IR 05000293/1987029

Safety Insp Rept 50-293/87-29 on 870713-17.Violation Noted. Major Areas Inspected:Licensee Action on Previous Findings, Radiological Controls Organization & Staffing,Several Worker Concerns & Radiological Controls

ML20238A725
Person / Time
Site:	Pilgrim
Issue date:	08/13/1987
From:	Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20238A687	List: IR 05000293/1987029 ML20238A683 ML20238A718
References
50-293-87-29, NUDOCS 8708310185
Download: ML20238A725 (12)

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l U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-29 Docket N l License N DPR-63 Priority Category C

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Licensee: Boston Edison Company M/C Nuclear 800 Boylston Street i Boston, Massachusetts 02199 i

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Facility Name: Pilgrim Nuclear Power Station

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Inspection At: Plymouth, Massachusetts i l

Inspection Conducted: July 13-17, 1987 l

1 Inspectors: R.LM w I R. L. Nimitz, Senior Radiation Specialist 8kn3kB7 date l I

Approved by: hLM k(r1 I3 07 M. Shanbaky, Chief, Facilitb6s Radiation date Protection Section  ;

Inspection Summary:

Areas Inspected: Routine, unannounced safety inspection of the following:

licensee action on previous findings; Radiological Controls organization and staffing; several worker concerns; and radiological control Results: One violation was identified (Failure to adhere to radiation work permits; details Paragraph 5).

8708310185 070824 PDR ADOCK 05000293 g PDR j

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DETAILS Individuals Contacted 1.1 Boston Edison Company

• Bird, Senior Vice President Nuclear R. Ledgett, Assistant to Senior Vice President Nuclear

• K. Roberts, Nuclear Operations Manager

• S. Hudson, Operations Section Manager

• J. Jens, Radiation Protection Manager T. Sowdon, Chief, Radiological Scientist  :

• N. Gannon, Chief, Radiological Engineer

• P. Hamilton, Actin Compliance Group Leader 1.2 NRC l

• T. J. Kim, Re~sident Inspector

• J. Lyash, Resident Inspector

• denotes those individuals attending the exit meetin The inspector also contacted other individuals during the inspectio . Purpose of Inspection The purpose of this inspection was to review the following:

licensee action on previous inspection findings

worker concerns regarding exposure to airborne alpha redicactivity

worker concerns regarding removal of radioactive material from the site

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worker concerns regarding removal of shielding from under the reactor vesse .0 Licensee Action on Previous Findings 3.1 (Closed) Unresolved Item (50-293/85-13-03)

The licensee was using Special Instructions, a non station approved document, to provide chemistry technicians guidance for sampling the Salt Service Water System. The Special Instruction appeared to supersede approved procedures for the purpose. Inspector review indicated there was no Technical Specification requirement to sample the Salt Service Water System. The Special Instruction guidance was incorporated into approved procedures prior to implementation of a Salt Service Water Sampling requirement contained in the new Radiological Effluent Technical Specificatio I i

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3.2 (Closed) Inspector Follow Item (50-293/85-27-22)

Establish procedures for in-situ calibration checks for the PASS radiation monitor. The licensee revised procedure No. 6.5-305, " Post Accident Sampling System Source Calibration of PASS Radiation Monitoring Instrument" to provide for in-situ calibration. Although not yet checked in-situ, the check has been placed on the master surveillance tracking system for performance during the current outag .3 (0 pen) Inspector Follow-up Item (50-293/85-27-25)  !

t Establish reliable back-up power for the chiller. Thc licensee provided I for back-up cooling for the PASS system chiller via the firewater syste {

An evaluation was performed which indicated that the firewater beat removal capability was adequate. ~ A special procedure to use the system has been established. However, the system has not yet been tested as recommended by the Engineering Service Request (ESR). In addition the  !

schematic for the backup cooling showed the. firewater to be dumped to a j j sum It was not apparent that the sump discharge was monitored for radioactivit l 3.4 (Closed) Inspector Follow-up Item (50-293/85-27-28) .

I Evaluate ability of low range effluent monitor to recover from off-scale {

operatio The licensee evaluated the ability of the present GE Analog l Type monitors to recover and operate properly after operating in an over range condition. A decision was made.to replace the detectors with new GE Numac type monitors prior to plant start-up. The new monitors recover satisfactorily from operation in an over range condition. Also, the current Analog monitors were found to recover properly.

