IR 05000293/1987017
| ML20214P953 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/20/1987 |
| From: | Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214P945 | List: |
| References | |
| 50-293-87-17, NUDOCS 8706040181 | |
| Download: ML20214P953 (19) | |
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U.S. NUCLEAR REGULATdRY COMMISSION
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REGION I
Report No.
50-293/87-17 Docket No.
50-293 License No. DPR-63 Priority Category C
Licensee:
Boston Edison Company
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800 Boylston Street Boston Massachusetts 02199 j
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Facility Name:
Pilgrim Nuclear Power Station Inspection At:
Plymouth Massachusetts Inspection Conducted: March 17-20, 1987 and April 7-10, 1987 Inspectors:
R.L. Q s \\ 2 d iff
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R. L. Nimitz, Senior Radiati'on Specialist date
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Approved by:
M.
.m C
e //[7 i
M. M. Shanbaky, Chief,
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Facilities Radiation Protection Section
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I Inspection Summary:
Inspection on March 17-20, 1987 and April 7-10, 1987 j
(Report No. 50-293/87-171 4"
Areas Inspected:
Special unannounced radiological controls inspection of the i
following areas: circumstances, licensee evaluation, and corrective action following a March 16, 1987 personnel contamination event; extremity monitoring; exposure evaluations; personnel contamination control; radiological goals
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program; exposure reporting; and two instances of personnel exposure to
airborne radioactive material.
l Results: No violations were identified. One unresolved item involving reports of occupational exposure was identified.
Program weaknesses were s
identified in the extremity monitoring program, the exposure evaluation
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i program, and the personnel contamination control program.
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8706040181 870521
PDR ADOCK 05000293 i
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Details
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Individuals Contacted Boston Edison Company j
1)R. G. Bird, Senior Vice-President, Nuclear
1)R. Ledgett, Assistant to Senior Vice-President 1)A.L. Oxsen, Vice-President, Nuclear
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1)K.P. Roberts, Nuclear Operations Manager i
i 1)S. Stowe, Legal Counsel i
1)T. Sowdon, Radiological Section Manager i
1)2)G. Gannon, Chief Radiological Engineer 1)2)J. Mattia, QA Group Leader I
2)N. Brosse, Acting Nuclear Operations Manager 2)E. Gordon, Environmental and Radiological Health Services Group Leader l
USNRC i
- J. Lyash, Resident Inspector, Pilgrim Station M. McBride, Senior Resident Inspector, Pilgrim Station L. Plisco, Senior Resident Inspector, Susquehanna Station
1) Denotes those individuals attending the exit meeting on March 20, 1987
2) Denotes those individuals attending the exit meeting on April 10, 1987
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i The inspector also contacted other licensee personnel, including contrac-tor personnel, during the inspection.
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2.
Purpose of Inspection
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The purpose of this special unannounced Radiological Controls Inspection j
was to review the following matters:
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licensee action on previous findings
circumstances, licensee evaluation and corrective action for the e
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March 16, 1987 personnel skin contaminatior event Extremity monitoring
Exposure Evaluation Reports
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Radiological Goals Program
Personnel Exposure Report
Additional items
3.0 Licensee Action on Previous Findings
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3.1 (0 pen) Inspector Followup Item (50-293/86-19-06).
Licensee to
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I address five dosimetry concerns.
The items a e as follows:
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a.
completion of dosimetry procedure revisions and implerr.entatione-b.
complete development and implementation of new dosimetry training program c.
complete perunnel dosimetry staffing d.
complete resolution of outstanding dosimetry technical issues i
e.
complete arrangements to perform offsite irradiatior. of TLD dosimeters for quality assurance purposes.
The licensee's January 22, 1987 letter to NRC indicated the five items were scheduled to be completed by March 31, 1987.
Within the scope of the review, the following was noted:
i Item a (open) Procedure revisions were not complete
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Item b (open) The Training Program for procedure revisions not
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implemented.
