IR 05000266/1990024
| ML20024F888 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/13/1990 |
| From: | Markley A, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024F882 | List: |
| References | |
| 50-266-90-24, 50-301-90-24, NUDOCS 9012270103 | |
| Download: ML20024F888 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-266/90024(DRSS);50-301/90024(DRSS)
Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27 Licensee: Wisconsin Electric Power Company 231 West Michigan Milwaukee, WI 53201 Facility Name:
Point Beach Units 1 & 2 Inspection At:
Two Rivers, Wisconsin Inspection. Conducted:
November 26-30, 1990
' A. d b d /"
L Inspector: ~
W. Markley
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izh//o Date
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(4)<$bE-~ Y Approved By: William Snell, Chief,
- A/A Radiological Controls-and Date
. Emergency Preparedness Section Inspection Summary Iiispection on November 26-30, 1990 (Report No. 50-266/90024(DRSS);
No.50-301/90024(DRSS))
Areas inspected: -Routine, unannounced inspection of the radiological protection program following a refueling and maintenance outage, including:
organization, management controls and training, audits and surveillances, external: exposure control, internal exposure control, control of radioactive materials contamination, and surveys, and maintaining occupational exposures ALARA (IP 83750). ~Also, reviewed were outstanding items from past identified
concerns (IP 83750,84750).
Results:
During this inspection, one non-cited violation was identified for
.a. failure to post and boundary a contaminated area (Section 10).
In the area of radiation protection, several weaknesses were identified. The ALARA program has not been aggressive in implementing exposure reduction methodologies (Section 9).
Weaknesses were identified in the areas of extremity dose assessment (Section 6.b). radiological hazard characterization at the spent fuel pit demineralizer access (Section 8)., training and utilization of health physics technicians (Section 4.b & c), housekeeping (Section 10), and understanding the release 9012270103 901213
PDR ADOCK 05000266 I'
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pathway during the gas analyzer release incident (Section 4.d).
Weaknesses were also identified in the quality assurance surveillance program (Section 5).
Strengths were identified in the areas of staff stability and the technical competence of the staff (Section 4.a) and efforts to scope and plan improvements to the ALARA program (Section 9).
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DETAILS 1.
Persons Conttc. led e
- J. Anthony, Quality Engineer M. Baumann, Project Engineer - Radiological Design
- J. Bevelacqua, Superintendent - Health Physics R. Bredvad, Health Physicist W. Doolittle Health Physics Specialist E. Epstein, Health Physics Specialist
- T. Guay, Health Physicc Supervisor
- J. Jack, R gulatory Engineer
- D. Johnson, Superintendent - Nuclear Regulation
- P. Lightbody, Health Physics Supervisor
- G. Maxfield, Manager - Point Beach M. Moseman, Lead Health Physics Specialist
- R. Seizert, Regulatory Engineer J. Zach, Senior Manager - Nuclear Engineering
- C. Vanderniet, Senior Resident Inspector The inspector also interviewed other licensee personnel during the course of the inspection.
- Denotes those personnel present at the exit meeting on November 29, 1990.
- Denotes those personnel contacted by telephone on November 30, 1990.
2.
General This inspection was conducted to review aspects of the licensee's radiation protection program.
Included in this inspection was a follow-up of outstanding items in the areas of radiation protection and radioactive waste management.
The inspection included tours of radiation controlled areas, auxiliary building,- radwaste facilities, observations of licensee activities, review of representative records and discussions with lice-m personnel.
3.
Licensee Action on Previous Inspection Findings (IP 83750)
(Closed) Violation No. 266/90008-01:
Failure to make adequate surveys or evaluations to ensure compliance with the occupational dose limits of 10 CFR 20.101 after a health physics technologist handled a 142.5 millicurie fuel fragment on April 3, 1989.
Implementation of committed corrective actions that resulted from this event appears to be adequate.
(0 pen) Violation Nos. 266/9008-03; 301/90008-03:
Failure to control access to high radiation areas (HRAs) as required by technical specifications.
