IR 05000293/1987011

Insp Rept 50-293/87-11 on 870210-13.Violation Noted:Failure to Adhere to Station Approved Procedures Including Key Control,Key Audit,Post Airborne Radioactivity Area,Radiation Work Permit & Post & Barricade Contaminated Area Procedures

ML20207S545
Person / Time
Site:	Pilgrim
Issue date:	03/12/1987
From:	Cooper W, Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207S542	List: IR 05000293/1987011 ML20207S541 ML20207S543
References
50-293-87-11, NUDOCS 8703200013
Download: ML20207S545 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-293/87-11 Docket N License N DPR-63 Priority --

Category C Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Power Station Inspection At: Plymouth,-Massachusetts Inspection Conducted: February 10-13, 1987 Inspectors: h R. L. Nimitz, Senior Radiatioh) Specialist

~3 date n\ M Region I (2-L. td d for W. T. Cooper, Jr., Radiation She)1alist, fa da en Region II Approved by: #, 3M2.!f'7

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M. M. Shanbaky, Chief, Facilities 4 adiation ' date Protection Section Inspection Summary: Inspection on February 10-13, 1987 Report Number 50-293/87-11)

Areas Inspectad: Routine, unannounced inspection of Radiological Controls for the outage including: action on previous findings; high radiation area controls; ALARA; in-field radiological control; and posting and labeling. The inspection involved two region based inspector Results: One violation was identified: (failure to adhere to station approved procedures - five examples; failure to adhere to key control procedure; failure to adhere to the key audit procedure; failure to post an airborne radioactivity area; failure to adhere to the radiation work permit procedure; failure to post and barricade a contaminated area in accordance with procedures).

87032 PDR g j $ h$93 PDR _

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DETAILS Individuals Cont' acted Boston Edison Company

• Roberts, Nuclear Operation Manager

• Sowden, Radiological Section Manager

• Gordon, Environmental and Radiological Health Services Group Leader

• Hudson, Chief Operation Engineer USNRC

• J. Lyash, Resident Inspector, Pilgrim

• denotes those individuals attending the exit meeting on February 13, 1987 Purpose of Inspection This inspection was a routine, unannounced radiological controls inspection during the outage. Specific areas reviewed were as follows:

Licensee action on previous inspection findings

ALARA Controls

In-field Radiological Controls:

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. External Exposure Control

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Internal Exposure Control

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Respiratory Protection

Posting, Labeling and Access Control (as appropriate) for:

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Radioactive and Contaminated Material

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Radiation and High Radiation Areas

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Airborne Radioactivity Areas Licensee Action on Previous Inspection Findings 3.1 (Closed) Follow Item (50-293/85-32-20) Licensee to approve procedure for accounta'oility and storage of air sample data. The licensee established and approved procedure SI-RP.1002, " Radiological Survey and Air Sample Data Records," Revision 0 on January 15, 1987. This item is close .2 (Closed) Follow Item (50-293/83-17-03) NRC to review licensee post-accident sampling capabilities. This matter was reviewed during inspection No. 85-27. This item is close ~- _-

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i 3.3 (Closed) Follow Item (50-293/85-32-27) Licensee to provide criteria for shielding of radwaste storage areas. The licensee established procedure 6.9-197, " Operation and Control of Radioactive Material Storage Areas." The procedure provides criteria and guidance for shielding of such areas. This item is close .4 (Closed) Violation (50-293/84-44-02) Personnel did not adhere to radiation work permit requirements. The matter was reviewed during Inspection 85-02 and during this inspection. The licensee implemented corrective actions described in his August 19, 1984 lette This item is close .5 (Closed) Violation (50-293/84-44-03) Personnel did not modify a radiation work permit in accordance with procedure requirement This matter was reviewed during Inspection 85-02 and during this inspection. The licensee implemented the corrective action specified in his August.19, 1984 letter. This item is close .6 (Closed) Violation (50-293/84-44-04) Licensee to establish procedures for use of tele-dosimetry devices. This matter was reviewed during Inspection 85-02 and during this inspection. The licensee revised procedures to address NRC concerns in this are This item is close .7 (Closed) Violation (50-293/84-44-05) Personnel did not adhere to airborne radioactivity survey requirements presented on a radiation work permi The matter was reviewed during inspection No. 85-02 and during this inspection. The licensee _ implemented the corrective

