IR 05000266/1990008

Insp Repts 50-266/90-08 & 50-301/90-08 on 900423-26 & 0503. Violations Noted.Major Areas Inspected:Radiological Protection Program During Refueling & Maint Outage,Including Hot Particle Event & Organization & Mgt Controls

ML20043B261
Person / Time
Site:	Point Beach
Issue date:	05/17/1990
From:	Grant A, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20043B260	List: IR 05000266/1990008 ML20043B259
References
50-266-90-08, 50-266-90-8, 50-301-90-08, 50-301-90-8, NUDOCS 9005250164
Download: ML20043B261 (16)

Text

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mm l< - . . - ' ,, gW{9 w 'g cU.St.. NUCLEAR-REGULATORY COMMISSION' , ,

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REGION III

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, , "Re' or't1Nb 150f26D90008(DRSS){ 50-301/90008(DRSS) ,' . p r co m \\ ii*, ' i

J Docket Hos; '50-266;:50 301 LicenseLNos.'DPR-24; DPR-27!

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- M LLicenseesW1sconsin Electric l Power ' Company' ~ ' ' ' 2311 West Michigan- >> y' , Milwaukee,;. WI ' ' 53201".

/ , ",- , . - t g-1 Facilit9; Name:!PointLBeach Units'1 & 2 < E (Inspection : At: TwotRivers, Wisconsin -

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Ins'pectioniconduc pril 23-26~,1990 and May'3,11990 e

p.A / -/ ' g ' Inspector: (W. B. Grant? 57ll/TO eq O&te ' iAccompanying ('d GMC y , W 1 Inspector-

A.=We Markley W

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~ - ' Approved By: iWiT11am Snell,' Chief.

s/n/96

Radiological Controls and-

. Date q _e , .- Emergency Preparedness-Section

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A ! In spec tionD Sunimary i i -

) ,,.Insp_ection on April 23-26,u1990 and May 3, 1990 (Report No.- '

M '. Noe 50-301/90008(DRSS)) 50-266/90008(DRSS)1 j . . l P 4, Areas Inspected: Routine'andlspecial announced' inspection of theiradiologleal d ! protection; program during-a: refueling and-maintenance outage,11ncluding: ~ ' '" ! ('1)3 otEparticle: event (IP,93702), (2) organizational:Tand' management l controls; h > a W ' ((3)fauditsVandfappraisals, (4) external exposure control, (5) control ofl - L1 radio . D, Hoccup. active materials, (6) contamination and1 surveys, and (7) maintaining,. ational exposures ALARA (IP:-83729, 83750). - Also. reviewed were several-jN ..recentLincidents-involving: breaching of high radiation areaD(HRA)- barriers, a - M % , f corrective; actions on previous violations:and other identified concerns ~' $$

[(IP-92701,92702).-

.. . . i ! J y 1Results: -The review.of the April 3, 1989,. hot particle incident: indicated

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that a regulatory-overexposure' (pursuant to.10 CFR 20.101) did not occur.

a ., -! E JApparent'. violations of regulatory requirements associated with the hot

• a particleLincident and recurrent high radiation area boundary 'vf olations were:.

' l identified (Section.4;and 5, respectively).

The appropriatetenforcement Lactions?for thase-apparent" violations will be determined and communicated to

i $ ! ! the'slicensee.b9 separate correspondence..In addition, one non-cited

, + violation?(NCV) was identified in a Technical Specification audit.

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men ' , . , J - 4- . DETAILS 1.

Persons Contacted'

• J.. Anthony, Quality Engineer
• J.:Bevelacqua, Superintendent, Health Physics
• R. Bredvad, Health Physicist

W..Doolittle, Health Physics Specialist E Epstein, Health Physics-Specialist D. ' Florence, Health Physics Technologist

• C. Gates, Radwaste Supervisor

- ! T. Guay, Health Physics Supervisor D.-Johnson, Superintendent, Nuclear Regulation E. Lange, Lead Health Physics Supervisor M. Moseman, Lead Health Physics Specialist ! P, Scheffel, Health Physics Supervisor

• R. Seizert, Regulatory Engineer
• J. :Zach, Point Beach Nuclear Plant, Manager
• C. Vanderniet, Senior Resident Inspector-J. Gadzala, Resident Inspector The inspectors also interviewed other Licensee and contractor personnel

'during.the course of the inspection.

• Denotes those present at the Exit Meeting on-April 26, 1990, 2.

