IR 05000266/1997018

Insp Repts 50-266/97-18 & 50-301/97-18 on 970825-29. Violations Noted.Major Areas Inspected:Self Reading Dosimeter Calibrations,Radiation Work Permit Program, Condition Reporting Sys & Health Physics Organization

ML20211J889
Person / Time
Site:	Point Beach
Issue date:	10/04/1997
From:	Kenneth Lambert NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211J879	List: IR 05000266/1997018 ML20211J876 ML20211J883
References
50-266-97-18, 50-301-97-18, NUDOCS 9710090011
Download: ML20211J889 (13)

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli-Docket Nos: 50-266;50-301 License Nos: DPR-24; DPR 27 Report Nos: SC-263/97018(DRS); 50-301/97018(DRS)

Licensee: Wir,consin Electric Power Company _

Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: 6610 Nuclear Road .

Two Rivers, WI 54241 Dates: August 25-29,1997 Inspector: K. Lambert, Radiation Specialist Approved by: Gary Shear, Chief, Plant Support Branch 2 Division of Reactor Safety 4710090011 971004 f DR ADOCK0500g6

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. EXECUTIVE SUMMARY l l Point Beach Nuclear Plant, Units 1 & 2

. NRC inspection Reports 50-266/97018,50-301/97018 =  ;

i- This routine inspection included a review of self reading dosimeter calibrations, radiation work

permit program, condition reporting system, health physics organization, and the observation of -

the loading of a radioactive material waste shipment. The following specific observations were -

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One violation was identified for the failure to calibrate and maintain calibration records

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for the 0-200 roentgen emergency plan self reading dosimeters (Section R1.1).

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A Non-Cited Violation was identified for allowing a contractor health physics supervisor to review and approve radiation work permits (Section R1.2).

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Unit 1 outage p!anning was in progress and the ALARA analysts were collecting data for work that was expected to be performed during the outage (Section R1.3).

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No problems were Identified during the loading, surveying, and labeling, of a radioactive -

j material waste shipment (Section R1.4).

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. The addition of a health physicist and the planned addition of two supervisors and several technicians should improve the effectiveness of the health physics organization

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Corrective actions were being implemented for deficiencies identified in two separate

audits of the health physics program (Section R7.1).

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The condition reporting system was not effectively implemented in the health physics department (Section R7.2).

h . A violation for the failure to follow a health physics procedure during the maintenance of

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environmental air samplers was closed (Section R8.1).

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Reoort Details R1 Radiological Protection and Chemistry (RP&C) Controls R Self Reading nosimeter Calibration Insoection Scoce UP 83750)

The inspector reviewed the self reading dosimeter (SRD) calibration program including procedures, calibration data, and knowledge of Individuals performing calibration Condition Report (CR) numbers 97-2539 and 97-2545 were also reviewed, which pertained to the calibration of docimeters, Observations and Findinas SRD calibrations were performed using Health Physics Calibration Procedure HPCAL 1.28,"Self Reading Dosimeter Response and Drift Check (Calibration) Procedure." The procedure required, in part, that response checks (calibration) were to be performed prior to Initial use, after damage may have occurred, and routinely in June and December for the emergency plan SRDs. The procedure also required that the SRD calibrations be documente Condition Report 97-2545 noted that during the calibration of emergency plan SRDs in June 1997, the response check failure rate was higher than normally observed. The CR noted that calibration data for some of the SRDs calibrated in June 1997 were missin In addition, the CR noted that the detector for the instrument used to verify the dose rates from the instrument calibrator was broken, and therefore data used to calibrate the SRDs may be inaccurate. CR 97-2539 indicated that for the instrument used to verify the dose rate from the calibrator, no technical manual existed, no training on its use had been performed, and no procedure for its use was develope The inspector discussed the calibration of emergency pisn SRDs Oth health physics supervision. Health physics supervision Indicated that to resolve the differences between two calibrators, tne department purchased a RadCal, Model 2026 to measure the dose rate output of the calibrators and generate their own set of calibration curve Data points for the curves were generated in April 1997, but were not compared to the manufacturer's curves. The manufacturer's instructions were used to operate the instrument and the health physics department did not develop an operating procedure for this instrumen During the last week of June 1997, the emergency plan SRDs were response checked using the new data points. A higher number of dosimeters than expected were failing the response check, by under responding to the expected dose. The staff also noted for l those SRDs passing the response check, that although they were in tolerance, they l were under responding. The health physics department sent the RadCal 2026 back to the manufacturer for calibration. It was previously calibrated in December 1996. The manufacturer informed the licensee that the detector was cracked and as found