3.5 (Closed) Inspector Follow-up Item (50-293/85-27-41)

SAM-2 procedures did not describe " percent" efficiency or " decimal" efficiency when analyzing charcoal cartridges. The licensee revised a additional applicable procedures for calibrating SAM-2s and analyzing l charcoal cartridges on them to address this matte !

3.6 (Closed) Inspector Follow-up Item (50-293/85-32-12) I I

Licensee to evaluate self-absorption factors for filter media considering '

dust loading. The licensee evaluated the acceptability of the self-absorption facto The licensee considers the factor acceptabl .7 (Closed) Inspector Follow-up Item (293/86-09-03) Licensee to determine j the validity of past Environmental TLD Data. The licensee used the -

results from past studies by the International Environmental Dosimeter Intercomparison Project as the basis for determining the validity of its  ;

data. The licensee has participated in these studies since 1977. The i comparison of the licensee's results to the values stated by the program I sponsors have shown reasonably good agreement in recent years, with the {

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exception of 198 The data from 1984 study showed the licensee's results to be about 50% of the actual value; thus the 1984 field data were adjusted to account for this under respons .8 (Closed) Inspector Follow-up Item (293/86-09-04) NRC to review adequacy of Environment' TLD Program. The licensee began the use of a new TLD system as of January 1,1987; this system is operated by an independent laboratory. The licensee has obtained documentation on the ability of this system to meet the eriteria of Regulatory Guide 4.13 and ANSI N545-1975. The :riterion of one of the tests, energy depe.ndence, could not be met at some energies by the calcium sulfate elements of one badge type, and further studies may be undertaken. However, the overall per-formance of the system appears to be adequate. The licensee has a pro-cedure for quality assurance to evaluate the ability of the independent laboratory to accurately treasure environmental levels of radiation. The licensee also plans to examine the TLD system and its associated proce-dures and records as part of its regular audit of the laborator .9 (Closed) Inspector Follow-up Item (50-293/86-16-02)

Licensee to establish procedures for operation and calibration of the recently purchased Continuous Air Monitors (CAMS). The licensee established and implemented Procedures SSI-RP.4715 and SI-RP.5715 for operation and calibration (respectively) of the CAMS. The licensee will train and qualify appropriate personnel in the calibration and use of the CAMS including alarm set points. All CAMS have not yet arrived on sit The CAMS will be placed at selected locations within the plant. A total of 15 are to be ordere .10 (Closed) Inspector Follow-up Item (50-293/86-19-07)

Licensee to esteblish procedures for in-vitro monitoring. The licensee revised procedures SI-RP.2100 and 6.2-161 to include guidance for collection and analysis of in-vitro sample .11 (Closed) Inspector Follow-up Item (50-293/86-14-08)

Licensee to review and evaluate the need to include guidance in radiological surveillance procedures to provide for modification of the program based on survey results and/or plant conditions (e.g. failed fuel). The licensee revised procedure SI-RP.3001 to include guidance for review and evaluation of radiological surveillance result .12 (Closed) Inspector Follow-up Item (50-293/86-19-13)

Licensee to review the need to ptovide multiple size respirators and provide guidance to limit storage of respirators face pieces to two high. The licensee ordered and received small respirators. Procedures were revised to address use of small respirators. Also respirators are l now stored only two hig {

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i 3.13 (Closed) Violation (50-293/87-03-02) )J Licensee did not properly implement high radiation area controls i following loss of a high radiation area key. The licensee implemented the corrective actions described in his April 13, 1987 letter to NRC Region I. The corrective actions were independently verified by the inspecto .14 (Closed) Violation (50-293/87-11-01)

Licensee did not adhere to several radiation protection procedures. The ,

licensee implemented the corrective action described in his June 17, 1987 letter to NRC Region I. The ccrrective actions were independently verified by the inspecto .15 (Closed) Inspector Follow-up Item (50-293/87-17-04)

Licensee to revise procedures for administrative exposure limits and for tracking of exposure to the extremitie The licensee revised and clarified procedure 6.1-212 to reduce the allowable exposure to the extremities to 3 rem per quarter. Extremity exposure is tracked on a separate Radiation Exposure card. A special procedure requires that a review be performed for jobs with the potential for extremity exposur Additional radiological controls are provided for estimating dose to tips of fingers. This dose is corrected upon finger ring read out. Also the RWP procedure provides for control of exposure to tips of finger. A separate procedure requires verification of use of special dosimatr .16 (Closed) Violation (50-293/87-39-01)