General This inspection was conducted to review various aspects of the licensee s i radiation protection program during a refueling and maintenance outage,

' including: the April 3,1989 hot particle event, changes since the last inspectiord audits'and surveillances, exposure. control, control of ! radioactive materials, ALARA,- and the licensee's corrective actions - regarding previous violations and identified concerns.

During the

performance of plant tours, no significant access control, posting or procedural adherence problems were identified. Housekeeping and material conditions were' generally good.

However, housekeeping was. poor in the-lower two levels of the primary auxiliary building and the lower level of both facade buildings.

3.

Licensee Action on Previous Inspection Findings (IP 92701) (Closed) Open Item (266/89022-04; 301/89021-04): Establish more stringent keyway entry controls.

In response to this concern the licensee has completed the following items: 1.

HP procedure 2.14 has been written and issued.

This procedure is a step-by-step sign off procedure which is designed to ensure proper authorizations and verifications.

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- , P7 h 12.n Health Physics'Guidelinel(HPGD)}32'has b'een issued.;,This' guideline Q 1g 'provides health physicsfpersonnel'withLinstructions.:regarding' ' ' %d,, sexpected ra'diological conditions and~ appropriate? precautions-for ym * , keyways entry.1 ' 7' , , .- - _ ALuniquepadlockfis.now--usedtocontrolaccesstothekeyways.The-MM ' 33; - c - @_ ! keys.to-these' padlocks)are underLdirect control:of health physics ' g.f 7., p' 6 isupervision; Entries to the keyway maytonly beLauthorized by.the' ' . . Superintendent - Health' Physics or the~ Health Physicist.

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(Closed)-Unresolved Item (266/89031-02; 301/89031-02): Resolve-the

, 4' , ~ 4 ' problems withtthe solidification process and discuss with the processings a* 1 ? vendoriand'the burial site to arrive-at a suit'able; solution. LThe{ licensee -

hasicompleteditbe! action items associated with the solidification process.:; Discussions with'the. processing vendor and:the burialisite;

have been held.-

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..(Closed) Unresolved Item (266/89030-02): Potential overexposure of at , ~ health physics technician. The licensee'has completed their investigation J A of.this. event. The licensee's investigation concluded that'the; ' technician--received a maximum localized dose ~ to the skin of the extremity-of 12.4" rem. DTheLinspectors reviewed the licensee's-' analysis of this g -

event and theirecommended corrective actions'(See Section 4).

.a- . ' _ ' Hot Particle Event:(IP 937021-14 ~. L (While performing a-survey of the lower reactor 1 cavity;on AprilL3,1989,- . '4 a: health' physics technologist handled a small' fuel fragmentiin hisjleft n Ehand; This; action resultedrin a significant extremit'y skin exposure, t Corrective actions and' exposure evaluations: performed following the event-

did.n'ot! appropriately characterize th 'eventfand the associated exposure cone event' ?The significance,of-thei sequences were not11dentified untilz , ' the health-physics technologist-directly1comm'unicated-his concerns:to the ~ o,' Superinten' dent -Health Physics on November 9,7 1989.

> w , On November-15, 1989,-the: initial' dose assessment was reported to the NRC.

, . as 75 ' rem to the skin of the -left hand. This estimate wasirevised and- ' ' reported.as 375 --400 rem on November-'17,-1989..Further refinement?of-the' . TdoseJassessment;by December '8,1989, indicated a ~ maximum extremity skin

J > dose.to one' square-centimeter of-the health l physics technologist'slleft hand of approximatelyL20 rem.

g tv On December 8, 1989, the licensee commissioned.aniEvent Investigation . > ~ ~" Committee composed of individuals who were not associated with Point Beach ~ m-Nuclear Plant..This committee was chartered to investigate the failure'

' Lto' properly characterize the event in April 1989, to evaluate event precursors, and to recommend corrective actions to prevent a similar event c Q .from recurring..On January 31, 1990, the licensee completed the dose ~', assessment and concluded that the health physics technologist received a + , , maximum extremity skin dose of 12.4 rem as a result of his exposure to the w["

fuel fragment.

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dispatched from" Region III

to the site to perform thesinitial event

< $6 .fo11os-up; inspection on December.4.11989;. Intaddition to the licensee's-- - m R " assessmentJthe NRC engaged 1Brookhaven NationaliLaboratory to perform an independent-dose assessment. The BNL evaluation resulted-in:a calculated pW = maximum 1exposuretof 13-rem utilizing < licensee assumptions for fuel N '

fragment

composition,' activity and exposure scenario (time, distance and g6

" shielding) f The'BNL evaluation was completed on March 13,,1990., , g,,

iThisi nspection was performed to foll.ow-up_on the results;of thel i g < - am

11censee's investigation-committee's-report'and findings, completion

of?

