IR 05000293/1982027
| ML20028F117 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/04/1983 |
| From: | Mcbride M, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20028F109 | List: |
| References | |
| 50-293-82-27, NUDOCS 8301310164 | |
| Download: ML20028F117 (7) | |
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U. S. NUCLEAR REGULATORY COMMISSION I
REGION I
Report No.
50-293/82-27 Docket No.
50-293 License No.
DPR-35 Priority Category C
Licensee:
Boston Edison Company 800 Boylston Street Boston, MA 02199 Facility Name:
Pilgrim Nuclear Power Station Inspection At:
Plymouth, Massachusetts Inspection Conducted:
September 27 to October 1, 1982 Inspectors: /
'H. McBride; Radiation Specialist
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'date Approved by: M ult:Adi/'
/
d M. Shanbaky, Chief, Fac(11 ties
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Radiation Protection Section Inspection Summary:
Inspection on September 27 to October 1, 1982 (Report No. 50-293/82-27)
Areas Inspected:
Routine, unannounced safety inspection of the Radiation Protection Program by a region-based inspector.
Inspection areas included:
licensee action on previous inspection findings and licensee evaluation of a recent radiological incident associated with the decontamination of the Con-centrator Room. The inspection involved 32 inspector-hours onsite.
Results: While no violations were identified, an apparent weakness in the
health physics management control, as indicated by lack of adequate response to I
the September 10, 1982, Concentrator Room incident, was identified (Detail 3).
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Fifteen outstanding items were reviewed by the inspector, fourteen of which are now considered closed (Detail 2).
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8301310164 830118 PDR ADOCK 05000293 O
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DETAILS 1.
Persons Contacted
- J.
Ballentine, Vice President, Operations
- P. Mastrangelo, Chief Operating Engineer
- C. Mathis, Station Manager
- D. Sanford, Nuclear Training Manger
- P. Smith, Chief Technical Engineer
- T. Thurston, Licensing
- A. Trudeau, Chief Radiological Engineer
- E. Ziemianski, Management Services Group Leader NRC
- H. Eichenholz, Resident Inspector
- Denotes those persons present at the exit meeting on October 1,1982.
Other persons were also contacted.
2.
Licensee Action on Previous Inspection Findings 2.1 (Closed) Inspector Follow-up Item (293/79-19-01 and 03).
Review licensee training and audits in the area of radwaste training to be done by licen-see in mid-1980. The radwaste training issue was recently addressed in Inspection Report 50-293/82-06 and a Notice of Deviation was issued.
In a response letter, dated July 19, 1982, the licensee stated that the rad-waste training program would be implemented by January 1, 1983. This matter will be reviewed during the follow-up on the Notice of Deviation (82-06-01).
2.2 (Closed) Inspector Follow-up Item (293/80-05-14) Formalize ALARA program by June 1, 1980. The licensee has implemented a formal ALARA program, including ALARA reviews by ALARA technicians.
Recently, the ALARA program was substantially revised, eliminating the ALARA technician jobs. The licensee stated at the Exit Interview that the revised ALARA program will be formally documented prior to the 1983 refueling outage. This will be reviewed in a subsequent inspection (293/82-27-01).
2.3 (Closed) Inspector Follow-up Item (293/81-21-01) Review Regulatory Guide 8.27 radiation worker training.
The licensee stated that training cri-teria in Regulatory Guide 8.27 were under review and not formally accepted by corporate management.
The licensee plans to have a revised radiation training program developed by 1984 and implemented by 1985.
The licensee made the following training commitments at the Exit Interview:
1.
The licensee will revise the General Employee Training (GET) presi.n-tation to clarify the status of ALARA Technicians by October 1,1982.
The licensee is no longer using ALARA technicians, as described in the GET video tape. To insure that changes in plant work practices are reflected in GET, the licensee will develop a link between the Training and Radiation Protection Department.
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2.
The licensee will evaluate worker ability to read and understand Radiation Work Permits in GET. These evaluations will begin by October 31, 1982.
3.
The licensee will evaluate and form a Corporate policy on Regulatory Guide 8.27.
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The licensee will require 80% passing grade for GET by.0ctober 31, 1982.
The implementation of these commitments will be reviewed in a future inspection (293/82-27-02).
2.4 (Closed) Noncompliance (293/81-21-02):
Failure to post a Notice of Violation as required by 10 CFR 19.11.
Posted information at selected work locations was reviewed and found consistent with the requirements of 10 CFR 19.11.
2.5 (Closed) Inspector Follow-up Item (293/81-21-03):
Formalize ALARA pro-gram.
See item 293/80-05-14.
2.6 (Closed) Inspector Follow-up Item (293/81-21-04):
Formalize bioassay program.
