IR 05000293/1987043
| ML20237F036 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/15/1987 |
| From: | Dragoun T, Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20237F022 | List: |
| References | |
| 50-293-87-43, NUDOCS 8712290317 | |
| Download: ML20237F036 (20) | |
Text
- - __ - _ ___ _ - - __. _ _ _ _ _ _ _
_ _.
.
..
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-293/87-43 Docket No.
50-293 Category C
License No.
DPR-63 Priority
--
Licensee:
Boston Edison Company, 800 Boylston Street Boston, Massachusetts 02199 Facility Name:
P_ilgrim Nuclear Power Station Inspection At:
Plymouth, Massachusetts Inspection Conducted:
November 2-5, 1987 Inspectors:
Q L tdM likis\\M R. L. Nimitz, Senior Radiatitn date Specialist R L N td b t? h5 \\ E7 T. F. Dragoun, Senior Radiation date Specialist Approved by:
/M. 5 3 I//
/2//r[f7
M. M. Shanbaki, Chief,'ftcilities date
{
Radiation Protection Section n,
mmary:
Inspection on November 2-5, 1987 (Inspection Report Areas Inspected: Special, announced inspection to evaluate the upgraded Radiological Controls Program developed in response to an NRC Order Modifying License dated November 29, 1984. Areas reviewed were certain items identified
.
8712290317 871229 hDR ADOCK 05000293 DCD
-_
_ - _ _ _ - _ _ _ _ _ _ _ - - _ _ - _ _ _ _ _
_ __ __ - _ _ _ _ _ _ - _
-
..
as open items in NRC Report No. 50-293/86-19. Also reviewed was implementa-tion of the licensee's Radiological Controls Program.
Results:
No violations of NRC regulatory requirements, including the NRC Order Modifying Licer.se, were identified. Although some weaknesses were noted, no programmatic problems were identified which would preclude closure of the NRC Order Modifying License dated November 29, 1984.
!
l i
,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
j
_ _ _ _
,
.
Details 1.
Individuals Contacted 1.1 Boston Edison Company, Inc.
R. J. Bird, Senior Vice-President
- W. Ledgett, Executive Assistant to Senior Vice President
- K. P. Roberts, Nuclear Operations Manager
- J. P. Jens, Radiological Section Manager
- J. Seery, Technical Section Manager
- S. Hudson, Operations Section Manager N. Brosse, Maintenance Section Manager
- P. Hamilton, Compliance Group Leader
- R. Canalas, Chief Chemical Engineer
- C. Gannon, Chief Radiological Engineer
- L. Whittenberger, Radiological Operations Support Group Leader
- W. Zurliene, Radiological Technical Support Group Leader 2.2 U.S. NRC
- J. Lyash, Resident Inspector, Pilgrim T. Kim, Resident Inspector, Pilgrim
- M. Shanbaky, Chief Facilities Radiation Protection Section
- R. Bellamy, Chief, Emergency Preparedness and Radiological Protection Branch
- Denotes those individuals attending the exit meeting on November 5, 1987.
The inspectors also contacted other individuals.
2.0 Background, Purpose and Scope of Inspection As a result of significant deficiencies in the Radiological Controls Program at Pilgrim Station, an NRC Order Modifying License was issued on November 29, 1984. The Order required the following:
Performance of an independent contractor assessment of the Radiological Controls Program, Submission of copies of the assessment, to the Regional Administrator, Development and submittal to the Regional Administrator of an
,
Interim Plan for achieving adequate management oversight of radiological work in progress, Development and submittal to the Regional Administrator of a Radiological Improvement Plan (RIP) for upgrading the Radiological Controls Program.
_ _ _ _ _ - _ _.
_ _ _ _ - _ - _ _ _ _ _ _ _ _
___
,
.
Multiple program inspections were conoucted following issuance of the Order to monitor its implementation and evaluate the adequacy and effectiveness of Radiological Controls Program upgrades.
A special Health Physics Appraisal (Inspection No. 50-293/86-19)was performed in October,1986, to determine whether the licensee had fully established and implemented an effective Radiation Protection Program in response to the Order. As a result of program deficiencies identified, the Order was not closed. Additional inspections were conducted subsequent to Inspection 50-293/86-19 to monitor and evaluate licensee actions on the identified deficiencies.
The purpose of this current inspection was to review licensee action on the remaining NRC findings.
Plant tours were made to review in-field radiological controls.
