IR 05000266/1998012
| ML20249A067 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/11/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20249A060 | List: |
| References | |
| 50-266-98-12, 50-301-98-12, NUDOCS 9806160022 | |
| Download: ML20249A067 (17) | |
Text
- l
.
U.S. NUCLEAR REGULATORY COMMISSION REGION lll Docket Nos: 50-266; 50-301 License Nos: DPR-24; DPR-27 i Report Nos: 50-266/98012(DRS); 50-301/98012(DRS)
,
Licensee: Wisconsin Electric Power Company Facility: Point Beach Nuclear Plant, Units 1 and 2
{
Location: 6610 Nuclear Road Two Rivers, WI 54241 Dates: May 18-22,1998
<
'
Inspectors: K. Lambert, Radiation Specialist N. Shah, Radiation Specialist Approved by: G. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety
,
i l
y:
!
l l
9906160022 990611 PDR ADOCK 05000266 9 PDR
_. . _ _ _ . _
. _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _
'
.
EXECUTIVE SUMMARY Point Beach Nuclear Plant, Units 1 & 2 NRC Inspection Reports 50-266/98012; 50-301/98012 This routine inspection included a review of Unit i refueling outage (U1R234) doses, solid radioactive waste management, transportation of radioactive materials, health physics program audit, and control of high, locked high, and very high radiation area .
.One violation was identified for the failure to calibrate self-reading dosimeters in emergency plan sampling kits at the required frequency. Corrective actions implemented in response to a previous violation, for failure to calibrate emergency plan dosimeters, were not effective in preventing a recurrence of the violation (Section R1.1).
.
The as-low-as-is-reasonably-achievable (ALARA) planning and controls for the resistance temperature detectors pipe support work were good. However, a problem was identified with the job not being included in the outage schedule and there were several examples identified of wenk or missing items in the ALARA documentation (Section R1.2).
.
The solid radioactive waste processirG and storage program was well implemented and was as described in station documents. Material condition of processing equipment and storage containers was good. The station was evaluating additional waste reduction efforts for dry active waste, with plans to implement new efforts after the current outage was completed (Section R1.3).
.
Outage work controls were effectively carried out during work activities, and workers exhibited good radiation worker practices. However, total outage dose exceeded dose goals primarily due to two dose intensive emergent jobs (Section R1.4).
.
The licensee maintained effective controls over high, locked high, and very high radiation areas, but did not effectively communicate expectations for controlling these areas or for controlling keys allowing access to these areas in station procedures or training. One violation was identified for failure to properly control a locked high radiation area key as required by Technical Specifications (Section R2.1).
.
Several examples of poor procedural guidance were identified during this inspection specific to ALARA planning and high radiation area / locked high radiation area control These examples were similar to others identified earlier this outage relating to radiation ;
<
work permits and ALARA job briefings (Section R3.1). {
l
. The quality assurance audit of the Health Physics program was wellimplemented and I j identified several areas with deficiencies or areas where improvements could be made, l l with many of these a'aas related to weak procedures. Health physics staff were j l developing corrective actions for the areas needing improvement (Section R7.1) i
,
1
. _ . . _ __ J
F .
.
.
The radioactive material shipping program was well implemented. Personnel involved with the shipping program were knowledgeable of regulations and station procedure Shipping paperwork was appropriately completed with no problems identified (Section R8.1).
!
I
!
I-l
'
,
l l
l
.
l
1.-
l
!
i
.