Failure to account for high-high radiation area keys and to maintain keys in special key cabine The licensee implemented the corrective action described in his April 29, 1987 letter to NRC Region I. The corrective actions were independently verified by the inspecto .0 Organization and Staffing '

The inspector reviewed the licensee's Radiological Controls Organization and Staffing with respect to criteria contained in Technical Specifications. The following observations were made:

A new Radiological Section Manager has been hire The licensee has not determined if the individual will be designated as the individual meeting the Regulatory Guide 1.8 qualification as Radiation Protection Manage *

The Radiological Engineering and Technical Support Group has been separated into two separate group . .. . .. . .

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The in place organization is not consistent with the Technical l Specification described organization i

A new dosimetry supervisor has been hired

The entire ALARA group is staffed by contractor The above matters were discussed with the licensee. The licensee is i currently reviewing the organization and the need to update Technical Specifications and applicable administrative procedures, l i

l t4o apparently unqualified individuals were acting in responsible position ]

The organization and staffing will be reviewed during future inspection I 5.0 Plant Tours I

The inspector toured the plant and reviewed the following matters: ]

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control, posting and labeling of radioactive and contaminated material i posting of radiation and high radiation areas i

access control, including locking, of high radiation areas

adequacy of and personnel adherence to radiation work permits a

housekeeping l

The review was with respect to criteria contained in applicable licensee  ;

procedures and regulatory requirement !

Findings Within the scope of this the following was noted:

radioactive and contaminated material was properly poned, labeled and controlled

radiation and high radiation areas were properly controlled

housekeeping was acceptable Within the scope of this review, the following apparent violation was  ;

identifiec; (50-293/87-29-01)

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Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared and adhered to for all operations involving personnel radiation exposure. Radiation Protection Procedure  ;

6.1-022 requires in part in section VI A and VII J.7, that individuals j follow the instructions of radiation work permit i Contrary to the above, at about 10:10 p.m. on July 16, 1987 the inspector 1 found a reactor operator inside the Reactor Water Clean-up Pumps and Heat F Exchanger Cubicle,.a posted, locked High Radiation Area, without the radiation survey meter required to be used by the applicable radiation work permit (RWP No. 87E-4). The individual had signed the RWP indicating {

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his understanding of the RWP's requirement .0 Worker Concerns (RI-87-A-0078)

6.1 General l l On July 7,1987 NRC Region I was notified of several concerns involving j radiological controls. The concerns and inspector findings associated with each concern are discussed belo .2 Specifics >

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k 6. Concern 1 j Since June 1, 1987 six security personnel posted on the 91 foot elevation I of the reactor building have alarmed the Radiological Controls Control i Point Monitor upon attempting to egress the plant. The individuals were told that the contamination was due to radon. The workers were concerned 1 about internal exposure to alpha particle j Findings  !

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The inspector reviewed the personnel contamination log for the period March 1,1987 through July 15, 1987. The inspector also reviewed applicable airborne radioactivity survey data for 91' elevation, and met with cognizant personnel to discuss the results. The review indicated .

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Three individuals were identified as being contaminated with alpha l l contamination during the period. The contamination was short lived i cipha contamination from radon and its daughter products. No reactor i produced activity was identifie !

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A Radiological Occurrence Report (ROR) was written for the first ;

incident (identified March 30,1987). The contamination was i attributed to natural radioactivity and close '

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The licensee was performing maintenance on the ventilation system for the 91' elevation. The activity was caused by a build-up of natural airborne activity due to rado *

Licensee calculations indicated the levels of natural airborne radioactivity on the 91' elevation were lo However, the short lived contamination was adhering to worker's polyester clothing resulting in alarming of the whole body frisker *

The licensee was aware of the problem and had provided written guidance to radiation protection technicians as to how to handle personnel contaminated with natural radioactivit The following items for improvement / clarification was discussed with the licensee:

The guidance provided to radiological controls technicians did not l indicate at what level of alpha contamination a Radiological Occurrence Report should be written or when supervision should be notified when unexpectedly high levels of alpha contamination was identifie *