Licensee procedures cover whole body counting and techniques for collecting fecal and urine. samples.
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2.7 (Closed) Inspector Follow-up Item (293/81-21-06):
Review health physics staff retraining program. The licensee stated that health physics staff retraining requirements and schedule were determined by health physics management and not contained in station procedures.
Licensee health physics staff completed an 80-hr course in basic health physics in 1981 (repeated for new staff in 1982).
2.8 (Closed) Inspector Follow-up Item (293/81-21-09):
Review modified drawings made after walkdown of condensate demineralizer system piping.
Piping diaghram M-214, revision E4 reflects the system changes noted during a walk-down on September 10, 1981.
2.9 (Closed) Inspector Follow-up Item (293/82-KP-01):
Review licensee Radi-ation Deficiency Report 82-1-30-2, RWP 82-42, and RWP 82-273. These documents were reviewed.
No inadequacies were identified.
2.10 t' Closed) Noncompliance (293/82-01-01):
Failure to brief workers on storage of resin in SBGT room. The licensee reponse letter, dated April 15, 1982, stated that in this instance information on changing radio-logical conditions (i.e. storage of radioactive resin in a barrel) was not properly communicated between work shifts by an ALARA technician. The licensee stated that all technicians had been instructed to communicate changing radiological conditions to personnel on the next shift. The licensee relies to a large extent on verbal communication between health physics technicians to transmit information on radiological changes between work shifts.
Interviews with licensee health physics personnel and a review of appropriate records indicated that the corrective action
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was satisfactory and that the incident was isolated.
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2.11 (Closed) Inspector Follow-up Item (293/82-14-02):
Review use of ICRP-2 methodology in bioassay program. The licensee has a Canberra computer program which can generate internal dose estimates based on ICRP-2 methods.
Estimates of MPC-hr exposures from whole body count data are derived from manual calculations. The MPC-hr calculations connnected with the September 10, 1982 concentrator room incident were reviewed and found acceptable (paragraph 3).
2.12 (Closed) Noncompliance (293/82-16-05):
Failure to adequately control access to the TIP high radiation area.
Inspection Report 293/82-16 stated that the health physics technician assigned to control access to the TIP area had fallen asleep. The licensee response letter dated August 6, 1982, stated that the use of prescribed medication by a health physics technician contributed to this incident. The licensee subsequently implemented an employee medication screening program.
Interviews with medical department personnel and plant workers confirmed that this program was being actively implemented.
2.13 (Closed) Inspector Follow-up Item (293/82-20-01): Review circumstances around initial identification of spent resin contamination of ventilation ducts.
Licensee documents state that resin contamination in ventilation duct work has been known for many years and that one or more leaking vent valves in the condensate demineralizer system was the suspected resin source.
Prior to the discovery of radioactive resin on plant roofs on June 11, 1982, large quantities of resin were discovered in the A and B Stand-by Gas Treatment Filter units in January, 1982. A pathway for resin travel from the condensate demineralizers through a vent gas scrubber to the SBGT system was documented in March, 1982. However, the path to the Reactor Building vent was not suspected until resin was detected outside the plant buildings in June. The licensee believes that numerous back-washes of demineralizer beds during ascension to power after the 1981-82 refueling outage probably hastened resin migration through the duct work.
2.14 (0 pen) Inspector Follow-up Item (293/82-20-02) Review licensee implemen-tation of Confirmatory Action Letter, CAL-82-19.
Licensee implementation of ccrrective action documented in their response letter to Region I, dated July 15, 1982 was reviewed. A small amount of additional resin (several cubic inches) was found in the TIP room plenum during routine inspections of the ventilation system in September, 1982. The licensee stated that no additional resin has been observed in the Reactor Building vent plenum since June. At the time of the inspection the licensee had reduced the frequency of visual ventilation system inspections from daily to monthly. A schedule for routine inspections of the contaminated ventilation exhaust system had not been finalized. The licensee expects to formally implement periodic ventilation system visual inspections in the near future.
The results of these checks will be reviewed in a future inspection.
3.
Concentrator Room Decontamination Incident On September 10, 1982 at approximately 1600, an improperly installed portable ventilation unit caused the release of airborne radioactivity to
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4 a corridor adjacent to the Concentrator Room on the -1 foot level of the Reactor Building. Airborne activity levels were later estimated to be 22 times the levels in 10 CFR 20 Appendix B, Table I, Column I (MPC) at the ventilation unit exhaust port in the corridor. The ventilation unit had been installed to control Concentrator Room airborne activity during decontamination work.
Sixteen workers were in the corridor during the. increased airborne activity period. The licensee later determined that nine of these individuals sustained uptakes of radioactive material equivalent to 12 to 32 MPC-hr of exposure.