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(Note:
The licensee did provide training for the current procedure revisions).
Item c (open) One position (dosimetry assistant) remair,s open i
Item d (open)
Issues not fully resolved (e.g. beta correction factor for TLDs).
j Item e (open) Licensee did obtain offsite irradiation of his TLDs for QA l
purposes. Some QA findings needing resolution were ioentified.
NOTE: Although action to resolve these issues was in progress, the
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March 31, 1987 date provided to the NRC was not met due, in part, to a i
continuing lack of management oversight and weaknesses in the licensee's
sytem for task followup and accountability.
I 3.2 (0 pen) Inspection Follow-up Item (50-293/85-?2-12)
Licensee to evaluate air sample analyses procedures and the accept-ability of the filter loading correction for sample analyses.
The licensee's evaluation appears only to address filter self-absorption
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i and not absorption through dust loading.
The licensee is using a j
self-absorption factor of 1.5 based on a vorse case situation.
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inspector was not certain that the factor represented a worse case situation for the filter media used and included absorption of alpha particles due to dust loading of the filter.
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3.3 (0 pen)
Inspector Follow-up Item (50-293/85-32,09),
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The licensee indicated he would evaluate the beta correction factor for his TLD dosimeter and evaluate the need to correct personnel exposure results. The licensee evaluated the beta correction j
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factor and did not identify a need to correct individual TLD readings.
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However, the evaluation in this area was not complete because of an
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identified problem relating to summing the exposure for individuals who wore more than one TLD in a quarter to obtain the cummulative
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exposure for the individual. The exposures were, however, low.
The licensee was unable to identify what action had been taken on this matter. This item remains open and reflects lack of attention to technical details.
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3.4 (0 pen)
Inspector Follow-up Item (50-293/85-32-21)
Licensee indicated he would evaluate the acceptability of using friskers to perform clean area smear surveys.
The licensee indicated this matter was closed. However, it was not apparent that all recommendations contained in the licensee's evaluation were imple-mented. The close-out package provided the inspector, did not provide clear information or basis as to the minimum detectable activity for counting clean area smears in an area with a background of 300 counts per minute on a frisker.
4.0 Personnel Contamination Event 4.1 General On March 16, 1987 a contractor employee assisting in the cutting of Drytubes was contaminated by a particle of contamination on the 117'
elevation of the Refueling Floor.
The inspector reviewed the following aspects related to the event:
circumstances a
immediate and long term corrective action
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dose evaluations a
Radiological Controls for the work including Personnel
Contamination Control / Monitoring Radiological Occurrence Reports.
- The review was with respect to applicable regulatory requirements and licensee procedures.
The evaluation of the licensee's performance in the area was based on:
discussions with cognizant personnel including the involved
worker observation of the Refueling Floor and Refueling Bridge
Review of Documentation.
a 4.2 Circumstances and Description of Event On February 25, 1987, the licensee issued Radiation Work Permit (RWP) No.87-948, " Exchange 12 SRM/IRM Drytubes 8 LPRM Detectors and 20 CRBs."
During the period February 25, 1987 through 12 noon on March 16, 1987, 8 Drytubes were cut. No unusual radiological conditions were encoun-tered during the work. The personnel contamination was identified at 4:00 p.m. on March 16, 1987 subsequent to the cutting of the 9th Drytub _. -
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During the cutting operations, six individuals were located on the Refueling Bridge. Each had an assigned task. The individual who was contaminated (Individual A) was responsible for movement of the underwater camera used for monitoring the cutting operations.
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individual was signed in on RWP No.87-948 from 1:30 p.m. to 3:50 p.m. on March 16, 1987.
During the cutting operation, the individual repeatedly raised and lowered the camera by pulling contaminated cables out of the water.
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As a result of the activity it appears that the hot particle was transferred to the individual's protective clothing and subsequently transferred to his skin either through penetration of the coveralls or transfer to his skin during removal of his protective clothing.
This is estimated to have occurred at about 3:40 p.m.