The inspector reviewed the corrective actions that have been implemented and are planned to address HRA boundary violations. Most hardware solutions have been implemented with the exception of shielding on the Unit 1 fuel transfer canal.
This item remains open.
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er 4.
' Organizational Management Controls and Training (Ip 83750)
The inspector reviewed the licensee's organization and management controls for the radiation protection program including:
organizational structure, staffing, delineation of authority and management techniques used to implement the program and experience concerning self identifica-tion and correction of program implementation weaknesses, a.
Organization The licensee's radiation protection organization remains essentially the same as last reported.
There has been no staff turnover since the last inspection. Two' individuals have been added to the General Employee Training staff.
The health
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physicist who _formerly supervised operational health physics has
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been reassigned to a radiation protection planning tole.
In this position, he interfaces with the operating and maintenance departments to coordinate radiological support for planned
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activities. The lead health physics supervisor now reports directly to the Superintendent - Health Physics. The health physics staff appears to be technically competent and proficient at tasks for which they are responsible, b.
Training and Qualifications Trai.ning and qualifications of licensee health physics-technologists were reviewed.
While the training and qualification program appears to be adequate, it was noted that some health physics technologists (HPTs) had a large number of job performance modules outstanding.
Health physics technologists and training staff. personnel were questioned about this.
Both groups reported that the health physics operating group has, due to operational support. requirements, pushed " trainees" into tasks for which they are qualified rather than tasks for which qualifications are sought and required. This is considered a potential weakness in the training program and has the potential of limiting operational flexibility and emergency response capability.
.c.
Utilization of Health Physics Technologists During discussions with health physics management and HPTs, it was noted that the licensee does not have a professional labor force dedicated to cleanup of the auxiliary building and removal-of. trash and radioactive materials.
Instead, the licensee has utilized members of the plant operating staff such as maintenance, health physics and operations to perform general housekeeping in the' radiation control area (RCA).
Health physics technologists are used.for such tasks as mopping and waxing of floors, trash removal, painting and assignment to plant cleanup crews.
These activities impact upon the time spent performing radiation
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safety functions and the time spent in training and pursuing qualifications.
d.
Gas Analyzer Release Event i
The inspector reviewed an unplanned gaseous release associated with a failure of the gas analyzer sample pump diaphragm.
This event resulted in the release of approximately 1.1 curries of noble gas, predominantly xenon-135 and krypton-88, the contamination of four individuals and a limited evacuation of the primary auxiliaries building (PAB).
During the period of 7:40 a.m. through 7:47 a.m. on October 3,1990, four radiation monitor alarms were l
received in the control room.
RE-214, PAB exhaust gas monitor
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RE-315, PAB exhaust gas SPING RE-109, Failed fuel monitor in Unit 1 sample room
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RE-219, Blowdown monitor
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Control room personnel communicated this information to health physics (HP) supervision.
HP supervision confirmed the monitor alarm status (Alert Level Alarms) with the control room and obtained local readings via telephone from the operator at the C59 station. HP supervision then dispatched HPTs to pull a sample from the auxiliary building stack, verify the dose rates at the blowdown monitor and to obtain a reading with a teletector of dose rates at the failed fuel monitor. The HPT that was dispatched to take a dose rate reading at the failed fuel monitor was sent into the PAB without protective clothing and without respiratory protective equipment.
Subsequently, the chemistry technician and other personnel were discovered contaminated at the PAB exit point.
HP supe ~ision then notified the control room at 8:05 a.m. to request an evacuation of the PAB.
Recovery of the PAB proceeded and access was restored to the PAB at 9:28 a.m.
The inspector reviewed the actions taken in response to this event by on shift health physics personnel.
Responses to this evcnt by health physics personnel were generally timely and appropriate. However, one significant weakness was noted.
Interviews with the HP supervisor and HPTs indicated that licensee personnel had classified this event as a primary to secondary leak with increased radiation levels at the PAB ventilation stack monitors.
If a primary to secondary leak had occurred, main steamline n.onitors and air ejector monitor alarms would have initiated.