Report Detalla IV. Plant Suonort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Self Reading Dosimeter Calibration a.- Insoection Scoce (IP 83750)
The inspectors reviewed condition report 98-1675, which documented that during the quarterly inventory of emergency preparedness health physics equipment, numerous items did not meet inventory expectations. One deficiency included self-reading dosimeters (SRDs) that were not calibrated at the required frequenc Observations and Findings During a quarterly audit, conducted in March 1998, of the emergency preparedness health physics equipment, two 0-5 roentgen (R) SRDs in an emergency plan sampling kit were found wlth calibration stickers indicating that calibration was due in December 1997. There were two sampling kits, with two 0-5 R SRDS per kit, at the site boundary control center, with the other kit containing dosimeters calibrated in December 199 '
Discussions with health physics (HP) management revealed that the previous inventory was performed in December 1997. One health physics technician (HPT) was responsible for conducting the inventory, while a second HPT was responsible for performing the calibrations on SRDS, portable survey instruments, and air sampling
<
equipment. HP management believed that the SRDs in the sampling kit were missed during the calibration of emergency plan equipment during the December inventor The inventory form only accounts for the number of SRDs per kit and not whether the SRDs were in calibratio The inspectors reviewed health physics procedure HPCAL 1.28, "Self-Reading Dosimeter Response and Drift Check (Calibration) Procedure." This procedure stated in l Attachment 1, that emergency plan SRDs are due for calibration in June and December and indicated that a total of four 0-5 R SRDs were assigned to the sampling kits. The failure to calibrate two 0-5 SRDs in one of the campling kits in December 1997, was a violation of procedure HPCAL 1.28 (VIO 50-266/98012-01(DRS); VIO 50-301/98012-01 (DRS)). This was a repeat violatio l The immediate corrective action was to replace the SRDs in the sampling kit with j dosimeters that were in current calibration, which was completed on March 22,1998.
l Additional corrective actions were to develop a data base of all SRDs onsite, which l
consisted of a serial number, SRD location, calibration date, and calibration due dat In addition, a calibration form was developed which included the SRD serial number, I and for the drift test the SRD reading, reading after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and percent drift. The form t also included response test information for SRD reading, percent response, percent
t
- _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ '
.
1 error, exposure time, and whether the SRD passed or failed the tests. The acceptance criteria were also included on the for The inspectors discussed with HP management why these corrective actions would be more effective in preventing a recurrence than those implemented in response to a similar violation in August 1997, inspection Report 50-266/97018(DRS); 50-301/97018 (DRS), violation (VIO) 50-266(301)/97018-01(DRS). Corrective actions for this previous violation included updating a table listing the number and location of dosimeters and when calibration was due, and discussions with HPTs on the importance of ensuring i that dosimeters are calibrabd within the required frequency. HP management indicated !
that the development of a data base with SRD serial numbers would provide a check list ;
against which SRDs could be compared to ensure that all SRDs were calibrated at the appropriate frequenc Conclusions One violation was identified for the failure to calibrate SRDs in emergency plan sampling kits at the required frequency. Corrective actions implemented in response to a previous violation, for failure to calibrate SRDs, were not effectiva in preventing a recurrence of the violatio R1.2 Resistance Temperature Detector (RTD) Work Insoection Scoce (IP 83750)
The inspectors reviewed the as-low-as-is-reasonably-achievable (ALARA) planning and controls for work on the RTD system. The inspection consisted of interviews with workers, a review of documents and observations of ongoing wor Observatic.1s and Findings The work scope consisted of upgrading the pipe supports on the Unit 1 A and B RTD bypass lines to address seismic and thermal expansion concerns. The total expected dose was 10 rem and as of May 22,1998, about five rem was accrued with more than 60% of the work complete The inspectors observed good use of ALARA controls such as temporary shielding and good job coverage by HPTs. Workers displayed good radworker practices and were familiar with the radiation work permit (RWP) and ALARA plan requirements. The inspectors also noted that both of these documents addressed " lessons learned" from Unit 2 RTD work in 1997. Management support for this job, such as allocating engineering resources for the shielding evaluations, was considered good by the station ALARA planner However, there was a problem with the scheduling of this work. During the Unit 2 RTD work, the licensee recognized the need for subsequent work on Unit 1, but did not include this task in the Unit 1 outage schedule. This resulted in the HP staff having to
i
_ _ _ _ - _ _ - _ _ - _ - _ _ _ _ _ - _ _ - _ _ _ - _ _ _ - _ - - _ _
.
<
plan this job as emergent work. The license planned to address this issue during the Unit 1 post-outage revie The inspectors also identified several examples of weak or missing items in the ALARA documentation. Specifically:
A single RWP (No.98-364, dated April 27,1998) was written for both the A and B RTD work, which described both initial and updated radiological conditions (i.e, dose rates, contamination levels, airborne sample results, etc.). However, the location and date of these radiological surveys were not stated which caused some confusion. Although HP management expected that the survey location and date be stated, it was not a procedural requirement. The inspectors verified that other radiological surveys were dated and clearly showed the affected locatio .