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During the individual's exit from the Main Access Control Point, the Whole Body Frisker alarmed at about 4:00 p.m.
Subsequent contamination surveys identified a speck of contamination measuring 1 mR/hr gamma and 55 mrad /hr beta on contact as measured
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by a R0-2 ion chamber under the right arm.
The individual was immediately showered and the particle was not recovered.
The licensee subsequently estimated the speck to be about 1 uCi of cobalt-60.
4.3 Corrective Actions
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Following identification of the particle on Individual A, the licen-see was unable to readily determine how the individual became con-
taminated.
Consequently, the licensee took a number of actions to limit further personnel exposure until the source could be found.
The following actions were taken:
I 4.3.1 Immediate Actions Taken
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All work on the Refuel Floor 117' elevation was suspended
immediately.
All personnel were prohibited from working in laundered
protective clothing.
Personnel were permitted to wear only new protective cloth-
ing or laundered protective clothing that was hand-frisked by health physics technicians.
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Because the licensee did not have any new rubber gloves,
all laundered rubber gloves were hand frisked by health physics personnel prior to distribution to workers.
The flow of personnel traffic from the process buildings
was restricted to ensure personnel exited the building via the Main Health Physics Access Control Point after using the stand-up whole body friskers.
Guards were placed at other access control points to pre-
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vent personnel from leaving the process buildings except via the Main Health Physics Access Control point.
A comprehensive survey of all process buildings was initi-
ated for the purpose of identifying additional particles.
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Investigatory surveys were conducted of the Refuel Bridge
to identify the presence of other particles.
The licensee placed in-service other whole-body friskers.
- One was placed on the 91' elevation of the Reactor Build-ing.
Personnel exiting the Refueling Floor were required to use the new frisker.
The licensee restricted the individual (Individual A) from
working in radiation areas.
The licensee initiated a dose evaluation for the indivi-
dual.
4.3.2 Long Term Actions Taken The licensee dispatched an individual to his laundry vendor
(March 17, 1987). The individual performed independent radioactive source checks of the vendor's laundry monitor.
All laundered protective clothing to be used by personnel
will continue to be hand-frisked until the licensee has evaluated the acceptability of his laundry vendor's monitoring program.
The revised traffic pattern for exiting the process build-
ing will be maintained until whole-body friskers are in-stalled at the other access control points.
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The licensee did not allow work on the Refueling Floor
until he evaluated the event and implemented the following revisions to RWP No.97-948.
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The licensee incorporated additional guidance onto the RWP
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regarding contamination control for material coming out of the water.
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The RWP was revised to require two pair of coveralls while working on the Refueling Bridge.
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The RWP was revised to require special adhesive tape contamination surveys of the Refueling Bridge.
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The RWP was revised to require escort of personnel working on RWP No.87-948 to the whole body frisker on 91' foot elevation.
The RWP was revised to provide additional guidance for
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changing the blade on the Drytube Cutting Tool.
The licensee initiated action to revise the routine
surveillance program to address performanca of " sticky tape" smear surveys in areas which have a potential for particle contamination.
Based on the above, the licensee appears to have taken accept-able action to address the immediate radiological health and safety consequences of this problem.
The licensee's long term corrective measures in this area will be reviewed during a subsequent inspection (50-293/87-17-01).
4.4 Skin Dose Evaluation of Individual A The inspector reviewed the licensee's dose estimate and dose deter-mination methodology.
The individual's total whole body dose for the first quarter of 1987 was 190 nillirem. This includes the 5 millfrem received on March 16, 1987. Surveys of equipment and rags used on the Refuel Bridge did not indicate the need for extremity dosimetry.
The extremity dose received for the quarter was the same as the whole body dose.
Because the particle produced a localized dose to the skin, the licensee focused efforts on determining the maximum dose to a 1 cm2 area of the skin caused by radiation from the particle.
The licensee postulated a number of scenarios whereby the individual may have been contaminated.