'* ..' t-dose assessment; activities,Jand the.:oentification and implementationLofi K correctivefactions, ygy fa.

Particle Collection 'On April 3,L1989,"while~ performing a survey of the reactor cavity,- y" . _ N La' health physics technologist (HPT). accompanied by a HPT trainee . -encountered a-hot _ particle located on the floor. -The HPT's - - teletector exhibited ^a reading of-2-3; rem /hr.- The HPT attempted , to collect this particle by utilizing a piece of tape, The tape

was pressed onto the_ particle by the HPT'sileft: hand.-MThis.

technique.was employed several: times 'until-therparticle was- .,1 "

h captured.1 :The teletector was used tolprovide-confirmation,of-

particle col.lection between-attempts and upon collection. The tape with the adhered. particle was then placed inta plastic. bag which was<. 1-then set 1 adjacent to the: cavity wall., At thisLtime, the particle had.

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' g; 1n contact with=the HPT's left h'and for-approximately six: . secondsL(as determined through'a're-enactment). ' " Tho'HPT-a^nd1HPT. trainee continued their survey of the. lower cavity > i_

' = collecting' approximately five hot _ particles of significantly-- lower activity, The-HPT who collected t.he: initial particle:then -

measured:the bag containing that particle with a.n' ion chamber <

in strument < (Bicron' RS0-50). The observed dose rate was in excess; . of 50 rem /hr_with'the window open.

The HPT verified this dose rate y with-a'different ion chamber instrument'(BicronLRS0-50). The: $ .

observed dose rate this' time was'also in excess of 50 rem /hr with

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Lthe-window _open.

Each time these; readings wereitaken, the-HPT who1 captured:the' hot particle handled:the bag containing the particle.at ' the open end of the bag. -Tho' plastic bag'containing the1 particle was then tied.to a rope which was suspended from the 66' elevation of the containment.

- ,mm The collection of low activity particles with tape is generally an. industry acceptable practice.

However, the collection of~high . , ' , activity particles by hand, held adhesive tape is not an acceptable . practice.

The inspectors reviewed the training records for the HPTs _ and the approved radiation control procedures for hot particle %", collection and handling methodology.

While nuclear ' industry . experiences with hot particles and skin dose assessment methodologies , l ,

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- , were discussed in the training lesson plans, hot particle collection, ' handling and action level instructions topics were not presented.to the_HPTs. Approved radiation control procedures that provided instructions for hot particle collection, handling and action levels were not available to station personnel, b.

Management Notification and Review Upon exiting from the reactor cavity, the HPT notified a health physics supervisor of the collection of the hot particle. The HP supervisor called the Health Physicist at home and reported the hot particle. The Health Physicist asked that the applicable surveys be placed on his desk by morning.

On' April 4,1989, the Health Physicist forwarded the surveys to the Superintendent'- Health Physics and the Nuclear Specialist for review.

The Nuclear Specialist wrote a report to the Superintendent - Health Physics that identified dose rates greater than-200 R/hr beta-and 8 R/hr gamma on contact and 12 R/hr beta and 500 mr/hr gamma at eighteen inches. This report also discussed potential problems in performing an analysis using acid digestion, multichannel analysis and recommending a radwaste drum analysis methodology.

Included in this report was an initial dnse assessment of 2 rem skin dose from the reported surveys and handling methods, but no discussion was provided on the collection method.

On April 4, 1989, the Superintendent - Health Physics reviewed this report and returned it to the Nuclear Specialist with written comments, These comments requested a determination by the Nuclear Specialist of_the need for analysis; agreed that personal statements were needed; questioned the methodology of the initial dose assessment and directed him to ensure that the hot particle guidelines were implemented.

On-April 4, 1989, the Nuclear Specialist revised the report to the Superintendent - Health Physics.

This report maintained the previous exposure rate _information.

The Nuclear Specialist indicated that the need for analysis of the hot particle and determination of whether a significant beta skin exposure occurred would be based on the personal statements provided.

In addition, a worst case skin dose estimate would be less than two tem from surveys and reported handling methods. This estimate assumed a six-minute exposure at eighteen inches from the bag for a skin dose to the extremities.

In summary, health physics management was aware that a significant hot particle had been found. The need to obtain additional information regarding the potential exposure was recognized.

Concerns expressed by the Superintendent - Health Physics regarding the initial dose assessment methodology were not addressed.

Lastly, dose assessment information which did not have an adequate basis was communicated to the Superintendent - Health Physics.