The ALARA review stated that respirators were not necessary for the RTD work, but did not list the basis. During interviews, the ALARA planners stated that this conclusion was based on actual radiological conditions, but that an ALARA
'
calculation may not have been performed. The inspectors performed this calculation to verify that not using respirators was ALAR Station procedure HP 4.4 (dated March 31,1997), " Restriction of Intemal Dose,"
step 9.3.3, recommended that engineering controls and area ventilation be evaluated given the job radiological conditions. However, the inspectors could not verify whether this had been don The root cause of these examples was that HP procedures did not clearly state what was required (per management expectations) nor provide guidance on how to meet l these requirements. For example, as stated above, the inspectors could not verify the !
basis for not using respiratory protection or whether an evaluation had been performed l for engineering controls and/or area ventilation. This information was not specifically l required in the associr 'sd procedure and there was little associated guidanc I However, HP management expected that the basis for respiratory protection i recommendations be stated in the ALARA package and that an evaluation of engineering controls and/or area ventilation should have been performed and ,
documente '
The licensee had initiated a condition report regarding the lack of procedural guidance for ALARA procedures and was revising the procedures to more clearly state what was required and to provide appropriate guidance. In addition, the licensee planned to review all HP procedures within a two year period, beginning after the completion of the Unit 1 outag Conclusions The ALARA planning and controls for the RTD pipe support work were good. However, a problem was identified with the job not being included !n the outage schedule and
l l
I L
,
._ _ _ - _ _ - _ _ _ _ _ _ _
.
there were several examples identified of weak or missing items in the ALARA documentatio R1.3 Solid Radioactive Waste Manaaement !nsoection Scoce (IP 86750)
The inspectors reviewed the station's solid radioactive waste program. This included reviews of generation, processing, and storage of solid radioactive waste, and 10 CFR Part 61 waste classification and characterization analysis, in addition, inspectors toured radioactive waste storage facilitie Observations and Findinas Radioactive waste at the station included dry active waste (DAW), spent resins, blowdown evaporator concentrates, and process stream filter media. Spent resins, l filtcrs and evaporator bottoms were dewatered onsite and placed into high integrity containers (HICs) prior to disposal at a licensed offsite facility. DAW was sent to a ,
'
processor for segregation and volume reduction, prior to disposal. Approximately 20,000 pounds of DAW had been generated this year to date with a goal of generating about 42,000 pounds for 1998. Two HICs containing solidified evaporator bottoms had been disposed of this year. Spent resins had not been shipped this year. However, a partially filled HIC was onsite and was expected to be shipped late this year or early next l yea The radioactive waste specialist indicated that several DAW waste reduction efforts
'
were being evaluated. These efforts included increasing the use of reusable bags, eliminating the use of wood in the radiologically controlled area (RCA), limiting the use of tape, and limit or eliminate bringing cardboard into the RCA. The specialist indicated that these additional waste reduction efforts would be implemented after the current Unit 1 outage was complete Waste stream sampling and analysis were conducted in accordance with 10 CFR Part 61, the process control program, and procedere RDW 18.1.1, "10 CFR 61 Sampling Program." Samples from each waste stream were collected at least annually, with some waste streams composited. Independent laboratory analysis data was compared to house data to validate the independent laboratory data. Once validated, the independent laboratory data was used to generate scaling factors. The RADMAN computer code was used to validate data, generate scaling factors, and classify l radioactive waste for disposal. Inspectors performed evaluations of the independent laboratory validations, with no problems identifie The inspectors toured the radioactive waste processing and storage areas, including the following areas: the interim storage, drumming and compacting areas; the resin HIC storage area in the truck bay; the radioactive waste storage areas outside the primary auxiliary building (PAB), but inside the RCA; and the radioactive material storage and steam generator mausoleum storage areas outside the protected area at the north end
i
_ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ __ _ _ J
.