Each scenario was evaluated for reason-ableness relati e to available facts.
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the particle was introduced onto the skin due to cross-contamination when the worker was removing camera cables at about 3:40 p.m. (on March 16, 1987).
(See General Description - Section 4.3) As a result, the licensee believes, the worker received a skin dose of about 2.8 rem to 1 cm2 of skin.
(Note: The regulatory limit for f
exposure to the skin is 7.5 rem.)
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The inspector's independent evaluation of the event including a time and motion study indicated that the scenario selected, the dose
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-determination methodology used, and the skin dose estimated (2.8 rem)
were reasonable.
No violations were identified.
4.5 Radiological Controls Including personnel Contamination
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Control / Monitoring l
l The inspector reviewed the adequacy and effectiveness of radiological
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controls and contamination control for personnel working on the l
Refueling Bridge.
Findings Inspector review indicated the following:
General area contamination levels on the refueling bridge were
low.
Surveys of cables and rope on the deck of the Refuel Bridge
indicated generally low levels of contamination.
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Material brought out of the water and placed on the bridge was a
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surveyed with open window ion chambers.
A shielded frisking booth was located near the Refuel Floor con-
trol point (elevation 91' Reactor Building). The frisker had a background count rate of about 200-300 counts per minute.
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was considered adequate to identify significant personnel con-tamination.
Upon leaving the refueling control floor, personnel leave
the process building by exiting the main health physics control point and pass through the whole body friskers or exit another access control point after having performed a second whole body frisk with a hand held frisker.
The hand held frisker generally exhibits a background of about 100 counts per minut !
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The licensee was documenting personnel skin contaminations.
- Radiological Occurrence Reports were being written for personnel contamination in excess of 1000 disintegrations per minute (dpm).
l Within the scope of this review, no violations were identified,
however, the following weakness was identified in the area of l
contamination control and personnel monitoring:
(See also
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Corrective Actions in Section 4.3.)
The RWP controlling work on the refuel bridge (RWP No.- 87-948) did not provide clear guidance relative to contami-nation controls for removal of cables and ropes from the water and transfer to the bridge. The RWP was unclear as to which equipment was to be hosed off.
The licensee revised the RWP on March 21, 1987 to provide
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clear guidance relative to:
additional protective cloth-ing, changing of gloves; use of rags, and hosing off of equipment prior to restart of work, f
4.6 Laundry Monitoring l
The licensee initially believed that the particle which was found on Individual A may have originated from improperly pro-cessed laundry.
The inspector reviewed the licer.see's laundry monitoring prac-tices with respect to recommendations contained in IE Informa-tion Notice No. 86-23, " Excessive Skin Exposures Due to Contam-ination With Hot Particles", dated April 9, 1986.
Findings
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The licensee sends his contaminated laundry to a vendor for washing. Laundry bags indicating greater than 50 mrem /hr are not sent.
These are initially procested on site. The contractor laundry washes the protective clothing. The clean laundry is monitored by either hand frisking or monitored with a special large area laundry monitor. Upon return to the site, the laundry (large bundles) is surveyed by licensee personnel with an ion chamber.
Those indicating greater than 2 mr/hr are re-examined to determine the cause of the readings. Those bundles indicating less than 2 mr/hr are made available for use.
Within the scope of this review, the following was identified.
The licensee performed an evaluation of the acceptability
of the vendor laundry monitor on October 1985. The evalua-tion was in response to on INPO Event Report which was referenced in Information Notice Notice 86-23. The
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licensee concluded in October 1985 that: the laundry washing method, monitoring technique and onsite receipt laundry monitoring criteria would address the concerns discussed in the report and that all articles of protective clothing were hand frisked at that time.
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At the time of the inspection, the licensee could not
locate information indicating Information Notice 86-23 had been reviewed indicating poor control of close out information for NRC identified concerns.
The vendor initiated use of a large area laundry monitor
to survey protective clothing around January 1987. The licensee did not perform an evaluation of the acceptability of this monitor when its use was initiated.