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lThe'HPTs who; performed the reactor cavity-surveys and hot > particle-q PX, icollectionsion April 3, 1989, provided their. statements regarding zi T' lthese? activities onLApr.il 5,-1989.- ] , k ,

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. . . ._ J e JThe HPT whoihandled the hot particle: indicated;in his statement, ' , , MJ x that:he used tape held in his left hand ~to captureLthe particle, j W.

' .Upon collection, the-HPT indicated that the tape'with?thelparticlei ' N , 'f was immediatelye placed intoia p_lastic shoexbag and kept out' of the - N

work area..This; elPT

then took a dose rate ofJthe ) article 'with a'

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• M Bicron RS0-50 (ion" chamber: instrument) and; tied tie; bag'with the

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- ,l containment, i ' a , . . -! - f Atithis point, health physics management personnel 'were-made aware t ' xs' .that the HPT had handled the hot. particle in his left hand.

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Dose' Assessments'of April-1989- , .-

e , I , . . ... L ' During" the ensuing weeks.after the hot' particle: had.been handled by

the-HPT.; the HPT' reportedly. made periodic inquiries.regarding an " , assessment of exposure that he had. received. This-culminated in an , " unofficial estimate" prepared by the Huclear Specialist.. In a , . .documentrtitled Extremity Exposure-Estimate For Hot Particle

Collection, the Nuclear Specialist identified the methodology. .

" g" . utilized and the calculationsJperformed to assess =the'HPT's1 extremity W

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skin' dose. This resulted in a -" Total Estimated Extremity Dose" of. '

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530. mrem.= . , , LThe"i'nspectors reviewed this " unofficial' estimate" for-technical-adequacy 'and-for conformance-with approved procedures and1 established.. c methods. The-technique utilized differed >from the method'specified,, - i .but not required,~by licensee procedure HP.? 1.6, Estimating? Skin-&-

^ . Internal Dose Rates Due To SkinLContamination.z In addition,'this= ' assessment did4not utilize the dose assessment software that had-

o* -been'used by the licensee to evaluate hot ~ particle / activated j component exposures that had -occurred previously, as.follows:

'

,, Date-Software Incident a , J , 4 14/89 QAD,BTHIN Split pin; fragment'found in F - . steam generator =and handled'by-i ' ' . staff engineers 5 10/87 QAD Calibration source wcs handled-d , by instrument maintenance-

personnel- ' , y , , , 4/21/87 VARSKIN, QAD Hot particles found on two l , ,- contract HP technicians , + , < p

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' , . (Inisummary,chealth physics management -was' made. aware ofia' potentially { n"f tsignificantl extremity skin exposure:during: April.1989:: The 1icensee; q - had adequate. methods 1available to_ perform dose assessments due to hot: '+ ,% ". _ particles. fThellicensee failed to ' perform;ari adequate evaluation of - ' @ '/ the= exposure received by the HPT ' .. . ' ' ' m

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" ' ' Event Investigation Committee' Conclusions , 7;o t T . , - . . .The= Event' Investigation; Committee identified-the following items as

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the root'and

contributing causes of the event.

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(1)..HPTsl were' not" properly trained in handling t hot particles..found -

< - .on alsurface'.l Thisjincludes the. proper. method'of. surveying.as '

awellfas retrieval.. ~ ' , (2). HPTs-do not report to a specific HPl supervisor during-outagesn ' This leads to confusion over specific work directions.

< N (3b J uring outages',' HP personnel /(Superintendent, Health Physicist,- D ', =. Supervisors"and HPTs) are consumed by; daily' events"and havet

11ttlet if' any; time to look~ back.or-plan ahead.1 g.,

- (4)l The Nuclear Specialist was"not aware that he had prime / sole responsibility.for the Hot =Particiel Program.

'

s .(5)n:The. Health Physicist gets too many4 calls!at home'during;an , ' outage.

- - 't (6). :Th'ere is~.no uniform, method ~ for retrieving; a ; hot particle on s Eeither:a person or acsurface- , _.. ' p (7) The Nuclear Specialist'suspectedethere was a" potential problem '

with an overexposure but based on lack of feedback from the

/ Superintendents-Health = Physics conducted-not further. formal ' -evaluation:of the event, , '(8); LHPTs.did not have a good understanding of the draft-Hot Particle ' , , 9. g Guidelines during the Spring 1989 outage.

([dli, N,./ - - , (9) HPTs.do not routinely receive feedback on events that concern , them.

,W " . . q "' (10) HP Supervisors appear to have limited knowledge of individual - . ,43 'HPT!s and HPT trainee's training and qualifications.

