the reuss of low-cut toe ' rubbers in the RCA; high-top plastic disposable shoe covers will be used instead. Also

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contributing to the number of' events is the. current practice of hand i frisking each laundered piece of protective clothing; a practice l other licensees have found less efficient in identifying contamination

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than the~ use of laundry monitors. The licensee intends to purchase N

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a new laundry monitor in the.near future. This matter was discussed at the exit meetin Hot Particle Progra i

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During a previous refueling outage in 1988, the licensee identified several hot particles on and around a step-off pad (50P) leading from

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the. reactor cavity. As a: result, the' licensee increased area and personal surveillance during cavity work, implemented more stringent

clothing requirements at SOPS, and improved cavity decontaminatio practice '

During the spring 1989 Unit 1 refueling outage, the licensee

.found approximately 28 hot particles in the lower and upper cavity;L predominately niobium-95, zirconium-95, cerium-144, and ruthenium-10 .The particles were found on.large area masslinn-smears direct surveys; Portable ion chamber readings of.the particles at' contact indicated they ranged up to.58 R/ hour with the beta window open-and 8 R/ hour with the window closed. Based on intermittent surveys of personnel working in the cavities, it appears none of the- hot particles were.on any of the workers or their removed protecuive clothing, nor were any transferred from the cavity to t % refueling floo No' violations or deviations were identifle . ' Audits and Appraisals (IP 83750)

The inspectors reviewed reports of audits-and appraisals conducted for or by the licensee-including audits required by Technical Specification Also reviewed were management' techniques used to implement and audit the program, and experience concerning identification and correction of programmatic weaknesse The inspectors selectively reviewed portions of the QA audit and surveillance reports and corporate health physics group audit. reports for 1988 and 1989. The licensee's QA and corporate HP audit / surveillance

. program appears adequate to assess technical performance, compliance with requirements, and personnel training / qualification relating to the radiation protection program. The QA and orporate HP auditors assigned to review this functional area appear to have the necessary expertise and experience prerequisites. ' Interviews with appropriate licensee personnel indicate that responses to audit / surveillance findings are generally thorough, timely, and technically soun No violations or deviations were identified by the. inspector . Maintaining Occupational Exposure ALARA

- .,The inspectors reviewed the licensee's program for maintaining

. occupational exposures AtARA, including: changes in ALARA policy and procedures; ALARA considerations for maintenance and refueling outages; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them. Also reviewed were management techniques used to implement the program and

. experience concerning,self-identification and correction of implementation weaknesses.

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The ALARA program is coordinated by the Exposure Reduction Committee (ERC) which meets. monthly or on an as-needed basis. The ERC chairman is a Nuclear l Specialist (Health Physicist) in the HP Group; the committee

- contains a member.from each plant work group. The ERC reviews radiation exposure. reduction suggestions; work group and contractor collective exposure trends; successful.and unsuccessful exposure reduction

. practices; ALARA reviews completed for plant modifications, procedures, and regulatory commitments; work activity exposure on specific plant.

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systems; and exposure reducing products, procedures, and techniques for L plant-wide benefit. From these review activities, the ERC evaluates the ef festiveness .of the program and makes recommendations for improvement The ALARA program is implemented by Procedure PBNP 3.7.2, PBNP Exposure Reduction Program, which requires that annual person-rem goals be developed by each plant work group, reviewed by the HP Superintendent, and approved by the Plant Manager. PBNP-places much of the responsibility for employee exposure control on individual employees, first.line' supervisors and group heads; work groups are held responsible ,

for meeting goals; and program oversight responsibility is shared by the HP Superintendent and the ER The inspectors reviewed the effectiveness of the ALARA program by reviews of documentation and interviews with licensee personnel. The plant workers are presented with the. opportunity to enhance the ALARA program under the provisions of Procedures PBNP 3.7.3, Employee ALARA- Feedback Program,'and HP 12.2,. Radiation Exposure Reduction Suggestion Progra The inspectors found evidence that both of these programs are implemented adequately and most suggestions are resolved in a timely manner. The exposure goals established by e'ach work group appear reasonable, based on

, historical data and anticipated work activities. The 1988 station goal '

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was 393 person-rem, the actual total dose was approximately 388 person-rem; the station goal for 1989 is 414 person-rem which includes provisions for extensive outage activities. The plant-wide ALARA policy and management commitment to the ALARA program is specified in Procedure PBNP 8,2.1, PBNP.ALARA Program.' The involvement of management, the HP group, other j work groups, first line supervisors, and individual workers in the ALARA program has historically resulted in annual total doses which were i'

generally well below the national average for PWR A review of the licensee's documentation of'the 1989 accumulated person-rem for each work group indicates most work groups are staying within their established goals; although some individual work groups