Subsequent source checking of the monitor by licensee personnel after the incident, indicated it could not readily detect part-icle contamination (0.4 uCi Cobalt-60 source used, i.e.,
888,000 dpm).
(Note: The vendor, based on inspector discussions with licensee personnel had provided an onsite presentation (January 1987) which indicated the new monitor could detect 5000 disintegration per minute [dpm].)
Based on the above, the inspector concluded that the licensee's oversight of his laundry vendor was weak and did not reflect an appreciation for the recommendations presented in the Information Notice.
The licensee initiated a comprehensive review of his laundry processing activities subsequent to the event. The
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i licensee has directed the vendor to institute more stringent monitoring criteria.
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Regarding onsite QA monitoring criteria for vendor pro-
cessed laundry, the procedure for care and handling of protective clothing (6.9-210) states that protective clothing with dose rates in excess of 2 mR/hr will not be issued. Since the licensee performs a gross survey of bundles of protective clothing, the 2 mR/hr limit would not ensure detection of particles located in the center of the laundry bundles.
The inspector concluded it was not an adequate method of performing quality assurance of vendor laundry processing, particularly for particle contamination.
The inspector indicated that the licensee's actions on the above laundry concerns will be reviewed during a subsequent inspection (50-293/87-17-02).
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4.7 Radiological Occurrence Reports The licensee maintains a personnel contamination log at the Main Health Physics Access Control Point. A Radiological Occurrence Report (ROR) is issued for each personnel contamination in excess of 1000 dpm.
The inspector reviewed this personnel contamination log for the period February 25 through March 16, 1987. The purpose of the review was to determine the number of particle contaminations of personnel identified and the' licensee actions taken during the period Drytube cutting was performed.
Findings Within the scope of this review the following was identified:
The personnel contamination survey log-indicated about ten
incidents of personnel contamination with particles on the bottom of their shoes during March 5 and 6, 1987. The licensee investigated the cause and determined it to be coming from a winch on the 23' elevation of the Reactor Building.
The winch was removed on March 6, 1987.
The number of personnel indicated as contaminated with specks decreased.
Licensee action on this problem was acceptable for this gross contamination control problem.
During the period March 5, 1987 through March 16, 1987, four
personnel contamination events greater than 1000 dpm were re-ported as occurring on the Refuel Floor.
The contamination levels ranged from 6,000 dpm to 300,000 dpm. A single personnel
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contamination event of 400,000 dpm was reported as occurring on the 91' elevation of the reactor building on March 5, 1987.
The inspector examined the radiological occurrence reports (RORs)
for the March 5, 1987, 91' foot 400,000 dpm contamination event and the March 6,1987, Refuel Floor, 300,000 dpm contamination event incident.
The following was noted:
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As of March 20, 1987, the March 5, 1987 ROR (400,000 dpm)'was not closed out and signed off by a supervisor to document that the ROR disposition was adequate and does not require any l
further action.
This is considered lack of timely action on j
this problem.
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As of March 20, 1987 the March 6, 1987 ROR (300,000 dpm) was also not signed off by a supervisor to document adequate disposition of the ROR.
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The corrective actions section of the March 6, 1987 Refuel
Floor ROR stated that the actions taken to prevent recur-rences were that the worker was advised to ensure his frisks were thorough in the future.
No apparent action was taken to determine the source of the 300,000 dpm particle on the individual or initiate action to prevent exposure of
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other personnel on the Refueling Floor to such particles.
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This is considered a lack of aggressive action on this problem.
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The worker who was contaminated on the Refueling Floor on March 16, 1987 (Individual A) was also contaminated on February 27, 1987 (120,000 dpm spot on shirt) and on i
February 28, 1987 (8,000 dpm spot on pants pocket).
The following was noted relative to Individual A's previous i
personnel contamination events.