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Root Causes The inspectors reviewed the event, interviewed licensee personnel and evaluated' documentation. The following delineates the primary root causes of the hot particle incident of April 3, 1989.

' (1) HPTs did not receive adequate-training in the methods to minimize radiation exposure during the collection and handling of hot particles and activated components.

(2) Established methods and approved radiation control procedures for collection and handling of hot particles and activated components, including action levels to minimize radiation

exposure were not available to the HPTs.

(3) Approved procedures and methodologies to perform dose assessments were not utilized to evaluate potential radiation exposures.

(4) Poor communications among health physics management personnel contributed to the failure to recognize the significance of this event.

(5) Organizational responsibilities and duties (hot particle program) were not clearly delineated.

This contributed to the confusion and communication breakdowns, g.. Event I'nvestigation Committee Recommendations The Event-Investigation Committee made the following recommert tions to prevent recurrence of this event: ) . (1) Include in the Training Program for HP personnel proper methods for handling hot particles on both people and surfaces. This should include proper methods for detection, retrieval cnd storage.

Jq (2)- Formally assign lead responsibility and authority for the Hot j Particle Program.

(3) Limit offshif t calls to the -Health Physicist to things requiring immediate action. This includes training HP Su -; take necessary actions without contacting (the)pervisors to Health Physicist.

(4) Implement the following to improve two-way communications in , the Health Physics Group: ! W (a) Define responsibilities of the HP Supervisors during ! outages to assure HPTs are aware of specific supervisors' responsibilities such as: Personnel concerns, day-to-day

HP activities, specific projects follow up of concerns, etc.

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Health Physics and Health. Physicist'are allowed time to x

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provide " big picture": review and oversight of?HPJ

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'" ' activities:rather being-devoted to " task work."

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(c) Reviewethis event prior to the Spring 1990 outage with?all

, ' i HP personnel.

, ,. E! ri:' s '.(5).' Develop.a method =of formally: responding toirequests for dose < " ..

' calculations. The resulting: responses should be-independently- ^ reviewed:and maintained as a. record.L.

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.-Licensee Concurrence'and Additional Corrective" Actions -

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t-The licensee concurred with the Event: Investigation Committee a 4 conclusions and' committed to:further enhance the ' hot particle - ,. w_ icontrol? program.-by-implementing the following corrective actions: > .a .. '

(1) Increase the number of, hot particle retrieval = tools: at the-site. -

During refueling outage periods, make these retrieval: tools , -available at 'known hot' particle: control areas. - Train all; . employees on how to'use.the retrieval tools.

, 'oc mJ-(2) - A hot. particle' documentation: form (was implemented-priorJto the~ - Uni t -2. Fal.1; Outage, All:HP techno~1ogists and= trainees;shouldJ be' instructed on the appropriatei se of this1 form.

Similar to: s u - contamination' event forms, the hot particleicontamination1formi W should receive. timely review:by the Superintendent:- Health ~

lPhysicscor the Health.. Physicist.: ' a, s-(3). tRWPs which ' re issued for?wcrk in> known hot' particle areas a

' ' r , should1have specific hot particle precautions: 11stedi

':(4) (HPTs should be-provided rules of thumb regarding the-correlation; i L.

b ' i etweenisurvey instrument readings"and potentia 1Ll_ocalizediskin? ' " Q,'

dose" hazards resulting from. direct contact with theFparticle, io uAn understandin.g rof this correlation will' allow 'the :HPT to-Y better evaluate the. hazards of aihotuparticle'which' is: measured -

gr in-the field with a survey = meter.- , im-(5) -An evaluati.on of the health physics ' contractor training; module-should>be completed orior to the Unit 1.1990 Spring Outage. The

< program should be updated as appropriate to reflect the revised & PBNP hot particle control program.

M! n u (6) Ensure that all hot particle calculations are performed in? accordance with the specified methodologies described in the-p PBNP hot particle guidelines.

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' f(7)1 HP' personnel'were~provided a:two-day h.otiparticle: training: %,' ~ - ^ . program 11nTDecember ofL1989.- - Prior to:the' start of: the Unit 1:

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(1990 Spring outager it was recommended that the1 hands-on field ? L application aspects,0f this trainingLmodule be reinforced to , ?4 ithe'HPTs. < Formal'instructionsfon plant specific hotipar.ticle; if

guidelines were> also provided*

' , ^ ' ~ . (8)? An" evaluation ~ o'f the:adequ'acy of ~ the hot particle instructi.onal- ' h %(a ' ' '

content of;the General Employee-Training prog' ram should bec completed yThe program should be revised as deemed appropriate,

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Apparent Regulatory-Violations

, ,1 . < ,[" (1) 110 CFR 20,201(b) requires that each licensee make or cause toi o

~ be made such curveys as' (1)

may be.necessary for the' licensee ^

,

E ' to comply with the regulation.s in thisjpart, and (2);are ' , 'reasonableLunder the circumstances totevaluate the extentLofs , %, iradiationahazards that may be'present., . 10 CFR 20.201(a).