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have exceeded or will likely exceed their goals because of unanticipated work activities. The exposure reduction program required radiological j reviews of planned work activities are specified by Procedure PBNP 3.7.4, Radiological Review Guideline, which currently are categorized into two l distinct levels of review. Level 1 radiological reviews apply to routine dose activities, utilizes the RWP system, and review responsibility rests with the work group desiring to do the work. Level 2 radiological reviews apply to activities with the potential of high dose to personnel, also j

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-utilizes the RWP system, and review responsibility rests with the Health Physics Group. Level I tasks are:for activities where the total estimated dose to any individual will not exceed one rem and the total estimated

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co Nectivel dose'.will no't exceed two person-rem;' Level 2 task's forfany" N . activities where the Level 1 estimated doses may be exceeded. Because of~,

fthis two tiered review system, PBNP nominally has one." standing" RWPfforc each work group and a limited number of specific task RWPs. Theilicensee

is in the process of revising PBNP'3.7.4 to initiate a' Level 3 radiological

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x review for tasks which could. exceed 15 person-rem and are ofs a repetitive

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nature;- development of formal job'h.istory' files and more detailed ALARA:

review would likely be required for this. type of tas The~inspectorsy

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'also reviewed the shielding control program'specified by Procedures PBNP 3.4.13, Guidelines for Applying" Temporary? Shielding, and HP;9.3,; -

,, Lead Blanket Control, Procedure; no;significant pr6blems werejnote r Although PBNP annual doses have* generally beeniless than the.nationali

, s .PWR average since the plant' began operation, durin'g recentLyears;PBNP ,

m" does not appear _to exhibit the same downward trend as'the national PWR average annual dose. :This"may portend a need for reevaluation of the

• ALARA efforts by the licensee.' The: inspectors discussed with the ERC , , 4:

' Chairman and the HP Superintendent the features'of other licensee' ALARA programs with which the1 inspectors 'are familiar,> and.the apparent:

desirability.for the licensee'~to consider adapting portions of some s .

of these features'into the PBNP ALARA program.. The ALARA program-features-discussed which seem to merit serious licensee consideration iincluded the appointment of-a full time ALARA Coordinator;:ALARA shift coverage during outagest and.the development of formal job history files, ,

a photo library of equipment and components, video: tapes of certain tasks.

, -as a' diagnostic and training tool, lessons learned and dose-savings documentation;:more formal procedures,and documentation methodology'

'for ALARA reviews and pre / post-job briefings, and a long-term exposur reduction plan. At the licensee's requesti the inspectors discussed the

successful implementation of the above ALARA' features at sever'al regional

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nuclear power plants; the licensee indicated'that consideration would be ~

given to' sending appropriate personnel to other plants to review.their

- ALARA programs to ascertain whether certain features of their' programs

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might'be beneficial if incorporated into the PBNP ALARA program. This

. . matter was discussed at the exit meetin No-violations or deviations were identifie ; 1 Higt Radiation' Area (HRA)' Barrier Degradation Incidents (IP 93702)

L4, . In 1988, repeated inciderits occurred involving degraded HRA rope barriers at areas where dose rates were between 100 and 1000 millirem per hour, r 'most of which occurred during the Unit-2 outage (see'Section 11 of Inspection Reports No. 50-266/89003(DRSS); No. 50-301/89003(DRSS)).

Corrective actions included installation of swing-type gates at most-j; ~1ocationssin containment in lieu of rope barriers. However, in addition n ,

to the degradation of HRA rope barriers, on October 19, 1988, the licensee o discovered two HRA doors had been forcibly breached to pain access to an area located beneath the fuel transfer canal (see Section 6 of Inspection Reports No. 50-266/88023(DRP);No. 50-301/88022(DRP)). Because the

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licensee concluded that the probability was extremely small that anyone could have unintentionally received a significant radiation dose during w

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g the timeathe HRA; doors' were outfof= service Sn'd the 41icensee'appearedLto_

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' N 9mi ' meet allLthe criteria'of 104CFR Part 2, Appendix-C,1 for self-identification-yyg,' andl correction of problems,:a Notice of Violation was.not issuedi '

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the ' matter. was closed (see Section '3 of Insp?ection Reports?

No.-50-301/89003(DRSS)) L

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T,., p In" addition to"the HRA barrier; degradation incidents: discovered by

' J" r 'y the licensee in a988, during a tour on April- .20, 1988kNRC inspectors ,

C 4 o observed that al procedurally required flashing red light, used as a warning; ,,

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device.in HRAs wl.ere radiation fields' exceed 1000 mrem /hr, was insta11ed ' . "

.but not;in use. LAlso as a result of surveys' requested by the inspectors,"'

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l;l - , ,w two HRAs thattexceeded,100. mrem /hr during fuel transfer were identified

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that were not posted-and controlled as required by Procedure.3.2,. Posting' ..

