IR 05000293/1986044
| ML20210A963 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/21/1987 |
| From: | Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20210A927 | List: |
| References | |
| 50-293-86-44, NUDOCS 8702090048 | |
| Download: ML20210A963 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-293/86-44 Docket No.
50-293 License No.
DPR-63 Priority Category C
Licensee:
Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name:
Pilgrim Nuclear Power Station Inspection At:
Plymouth, Massachusetts I
Inspection Conducted: December 17-19, 1986 R L. N M l
11; 67 Inspectors:
R. L. Nimitz, Senior Radiation J
date Specialist
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Approved by:
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M. M. Shanbaky, Chief Facilities Radiation Protection Section Inspection Summary:
Inspection on December 17-19, 1986 (Report No. 50-293/86-44)
Areas Inspected:
Routine, unannounced inspection of licensee Radiological f
Controls for the outage including: action on previous findings; organization
and staffing; planning and preparation; ALARA; external exposure controls; internal exposure controls, personnel contamination controls, and vehicle contamination checks, t
Results: One violation was identified (failure to perform radiological survey
of vehicles leaving the site, paragraph 7.) A need to improve ALARA controls for work and improve high radiation area access controls was identified.
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DETAILS 1.
Individuals Contacted
- R. Sherry, Chief Maintenance Engineer
- J. Seerey, Active Station Manager
- A. Morisi, Assistant Director Outage Management
- C, Gannon, Chief Radiological Engineer
- E. Gordon, Environmental and Radiological Health Services Group Leader
- Denotes those individuals attending the exit meeting on December 19, 1986.
The inspector also contacted other Itcensee personnel.
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Purpose The purpose of this routine, unannounced Radiological Controls inspection was to review the following program elements:
licensee action on previous findings
organization and staffing
external exposure control
internal exposure control
TLD reader problems
Vehicle contamination checks 3.
Licensee Action on Previous Findings 3.1 (Closed) Follow Item (50-293/85-32-07)
Licensee to define " extremities" in procedures.
The licensee defined extremities in procedure SI-RP.2410, Issue, Control, Collection and Processing of Special Dosimetry.
3.2 (Closed) FollowItem(50-293/85-32-18)
Licensee to develop a summary / matrix for routine surveys.
The licensee established and implemented procedure $1-RP 3001, Radio-logical Protection Surveillance Program. The procedure includes a routine survey summary / matrix.
3.3 (Closed) Violation (50-293/85-32-01)
Licensee failed to perform functional test of radiation monitors.
The Itcensee established and implemented the corrective actions described in his January 28, 1986 letter to NRC Region F
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3.4 (Closed) Follow Item (50-293/85-22-11)
Licensee to upgrade and implement procedures for determination of skin dose. The licensee revised procedure SI-RP.2403, Skin Dose Assessment Due to Contamination, to provide skin dose conversion factors and limitations of survey meters used for skin dose assess-ment.
3.5 (Closed) Follow Item (50-293/85-13-09)
Licensee to provide guidance for conducting thyroid monitoring.
The licensee established and implemented procedure 6.1-161, Administration of the Internal Exposure Monitoring Program. The procedure contains the rational and criteria for conducting thyroid monitoring.
3.6 (Closed) Follow Item (50-293/85-22-08)
Licensee to upgrade radiological control personnel qualification process to provide a training policy; update procedure T-20 qual-ification checklist; and define minimum experience of personnel.
The licensee established and implemented a training policy and updated procedure T-20 check list. Minimum experience requirements of per sonnel was reviewed during inspection 50-293/86-16. (See Follow Item 50-293/86-19-03)
3.7 (Closed) Follow Item (50-293/85-32-11)
Licensee to approve revised high radiation area access control procedures.
The licensee approved procedure 6.1-12, Access to High Radiation Area, and procedure 6.1-022 Issue, Use and Termination of Radiation Work Permits. The former procedure describes key control l
requirements while the latter procedures describes minimum radio-
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logical controls requirements for entry.
