IR 05000266/1998008

Insp Repts 50-266/98-08 & 50-301/98-08 on 980316-20.No Violations Noted.Major Areas Inspected:Radiation Protection Performance During Refueling Outage

ML20216H297
Person / Time
Site:	Point Beach
Issue date:	04/15/1998
From:	Shear G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20216H284	List: IR 05000266/1998008 ML20216H280
References
50-266-98-08, 50-266-98-8, 50-301-98-08, 50-301-98-8, NUDOCS 9804210106
Download: ML20216H297 (10)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos: 50-266;50-301 License Nos: DPR-24; DPR-27 Report Nos: 50-266/98008(DRS); 50-301/98008(DRS)

Licensee: Wisconsin Electric Power Company l Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: 6610 Nuclear Road Two Rivers, WI 54241 Dates: March 16-20,1998 Inspector: K. Lambert, Radiation Specialist l

Approved by: G. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety

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EXECUTIVE SUMMARY Point Beach Nuclear Plant, Units 1 & 2 l NRC Inspection Reports 50-266/98008; 50-301/98008 This routine inspection included a review of radiation protection performance during the Unit 1 refueling outage (U1R24). This review included outage work controls, as-low-as-is-reasonably-achievable (ALARA) controls, radiation worker performance, and radiological posting, labeling and housekeeping. In addition, several open items from previous inspections were reviewed and close .

Outage work controls and ALARA efforts were effectively carried out during outage activities. Pre-job briefings were detailed and effectively communicated health physics expectations, radiation work permit (RWP) requirements, and ALARA reviews; however, special instructions in ALARA reviews were not clearly documented in the RWPs. Good communication was exhibited between health physics technicians and work groups during pre-job briefings and work activities. Significant rework activity had not occurred to date; therefore, the impact on the outage dose from rework activities was small (Section R1.1).

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Radiological postings were well maintained and appropriately inforrned workers of current radiological conditions. Labeling of containers was generally in accordance with procedures with several minor deficiencies promptly corrected when reported to health physics technicians. Housekeeping was acceptable, although several minor deficiencies were identified, which were also promptly corrected when brought to the licensee's attention (Section R1.2). l

. A lack of procedural guidance was identified in the health physics program regarding updating RWPs with the current radiological conditions and providing workers with the current radiological conditions during pre-job briefings. The health physics staff was reviewing applicable procedures to decide if changes in procedures were required to ensure that RWPs are updated when radiological conditions change significantly and to provide supervisor responsibility for ensuring that current radiological conditions are reflected in work control documents (Section R1.3).

. Overall radiation worker practices were effective. Workers generally demonstrated adequate use of ALARA techniques and were aware of the radiological conditions in work areas. In addition, workers appropriately removed protective clothing and generally performed adequate whole body frisks upon exiting containment (Section R4.1).

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Reoort Details IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R Unit 1 Outaae Work Control and As-Low-As-Is-Reasonablv-Achievable (ALARA)

Imolementation Insoection Scoce (IP 83729)

The inspector reviewed the radiological controls implemented and the ALARA goals for the Unit 1 1998 refueling outage (U1R24). The inspector also reviewed ALARA plans, radiation work permits (RWPs), ALARA reviews, and observed pre-job briefings and work activitie Observations and Findinas As of March 17,1998, with about 40 percent of the scheduled outage work completed, the outage dose was 27.1 rem, about 20 percent of the outage dose goal. However, several high dose jobs had not yet been performed, including steam generator (S/G)

eddy current testing, S/G wrapper plate modification, S/G level tap replacement, and S/G secondary side sludge lancin Health physics (HP) staff developed a refueling outage dose goal of 130 rem, based on the original work scope. Due to cmergent work on removal of part length control rod drive housings, HP staff estimated that an additional dose ranging from 6 to 12 rem would be incurred, dependent on how much shielding was to be installed. Emergent work for removing five incore thimble tubes from the reactor vessel added 219 millirem to the outage dose. HP staff expected that even with the additional dose from emergent l

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work, the outage dose goal would be met or only slightly exceeded. Discussion with HP staff also revealed that significant rework activity had not occurred to date and therefore, the impact on the outage dose from rework activities was smal ,