" defines a survey: as an evaluation of the: radiation' hazards - -- . . . 's: , incident to1the: production, use, release, disposal;or: presence- ' g"4* ofuradioactive~ materials or~other sources of radiation under a specific set of conditions.-

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% Contrary.to'the above, during: April 1989, adequate surveys; . .necessary and reasonable to ensure compliance with the a ,., n.* 9' occupationali. dose limits of 10 CFR120.101'were:not made;afteri ~ -a health. phys.ics technologist-handled a 142'.5Lmillicurie' fueli Ef ragment', on.~ April f 3, J 1989.

> ~ < '_(No.-266/90008-01), - , s O 'p-Technical Specification :15.6.11: requires that radiological- . . '

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, control. procedures shall-be writtenFand;made'available toLa11' . station personnel.

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" Contrary to the above,,on April 3,.1989, approved: radiological: < ,

control procedures for/ minimizing radiation exposure duri.ngsthe'

collectionLand handling of highly: radioactive particles and-j

activated components were not~made'available to station- - ', ' personnel. _.(No.. 266/90008-02) , .Two apparent violations were identified.

, . ' . .

5.

High Radiation-Area-(HRA) Barrier Incidents (ID 93702)

In 1988 and 1989, repeated incidents occurred involving HRA barriers in areas where' dose-rates were between 100 and 1000 millirem per hour. A listing of the incidents and the licensee's corrective action is as;

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follows:

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M > ;c k{#h; . ,..,.y M r,f/ Q 7? (Referencei '.0 ate.

m Description . r . ~.i4 9$ 1:IR18813/8813-4/20/88- ' VHRA warning devices (flashing red w ~ . light turned:off); Two HRAs not l.og: M'

Posted; NOV issued ' , n ' " . y.d ' :ib ' . ,g.,, w w ~ LIR18823/8822; '10/19/88.

cTwo HRAsJforcibly.b' reached, No)NOV? '

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^ '10/27/88 Plant -Manager informed all workers - , " Y '

of importance ofrbarricadss :. a '~ barriers orlotherlwarningLdevices.

", , W > ,. , ., jf > ) di ' IR 89.03/8903 10.-11/1988-y_ . Repeated incidents-occurred that 7, involved HRA' rope barriers- ' M 'IR 8922/8921! 14/5-15/89 Three.' times Unit li pre n urizer HRA: u ' barrierinot found in1 place- ' e <~ 'M IR 8922/8921 t4/11-14/89-Apparent willfu1Ldegrading '

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, of Unit IR 8928/8927, & q'

l Regen Hx HRA barrier;(Twice); _ ~

< - . m 'NOV issued.

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? IR 6922/8921- '4/17/89 ' f1 ' Three operators'.were observed- .., , violatingia1 posted "HRA', RWP Required, ,; & No; entry;during~ Fuel Movement;"xNOV- ' gy Lissued: > k 1A Severity Level.IV violation was; issued., ' - n s.

6,[ - >> ~TheJ11censee's corrective actio.ns-included she-.following: s y1"M (1) (Trai.ning' sessions for all-plant personnel regarding the HRA' ' n *, ' entry control; incidents, including. discussions of, applicable a.: regulations and Technical Specifications, summary.of? events, , M _ < consequences-of inappropriate Worker actions, management om intolerance of such worker behavior and each worker's k9 w Jresponsibilities and obligations.

This was conducted by the-M' , Superintendent - Health Pnysics.

!y.; n) } ig * '(2) A: video tape training session was to be presented to all.

" . '  ;".f contractor employees as a part---of General Employee Training.for.

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the Fall outage.. Contractors'already onsite would be required-

,. gg] to view the video tape.

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(3)!(Enhanced; training'on radiation 1 barriers was to be presented (to

+ contractor health physicsLtechnicians prior to_-the: Fall: outage.

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(4)i:A;mamorandum was~to be issued to-:all_ plant-personnel reinforcingc W

Lk Technical Specification: requirements and health physics?

pq procedure;conformance.