3.8 (Closed) FollowItem(50-293/85-32-14)
Licensee to evaluate controls in place to ensure off-site facilities (e.g.dosimetryprocessinglaboratories)receiveproperQAreviewand acceptance.
The licensee s evaluation indicated that adequate con-trols were in place to ensure QA oversight of off-site facilities via the QA Approved Supplies List Process.
3.9 (Closed) Follow Item (50-293/85-32-22)
Licensee to revise alpha smear counting procedure to provide for lower minimum detectable activity (MDA).
The licensee revised pro-cedure 6.3-110, Contamination Survey Techniques, to provide for use of a scintillation detector. These detectors were found to have an MDA of about 3 disintegrations per minute (dpm) for a one minute count, 3.10 (Closed) Follow Item (50-293/85-32-32)
Licensee to establish and implement a procedure for issuance and control of portable radiation survey instrumentation.
The licensee established, approved and implemented procedure 6.6-114. Issuance and Control of Radiation Protection Survey Instruments.
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3.11 (Closed) Follow Item (50-293/eb-02-02)
l Licensee to establish guidance to limit / control exposures to critical i
body parts for personnel working in non-uniform radiation fields, i
The licensee revised procedure 6.1-022, Issue, Use and Termination of Radiation Work Permits, to include guidance for limiting / controlling
exposure to the critical body parts j
4.
Planning and Preparation j
The inspector reviewed the Radiological Controls planning and preparation for the outage.
The following matters were reviewed and discussed with
cognizant licensee personnel:
organization and staffing i
adequacy of supervisory oversight of contractor radiological
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controls personnel to be used to augment the staff
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involvement of radiological controls group and knowledge of work to
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be performed during the outage
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interface and communication of radiological controls personnel with contractor work forces
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special training, including use of mock-ups
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increased supplies including clothing, shielding, radiation survey i
instrumentation and airborne radioactivity sampling equipment
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planned usage of engineering controls to minimize airborne j
radioactivity, j
Findings
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Within the scope of this review, no violations were identified. The
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l following items were noted
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The Itcensee has performed a person-loading study and augmented the
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staff based on planned outage work. The ALARA group was noted to
have been increased. About (10) additional contractor ALARA engin-
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i eers/ technicians were hired. About 100 additional contractor radio-
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logical controls technicians were hired to augment the staff.
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ALARA coordinators have been assigned to major work groups to improve
j communication and interface of the radiological controls organiza-
L tion with station work groups.
l The ALARA group is knowledgeable of planned outage work. An ALARA
coordinator interfaces with the planning and scheduling group.
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Special training courses (e.g. CR0 rebutiding) have been established, j
Increased supplies as appropriate, have been ordered.
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Additional portable HEPA ventilation equipment has been ordered.
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Within the scope of the review, the following items for improvement'were identified:
A clearly described Augmented Radiological Controls Outage.Organt-zation chart was not established and distributed to station and contractor work groups. Consequently, it was not clear which individuals were re- -
sponsible for radiological controls / matters for various plant areas. The lack of a clearly described organization chart which depicts separate supervisory responsibilities could result in work group / radiological controls communication problems.
Thelicenseeinitiatedactiontoestablishaclearlycescribedkugmented Radiological Chart and distribute it.
- Back-shift oversight of all station outage radiological controls activities was to be performeo by a technician temporarily upgraded to a supervisor. The inspector considered the span of control of this individual to be large and the supervisory oversight of' work activities to need improvement.
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s Licensee personnel indicated limited work activities were currently being performed during back-shift.
In the event additional work activities were to be performed on back-shifts, the supervisory
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oversight would be upgraded as appropriate.
5.
TLD Reader Problems The inspector reviewed and discussed recent TLD reader problems identified by the licensee.