Individuals were considered not well informed about exposures to natural alpha radioactivity as compared to reactor produced alpha activit The licensee personnel indicated these matters would be reviewe Conclusion No violations were identifie .2.2 Concern 2 A contractor was contaminated with alpha contamination on or about March 30, 198 Findings l This matter was reviewed in conjunction with concern The review indicated the following:

An individual was contaminated with alpha contamination resulting from natural radioactivity on March 30, 1987. A Radiological l

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Occurrence Report (ROR) was written for the event. The ROR was closed out because the activity was identified to be naturally occurrin Conclusi.on _

No violations were identified

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6.2.3 Concern 3 A health physics technician removed a package from the station via the Main Gate on March 16, 1987 and although it alarmed the Portal Monitors, there were no markings, permits, or tags on the packag Findings The inspector reviewed the circumstances surrounding the incident, applicable security logs, and applicable procedure requirements. The inspector also discussed the matter with cognizant licensee personne The review indicated the following:

A package containing small radioactive check sources, was removed from the Main Gate on March 16, 1987 by a Health Physics Supervisor. The sources were to be used to perform QA checks of the licensee's laundry vendor clothing monitor *

The material caused the Portal Monitor at the Main Gate to alar *

Security personnel would not permit the package to be removed without authorization from the Radiation Protection Manage The Radiation Protection Manager authorized its removal.

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sources was not required to be labele However, the inner package containing the sources was labele Conclusion No violations were identifie .0 Worker Concerns (RI-87-A-0081)

7.1 General On June 23, 1987 NRC Region I was notified of a worker concern associated with under vessel work. The concern and inspector findings are discussed belo .2 Speci fics Concern A worker was concerned that radiation shields placed on Control Rod Drive (CRD) flanges were being re.noved despite continuing Low Power Range Monitor cable work under the reactor vesse _ _ _ _ . ___

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I Findings The inspector reviewed the circumstances surrounding the event including: ALARA planning; work scheduling; shield removal; applicable dose rates with and without shielding; licensee reviews; and corrective actions as appropriate. The inspector met with cognizant licensee personnel to discuss the matte The review indicated the following:

During the early morning hours of June 23, 1987 about 27 flange shields were removed from under the reactor vesse *

At about 8:00 a.m. on June 23, 1987 a licensee ALARA engineer suspended shield removal on the belief that upcoming planned cable work could be performed with the shields in plac The hold was i placed to prevent further shield remova l

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At the direction of Outage Management personnel shield removal was reinitiated at about 8:30 a.m. that da Ten additional shields l were remove '

At about 8:50 a.m. that day the work was placed on hold by the Environmental and Radiological Group Supervisor because of a need to l perform ALARA reviews for a work request. The work request involved l an estimated six hours of additional work. The ALARA personnel had l been previously informed that all work that could have been l

performed with the shields in place was complete. This new work l could have been performed with the shields in place. GE ,

subsequently cancelled the six hours of work. The shield removal l was restarte *

At about 10:15 a.m. on that day the shield removal was again halted due to the need to inspect and test some cable connectors under the

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reactor vessel. Because the work was estimated to take about two hours, a decision was made to replace the connectors instead of inspecting and testing them. Work was restarted at that tim *

Because of a need to perform final cable checks in their normal configuration, shoot-out steel was to be reinserted. A decision was made at about 10:15 a.m. on that day to remove the shieldir.g, j re-insert the shoot-out steel and perform final cable checks with the shields removed.

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Licensee ALARA personnel were aggressively following under vessel nork. Work stoppages were initiated when apparent ALARA concerns were identified.

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• Some problems with under vessel cables resulted in the need to perform additional, unplanned work. The unplanned work was done to correct cable connector problem *

Final under vessel cable and connector work was required to be performed with the cables in their normal position with interferences removed. The interferences including shielding which was removed to prevent possible damage to the cables after final cable testin *

The licensee's ALARA group was unaware of some of the finer details associated with cable testing but did take action to suspend work in order to better understand the ALARA implication of the wor This was attributed to a lack of attendance on the part of the ALARA group at the 8:30 daily work planning meetings.

No violations were identifie *

No unnecessary or unplanned personnel exposure was identifie * Formally established work schedules clearly showed that additional undervessel cable work was to be performe . Exit Meeting The inspector met with licensee personnel, denoted in section 1, at the conclusion of this inspection on July 17, 1987. The inspector summarized the purpose, scope and findings of the inspectio No written material was provided to the licensee.

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