' - > ' fxt g & {< .(5)l RWPs-will;be Writtbn to provide specific:instructionsiregarding.

boundary contro11 responsibilities. - , @L. ,

(6)) 'Better; operator aids / instructions:will b'e placed on barriers

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j[ 'and postings regarding restrictions and responsibilities.: - 4" - _ 7) Continuingle'fforts will be.made to upgrade'HRA-barriers,- -. ( _ t

including; replacing l ropes:withL. swinging gates where possible.: m ,< G (8').ContinuingTefforts willibe made:to eliminate the need for HRA.

g.

-barriers, including additional s.hielding of the. Uni.t'l -. Regenerative Heat Exchanger Cubicle.

- - m . -(9) The: refueling barrier procedure has been revised for: clarity- .W 'andra training lneeds. analysis.has been issued to evaluate ~ ~ - -training needs for operations' personnel.

h' .bi /RecentHighRadiationArea' Violations ' . .Despite1the _ licensee'siattempts to institute effectiveLcorrective 1[0

actionito preventirecurrence of-the 1988/1989 HRA barrier .. H @g,+N violations, the licensee has' identified:the followingiviolations:L , ' - , " On:0ctober 12, 1989,4a Milwaukeetbasedtindividual wasMobserved - _ violating a posted "HighiRadiation. Area, RWP Required for. Entry" ' boundary at the -north'end of the Unitt 2 reactor. cavity -on the 66' ' elevation in, contain' ment. :The" individual was not' signed onto Jan - ' * RWP.* - , On April 17 1990', two operat' ors on rounds were observed crossing-a ' ' ~"High Radiation Area, RWP Required Fuel Movement In-Progress " - . , One of-these operators was a licensed-operator who:was performing

Auxiliary Operator duties. -The operators were on a Standing RWP.

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that authorized. operations personnel access ~ to the auxiliary, fuel A ~ % and facade buildings for routine operatorLrounds..The' Standing.RWP.

% procedure specifically prohibits access to areas whose radiation-levels are affected by the transfer of spent _ fuel. assemblies during . refueling ~ evolutions.

Spent fuel transfers were in progress, < p OnMay2,1990,-ahealthphysicscontractauditorwasobserved

' . violating a HRA boundary at-the entrance to the Unit 1 containment.

j .The auditor had-been assigned to audit HP operations in containment.

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, _,..... - - - - - - A-3 .J . . . s- , < -The HRA had recently-been established in this area because dose rates were between 100 and 1000 millirem per hour due to the lifting of l the reactor upper internals.

This individual had received General Employee Training, a guided tour of the primary auxiliary building and.had been. instructed-in the access requirements for containment.

These three incidents are apparent violations of High Radiation Area entry -requirements specified by Procedures HP 2.5 and HP 2.5.1 and

are representative of violations that could reasonably be expected to , qv have baen. prevented by the licensee's corrective action for the previousviolations(No. 266/90003-03; 301/90008-03).

One apparent-violation with three examples was identified.

, '6.

OrganizationalandManagementControls(1 83750) The inspectors reviewed the licensee's organization and management l controls for the radiation-protection program, including: organizational structure, staffing, effectiveness of procedures and other management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses.

Early in 1990, a new Superintendent - Health-Physics was appointed.

A transition period of approximately three months was utilized to allow continuity between the two individuals. The replacement HP Superintendent has assumed full responsibilities. The transition process between the HP Superintendents apparently went smoothly.

The Nuclear Specialists' training and qualifications were reviewed.

Each of the nuclear specialists appears to be well qualified and to have a. suitable academic background. Current plans include the addition of 4-5 HPTs to the health physics staff to support radwaste activities.- 7.

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, personnel, and procedures; adequacy of the dosimetry program to meet routine needs; required records, reports, and notifications; effectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation weaknesses.

No exposures greater than 10-CFR 20.101 limits were noted.

No individual ', exceeded the licensee's administrative quarterly whole body limit of 2500 mrem.

The licensee has been evaluating an electronic dosimetry system for use at the plant. Currently, they are evaluating methods to interface this system with the installed exposure records system.

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's > M ? .. .. <, $' ;, ~ cNolviolationsfor.deviationswere:identifiedi m - , ., . ]b,

[g[iControlo'fRadioastiveLMaterials"andContamination'(IP1837s0) h fThe?inspectops-reviewedtheilicensee'sprogramforcontrolofradioactive; a , "* '

materials.and contamination,

including:H adequacy Lof supply; maintenance, M,

- Land calibrationlof.. contamination, survey,~ and: monitoring-Lequipment; . wQ.h effectiveness lof survey methods,> practices, equipment,HandLprocedures;3 ' A ? adequacy of' control of-radioactive.and contaminated materials.-: , m J [}, fDUringIto'ufsof.theRadiologicallyControlledArea(RCA),thbinspectors( ' ' , s m s bservedc performance 'of contamination; surveys;- work being' penformed' ' ' e ' o , " unde r;- radi at i o'n work permits;iprotective. clothing (use, handling, and; ' , cleaning ~;; posting and l'abelling; Lfrisking;;too1Eand equipment) handling - ; , , MN m - ..andJstorage;and. housekeeping.