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actions described in his August 19, 1984 letter- This item.is' close . Posting, and Labeling The inspector reviewed the adequacy, effectiveness and implementation of the licensee's posting and labeling (as appropriate) of the following materials and areas:

radioactive and contaminated material

radiation and high radiation areas

airborne radioactivity area This review was with respect to criteria contained in applicable licensee procedures and 10 CFR 2 The evaluation of the licensee's performance was based on inspector tours of controlled areas and independent observations and surveys made by the inspecto Findings Within the scope of this review, the following apparent violal. ions were identified:

(50-293/87-11-01)

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Technical Specification 6.8 requires, in part, that the procedures recommended in Appendix A of Regulatory Guide 1.33 be established and implemente . Procedure 6.1-024, Revision 13, " Radiological Posting of Areas of the Station," requires in section VII E that areas where airborne radioactive concentrations are greater than .21MPC be posted as

" Caution Airborne Radioactivity Area','

Contrary to the above, at about 10 a.m. in February 12, 1987, the sand blasting tent on the Turbine Deck exhibited airborne radioactivity concentrations of .29 MPC and the area was not posted as specified abov NOTE: Airborne Radioactivity concentrations up to 6 MPC had been regularly previously measured in the tent. In addition, the area was required to be posted in accordance with 10 CFR 2 . Procedure 6.1-024, Revision 13, " Radiological Posting of Areas of the Station," requires in part, in section VII E, that areas where loose surface contamination exceeds 1000 dpm/100cm2 be posted with the words " Caution Contaminated Area" and be barricaded so as to show the extent of the affected are Contrary to the above, at about 7 p.m. on February .10, 1986 an area

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on the Refuel Floor around the stored reactor vessel head exhibited . -

loose surface contaminate levels of up to 2000 dpm/100cm2 and the

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areas was not barricaded so as to show the extent of the affected area. In addition,- the posting was inadequate in that personnel could enter the non-barricaded entry point of the area without realizing that the area was contaminate The above matters were brought to the licensee's attention. The areas were subsequently posted as require . High Radiation Area Access Controls The inspector reviewed the adequacy 3 implementation and effectiveness of the High Radiation Area Access Control Program. The review was with respect to criteria contained in applicable procedures, Technical Specification 6.8, " Procedures," and Technical Specification 6.13, "High Radiation Area Access Control."

The evaluation of the licensee's performance in the area was based on: independent inspector observations and radiation surveys, discussions with personnel and review of documentatio _

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Findings Within the scope of this review, the following apparent violations -

wereidentified:(50-293/87-11-01)

Technical Specification 6.8 requires, in part, that the procedures recom-mended in Appendix A of Regulatory Guide 1.33 be established and imple-mente . Procedure 1.3.10, Revision 15, " Key Control," requires in part in section IIIA.7 that the Watch Engineer signify his approval of issuance of a High-High Radiation Area Access Key to an individual by initialing the key log for that issuance. The Watch Engineer will also date and initial that the key has been returne Contrary to the above, on December 15, 1986, January 16, 1987 and January 20, 1987 and at other times, High-High Radiation Area Access keys were issued to an individual and the Watch Engineer did not initial the key log to signify his approval for issuance of the ke . Procedure 6.1-012, Revision 18, " Access to High Radiation Areas", requires that keys controlled by radiation protection personnel be audited at each shift turnove Key audits are to

. be documented on a form specified in the procedur _

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Contrary to the above, on February 3 and 8,1987, -t least one required audit was not performe NOTE: Licensee personnel were unable to locate documenta-tion of the audits and concluded that the audits were not performe Documentation for audits other than the above two, were readily availabl The following additional matters were brought to the licensee's attentio *

A High-High Radiation Area Key authorized users list is located l in the Watch Engineer's Administration Office. The following l was noted relative to this list and controlling procedure:

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Parts of the list were illegible l

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There is no clear guidance regarding qualification of individuals authorized to use the key .