of the facility. The storage areas were appropriately posted and controlled, and containers were appropriately labeled. Material condition and integrity of drums and containers were good. Housekeeping was also good in processing and storage area Conclusions The solid radioactive waste processing and storage program was wellimplemented and as described in station documents. Material condition of processing equipment and storage containers was good. The station was evaluating additional waste reduction effods for DAW, with plans to implement new efforts after the current outage was complete R1.4 Unit 1 Refueling OutLge Dose and Work Control Insoection Scoce (IP 83729)
The inspectors reviewed the station dose for the Unit 1 refueling outage (U1R24). The inspectors also observed severaljobs in progres Observations and Findinas As of May 20,1998, the total outage dose was 133 person-rem. The projected total I outage dose was 130 person-rem. ALARA group personnelindicated that the cause of the actual dose exceeding the projected dose was due to the significant amount of ,
emergent work. Emergent work had aoded about 20 person-rem to the total outage j dose, with most of the emergent dose accrued from two jobs, short length control rod l
drive removal (12.5 person-rem), and RTD pipe support work (5 person-rem). I i
The inspectors observed severaljobs in progress, including the RTD pipe support modifications, cleaning reactor head studs, and nondestructive testing of the reactor head flange area. HPTs provided good coverage for the above jobs. Good communication and cooperation between HPTs and workers were observed. Workers were also observed exhibiting appropriate radiation worker practices, properly removing protective clothing, and performing whole body frisking upon leaving containmen l c, CgarJusions l
i Outage work controls were effectively carried out during work activities, and workers i exhibited good radiation worker practices. However, total outage dose exceeded dvse goals due primarily to two dose intensive emergent job i
'
l
i I
_ . _ . _ __
_ _ _ - - _ _ _ _ _ _ _ - _ _ _ _ - _ ___
.
. R2 Status of RP&C Facilities and Equipment
,
R Control of Very Hiah (VHRAL Locked (LHRA) and Hiah Radiation (HRA) Areas I Insoection Scoce
!
The inspectors reviewed the licensee's control of VHRAs, LHRAs and HRAs. The !
inspection consisted of interviews with personnel, a review of procedures and a walkdown of the following LHRAs: U1 Facade Radwaste Storage Cubicle; U6 !
Demineralized Cubicle; U1 Mixed Bed South; U12 Boric Acid Evaporator Demineralized; U2 Reactor Coolant Filter; PAB Filter Storage Pillbox (on 46' elevation); U1 Sealwater Supply Filter Cubicle; and the Waste Holdup Tank Cubicl ] Observations and Findings The inspectors observed that the above LHRAs were controlled and posted consistent with station procedural and NRC requirements. Material condition and radiological housekeeping in these areas were considered good. Workers were familiar with j procedural requirements for VHRA, LHRA and HRA access and VHRA/LHRA keys, maintained by RP and control room staff, were maintained appropriatel The inspectors also reviewed the licensee's procedures and practices regarding controlling transient high radiation areas during fuel movement and radioactive waste activities. Specifically, the inspectors verified that these procedures contained )
instructions to keep RP informed of the fuel move or waste transfer process in order to establish necessary radiological postings and controls. The inspectors reviewed RP and operator logbook entries and required documentation for fuel movement occurring on February 26,1998 and for radioactive waste transfers occurring on January 7,1998, February 5,1998, and May 6,1998. For each activity, the inspectors verified that HP was informed and that appropriate radiological controls were establishe The inspectors identified two additional examples of procedural weaknesses as discussed in Section R1.2. During interviews with workers and RP management, the inspectors found that requirements for controlling an LHRA once inside or if found unlocked, were not well understood. In one example, an HPT could not clearly state what a worker was required to do in order to prevent an inadvertent LHRA entry. The inspectors also identified that RP management expectations were not listed in plant procedures or clearly discussed in Nuclear General Employee Training (NGET), which contributed to the confusion. This was discussed with RP management who planned to review the matte The inspectors also identified that there were no formal instructions for LHRA key control in station procedures or in NGET. This instruction was sometimes provided
'
informally by members of the RP staff to those assigned a key. This lack of formal guidance was the root cause of an event (CR 98-1727, dated April 27,1998) where an i
NRC inspector found an unattended LHRA key lying atop a step-off pad in front of the PAB pillbox on April 27,1998. The key had been inadvertently left behind by an HPT
l l
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ ______
'
l l
performing job coverage in the area. The key was immediately secured by the RP staff upon discovery, no inadvertent entries were determined to have occurred, and the event was subsequently discussed with all RPTs. HP management indicated that additional l corrective action to prevent recurrence were being developed, including changing LHRA locks so that each LHRA has a unique lock, and adding a tag to each LHRA key stating requirements and expectations for key and area controls. However, the failure to maintain proper control of the key was considered a violation of Technical Specification 15.6.11, which required that LHRA door and/or gate keys be maintained unaer the administrative control of the shift supervisor, radiation protection manager, or his or her designee (VIO 50-266/98012-02; 50-301/98012-02). Conclusions