The inspector reviewed ALARA plans and RWPs for several high dose jobs, including incore flux thimble tube removal, "B" loop insulation removal, upper internals lift rig inspection, and the removal of the part length control rod drive housings. ALARA reviews were completed in accordance with station procedures. ALARA reviews 4 included previous job dose history, radiological hold points, and special instruction The ALARA review for the control rod drive housings was ongoing to assess whether additional dose reductions could be incorporated into the work plan. Discussions with the ALARA technicians, revealed that the incore flux thimble removal work plan was revised based on suggestions by the technicians; however, the suggested changes were not documented in the ALARA review. In addition, specialinstructions in the ALARA plans were not clearly documented in the RWPs. The HP manager stated that the relationship between ALARA reviews and RWPs was to be reviewed to improve the effectiveness of the ALARA review \ _ _ - - _ _ _ _ - _ - _ _ _

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The inspector attended several pre-job briefings, which provided detailed information to the workers on radiological conditions, dosimetry placement, and protective clothing requirements. The HP staff communicated RWP requirements, radiological hold points, and ALARA review information (for those jobs with ALARA reviews) to workers. The pre-job briefing also included a discussion of the work plan by the work group leade Good discussions between work groups were evident, which ensured that the job scope and workers' responsibilities were well understoo The inspector observed several jobs in progress, including the removal of incore flux thimble tubes and the disassembly of equipment used for examination of reactor vessel nozzles. HP technicians (HPTs) provided good coverage for the above jobs, and suspended work to assess activities and rciodify or add protective clothing when necessary. Good communication and cooperation between the HPTs and work groups was observed. In addition, an HP supervisor was present during the incore flux thimble tube removal evolution to help the HP staff and work group if radiological complications were encountered or additional guidance was neede Conclusions Outage work controls and ALARA efforts were effectively carried out during outage activities. Pre-job briefings were detailed and effectively communicated health physics expectations, RWP requirements, and ALARA reviews. However, specialinstructions in ALARA reviews were not clearly documented in the RWPs. Good communication was exhibited between health physics technicians and work groups during pre-job briefings and work activities. Significant rework activity had not occurred to date and therefore, the impact on the outage dose from rework activities was smal R1.2 Radiolooical Postings. Labeling. and Housekeeoing Insoection Scoce (IP 83729)

The inspector reviewed radiological postings and labeling of containers in the Unit 1 containment. In addition, housekeeping practices in the Unit 1 containment were reviewe Observations and Findinos The inspector observed, during several tours of containment, that radiological postings and boundaries were well maintained. The inspector also determined, through independent measurements, that radiation areas and high radiation areas were appropriately posted in accordance with regulatory requirements. Container labeling was generally in accordance with station procedures with several minor labeling inconsistencies promptly corrected when reported to HPTs. The inspector also noted that the HP staff had initiated a condition report to address labeling inconsistencie The inspector observed, during several tours of containment, that housekeeping was acceptable. However, several housekeeping deficiencies were identified including rags

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laying on the floor, a bag of trash against a wall, and an empty spray bottle laying on the floor with the lid off. The inspector reported these deficiencies to HPTs, who took prompt corrective adon Conclusions Radiological postings were well maintained and appropriately informed workers of current radiological conditions. Labeling of containers was generally in accordance with procedures with several minor deficiencies promptly corrected when reported to health physics technicians. Housekeeping was acceptable, although several minor deficiencies were identified, which were also promptly corrected when brought to the licensee's attentio R1.3 Lack of an Uodated RWP After Radioloaical Conditions Chanaed Insoection Scoce (IP 92904)

The inspector reviewed the circumstances surrounding an unresolved item regarding a resident inspector's observation that during pre-job briefings for reactor vessel head work on June 26 and 27,1997, updated radiological survey data for RWP 97-267 was not provided to the workers. The radiological conditions had changed following the removal of the lead shielding surrounding the vessel head on June 24,1997. This included reviews of survey records, applicable procedures, the condition report initiated in response to the event, and discussions with the HP staf Observations and Findinas The inspector determined, through discussions with HPTs, that during the vessel head work on June 26 and 27,1997, informal surveys were performed and the current radiological conditions were provided to the workers. However, this information was not provided during the pre-job briefing and the RWP for the job was not updated with the survey information. In response to an inquiry from the resident inspectors on the aftemoon of June 27,1997, a formal radiological survey was performed and this information was utilized to update the RW The inspector reviewed the RWP lssuance instructions (HP 2.5.4) and the Radiological Surveys and Records (HP 3.1) procedures. These procedures did not include responsibilities for HP supervision to ensure that the current radiological conditions were used in appropriate documents. In addition, the Radiation Work Permit Preparation (HP 2.5.5) procedure only indicated that the first and second updates of area radiological conditions may be used to document significant radiological condition changes that occur. The inspector determined that the health physics program lacked procedural guidance regarding updating RWPs and informing workers when radiological conditions change significantly.