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measurements could not be determined. Due to the cracked detector, the data used to generate the exposure rate curves could have been inaccurate, resulting in the perceived under response of the SRD The inspector reviewed response check records for the SRDs and determined that data was available for 42 dosimeters of which one failed the response check. Additional data sheets for the remaining SRDs calibrated in June and those failing calibration could not be provided. The inspector visited each location of the emergency plan SRDs to determine if dosimeters were calibrated in accordance with the procedure. The inspector determined that of the 72 SRDs in service,11 had not been calibrated in June 1997. They were last calibrated in December 1996. The remaining ei SRDs, had calibration stickers which indicated they were last calibrated in June 1997. Of the 61 SRDs with June 1997 calibration stickers, calibration data was available for 38 of the dosimeters. The failure to response check (calibrate) 11 emergency plan SRDs routinely in June 1997, and the failure to maintain docamentation for 23 of the SRDs checked in June 1997, is a violation of Health Physics Calibration Procedure HPCAL 1.28. (VIO 50-266/97018-01(DRS); 50-301/97018-01(DRS)).

The health physics manager determined that the 11 SRDs that were not calibrated would remain in service, as there were no calibrated spare dosimeters. At the conclusion of the inspection on August 29,1997, the health physics staff was preparing to re calibrate the emergency plan SRDs calibrated in June 1997 and those that had

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failed calibration. While the SRDs were available for use, they had not been used to determine personnel doses, Conclusions One violation was identified for the failure to calibrate and maintain calibration records for the emergency plan SRDs as required by HPCAL 1.2 R1.2 Radiation Work Permits (RWPs) Insoection Scoce (IP 83750)

The inspector reviewed RWP procedures for initiating requests, writing RWPs and approving RWPs. A random seiection of completed RWPs was reviewed for completeness in addition, Condition Report CR-97-1713 regarding a contractor health physics supervisor approving RWPs contrary to procedures was reviewe Observations and Findinos There were five procedures at the plant pertaining to RWPs. Two were nuclear procedures intended to provide general information to radiation workers and three were health physics procedures. Health physics procedures were used to generate RWP requests, prepare RWPs, and provide RWP issuance instructions. There have been no recent changes to the procedure _ . _, . . . __ . . . _--. __ . l l

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The RWPs reviewed during the inspection were appropriately filled out and approved by health physics supervision.- The RWPs were initiated by authorized workers and their SRD dose was recorded.- RWPs were updated as radiological conditions change ' Condition Report CR 97-1713 Identified that a contractor health physics supervisor was approving RWPs contrary to Health Physics Procedure HP 2.5.5,"RWP issuance Instructions." The procedure requires that a health physics supervisor approval be obtained. The procedure further defines a health physics supervisor, for the purpose of RWP review and approval, as any health physics management personoci having health physics duty and cal: supervisor responsibilities and the manager - health physics. The

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contractor health physics supervisor does not have duty arid call supervisor responsibilitie The contractor supervisor was authorized to review and approve RWPs in January 1996. The acting general health physics supervisor at the time authorization was granted, dicated that he reviewed several of the procedures and determined the

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contract supervisor could sign the RWPs. The individualindicated that he had not

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reviewed procedure HP 2.5.5 before he made the decision. Once the condition report was written, and the procedures were reviewed, the contractor health physics supervisor was informed that he could no longer approve RWP The inspector reviewed the applicable procedures and determined that the number of RWP procedures was cumbersome and that the definition of a health physics supervisor, if it was included, was not consistent in all procedures. The health physics manager Indicated that while the contractor supervisor could not review and approve RWPs according to the procedure, the supervisor possessed the experience and I qualifications to review RWPs. The failure to follow Health Physics Procedure HP 2.5.5,

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"RWP issuance Instructions" and allow the contractor health physics supervisor to review and approve RWPs is a violation of health physics procedure HP 2.5.5 (NCV 50-266/97018-02(DRS); 50-301/97018-02(DRS)). However, this non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Polic Conclusions

One Non-Cited Violation was identified for the failure to follow health physics procedure HP 2.5.5 by allowing the contractor health physics supervisor to review and approve RWPs. Reviewed RWPs wero complete and updated as radiological conditions changed.

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R1.3 Unit 1 Refueling Outage Planning Insoection Scoce (IP 83750)

The inspector reviewed health physics * advanced planning and preparation for the fall 1997 Unit 1 Refueling Outage, including staff qualifications training, and As Low As Reasonably Achievable (ALARA) work plannin .