The licensee maintained effective controls over high, locked high and very high radiation areas, but did not effectively communicate expectations for controlling these areas or for controlling keys allowing access to these areas in station procedures or training. One violation was identified for failure to properly control a locked high radiation area key as required by Technical Specification R3 RP&C Procedures and Documentation R Health Physics Procedures Several examples of poor procedural guidance were identified this inspection (sections R1.2, R2.1, and R7.1) specific to ALARA planning and HRA/LHRA controls. These examples were similar to others identified earlier this outage (Inspection Report 98008)
relating to RWPs and ALARA job briefings. In some cases, the stated procedural guidance was inconsistent with other procedures and/or with HP management expectations. For example, procedure HP 4.4 (dated March 31,1997), * Restriction of Internal Dose," did not reflect HP management direction for evaluating risk for internal doses or the use of engineering controls. Additionally, direction on when to use HP was not clearly stated in other HP procedure A contributing cause to this problem was a non-systematic approach to developing procedures. According to workers, it was not unusual to develop a unique procedure in response to a specific NRC or station audit finding. For example, procedure NP 4. (dated August 14,1997)," Response to Health Physics Work Practice Violation" was l written to address the specifics for NRC violation no. 50-266/97004-01; 50-301/97004-01 (Section R8.2) regarding two examples of poor control of high radiation area l Additionally, a stable and experienced work staff has resulted in many workers simply performing what they believe to be proper work practices without relying on procedural guidance. Collectively, these practices have resulted in HP instructions being communicated through many administrative and implementing procedures that were not periodically reviewed for completeness or consistency. Thess findings were consistent with findings identified in other departments by the resident inspectors and documented j in inspection report 50-266/301-97020(DRP). As a result of the inspection findings, the resident inspectors initiated an inspection follow up item IFl 50-266/97020-02(RP); 50-l
l l
. _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ _ _ - _ .
1 .
,
301-97020-02(RP) to follow the progress of reviewing and revising station procedures, including the health physics program procedures.
l Station management agreed with the inspectors' conclusions and had identified similar examples in other, non-HP procedures. Although some individual problems have been corrected, a concerted r pproach to revise all station procedures was ongoing. Specific to HP, the department head stated to the inspectors that this effort would begin following the Unit 1 outage and was expected to continue for the next two years, with a goal of reviewing 12-15 procedures per mont R7 Quality Assurance in RP&C activities R Radiation Protection Program Audit The inspectors reviewed the results of an audit (Number A-P-98-03 ) of the HP program I conducted from March 24 - April 3,1998. The audit included a contractor technical specialist in radioactive waste and transportation. The audit scope included the 3 following: Radiation monitoring; RWPs; waste disposal; dosimetry; respiratory {
protection; instrument calibration and radiological environmental monitorin j The audit concluded that the health physics program was marginally effective, but improving. Fourteen quality condition reports were initiated as a result of the audit identified deficiencies. The inspectors concluded that many of the condition reports were the result of procedure deficiencies. Deficiencies included procedures that were cumbersome, did not reference forms, were conflicting with other procedures, or were unclear resulting in different expectations by individuals. In addition, several condition reports were issued regarding deficiencies in documentation. For exarnple, required data on a form was not completely filled out and holes punched in a form resulted in missing data. These documentation deficiencies indicated a lack of attention to detai Discussions with the HP manager revealed that the condition reports had been assigned to individuals with corrective actions being developed for each condition report. In addition, the HP manager indicated that all procedures were to be reviewed within a two year periM. which should result in clearer procedures and expectation R8 Miscellaneous RP&C lssues R8.1 Transportation of Radioactive Material Insoection Scoce (IP 86750)
The inspectors reviewed the radioactive material transportation program, including a review of applicable procedures and discussion with personnel. The review included training of personnel, transportation of low specific activity (LSA) materials and surface contaminated objects (SCO), and review of shipping documents associated with several shipment _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
i I Observations and Findinas The inspectors verified that plant procedures correctly reference Department of Transportation (DOT) and NRC shipping regulations including the 1995 DOT revision The inspectors notad that the procedures were generally good, although several inconsistencies were identified. In addition, the procedures were written by the individual responsible for the shipping program for his own use and may not provide enough detail for other less knowledgeable individuals to follow. The inconsistencies were brought to the attention of the responsible individual, who acknowledged them and indicated the procedures would be reviewed and revised if deemed necessar Radioactive materials shipped offsite included laundry, dry active waste (DAW), resins, filters, and equipment. From January 1,1998 through May 22,1998, the station made 61 radioactive material shipments. Shipments included LSA II, SCO, and limited quantity shipments. The majority of shipments were Ic.sdry and DAW for segregation and volume reduction. Two shipments of solidified evaporator concentrates were sen'.