This did not occur.
Further. ir a primary to u ondary leak had occurred, it would have taken an inordinate amount of time before the auxiliary building ventilation stack monitors would have alarmed.
In summary, indications available
.l at the time indicated that a gas release was in progress in the PAB.
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The failure to recognize that a gas release into the PAB was in progress resulted in the contamination of the HPT who was dispatched to take failed fuel monitor dose rates. This individual was dispatched without appropriate protective clothing and respiratory protective equipment that would normally be used to respond to a plant emergency. This event identified weaknesses in the knowledge level and understanding within the health physics supervision of the installed radiation monitoring system, systems monitored and identification of event sequences associated with radiation monitoring system alarms, This concern will be evaluated during a future inspection (0 pen Item 266/90024-01;301/90024-01).
No violations or deviations were identified. One open item and program weakness were identified.
5.
Audits, Surveillances and Self Assessments (IP 83750,84750)
The inspector reviewed the results of Quality Assurance audits and surveillances conducted by the licensee since the last inspection.
The inspector also reviewed the extent and thoroughness of the audits and surveillances.
Since the last inspection in April 1990, one audit and no surveillances were conducted in the radiation protection and radioactive waste management areas. The audit identified weaknesses in the areas of procedure formatting, control of lead blankets and accountability of portable survey instruments.
The scope and thoroughness of the audit appeared to be acceptable. Although this was a deviation from the frequency of past surveillances, it was within the scope of procedural requirements.
No surveillances had been performed in over a year.
The licensee has scheduled a surveillance in the area of radioactive waste packaging and another in the radiation protection area.
Licensee performance in this appears to be weak and will be further evaluated during a future inspection (0 pen Item 266/90024-02; 301/90024-02).
No violations or deviations were idt stified. One open item was identified.
6.
External Exposure Control (IP 83750)
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 preparation for maintenance and refueling outage tasks including ALARA considerations and required records, reports and notifications, a.
Personnel Dosimetry and Extremity Dose Assessment Personnel exposure records for current and past licensee and contractor employees were selectively reviewed for completeness, accuracy and inconsistencies.
In addition, reporting of exposure information was reviewed for timeliness.
The licensee utilizes a Landaurer system that is National Voluntary Laboratory l
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Accreditation Program (NVLAP) accredited in.all eight areas of concern. No exposures above the 10 CFR 20.101 limits were noted.
The inspector noted that extremity exposures appeared to track exactly twice the whole-body exposure. for all records reviewed.
The licensee was questioned about the methodology used to assess.
extremity exposure.
The licensee responded that they assumed a worst case by taking the ratio of the threshold for monitoring extremity exposure (approximately 4.7 rem /qtr) to.a worst case ;?
2.5 rem /qtr who, body exposure.
This resulted in a ratio of.
approximately 2:1 (1.88:1 actual).
The licensee stated'that they would then assess an extremity exposure of twice the whole body exposure for periods in which the extremities were unmonitored.
The inspector informed the licensee tha't the: licensee's technical I
basis.for assessing extremity dose was in error.
This methodology resulted in.the assessing of excessive-levels of
extremity exposure. Acceptable methods of assessing extremity exposure were. discussed with the licensee.
The licensee acknowledged the inspector's concern and committed to revise their> extremity dose assessment methodology (0 pen Item 266/90024-03; 301/90024-03),
b.-
Electro'nic Dosimetry
.The licensee has been attempting to implement an electronic dosimetry system.for several years.
This effort has been plagued with sof tware incompatibilities, hardware incompatibilicies and 10 CFR 21 issues associated with the~. selected Alnor systenn The
licensee is evaluating software.for this system that is currently
. utilized by other utility users.
The Alnor system is also being modified by.the vendor to improve hardware compatibilities.
The ilicensee expressed optimism that progress would be made in the implementation of this system.
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c.-
Hot particle -Dose Assessment The inspector reviewed approximately. fifteen dose assessments for hott particle exposures.
This review included documentation of particles collected, method 3 of performing dose assessments, and recording of exposure in the individual's exposure record.