l The HP manager indicated it was his expectation that RWPs and survey data be updated when significant changes to radiological conditions occur. Corrective actions

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were being implemented to ensure that RWPs were updated to contain current radiological conditions. The corrective actions included revising Health Physics procedures HP 3.1 and HP 2.5.5 to include supervisor responsibilities for ensuring that ;

the most recent representative surveys of radiological conditions are reflected on RWPs before issuance. The HP manager also indicated that procedure HP 2.5.5 would be {

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reviewed to decide if changes in the procedure for updating RWPs when radiological conditions change significantly are required. As indicated in Section R1.1, during )

U1R24, pre-job briefings were effective and included appropriate radiological information. In addition, RWPs contained updated radiologicalinformatio Conclusions A lack of procedural guidance was identified in the health physics program regarding updating RWPs with the current radiological conditions and providing workers with the current radiological conditions during pre-job briefings. Corrective actions were being implemented to ensure that RWPs were updated to contain current radiological conditions. In addition, the HP staff was reviewing applicable procedures to decide if changes in procedures were required to provide supervisor responsibility for ensuring that current radiological conditions are reflected in work control documents (Section R1.3).

R4 Staff Knowledge and Performance in RP&C R4.1 Review of Outaae Radworker Performance I Insoection Scoce (IP 83729)

The inspector reviewed outage radiation worker performances, by reviewing work packages, attending pre-job briefings, interviewing workers, and observing outage work activities in containmen Observations and Findinas During tours of containment, the inspector observed generally good radiation worker practices, in particular, good radiation worker practices were observed during the removal of five incore flux thimble tubes and disassembly of reactor vessel nozzle ,

inspection equipment. With minor exceptions, personnel donned and removed j'

protective clothing correctly. Workers demonstrated adequate use of ALARA techniques and were aware of the radiological conditions. Workers communicated with the HPTs providing job coverage, to keep the technicians informed of the status of the work and to request clarification of radiation worker expectations, as neede During a tour of containment with an HP supervisor, the inspector observed an individual )

on the 21-foot level of containment sitting by an opening in the floor and under an Al. ARA alert sign. ALARA alert signs were used to inform workers of areas with elevated radiation levels within radiation areas. This sign indicated that dose rates in the area were up to 35 millirem per hour (mrem /hr). The inspector also noted that the ,

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worker had his back up against the let down pipe line by valve 1CV-3718. The HP l

supervisor had the individual move awav from the pipe and discussed the individual's job. The individual indicated that he was testing a valve and because of the opening in the floor, had to be present in the area for safety considerations. The inspector performed a survey of the pipe that the individual was sitting against with a portable survey instrument. The survey indicated 35 milliroentgens per hour (mR/hr) on contact with the pipe. The individual's self reading dosimeter (SRD) indicated an exposure of 15 mrem. The individual indicated that he was leaning against the pipe for approximately 10 minutes and before that was sitting on the other side of the opening by a stairwa The dose rate by the stairway was measured at less than 5 mR/hr. The HP supervisor ,

had the job placed into a safe condition, and then had the individual leave the radiologically controlled are The inspector questioned the individual regarding his understanding of ALARA alert signs. The individualindicated that the sign meant that elevated radiation levels were beyond where the sign was posted, similar to radiation area and high radiation area signs. The inspector questioned several other workers in containment during the inspection with these workers expressing the correct understanding of ALARA. alert signs, which was that the signs indicated that radiation levels near the signs were elevated and individuals should avoid these areas unless their job required them to be in the are HP management indicated that corrective actions included suspending the individual's radiologically controlled area ar%,ess until the individual and his supervisor met with the HP manager. The indvided was to attend general employee training and the radiologically controlled area orientation again, before receiving renewed access to the radiologically controlled area. This orientation included a tour of the radiologically controlled area with an HPT explaining to the individual access requirements, frisking procedures, and the radiological postings and controls used. HP management also indicated that the use of ALARA alert signs would be discussed with work group The inspector observed individuals appropriately removing protective clothing and performing whole body frisking upon exiting containment. Overall, individuals were effectively performing frisking operations in accordance with station procedures. The inspector also observed HP's response to an individual who had alarmed a personnel contamination monitor when exiting the radiologically controlled area. HPTs performed 4 a frisk of the individual using portable survey instruments and identified approximately 1 100 counts per minute (cpm) of radioactive contamination on his T-shirt. Additional i surveys identified contamination on his identification badge of approximately 2000 cp This individual was working in containment and had performed a whole body frisk upon exiting containment. The identification of contamination on the individuals identification badge by the HPTs, indicated to the inspector, that the individual did not adequately perform a whole body frisk upon exiting containment. This was discussed with HP

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management, who indicated that additional attention would be placed on observing l individuals frisking when exiting containment.