. Observations and Findings The ALARA analyst's indicated that they did not have a schedule of the work to be

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completed during the fall outage, but that the planning group was meeting and should provide a schedule shortly. The Unit 1 outage work schedule had not been completed, because work had just been completed for restarting Unit 2. However, ALARA analysts were collecting data for routine outage work and modifications that they believed would be performed based on Unit 2 wor The health physics department trainer was reviewing qualifications and required training for potential contractor health physics technicians. Contractor technicians who were qualified for tasks at the station less than 18 months ago will not have to re-qualify, only review procedures. New technicians or technicians who were qualified on station tasks greater that 18 months ago will be required to attend training and qualify for a task prior to performing that tas Conclusions Outage planning is behind schedule for the Unit 1 Refueling Outage due to Unit 2 only recently being restarted. ALARA analysts were gathering data for expected work, and the health physics trainer was reviewing contractor technician qualification R1.4 Transrortation of Radioactive Material (IP 86750)

The inspector observed the loading of a radioactive material waste shipment. The inspector noted that the shipment was properly surveyed, labeled, placarded, and shipping papers were properly completed. No problems were identifie R6- RPAC Organization and Administration R Health Physics Organization InsoeMion Scoce (IP 83750)

The inspector discussed the health physics organization with the department manager and reviewed the procedures describing the responsibilities of department personnel, Observations and Findinas The inspector discussed the health physics organization with the manager-health physics. The manager indicated that two additional supervisors were to be hired along with several technicians, and that several laundry workers were recently hired. In addition, the health physicist position was filled with an individual from the corporate office. This individual had been completing earlier assignments and had just recently begun to fulfill the responsibilities of the health physicist. Discussions with the health physicist indicated that he was currently involved in closing several condition reports and was in the process of learning all the components of the radiation protection progra _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ --

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The manager indicated the Health Physics' Organization Manual NOM HP.2," General Supervisor-Health Physics," was being reviewed. The title and responsibilities will be revised to reflect the responsibilities of the recently created position of health physicis The manager also indicated that the revision to the manual will include a statement that the health physicist reports to the manager health physics, but has the option of communicating directly with the plant manager on matters of health and safety. The inspector reviewed the manuals for the positions of the managenhealth physics, health physicist, supervisors, and technicians. The responsibilities listed in the manuals were generalin nature. Specific duties and responsibilities of supervisors were listed on the department daily duty board.- The board also listed the duties assigned to the technicians for that da The station employed approximately 20 health physics technicians who performed

, instrument calibrations, routine surveys and sampling, manned the radiologically controlled area egiess point and the health physics desk. Approximately 10 contractor health physics technicians provided health physics coverage for work performed in the radiologically controlled are The inspector noted that the NRC project manager for Point Beach had requested additionallnformation on Technical Specification Change Request 182. This change requested that the health physicist replace the manager-health physics in the technical specifications. The request asked that the description of the health physicist document that the position is a professional supervisor position with adequate authority to represent the radiation protection program interests on a plant wide basis. In addition, the request asked for the involvement of the health physicist in the day-to-day operation and oversight of the program. The manager health physics indicated that the station

was reviewing the request and formulating a response.

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! In an effort to improve the effectiveness of the health physics organization the licensee has added the health physicist position and was in the process of hiring additional supervisors and technician R7 Quality Assurance in RP&C activities

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R7,1 Eollow-uo on Health Physics Quality Assurance Audits (IP 92904)

2 The inspector reviewed corrective actions for two audits of the health physics department completed in April and May 1997. The April sadit was an operations review of the health physics department. This review consisted primarily of discussion with department personnel. The review identified deficiencies in training, supervisor communication, and procedures and radiation worker practices. Corrective actions include a review of the computer-based training program, hiring of two additional supervisors, and discussing an additional assessment of the health physics departmen l

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A May 1997 audit of the health physics department identified several areas with deficiencies for which condition reports were initiated. The inspector reviewed the condition reports generated from the audit and determined that the health physics department was actively tracking and closing condition report j R7.2 Condition Reoorting System Insoection Scoce (IP 83750)