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As of March 20, 1987, neither of the Individual's ROR con-tained actions taken to prevent recurrence or were signed off by a supervisor to document that the ROR dispositioning was adequate and requires no further action.
Based on the above findings, the inspector concluded that the
licensee's monitoring and closure of RORs associated with personnel contamination events was not aggressive and did not ensure adequate corrective action was taken to prevent recurrent
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contamination incidents of individuals, particularly the same individual.
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The licensee's actions on the matter will be reviewed during a subsequent inspection (50-293/87-17-03).
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5.0 Extremity Monitoring The inspector reviewed the use of extremity dosimetry and radiological l
controls provided for change-out of the Drytube Cutting Tool Blade.
The review was with respect to criteria contained in applicable regulatory
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requirements and procedures.
Findings Within the scope of this review, no violations were identified.
The following weaknesses were identified:
Individuals changed the radioactive blade by hand.
The tool was
hydro-lazed prior to handling.
Handling of the blade by hand was considered poor practice.
Inspector discussions with GE personnel
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l onsite indicated the blade could be changed with a remote tool.
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The licensee normally issues a wrist TLD, a wrist pocket dosimeter
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and a finger ring TLD to those individuals needing dosimetry for the hands. The exposure to the extremity, including the tips of the fingers is controlled by use of the wrist pocket dosimeter and a administration limit of 5 rem to the extremity.
The regulatory limit is 18.75 rem per quarter.
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The inspector noted, and the licensee verified that the tips of the fingers could receive a dose of up to five times greater than that i
indicated by the wrist pocket dosimeter.
Consequently, the inspector concluded that the 5 rem extremity limit would not, under some circumstances, ensure compliance with 10 CFR Part 20 limit (18.75 rem). The following factors were considered:
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the wrist pocket dosimeter did not indicate the dose to the tips of the fingers and the finger ring TLDs were not read out and evaluated after each
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dual put his hand to change the blade was a " hot dog" type probe containing two GM tubes. The low range tube was located.in the front of the probe while the high range was located at the rear of the probe. The inspector noticed that the high range tube is located about 3-4 inches from the front face of the probe.
Consequently it was not apparent that the use of the survey
meter with this tube configuration was adequate to survey for small pieces of cut dry tube which may.be lodged in the cutter.
(Note: The inspector reviewed extremity exposure data for 1987
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and 1986. The maximum exposures to the hands, based on reading-of the finger ring TLD,was about 1.5 rem consequently, no
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overexposure was identified.)
l The licensee's tracking of the dose to the extremity was based on
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reading of the pocket dosimeter until the finger ring and wrist TLDs l
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The inspector noted that this may be unconservative i
considering that the TLDs will not be read-out until the particular i
job is terminated or the calendar quarter has ended.
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Licensee Actions
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The licensee suspended cutting blade changes.
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- The GM tubes in the survey meter were reconfigured to place the
high range tube near the front of the probe. The detector was recalibrated.
In addition, guidance was included in the appro-i priate RWP for use of the modified survey meters.
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The licensee placed a pocket dosimete.' on the fingers to monitor dose
to the fingers during subsequent blade change-outs.
The licensee lowered the extremity administration dose limit
identified in procedures to 3 rem. However, the procedure change was confusing. The licensee initiated action to clarify the procedure.
The following matter will be reviewed during a subsequent inspection:
(50-293/87-17-04)
Modification of procedures for administrative exposure limits
for extremities and tracking of exposure to the extremities.
6.0 Exposure Evaluation Reports The inspector reviewed the adequacy and implementation of the licensee's exposure evaluation program. The review was with respect to applicable licensee procedures and regulatory requirements.
The licensee uses an Exposure Evaluation Report (EER) as a means to document the review of dosimetry problems.
These include:
discrepancies between TLD and pocket dosimeter readings, off-scale pocket dosimeters; and lost TLD badges.
The inspector reviewed selected exposure evaluation reports performed in 1986 and 1987.
Findings Within the scope of this review, no violations were identified.