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of Radiological Areas. Because'the licensee did not meet all'the -

,.g 3  ; criteria offl0 CFR Part 2, Appendix C, for self-identification'andi

r> correction of problems, a Notice of Violation was issued for these;

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' NRC-identified procedural' violations (see-Section 11 of. Intpection'

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Reports No.:50-266/88013(DRSS); No.:50-301/88013(DRSS)). In'the: response, i dated June 17, 1988', to the Notice of Violation,~the licensee acknowledged i7 .

, that/the' night-shift refueling supervisor regarded the flashing red ligh * , ;as a distraction >and arranged with a HPT to remove the flashi_ng) red light from service and to expand the HRA. rope barrietto provide better access *

'controi tto:the area. Licen'see corrective actions' included immediate v '

establishment of proper HRA. barriers, an information session was conducted

'with HP staffemembers regarding the HRA-barrier degradation'sland the HRA control and posting requirements of T/S 15.6.11 and Procedure HP'3.2, Lan :a commitment 1tolformally retrain HPTs and HP supervision on HRA control

'and posting requirements on;a .much broader scope; than the specific

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4 ,4 '" incidents by October 1, 198

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, In' addition to the corrective -actions associated with the individual 1988 :

s 'HRA' barrier incidents discussed above, the, Plant Manager'sent a memorandum, -

. dated October:27,1988, to all plant employees stating that when barricades

4 'or barriers or other warning devices are propped open or, breached (whether T' ,'

intentionally or unintentionally) plant management's concern tis that some a employees 'do not appreciate the. importance of those barriers and there may be a casual attitude toward barriers and warning devices being demonstrated:

, by a few employees. The Plant Manager concluded the memorandum by stating 4 Lthat if barriers' or other warning devices:are found in a degraded condition,

. the cause of'the condition will be investigated and appropriate action will be taken including discipline, if necessary. Despite the licensee's attempts to institute effective corrective action' to prevent recurrence s of=the 1988 HRA barrier degradations, the. licensee identified six incidents which occurred between April 5-17, 1989, which involved either HRA barrier degradation or willful violation of a HRA barrier.- Although the NRC

"_ * endeavors to encourage 1icensee identification and correction of problems

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a, Ethrough appropriate' discretionary'use of the enforcement policy (10 CFR Part 2, Appendix C), the licensee's failure to implement corrective

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actions to prevent recurrences of HRA barrier degradation and the apparent willful'(intentional) failures to follow the procedural e HRA posting and control requirements precludes application'of such discretion for these incidents, t

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f On April 5, 8,- aad 15,1989, during the recent Unit

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Lbarrier. rope'at the entrance ~to the pressurizer wa outage, found not to'be the.HRA in- >

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. place; licensee' representatives stated that it is not known if there -

were actual breachescof the1 barrier by plant personnel. On April 11,-

1989, the HRA barrier rope at the SOP:for.the Unitil Regenerative Heat

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Exchanger Cubicle wasDfoundito be moved in toward*the cubicle entry by t about 18 inches on one c/ ner; the corner stanchion was unbolted from the-J 'i grating, moved, and refa,tened to the grating .at' the new location inside

[ :of the' HRA. - On April 14,1989, the~same correctly replaced stanchion was-found bent over such that the barrier rope was' again inside; the HRA. On April 17,1989, a HPT observed'three operators violate the HRA boundary ' 4

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. on the 66-f t south walkway to the spent fuel pool The area was posted

"HRA, RWP,; no entry during" fuel movement." The RPT reporte.d that this area was. not ' authorized by.the ' operators' job specific RWP and they did:

l not'have'a dose' rate ~ instrument when the entries were made;.however, the-L

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operators who enter the area were, according to the licensee, o n re that no fuel movement.was-occurring. These last three! incidents are apparent willful:(intentional) violations of HRA barrier and entry requirements

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specified by Procedures.HP 3.2.3 and HP 2.5 and.are representative of

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violations that could reasonably be expected to have been prevented by the lic'ensee's corrective' action for a previous violation Y (Violation 266/89022-03; 301/89021-03). >

One violation with three examples was identifie . Exit Meeting (IP 30703)

' The' inspectors met with licensee representatives (denoted in Section 1)~

'at tne conclusion of.the onsite' inspection July 28, 1989, and by b telephone through August 24, 1989. .The inspectors summarized the scope and findings of the inspectio The inspectors also discussed the.likel informational content ~ of. the inspection report with regard to documents-and processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes as proprietar The following matters were discussed specifically by the inspectors: The perceived weaknesses in the keyway (reactor cavity pit) entry control policy. (Section 5)

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, : Inspector concerns regarding the number of personal contamination events. (Section 7) The effectiveness of the ALARA progra (Section 9)

'd . Recurrent violations of procedural HRA posting and control requirements. (Section 10) .;

i The licensee's f ailure to comply with TMI Action Plan Confirmatory 'j Orders. (Section 3) 1

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