The Concentrator Room is contaminated with highly radioactive, dried sludge generated by leaks in sludge transfer piping. The sludge has reached a depth of seieral feet in the room and radiation fields of more than 100 R/hr are expected in interior sections of the room. Beta radi-ation levels are approximately three times room gamma levels. No alpha activity has been detected in the room.
Licensee ALARA planning for the decontamination work was reviewed and four J acceptable.
The intake port for the Concentrator Room portable ventilation unit on September 10, 1982 was located inside the room, in airborne activity levels of 67 MPC. The airborne activity consisted primarily of Co-60 with small amounts of Cs-137 and Mn-54. The licensee stated that a previous analysis of room sludge showed only trace amounts of Sr-90 (less than 1%
of Co-60 levels) and transuranics (0.01%of Co-60 levels).
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The corridor airborne activity was detected approximately one half hour after job completion, after technicians analyzed corridor air particulate samples. A health physics supervisor was notified of the unexpected corridor airborne activity and instructed three technicians to take nasal smears and whole body counts of as many of the Concentrator Room workers as possible. The supervisor then left the site for the weekend. By this
time (approximately 5 p.m.), many of the workers had also left the site for
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the weekend.
Five of the 16 workers who had signed in on the Concentrator Room decontam-
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l ination Radiation Work Permit No. 82-1360 were given whole body counts that evening (September 10). All showed indications of uptake of radio-l active material, ranging from 2 to 12% of the maximum permissible organ burden (MP08).
Contrary to procedural guidance no attempt was made to determine what fraction of the whole body count activities corresponded to external contamination.
Further, Procedure 6.2-161, " Administration of the Internal Exposure Monitoring Program," Revision 2, August 26, 1982, states that the Chief Radiological Engineer or his alternate shall be notified of whole body count results in excess of 10% MPOB. However, no attempt was made to contact the health physics supervisory personnel Friday evening, after the
whole body count of one individual indicated an uptake of 11 to 12% MP08.
The licensee performed additional whole body counts on the affected individuals during the week following the incident.
No uptake greater than 32 MPC-hr was detected.
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The licensee stated that the need to determine the external contamination component of whole body count activity was discussed with the three health physics technicians who conducted the Friday evening whole body counts on the following Monday.
The licensee stated that no action was taken, prior to the inspection, to identify the reasons why the health physics tech-nicians did not promptly notify health physics management of the possible 12% MP08 uptake.
At the time of the inspection, the licensee was not able to identify the exact nature of the failure in the ventilation unit.
Interviews with licensee personnel during the inspection indicated that a unit with no filters may have been inadvertently installed for the j,b.
The licensee stated that before decontamination work was resumed in the Concentrator Room, the three health physics technicians covering the job had been orally instructed to:1) check the differential pressure gauge on the portable ventilation unit during use and, 2) verify build-up of radioactive materials on the unit filters. Two of the three technicians who were interviewed during the inspection confirmed these instructions. No other carrective measures were taken.
In response to these inspection findings, the licensee reevaluated the incident and made the following commitments at the Exit Interview:
1.
A procedure for use and control of portable ventilation units will be developed.
Procedure 6.5 - 297, Use and Control of Portable Ventilation Units, Revision 0 was issued on October 5, 1982 and reviewed by Regional personnel.
2.
Notification criteria for whole body count results will be lowered to 5% MPOB and technicians will be required to record supervisor notifi-cation on the whole bcdy count data sheets. The licensee stated that lowering the notification threshold will help insure that significant uptakes are properly reported.
The licensee issued a memorandum to all Health Physics Technicians on September 30, 1982, informing them of the procedure change and reaffirming that off-shift notification of health physics supervisor personnel must be made. The formal procedure revisions will be reviewed during a subsequent inspection.
(293/82-27-03)
A corporate audit of th's incident was conducted in response to the inspection findings (Significant Incident Review Team Report, dated October 14,1982). A number of inadequacies were identified in this audit involving health physics management followup to the incident.
Licensee corrective actions in response to these audit findings will be reviewed in a subsequent inspection. (293/82-27-04)
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4.
Exit Interview The inspector met with licensee representatives denoted in para-graph 1 at the conclusion of the inspection on October 1, 1982. The purpose, scope, and findings of the inspection were-summarized at that time.
The Concentrator Room incident on September 10, 1982, and the apparent lack of complete followup were highlighted during the meeting.
The licensee made the following commitments relative to the items discussed:
- Radiation Worker Training commitments as identified in paragraph 2.3;
- ALARA Program development as identified in paragraph 2.2; and
- Concentrator Room corrective actions as identified in paragraph 3.
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