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l Conclusions i

Overall, radiation worker practices were effective. Workers generally demonstrated adequate use of ALARA techniques and were aware of the radiological conditions in j work areas. In addition, workers appropriately removed protective clothing and generally performed adequate whole body frisks upon exiting containmen R8 Miscellaneous RP&C lssues l R (Closed) URI 50-301-97013-06(DRS): The health physics staff did not adequately I document changed radiological conditions for the Unit 2 reactor vessel head work performed on June 26, and 27,1997. This unresolved item was discussed in detail in Section R1.3 of his report and is considered closed.

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R8.2 (Closed) VIO 50-266/97018-01(DRS): 50-301/97018(DRS): Failure to calibrate emergency plan self reading dosimeters in accordance with the procedure. The corrective actions, described in a letter dated November 3,1997, were reviewed during an inspection in February 1998, and documented in inspection report numbers 50-266/98004(DRS); 50-301/98004(DRS). During that inspection, one corrective action -

item had not been completed. This corrective action concemed the implementation of an administrative procedure to define health physics expectations for completing and documenting surveillances. Procedure, NP 4.3.2," Documentation of Technical Specification Surveillance Requirements," was implemented on March 25,1998. This item is considered close X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on March 20,1998. The licensee acknowledged the findings presente The licensee did not identify any information discussed as proprietar !

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PARTIAL LIST OF PERSONS CONTACTED l Licensee

I R. Adams, Quality Assurance Engineer l A. Cayia, Plant Manager i R. Farrell, Manager, Health Physics F. Flentje, Regulation & Compliance Specialist D. LeClair, Health Physics Coordinator M. Moseman, Health Physics Specialist T. Smith, Health Physics Supervisor ,

M. Reddemann, Plant Manager (effective April 3,1998) l R. Walesh, Quality Assurance Specialist INSPECTION PROCEDURES USED ll IP 83729: Occupational Exposure During Extended Outages IP 92904: Followup - Plant Support LIST OF ITEMS OPENED AND CLOSED Omened None Closed 50-301/97013-06 URI Lack of updated radiological survey information during Unit 2 reactor vessel head work 50-266/301/97018-01 VIO Failure to calibrate emergency plan 0-200 roentgen self reading dosimeters in accordance with the procedure Discussed None I

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LIST OF ACRONYMS USED ALARA As-Low-As-Is-Reasonably Achievable cpm Counts Per Minute HP Health Physics HPT Health Physics Technicians mR/hr milliroentgen per hour mrem /hr millirem per hour NRC Nuclear Regulatory Commission PDR Public Document Room )

j RWP Radiation Work Permit i S/G Steam Generator SRD Self Reading Dosimeters LIST OF DOCUMENTS REVIEWED 1998 BPNP Site Annual Dose Graph ALARA Evaluation, Part-Length Control Rod Drive Modification, DRAFT Condition Report 97-2002 Health Physics Procedure, HP 2.5.4, Revision 5, Radiation Work Permit Preparation Health Physics Procedure, HP 2.5.5, Revision 7, RWP issuance Instructions Health Physics Procedure, HP 3.1, Revision 8, Radiological Surveys and Records Health Physics Procedure, HP 3.2.5, Revision 10, Radioactive Material Container Posting Requirements Nuclear Procedures Manual, NP 4.2.19, Revision 2, General Rules for Work in a Radiologically Controlled Area l Nuclear Procedures, NP 4.2.20, Revision 3, Radiation Work Permit j Pre-job ALARA Review, Removal of Incore Flux Thimbles (5)  !

Radiological Surveys of Unit 2 Reactor Cavity-Upper Level from 6/19/97 to 6/27/97 l

RWP 97-267, U2 Reactor Head Restoration RWP 98-223,1CV 313A RWP 98-224, incore Flux Thimble Removal

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