However, the following programmatic weaknesses were identified:
The exposure evaluation report procedure provided limited guidance
and review criteria for evaluating exposure problems.
Exposure Evaluation Reports were not signed off in a timely manner as
being fully resolved. As of April 10, 1987, about 120 Reports were not signed off. The latest was dated February 19, 1987.
Some had been identified as being open as far back as 1984.
(See Inspection l
Report 87-09).
The licensee was using a generic form (pre printed evaluation) to
document a significant number of exposure evaluations.
It was not apparent that the form was properly used.
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The following matters will be reviewed during a subsequent inspection:
(50-293/87-17-05)
Implementation of new procedure for performing exposure
evaluations. The licensee committed to review and revise the procedure as appropriate.
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Resolution of exposure evaluations not being signed off as
completely resolved.
Note:
Licensee personnel indicated open exposure evaluations will be signed off as resolved within 30 days.
In addition, criteria has been included in the new exposure evaluation procedure (SI.RP-2400)
requiring full resolution and sign-off within 30 days.
7.0 Radiological Goals Program The inspector reviewed the implementation and oversight of the Radiological Goals Program.
Findings The licensee fully implemented the Goals Program for the first quarter
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of 1987. The effectiveness of the Goals Program ::uld not be fully assessed in that:
- The Station Section Action Plans were not verifie: as implemented relative to established goals.
- Performance for each Station Section has not yet :een evaluated by the station ALARA Committee relative to meeting established goals as required by procedure.
Some sections' total expos.*e was noted to be well below actual Quarterly Exposure Goals.
It was not apparent as to the reason for this (e.g. poor Goals development or excellent section performance).
- Total station contaminated area has been running at 40,000 square i
l feet above the established goal of about 12,000 s:uare feet for about
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the last five months.
It was unclear as to the reason for this.
- The licensee issued an ALARA Annual Report for 1986.
The document summarized the station ALARA performance for 1986. The inspector
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noted that the report provided goals for limiting personnel intake of radioactive material. The 1986 results presented were in error. The report indicated no personnel intakes in excess of 5 MPC-hours.
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inspector independently determined that 5 personnel exposures in excess of 5 MPC-hours occurred (maximum about 7 M?C-hours).
- All types of Exposure Evaluation Reports were not being trended.
Some were tracked and trended by the Radiological Occurrence Report Process. The inspector noted about 200 Reports were initiated for differences between pocket dosimeter readings and TLD readings during the period July through September 1986. Trending of such reports l
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would assist in identifying a problem in a timely fashion.
The licensee's Goals Program will be reviewed during subsequent inspections.
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4 8.
Personnel Exposure Reporting The inspector reviewed the licensee's yearly occupational personnel exposure tabulation for 1986.
Finding Within the scope of this review, the following unresolved item was identi-fied:
(50-293/87-17-06)
Technical Specification 6.9, Reporting Requirements, requires in section A.3, that an Occupational Exposure Tabulation be submitted annually.
Section A-3 further requires that in the aggregate, at least 80% of the total whole body dose received from external sources be assigned to specific major work functions.
The 1986 Occupation Exposure Tabulation assigned only 69% of the aggregate total whole body dose to specific major work functions. This indicates that about 200 person-rem was not accounted for or apparently included in appropriate ALARA reviews.
Licensee personnel indicated a revised report will be sent to the NRC to account for 80% of the total aggregate exposure.
Licensee personnel have initiated actions to provide for better account-ability of station aggregate exposure.
However, the inspector considers them not aggressive.
For example, the inspector noted that the Nuclear Operations Manager sent a February 23, 1987 memorandum to the Maintenance Manager requesting investigation into the concern that personnel are receiving considerable exposures in general areas (non-Radiation Work Permit dose).
However, the inspector noted that:
no completion date for the investigation was identified and
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as of April 10, 1987, no response to the memorandum had
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been provided.
The inspector concluded that management oversight and
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monitoring of station aggregate exposure was in need of improvement.