3.0 Licensee Action on Previous Findings 3.1 (Closed) Inspector Follow-up Item (50-293/86-19-01)
This item consisted of five sub-items.
Item 1 (Closed) Communication and Working Relations Inspection 86-19 conducted on October 10-24, 1986, noted that additional management attention was needed to improve communication and working relationships between the radiological controls section and other sections.
Findings i
'
Based on interviews with management and other personnel and observation of ongoing activities, the inspector determined that the following improvements have occurred:
)
Six senior HP personnel are assigned to different organizations J
-
to act as coordinators. One or more coordinators are assigned cooperations, Construction,Maintenanceandsubcontractor(GE and Bechtel) groups. They ensure that the work groups become familiar with the HP program and serve as expeditors for processing RWP requests and ALARA reviews.
As the outage work was completed, management selectively
-
reduced the contractor work force, keeping the most competent performers.
Senior Management periodically meets with all station personnel
-
to discuss concerns and questions.
- - _ - _ _ - _ - _ _ _ _ _ _ _ _
_- _
4 The Radiological Section Manager has been frequently meeting
-
informally with other station groups to discuss and resolve the sources of friction between the HP and other groups.
The inspector concluded that management action is appropriate in improving communication and working relationships. The level of performance is now satisfactory but will require long term application of the above actions to achieve a high level of performance.
Item 2 (Closed) Radiological Controls Goals Program Under this item the licensee was advised of the need to establish challenging goals particularly for ALARA with vigorous accountability towards these goals.
Findings The station has established several annual goals including total radiation exposure, individual worker exposure, volume of radwaste and square footage of contaminated area. A long range goal of 500 Rem total annual exposure has been set for 1990.
Station goals are widely published and conspicuously posted on bulletin boards.
Colored charts clearly indicate progress and trends. Overall goals are proportioned to each department with further breakdown into goals for each section.
For example, the Instrumentation and Controls Section of the Maintenance Department has a 1987 exposure goal of 22.5 Rem. Supervisors are held accountable to upper management via the " Performance Monitoring System." Performance relative to ALARA goals is reviewed by the Vice President and the ALARA Oversight Committee.
The inspector concluded that goal setting and management oversight of these goals has improved. The mechanisms to ensure accountability are in place.
However, management needs to review long range goals once the extended outage is completed.
Licensee management stated that long range goals will be established once the outage is completed.
Item 3 (Closed)
Aggressive management action is needed to substantially reduce the number of Radiological Occurrence at the station.
Recurrent I
problems continue to be identified by the Radiological Occurrence Report Program.
!
l L-_-_-_____-_____ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _
_
-
..
l l
I Findings The licensee has taken aggressive action to resolve concerns identified in Radiological Occurrence Reports. This matter is discussed in Section 4 of the report.
Item 4 (Closed) Review and Upgrade Radiological Controls Procedures Findings The licensee has reviewed and upgraded (as appropriate) the quality
,
of Radiological Controls Procedures in all functional areas.
l Selected program procedures were independently reviewed and found to be upgraded in areas such as:
procedure development, external exposure controls, internal exposure controls, radioactive waste handling, and ALARA. The liccnsee performed reviews of their Radiation Protection Plan and Radioactive Material Control Plan to l
ensure appropriate procedures were in place. Some procedure inconsistencies remain which the licensee is reviewing. Licensee
,
I action on these will be reviewed during routine programmatic inspections.
l Item 5 (Closed)
A Program audit was conducted by the Radiological Oversight Committee and by a contractor. Appropriate milestones should be established for completion of corrective actions for weaknesses identified in both audits.
l Findings l
This audit was performed by the licensee to identify areas for pr.ogram enhancement. The licensee's new Radiation Protection Manager was currently becoming familiar with the findings. The licensee's actions on the matters identified in the audit will be reviewed during routine programmatic inspections.
3.2 (Closed)InspectorFollow-upItem(50-293/83-18-02)
Licensee to review the acceptability of the alarm set points for the Drywell Atmosphere Airborne Radioactivity Monitors. The licensee evaluated the alarm set points and found them to be acceptable. The licensee also performed a generic review of other process radiation monitors to identify any other potential concerns with alarm set points. The licensee identified a need to establish guidance for setting of alarm points for the Augmented Off-gas Post Treatment Monitor and the Stearr det Air Ejector Monitor. The licensee initiated action to establish guidance for setting of alarm set l
_ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- - - _ _ _ - _ _ _ _ _ _ _ _ _ _ _..
_
_.
,
.
'
'
- ,
.