No problems were noted.
d.-
HighiRadiation Area Access Control Violations The-inspector reviewed radiological nonconformances documented
. since the last inspection.
Several deficiencies were noted in
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the areas'of training, contamination control and Final Safety-Analysis Report descriptions 'of tritium sampilng and personnel decontamination kits. Also roted were two incidents of high radiation area access control v1olations. The first (May 8, 1990) involved an unplugged flashing red light at the entrance of the regenerative heat exchanger.
The second (May 12,1990)
involved a maintenance supervisor who followed two health physics
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technologists-into containment.
The maintenance supervisor had not signed onto a radiation work permit that-would have authorized access to the containment. This second event was similar to a previously cited high radiation area violation.
However, since these events are additional examples for which enforcement actions were taken and corrective actions to address this. type of problem were ongoing (References: EA 90-99, Dated June 8, 1989, Inspection Report Nos. 50-266/90012(DRSS);
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I 50-301/90012(DRSS)), violations will not be cited.
It should be noted that there have been no violations of high radiation area access controls since May 1990.
No violations or deviations _were identified. Or,s open item was identified.
7.
J_n,ternal Exposure Control (IP 83750)
The inspector rev.iewed the licensee's internal exposure control and i
assessment programs, including:
changes to facilities, equipment, and procedures.affecting in_ternal exposure control and personal exposure assessment; determination. whether respiratory equipment, and assessment of individual intakes meet regulatory requirements; and required
- records, reports, and notifications.
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The inspector selectively reviewed the results of the licensee's whole body counting and internal dose assessment efforts. The licensee
- identified and evaluated two uptakes of radioactive materials.
The
. individuals who received. uptakes were whole body counted several times and were evaluated for exposure. The licensee utilizes NUREG/CR-4884 in performing dose assessnents for. internal depositions of radioactive ma terials.
No problems were noted.
No violations or deviations were identified.
8.
Control of Radioactive Material (IP 83750)
The -inspector reviewed the licensee's program for control of-radioactive materials -and contamination, including:
adequacy of supply, 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 material controls.
The inspector verified by a review of records, discussions with licensee personnel and to_urs of operational areas, that the supply, maintenance, and performance checks of survey and monitoring instruments were adequate.
No significant problems were identified.
During a tour of-the PAB, the inspector identified an area that exhibited a significant difference in survey meter readings.
This area was at the entry to the Spent Fuel Pit Demineralizer Room (U6) on the 26' elevation. A Bicron survey instrument indicated a closed window reading of 160 mr/hr and an open window reading of 260 mr/hr.
The licensee routinely uses a Teletector to conduct surveys of this area
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which provided readings of 160 mr/hr.
There was no readily apparent sources-of beta radiation in this area.
This appears to be bremsstrah-lung X-rays or low energy gamma rays emanating from the demineralizer tank or reflected from the shield walls.
It appears the actual radiation levels-in the area may be higher than the 160 mr/hr the licensee is using for job planning ~ evaluations.
This was discussed with the licensee.
The licensee committed to evaluate survey methods used to identify the hazards and the posting controls applied to this area (0 pen Item Nos. 266/90024-04; 301/90024-04).
No violations or deviations were identified. One open item was identified.
9.
Maintaining Occupational Exposures ALARA (IP 83750)
The inspector reviewed the licensee's program for maintaining
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occupational exposures ALARA, including: ALARA group staffing and qualification; changes in ALARA policy and procedures, and their implementation; ALARA considerations for planned, maintenarie and c
refueling outages; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them. Also reviewed management techniques, program experience and correction of self identified program weaknesses, a.
ALARA Program /0rganization The licensee's ALARA organization consists of a part-time Nuclear Specialist and an Exposure Reduction Committee that meets monthly.
The Nuclear Specialist has many other collateral responsibilities in addition to ALARA. The Exposure Reduction Committee is composed of representatives from maintenance, chemistry, operations, health physics, instrumentation and controls (I&C), engineering, and training organizations. The licensee's ALARA program guidance consists of a two page procedure, HP 12.2, Radiation Exposure Reduction Suggestion Program.