directly for disposal at a licensed burial facility. DAW was volume reduced by incineration and then sent to burial by the station's DAW processing contractor. All of the LSA and SCO shipments from the station were shipped by exclusive use vehicle The inspectors reviewed shipping paperwork for the following shipments 9814,9825, 9832,9853, and 9855. Shipping papers were complete and contained the proper information regarding waste classification, reportable quantity, physical and chemical form, volume, weight, total activity, and transportation index in accordance with DOT and NRC regulations. In addition, the inspectors observed the radiological survey of an incoming laundry shipment. Surveys were performed as required by procedures and regulations, and included direct measurements and smears for removable contamination. Discussions with the technician revealed that the technician was knowledgeable of the procedure for surveying incoming shipment A review of training records for those technicians and individuals involved with the shipment of radioactive material, indicated that workers were trained as hazardous material workers within the required frequency and in accordance with DOT regulation Conclusions The radioactive materlat shipping program was wellimplemented. Personnelinvolved with the shipping program were knowledgeable of regulations and station procedure Shipping paperwork was appropriately completed with ne problems identifie R8.2 (Closed) Violation 50-266/97004-01(DRS): 50-301-97004-01(DRS): An auxiliary operator trainee entered a radiography area in violation of an RWP. The affected worker's access to the RCA was suspended, the events were discussed with the worker's work group, and revisions were made to RWPs and/or procedures. Due to recurring high radiation area boundary violations, a memo was issued to all staff from p! ant management regarding expectations for radiation workers (including control of HRAs) which was later included in a station procedure. In addition, revisions were made
.
.
to NGET lesson plans, and the RCA access point was modified to enhance access and egress and overall monitoring and control by HP personnel. The inspectors verified that these actions had been taken and that there had been no recurrence of HRA boundary violations during the current outage (U1R24). This item is considered close R8.3 (Closed) Violation 50-266/96001-01(DRS): 50-301-96001-01(DRSk Unauthorized individualin a high radiation area. The licensee discussed this event with station HPTs and revised the appropriate HP procedures to include instructions to verify that all personnel have exited a high radiation area when required. The inspectors reviewed these actions and verified that there has been no recu!Tence of this event. This item is considered close X1 Exit Meeting Summary The inspection results were presented to members of licensee management at the conclusion of the inspection on May 22,1998. The licensee acknowledged the findings presente The licensee did not identify any items discussed as proprietar I
<
h I
l i
!
l l
!
.
j
_ -_. ._ _ _ - - - - _ - _ _ - _ - _ __-_____ _ ___ _ __ _ -_________ _ _ --
.
PARTIAL LIST OF PERSONS CONTACTED Lir&nEAR R. Farrell, Manager, Health Physics F. Flentje, Senior Regulation & Compliance Specialist V. Kaminskas, Manager, Regulatory Services & Licensing J. Knorr, Manager, Regulation & Compliance E. Lange, Health Physics Supervisor M. Moseman, Health Physics Specialist C. Onesti, Health Physicist L. Pepple, Health Physics Supervisor M. Reddemann, Plant Manager A. Reff, Training Specialist - Health Physics G. Sherwood, Manager, Maintenance Field Services S. Thomas, Health Physics Specialist NBC F. Brown, Senior Resident inspector INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure IP 86750 Solid Radioactive waste Management and Transportation of Radioactive Materials IP 83729 Occupational Exposure During Extended Outages
LIST OF ITEMS OPENED AND CLOSED Ooened 50-266(301)/98012-01 VIO Failure to calibrate emergency plan 0-5 roentgen self reading dosimeters in accordance with the procedure 50-266(301)/98012-02 VIO Faiiure to maintain proper control for a key to locked high radiation areas
'
Closed 50-266(301)/97004-01 VIO Failure to follow a health physics procedure and a standing '
i l RWP resulted in an individual entering an area posted and (
'
controlled for radiographic evolutions 50-266(301)/96001-01 VIO Unauthorized individual in a posted high radiation area
- l ( l
'
J
. _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ - - _ _ _ _ _ _ _
'
.