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There is no guidance relative to what action to take >

following identification of a lost High-High Radiation Area Ke ,

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The exact number of ~High"High Radiation Area' Keys is not ,

specified. Reactor Operations and Health Physics personnel differed on the exact number in plac A Operations personnel were, aware of ths correct numbe .- .

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Procedure 6.1-12 provides gu'idance for issuance, control and .-

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audit of 'R' keys. Itnm keys'are used to control access to areas greater than 1 R/tir. The following was noted:

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The form used to dacument audits of the 'R' keys was no consistent with that described in the procedur .,

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No guidance is in place for control and updating of the

'R' key identification lo . In-field Radiological Controls The inspector reviewed the implementation, adequacy and s'?fectiveness of the radiological controls for on going radiological; wor The review was with respect to criteria contained ist appbcableprocedures and regulatory requirement > -

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The following matters were reviewv.d:

establishment, adequacy and implementation of aopropriate procedures for the activities,

adequacy and adherence to Radiation Work Permit's,

external exposure controls,

internal exposure controls

respiratory protection

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radiological surveys

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The evaluation of the licensee's performance in this area was

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based on:

observation of on going work activities (e.g. Turaine Work and Reactor Refueling Operations)

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discussions with personnel

review of documentation

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inspector performance of independent radiation surveys Findings

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Within the scope of this review, the following apparent violation was

. identified:(50-293/87-11-01)

. Technical Specification 6.8 requires, in part, that the procedures recommended in Appendix A of Regulatory Guide 1.33 be established and implemente Procedure 6.1-022, Revision 21, " Issue, Use, and Termination of Radiation Work Permits (RWPs)," requires in part in Section E.7 that individuals exiting'an RWP area note his/her time out and pocket dosimeter reading when they exit the are Centrary to the above, at or about 7:00 p.m.'on February 11, 1987 three individuals did.not properly sign ou Two individuals did not note their time out while the third individual did not note either his time out or pocket dosimeter reading. The individuals had left the are . ALARA

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'The inspector reviewed the adequacy na'd implementation of the licensee's

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ALARA Program. The review was with respect to criteria contained in the licensee's Radiation Protection Manual and applicable NRC guidanc The evaluation of the licensee's performance was based on observation of on going work activities, discussions with personnel and review of documentatio Findings Within the scope of the review, the following was noted:

The licensee has established and implemented 18 procedures in this are _

The procedures cover the following matters:

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Management Policy

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Goal Setting

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ALARA Audits

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Cost benefit analyses

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ALARA Committee guidance

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Dose reduction methods

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ALARA suggestions by employees ,

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' ALARA guidance for health physics technician

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Temporary shielding

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Engineering control

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On going job review

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daily exposure planning / tracking

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Exposure trending j

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ALARA guidance for health physics technician

Inspector review of the implementation of selected procedures found procedures to be implemented.-

The licensee is implementing methods to reduce personnel exposure during the outage activities as follows:

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The licensee has purchased and will install control rod drive flange shields. Use of these shields at other facilities has resulted in about a 70% reduction in exposure received by u personnel working under the reactor vessel. The licensee 0; y estimated that about 204 person-rem will be saved by use of, the i

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shields. This is considered a good licensee initiativ The licensee has constructed an under vessel mock-up. The ' '

L mock-up will be used to train personnel performing under. vessel

work (e.g. control rod drive removal, LPRM work).

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The licensee will perform hands-on training for personnel

,, performing CRD disassembly and cleanin ,

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The licensee is using prefabricated buildings and HEPA ventilation systems to reduce airborne radioactivity exoosure of personne Within the scope of this review, the following matter needing licensee attention was identified:

The ALARA program is not yet effectively integrated into the RWP process. Adequate administrative controls are not yet in

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place to ensure appropriate modification of the RWP and ALARA

> controls following work scope or job methodology change. The interface is described by a memorandu L

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9 Exit Meeting The inspector met with licensee personnel (denoted in Section 1) at the conclusion of this inspection on February 13, 1987. The inspector summarized the purpose scope and finding of the inspection. Apparent violations were brought to plant managements attentio No written material was provided to the license . . . . - . - . . . . . _ - _

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