This procedure establishes the Exposure Reduction Committee and functions' solely as an evaluator
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.of suggestions submitted to the committee.
The organized ALARA program at Point Beach is minimal. The licensee does not have an overall management policy statement that defines management's commitment to-the ALARA program.: There were no statements found that define ALARA program responsibilities for the following positions:
corporate ALARA organization, plant manager, ALARA coordinator, radiation protection manager, health physics department, design engineering, maintenance, operations, I&C, and outage management departments / groups.
The licensee does not have a full time ALARA coordinator nor ALARA support staff (professional and technical).
Nor does the licensee augment ALARA staff during outages. Outage augmentation generally consists of contract technicians.
The licensee did not present any information to indicate that a corporate ALARA function existed. 'No evidence was presented that a corporate ALARA function was involved in establishing station
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dose goals; in identifying, evaluating, and prioritizing dose reduction methodologies; and participating in industry study groups for source term reduction.
There was no evidence of long term planning and budgeting for ALARA improvement items.
The licensee has yet to establish a monetary figure by which dose reduction methods, technology and plant modifications could be evaluated for cost effectiveness, b.
ALARA Implementation There was no evidence of a defined process by which periodic and routine maintenance, operating and support activities were evaluated for ALARA considerations. Plant procedures did not define exposure trigger levels for increasing ALARA/ management attention.
Requirements for pre-job briefings were weak.
Requirements for post-job reviews and maintenance of job history files to capture lessons learned did not exist. Operational dose reduction efforts are totally dependent upon the evaluation of work perfonned and the capturing and utilizing of lessons learned for future similar work activities.
The radiation work permit (RWP) system was evaluated for ALARA support capabilities. The licensee currently writes RWPs on a shif tly basis.
Since ALARA planning and implementation focus on tracking a -particular job from start to finish, the current RWP approval time frame does not appear to support ALARA planning.
ALARA planning generally utilizes a planning threshold of one person-rem for a particular job (total duration).
If the planning horizon is reduced to a shiftly basis, very few jobs would ever reach the minimum ALARA planning trigger level.
The licensee has " experimented" with ALARA planning for some selected work activities, such as, the steam generator girth weld repairs during the recent outage.
Exposure Reduction Committee personnel commented favorably on the pre-job discussions for this job.
One aspect of an ALARA program that is in place is the ALARA Suggestion Program. The inspector attended a meeting of the Exposure Reduction Committee. This committee appears to be suitably staffed both in terms of representation of various plant organizations and by individuals who seemed genuinely interested in the ALARA program.
It was apparent from discussions with plant personnel that this committee's work was not well advertised.
c.
ALARA Initiatives The licensee identified several areas in which dose reduction efforts have commenced or are being considered.
These are described as follows.
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The licensee is currently considering down sizing of the installed filtars in plant process systems. As discussed in the Exposure Reduction Conenittee and with health physics management, plans have been made to down size the seal water filters from 25 micron nominal to 5 micron absolute. The inspector requested information as to the particulate characterization of plant fluid systems.
The licensee indicated that their studies have shown most of the particulate is within the range of 0.2 to 0.8 micron.
The licensee hus adopted a coordinated lithium / boron pH chemistry control program.
Efforts are currently underway to maintain tighter controls on plant chemistry.
The licensee also indicated that crud burst inducement by the addition of hydrogen peroxide prior to plant shutdown is performed.
The licensee also indicated that efforts were underway to reduce hot spots in plant systems. This is currently limited to flushing of plant systems.
Since the plant has yet co adopt a monetary cost benefit criteria, the licensee is not in a position to effectively evaluate other options of hot spot reduction, such as: cut and remove; hydrolazing of installea systems (floor drains), chemical decontamination, rerouting of piping, etc.