Background The licensee uses the TLD services of Yankee Atomic Electric Labs (YAEL)
for routine personnel monitoring.
In order to provide prompt processing
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of TL0s during the outage, a TLD reader (Harshaw Model 2271) was brought on site in October 1986. Personnel were trained to operate the reader at that time.
During October and November 1986, 15 faults occurred while reading TL0s.
The faults identified included:
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high or low temperature faults
logic interrupts
data transmission problems
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In some instances, TLD data was lost resulting in the need to perform personnel exposure evaluations to estimate exposure received.
Subsequent licensee review indicated the reader was effected by radio-frequency interference, primarily at about the 152 mega-hertz region.
Licensee Corective Actions The licensee took the following corrective actions:
Exposure evaluations were performed for those individuals whose TLD
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results were affected by the problem. A total of 9 exposure evaluations were performed.
- The TLD reader was moved offsite to an area free of radio-frequency I
interference. No subsequent problems were noted, f~
A note was sent out to INP0 on December 12, 1986 for distribution via its Nuclear Note Pad Network. The note described the problem.
6.
Vehicle Egress Contamination Checks
The inspector reviewed the adequacy, effectiveness and implementation of
licensee corective actions associated with several instances of vehicles l
departing the protected area without receiving proper radiological con-tamination checks. The incidents reviewed and discussed were as follows:
August 20, 1986 - Dump Truck Contents not checked
l November 25, 1986 _ Concrete Truck not checked
December 6, 1986 - Laundry Truck Not checked.
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l The inspector reviewed the events and licensee corrective action with j
respect to 10 CFR Part 2, Appendix C, General Statement of Policy and Procedure for NRC Enforcement Actions.
The Appendix provides for i
non-issuance of a violation if the criteria specified therein are met.
i Findings The inspector review indicate the licensee's correcive actions, relative to the August 20, 1986 event, were not adequate to prevent recurrence.
, s Based on this, the following violation was identified:
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(50-293/86-44-01)
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Technical Specification 6.11, requires that procedures for personnel
radiation protection be prepared and adhered to.
Procedure 6.1-211, r
. Radiological Release of Vehicles / Materials to Offsite, Revision
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t requires, in part, in Section II.B that all items leaving the site be cleared by a qualified member of the Radiological Section prior y
to being allowed through the Security Fence.
Contrary to the above, on November 25, 1986 and December 6, 1986, a concrete truck and laundry truck respectively, were allowed through the Security Fence and subsequently left the site without being cleared by a member of the Radiological Section,
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Radiological Controls The inspector reviewed the adequacy, effectiveness and implementation of Radiological Controls.
The review was with respect to criteria contained in 10 CFR 20 and applicable licensee procedures. The following matters were reviewed:
Adequacy and implementation of Radiation Work Permits issued
Performance and evaluation of appropriate radiation, contamination, and airborne radioactivity surveys to support on going work
ALARA planning and oversight of on going work
Communication
Posting, labeling and access control including high radiation area access control
Provision and use of personnel monitoring devices
Respiratory Protection
Use of engineering controls Findings Within the scope of the review, no violations wre identified.
The following matters needing licensee attention was identified:
Communications between the ALARA Group, work groups and radiation protection personnel needs improvement. Due to inadequate communication regarding the method to be used to cut out a section of pipe on the fuel pcol clean-up system (RWP No 86-3430) personnel were permitted to enter radiation fields up to 100 mr/hr to initiate work but were subsequently requested to terminate work due to confusion over method to be used to cut out the pipe section.
i The licensee indicated work methods (e.g. cutting) that would change radiological conditions would be clearly specified in ALARA reviews. Changes to the work methods would require radiation protection review and possible modification of RWP radiological controls.
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8.
Exit Meeting The inspector met with licensee representatives denoted in Section 1, at the conclusion of the inspection. The inspector summarized the purpose, scope and findings of the inspection.
No written material was provided to the licensee.
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