-i_
,
b
'
'1,
,
,
!
. Ah
points for these monitors. The alarm set points for these monitS t
were being set in a conservative manner.
No violations were
-
identified. This item is closed.
l, (
.
3.3 (Closed) Unresolved Item (50-293/84-25-03)
- (
NRC to review: licensee maintenance of airborne radioacti9Ry C y
exposure records, results of licensee evaluations for the,
y presence of pure beta emitters and the acceptability of, documentation of airborne radioactivity intake estimates'?or g/
individual termination reports. Tte licensee's airborne
'h
radioactivity exposure 3ecords program was n avieved dur}r.g NRC Inspection Report No. 50-293/86-19 and found to hs adequate. The licensee performed a detailed study of the tyrei and amounts of
', #
radionuclides encountered at the station Pru.edures have been i
established and implemented for analysis of air samples which tvko Ue
'
)
into consideration pure beta emittert. The in.ensee's termination reports were found to be consistent with the requirements of 10 CFR C
20.408 and 10 CFR 19.13. No violations were identified. This item
'j is closed.
,
e,,
/
'
( 'c'> (,;
')
c
,
3.4 (Closed) Inspectoc follow-up Item f60-293/85-3 M 9)
'
Licensee to correct the skin exposureg esn'ts,for some individuals
6e
)
who wore more than one TLD.
The licwnsee qirrected the skin a
exposures of those individuals who worn more than one TLD and'also i
received skin exposure due to beta raafution.
No regulatory limits
'
were exceeded when the additional exposure (gamma)' Mas added te the exposure sustained from beta radiation. Thelicefseeir, performing a review of all dosimetry ret.ceds to identify other anomalies.
Licensee personnel indicdted revised exposure rep M s, as
)
f;
}
appropriate, would ba is;Jed.
,
\\
y
v i
3.5 (Closed) Inspector Fc'iow-up? Iten (50-25fMcM/di)r
s This item contatq:d seven sub items. '
'
'
- .
>t
,
Item 1 (Closed)
/
(~
'
,
,
,I
/
,
o The current Radiation Protection Omnization it not consisS et with l
that depicted in Technical SpecifiObond TheTechnicaK
,j'
Specifications should be updated to epict j'he ccrrect 6 art'zation and clearly identify the Pegulatoryi M de 1.8 qualified Radiation
.
Protection Manager (or equivalent title)'
o i
J
'
l Findingqs_
g
-
ThelicenseetransmittedaletprfBINbtr..No.87-14, dated
,
October 27,1987) to the NRC te reyti the, organizational strLcture 4 to reflect recent changes. The lettb. also clear'v identifies the individuai(s) to be Regulat3cy Guide 1.8 qualified. Th% item is closed.
,,
,
,.
I
l t
I b
\\
p
/
i
,
_
_ _ _ _ _ _
m a
-
___
. _ _ _. _ _ _ _.
_
-
in i
}
4 ', <
.
r
.
.
\\
t I
i
,
,.
).
(
'
'
.? {
i
!
I
'
jtem2(Closed)
',,
Discussions with cognizant rnWation protection personnel indicate that dWing outa.y1 conditions, f.be section directly reports to the Outage Manager ed administratively repurts to the Station Manager.
'
This arr..vgement is not_provided for of described in Technical
'
Specifications.
t
>
Findings As discussed ft/ftem 1 (abwe} the licensee submitted a change to the Technical Specifications to cleaW y define the sttsion organization. The practice of station groups reporting to,it
separate Outage Manager during outages wat Miminated. This item is closed.
'
'
. Item 3 (Closed)
,
The Radiation Protection Plan does not describe functional f
responsibilities for all Radiation Protection Supervisors.
The
Plan serves as the primary program description document and should j
be updated to reflect radiation protection supervisor i
responsibilities.
,
'
Findings The licensee recently (October 30; 19E.7) reorganized his Radiological Controis Organization to provide for enhanced i
management oversight of day to fay activities in all icoctional
'
areas.
The,*ricensee is plannin:j tc develop ard distribeu 6 Radiological Controls Organization charter. Thii; dccument will idstffy all positicas within the organization and provide a description of each position's rssponsibilitih3 and authorities.
The licensee ccmmitted in the Rentart Plan to establistJ4.he definud organization prior to restart.
The licensee vi?) Update other
,
documents, including the Radiation Protection Plan, to reflect the ;
i I
new organization. The licensee plans completion by the end'of 1983.
ltem1(Closed)
s I
Responsibilities in the area of radioactive tir,d c0ntaminated material handling need upgrading and distribution to all station
.\\
sections involved with radioactive material harding, processing and
,
storing.