LIST OF ACRONYMS USED ALARA As-low as-is-reasonably-achievable CFR Code of Federal Regulations DAW Dry Active Waste DOT Department of Transportation DRS Division of Reactor Safety HIC High Integrity Container HP Health Physics HPT Health Physics Technician HRA High Radiation Area LHRA Locke High Radiation Area LSA Low Specific Activity NGET Nuclear General Employee Training NRC Nuclear Regulatory Commission PAB Primary Auxiliary Building PDR Public Document Room R Roentgen RCA Radiologically Controlled Area RP&C Radiation Protection and Chemistry RTD Resistance Temperature Detectors RWP Radiation Work Permit SCO Surface Contaminated Object SRD Self-Reading Dosimeter VHRA Very High Radiation Area VIO Violation
_ _ _ _ _ _ _ _ _ . _ _ _
_ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ - _ _ _ _ _
~
.
LIST OF DOCUMENTS REVIEWED Condition Report (CR) No. 98-1727, dated April 27,1998, regarding Locked High Radiation Area Key being left unattended outside Filter Storage Pillbo Condition Report (CR) No. 98-1675, dated March 31,1998, EP Inventories do not meet EPMP requirement Emergency Plan Quarterly Checklists, December 1887 and March 199 Quality Assurance Audit Report No. A-P-98-03, Radiation Protection Program ALARA Review No.98-022, dated May 5,1998, "A and B Loop RTD Pipe Support Modification" installation Work Plan No.98-038, dated April 27,1998," Modification of Unit 1 Loop A and B RTD Pipe Supports" Lesson Plan No. LP2715, "49 CFR HAZMAT Training" Training Attendance Report for 49 CFR HAZMAT Training Charts and Graphs of Radioactive Waste Generated, January 1 to May 18,199 Station Procedure No ,
NP 4.2.20 (revs. 3 and 4), * Radiation Work Permit" HP 3.2.3 (rev.16)," Radiation Area and High Radiation Area Posting and Barricading Requirements" HP 2.6 (rev.15),"High Radiation Area and Radioactive Source Key Control" HP 3.2.8 (rev. 7), * Posting Requirements for Areas Affected by Fuel Movement" RP 1C (rev. 37), " Refueling" 01-21 (rev.15), " Mixed Bed (HOH) Demineralized Resin Flush and Recharge,1U1 A(B) and 2U1A(B)"
l 01-20 (revs. 26 and 27), " Resin Transfer Cask and Resin Storage Tank (T-112)" l NP 2.5.5 (rev. 0), "RWP lssuance Instructions" i NP 4.2.2 (rev. 0), " Post-Job ALARA Evaluations" HP 2.17 (rev. 2),"Very High Radiation Area Personnel Access" HP 2.14 (rev. 7), " Containment Key way Personnel Access" NP 4.2.21 (rev. 3), " Standing Radiation Work Permit" HP 4.4 (rev.12), " Restriction of Internal Dose" HP 2.5.4 (rev. 5) " Radiation Work Permit Preparation" NP 4.2.3 (rev. 2), "ALARA Review Procedure" RDW 18.1.1 (rev.1),"10 CFR 61 Sampling Program" HPCAL 1.28 (rev.13), "Self-Reading Dosimeter Response and Drift Check (Calibration)
Procedure" RDW 13.1 (rev. 3)," Receipt of a Type A or Type B Quantity Radioactive Material" RDW 13.11 (rev. 3)," Receipt of Radioactive Material Shipped Via Exclusive Use Vehicles" l
16 .
_ __ ___ -
.
, RDW 15.16 (rev. 0), " Packaging and Shipping of LSA and SCO Material Via an Exclusive Use
-
Vehicle" Radiation Work Permit No i 98-364, dated April 27,1998,"RC Piping Supports, A and B RCP Loop" l 98-387, dated May 8,1998, " Empty and Refill 2U1 A Demineralized Bed / PAB 8', U2 B. !
Evaporator" l
98-0004-2, dated April 1,1998, " Operations Group: Operational Surveil!ance"
, 98-0001-2, dated April 1,1998, " Health Physics Group: Health Physics Coverage, Surveillance
!
and Routine Activities" l
i
.
!
l, h
.
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ - - _ _ _ _ _ _ - _ _ - _ _ - _ _ _