9.0 Additional Items 9.1 General The inspector reviewed two events involving personnel exposure to airborne radioactivity.
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9.2 Event 1 On November 11, 1986, a contractor individual was subjected to concen-The worker trations of airborne radioactivity of about 256 x MPC.
was cleaning up a small quantity of radioactive sludge identified during removal of a Chemistry Sampling Sink on - l' elevation of the The worker was inside a HEPA ventilated tent and Radwaste Building.
wore.a full face respirator.
This event was reviewed because of the high airborne radioactivity identified.
The following was reviewed:
adequacy of the radiation work permit;
provision of engineering controls;
airborne radioactivity sampling anc nistory of the tent;
evaluations made in accordance with
'.0 CFR 20.201;
aircorne radioactive material inta(e estiTI:es.
- Findings and Conclusions The Within the scope of the review, no violations as e identified.
licensee's evaluation made prior to the start c' the job appeared reasonable under the circumstances to evaluate : e anticipated air-borne radioactivity concentrations to be encour:ered.
Consequently, the licensee provided the worker with a full f ace respirator (protec-tion factor = 50) instead of one with a higher :rotection factor.
The licensee immediately stopped work in the te : following the event and orcered a special vacuum cleaner from a sendor :: complete the job.
The inspector reviewed a whole body count for tre involved worker performed immediately after the event.
(November 11, 1986 at 5:49 p.m).
No intake of radioactive material was icentified.
No violations were identified.
9.3 Event 2 This event was reviewed because of media interest.
On October 6,1984, a contractor individual working in the Drywell was exposed to airborne radioactive material. The individual was climbing at about the 63' elevation of the Drywell.
Upon exiting The the Drywell, the worker identified some facial contamination.
individual was restricted from entry into contaminated areas for seven days. His restriction was lifted on October 13, 1984.
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s The following was reviewed:
adequacy of the radiation work permit
provision of engineering controls a
airborne radioactivity sampling and history of the drywell area a
where the individual worked evaluations made in accordance with 10 CFR 20.201
use of respiratory protection equipment
airborne radioactive material intake estimates.
- Findings Within the scope of the review, no violations were identified. The following was noted:
The worker was signed in on the applicable radiation work
permit on September 6, 1984 from 7:40 a.m. to 9:20 a.m. and from 12:50 p.m. to 2:25 p.m.
The facial contamination was identified after exiting the drywell after 2:25 p.m.
A Radiological Occurrence Report was initiated following
identification of the facial contamination.
In order to remove traces of external contamination, the indi-
vidual was showered four times; The individual received multiple whole body counts during the
period in two different whole body counters; The worker was provided a beverage (beer) at the Instruction
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and Service (I&S) Building to assist in collection of excreta (urine) samples.
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The worker sustained an intake of about 2.3% (i.e. about 12 mpc
hours) of the quarterly quantity intake limit specified in 10 CFR 20.
NOTE: The quarterly quantity intake limit in 10 CFR 20 is 520 mpc-hours.
The intake was below the 10 CFR 20.103 criteria of 40 mpc-hours
requiring initiation of a review and implementation of corrective actions to prevent recurrence.
The licensee could not provide specific air sample data where the
individual worked.
The licensee could not provide specific contamination surveys
in the area where tho individual worke.
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General area air samples collected previously in the drywell,
including elevation 61' indicated low airborne radioactivity.
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Conclusion
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d No radiological safety violations were identified.
However, it was noted
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that the licensee's procedures for collection of excreta samples did not provide guidance relative to methods to be used to enhance excretion.
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10. Unresolved Matters An unresolved matter is an item for which more information is needed to
j determine if a violation of regulatory requirements has occurred.
One' unresolved item is discussed in paragraph 8.
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Exit Meeting The inspector met with those individuals (denoted in Section 1) at the conclusion of-the inspection on March 20, 1987. The inspector summarized the purpose, scope and findings of the inspection.
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No written material was provided to the licensee.
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