The inspector reviewed the implementation of the Condition Reporting System by the health physics departmen b, Observations and Findings A review of condition reports generated during the past six months indicated that approximately 75 percent of the condition reports were initiated by management. The inspector discussed the condition reporting system with technicians. The technicians indicated that if they saw a problem, they would correct it, Inform their supervision of the matter, and let supervision initiate the conditlon report. The technicians indicated that they wou d not hesitate to initiate a condition report if they disagreed with the resolution or handling of an issue brought to supervision attention. Additionally, the technicians indicated that they were comfortable initiating reports if they needed t The tcchnicians also showed they did not understand the purpore of initiating a condition report if the problem was corrected. The inspector discussed the tracking and trending functions of the condition reporting system with the technicians, who indicated they were not aware of those functions. The technicians also indicated that they did not receive information on the disposition of a condition report, but only that it was close The he9th physics manager was informed of the technician's lack of understanding regarding the condition reporting system. The manager inducted he would discuss the reporting system and management's expectations for using the system, Conclusions The technicians lack of understanding regarding the condition reporting system and the lack of feedback on resolutions to condition reports, prevented the technicians from effectively using the syste R8 Miscellaneous RP&C lssues R (Closed) VIO 50-266/97014-01 50-301/97014-01: Failure to follow a health physics procedure during the maintenance of environmental air samplers. Corrective actions implemented by the health physics manager were to instruct the staff not to use the temporary procedure change process as a substitute for initiating and expediting changes to procedures. The health physics manager also communicated his expectation that current and approved procedures will be used for performance of health physics activities, including checking for the current revision and temporary

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changes before doing the worx actively. The inspector reviewed the corrective actions and concluded that the actions were appropriate. ' -

i X1 Exit Meeting Summary.

The inspector presented the Inspection results to members of licensee management at the

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conclusion of the inspection on August 29,1997. The licensee acknowledged the findings presented and did not identify any information discussed as proprietary.

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. PARTIAL LIST OF PERSONS CONTACTED Licensee -

E.- Epstein, Health Physics Specialist-Nuclear E. Lange, Health Physics Supervisor -

C Onesti, Health Physicist T. Smith, Health Physics Supervisor S. Thomas, Health Physics Specialist-Nuclear P. Tindall, Health Physics Manger NHC T McMurtray, Senior Resident inspector INSPECTION PROCEDURES USED IP 83750:- Occupational Radiation Exposure IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92904: Followup - Plant Support LIST OF ITEMS OPENED AND CLOSED -

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50-266(301)/97018-01 VIO failure to calibrate emergency plan 0-200 roentgen self reading dosimeters in accordance with the procedure 50-266(301)/97018-02 NCV failure to have only health physics supervisors with duty and call responsibilities review and approve radiation work permits Gned 50-166(301)/97014-01 VIO failure to fo"ow a health physics procedure during the maintenance of environmental air samplers 50 266(301)/97018-02 NCV failure to have only health physics supervisors with duty and ca!! responsibilities review and approve radiation work permits

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LIST OF ACROWYMS USED I

=ALARA As Low As Reasonably Achievable-CR Condition Report i .. NCV Non-Cited Violation .

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NRC Nuclear Regulatory Commission 4 -RP&C Radiological Protection and Chemistry SRD _ Self Reading Dosimeters'

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" Roentgen RWP Radiation Work Permit

VIO Violation i

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LIST OF DOCUMENTS REVIEWED Condition Report No. 97-1713

- Condition Report No. 97-2376

- Condition Report No. 97-2539 Condition Report No. 97-2545 Health Physics Calibration Procedure, HPCAL 1.28, Revision 10, March 20,1997, "Sel Reading Dosimeter Response and Drift Check (Calibration) Procedure" Health Physics Manual, HP 2.5.3, Revision 4, June 27,1996, "RWP Request (Form PBF-9923C) Review" l

Health Physics Manual, HP 2.5.4, Revision 5, August 13,19%, " Radiation Wcrk Permit

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Preparation" Health Physics Manual, HP 2.5.5, Revision 7, September 13,1994,"RWP lssuance Instructions" Organization Manual, NOM-HP.2. Revision 0, February 16,1994, " General Supervisor - Health Physics" Organiz3 tion Manual, NOM HP.3, Revision 0, February 16,1994, * Health Physics Manager" Organization Manual, NOM HP.3, Revision 0, February 16,1994, " Health Physics Sup3rvisor" Organization Manual, NOM-HP 3, Revision 0, February 16,1994," Health Physics Technologist" i

Procedures Manual, NP 4.2.20, Revision 3, January 27,1995, " Radiation Work Permit" Procedures Manual, NP 4.2.21 Revision 3, April 25,1997," Standing Radiation Work Permit" Procedures Manual, NP 5.3.1, Revision 5, May 19,1997," Condition Reporting System" Radiation Work Permit No. 97-32 Radiation Work Parmi! No. 97-48

- Radiation Work Permit No.97-102 Radiation Work Permit No.17-115 Radiation Work Permit No.97-125

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. Radiation Work P:rmit No.97-145

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Radiation Work Permit No.97-199

- Root Cause Evaluation 97-06 . -

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Self Reading Dosimeter Recponse/ Drift Check Form, June 24,1997 Self Reading Dosimeter Response / Drift Check Form, June 30,1997 i d

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