No evidence was found that other initiatives such as zinc injection, chemical decontamination, Electric Power Research Institute methods for cobalt reduction, conduct of ALARA training for design engineers, use of mockup training, specialized ALARA training for the plant staff (beyond General Employee Training),
use of strippable coatings or other advanced decontamination techniques, reactor head shields and other specialized shielding applications have been considered or evaluated.
It should be noted that the licensee has commenced the initial meetings to determine the scope and resources necessary to establish an effective ALARA program at Point Beach.
This is viewed as a positive development.
Overall, licensee performance in this area has been and remains unaggressive.
No violations or deviations were identified.
10.
Plant Tours (IP 83750,84750)
The inspector performed several tours of radiologically controlled areas. These included walk downs of auxiliary building, radwaste facilities and spent fuel pool facilities. The inspector observed the following:
Radiation wo"kers access and egress from the RCA; personnel use
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of frisking stations and portal monitors were acceptable.
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Contamination monitoring, portable survey, crea radiation monitoring instrumentation in use throughout the plant; instrumentation observed had been recently source checked and had current calibrations, as appropriate. However, it was noted that several friskers were found set on the X-10 scale in areas of low background.
Posting and labeling for radiation, high radiation, contaminated
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and radioactive material storage areas; posting and labeling, with the exception noted below, were in accordance with regulatory requirements and approved station procedures.
Housekeeping and material conditions were generally poor and had
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declined since the last inspectior..
Problems were noted in the areas of tool and material
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control.
There are numerous examples of tools and small equipment strewn about various work sites or bagged and lying in open areas throughout the auxiliary building where no visible work activities were ongoing.
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Problems were noted in contaminated areas throughout the auxiliary building and radwaste facilities.
Within these areas, accumulations of dirt, debris and used protective clothing were found in many areas.
Heavy accumulations of boric acid were found around the
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boric acid transfer pumps and a large stalactite of boric acid was'found-broken off the B CVCS Letdown' Holdup Tank manway.
Paint was found peeling off the walls in the gas analyzer
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pump room on the 8' elevation of the PAB.
Accumulations of drums of radioactive, mixed and potentially
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. hazardous waste were observed in the PAB and facade area.
Some of the drums of mixed waste appeared to be in poor condition (rusting, denting,etc.).
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The inspector-identified an unposted and unboundaried contaminated area in the general area near the spent feel pool heat exchangers on the 46'
elevation of the PAB.. Procedure HP 3.2.2, RCA Contaminated Areas, Tools, Equipment and Materials Posting Requirements, requires that contaminated areas be posted and bounded with yellow and magenta tape which bears the words, CAUTION - CONTAMINATED AREA. The licensee was immediately notified of.the situation and responded by surveying the area in question and-posting and bourding the area as a contaminated area.
This appeared to-be an isolated. event. The violation is not being cited since the criteria specified.in Section V.A of the Enforcement Polic were met. This matter is closed. (NCV 266/90024-05; 301/90024-05
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i With respect to the other aforementioned problems, the licensee initiated corrective actions during the inspection.
However, corrective actions were incomplete by the end of the inspection.
The inspector noted that there were several examples of " permanently"
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installed _ temporary shielding and scaffolding around the the PAB.
These were identified to the licensee and the resident inspectors.
Potential concerns for seismic and safety evaluations will be reviewed by the resident inspectors.
One non-cited violation was identified.
11.
Exit Interview (IP 83750)
.The inspector met with licensee representatives (denoted in Section 1)
following the inspection on November 29, 1990, to discuss the scope and findings of the inspection.
During the exit interview, the inspector discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the' inspection.
Licensee representatives did not identify any.such documents or processes as
. proprieta ry.
The following matters were specifically discussed by the inspector:
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The apparent violation (Section 10)
b.
Inspector concerns regarding: Weaknesses in knowledge level identified during the gas analyzer event (Section 4.d); Scope of the quality assurance surveillance program (Section 5); Methods used to assess extremity exposure (Section 6.b); and potential Radiological hazards associated with the access to the Spent Fuel Pit Demineralizer Room (Section 8)
c.
Apparent weaknesses in the ALARA program (Section 9)
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