RCA housekeeping wasigenerallyigoodLwith.

' , theLexception the lower levels;of the auxiliary building:and the-lowerc ' ' flevel of the facade. buildings.

The inspectors reviewed;.contamin'ation- ,.

.controlsprocedures for,ade'uacy.and survey. records for procedural; ne . q [ Leompliance; -No' problems'were noted.

' < w, 1The. licensee; has purchased and.1s using a state of ~ the art' laundry, 4,

monitor;;LConsideration is also being given to.the use of wet; wash versus-

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' ' . dry cleaning.of protective' clothing.

.A decision on the most effective n' -methodLis expected inathe near future,- , 8 - . . L ' lNoiviolations or deviations were identified.

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x , $9.

Addits'. a'nd Surv"elllances (IP 83750)

6' .

1. "

lThelinspectors. reviewed the results of-Qual 1ty; Assurance l audits 'andi ~ . surveillances conducted -by-the licensee since3the last inspection.

M ?Also reviewed 1were:the; extent and-thoroughness =of the' audits and- .surveillances;

L ' - ?,, The-December.1989, quality assurance-audit of the radiation.pr6tection, > , radwaste,-radiological environmental monitoring (REMP); process control 5 g (programs and the Offsite< Dose Calculation. Manual (0DCM) wa's" reviewed.

. , The depth.and level.of eval'uation was good. -The1 findings ~and responses; rwere reviewed with the following items noted.

a.

. Technical' Specifications "

- The aedit of the 00CM which was required to be performed by July?1989 A was not nerformed 'until December 1989.

> ' y C-The audit of the. REMP which was required to be performed by January

_ 1989,' was not performed until December 1989.

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m , k > , . ' . The licensee's actions after identification of-the audit finding were timely. Corrective actions have been completed which should prevent ' future occurrences. Consequently, pursuant to Sections V.G.I. of- .(Appendix C to 10 CFR Part 2), a Notice of Violation will not be ~ issued for this Severity Level IV violation (NCV No. 266/90008-04; 301/90008-04).

b.

Corrective Action Implementation > The corrective action designated for closure of AFR A-P-88-13-060' had not been. completed by the committed due date of April 14, 1989.

The-corrective actions identified included procedure and checklist revisions for radwaste shipping activities. The audit response indicated a-new commitment due date of April 1, 1990, for the procedure and checklist revisions.

As of April 26, 1990, the inspectors determined that the-procedure and checklist revisions have yet to be approved and implemented.

10 CFR 50 Appendix B, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality such as failures, deficiencies, deviations and nonconformances are promptly identified and corrected.

This is another example of a violation.for which an enforcement action.has already been proposed (References: EA 89-254, Dated April 17, 1990, Inspection Reports No. 50-266/89033; No. 50-301/89033(DRP) and No. 50-266/89032;No.50-301/89032(DRP)). No surveillances had been performed since the last inspection.

One violation was identified; however, a notice of violation of ' will.not be issued.

10. Maintaining Occupational Exposures ALARA (1 83750) ' The inspector reviewed the licensee'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 effec'tiveness in meeting them. Also reviewed management techniques, program experience and correction of self identified program weaknesses.

The total station dose for 1990 was approximately 91 person-rem of which about'75 person-rem was attributed to the ongoing Unit I refueling and maintenance outage. The licensee's 1989 total dose of 474 person - rem indicates no significant change from previous years. This undergoes two refueling and maintenance outages each year (plant normally 12 month fuel cycles). Total exposure for the previous six years is listed as follows:

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. Year Person-Rom R<. arks i 1984 737.155 Includes 245.650 rem for Unit 1 SGRP 1985 444.050 1986 375.480 1987 532.010 1988 387.255 1989 474.390 No violations or deviations were identified.

11.

Exit Interview (IP 30703) The inspectors met with license representatives (denoted in Section 1) following the inspection on April 26, 1990, to discuss the scope and . findings of the inspection, including the apparent violations (Sections 4 ' and 5).

The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.

Licensee representatives did not identify any such documents or processes as proprietary, i e . 16 }}