Consideration should be giv(n to establishing a
'
,
radioactivewastehandling, process (crandshirainggroup.
Findings e
s
As discussed in Item 3 (abave), the lictnsee is establishing a
-
Radiological Controls Organization charter.
This charter will 3'
'
provide a clear description of individual responsibilities in all f
a
't
\\
s
> '
>
.
i
_ _ _ _ _ _ _ _ _ _ - _ _
_ _.. _ - _ _ _ _ _ - _ _.
_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _
Qf
-
i f
g Radiological Controls Program functional areas, including radioactive and contaminated material handling and control. This charter is scheduled to be completed prior to restart.
The licensee is considering, in long range plans, the need to ertablish a separate group whose primary responsibilities will be
,.
radioactive waste handling, processing and shipping.
j, Item 5 (Closed)
An individual with experience in internal dosimetry should be
.obtained. Otherwise, the individual supervising the internal
'-
>
' dosimetry program should be provided additional training. The
'
'
-
current individuals supervising this area have liaited experit: ace in interr.a1 dosimetey.
i Findings
)
,.
I The licensee has hired an individual with experience in internal
' "
dosimetry.
,
,
y
,
Item 6(Clos _ed)
The Senior Radiological Engineer - ALARA position is vacant. This position should be filled in a timely manner by a qualified individual.
Findings The licensee has hired a qualified individual to fill the position of Senior Radiological Engineer - ALARA.
_I._t_em. 7 (Closed)
,
g Personnel are being moved to other positions in the radiation protection technical support area. Movement of personnel in this
,
area should be finalized in a timely manner in order to stabilize
,
and provide consistent oversight of technical support functional area responsibilities.
Findings As discussed in Items 1, 3 and 4 (above), the licensee has established and implemented an enhanced Radiological Cortrols f
Organization.
Personnel have been assigned to appropriate positions within the organization.
Individuals are being hired to fill vacant positions.
3.6 (Closed) Inspection Follow-up Item (50-293/86-19-07)
[
,
This item contained three sub-items. All items were closed.
Vq
f
_ _ _ _ _ _ _ _ _ _ _ _
,.
l
l Item 1(closed]
The licensee had established a procedure for in vitro monitoring for internal exposure controls. However, specific instructions for obtaining fecal samples, and the appropriate analyses for certain isotopes such as transuranic had not been developed at the time of the inspection.
Findings The licensee established and implemented procedures for in vitro monitoring. Specific instructions for obtaining samples, including fecal samples, were established. A check-list, incorporated into the procedure, provides a listing of analyses to be made. This item is closed.
Item 2 (Closed)
The establishment of procedures for comparison of air sample results, whole body count data and respiratory protection should be considered.
Finding The licensee established well defined procedures for use in evaluation of the effectiveness of the internal exposure control program including the respiratory protection program.
Procedures provide for comparison of air sample results, whole body count data and respiratory protection equipment worn.
This item is closed.
Item 3 (Closed)
The appropriate guides and standards for determination of intake of radioactive material have not been referenced in procedures.
Findings The licensee established and implemented an enhanced internal exposure controls program. Appropriate guides and standards were used during development of the program and are referenced in appropriate procedures. This item is closed.
3.7 (0 pen) Inspector Follow-up Item (50-293/86-19-10)
This item contained seven sub-items. The licensee was found to have adequately addressed three of the seven items.
Four items remain open.
Item 1 (0 pen)
An unapproved, unreviewed, instruction is being used by maintenance personnel to provide guidance for decontamination and storage of
___
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _
_ _ _ __- __
_ _ _ -
_
_
_ _ _ _ _ _ _ _ _ _ _ _
..
contaminated tools.
Licensee personnel indicated the instruction will be reviewed and its information will be incorporated into the Radioactive and Contaminated Material Control Program.
Findings The licensee is currently reviewing and evaluating his program for decontamination and storage of tools.
Licensee action on the item will be reviewed during a subsequent inspection.
Item ? (0 pen)
The current radioactive and contaminated material storage program does not contain adequate provisions to ensure that the types and quantities of material stored comply with the limitations imposed by applicable safety evaluations.
Licensee personnel indicated that provisions would be included in applicable procedures to ensure that the type and quantities of material stored are within applicable safety evaluations.
Findings The licensee performed safety evaluations for purposes of determining maximum allowable quantities and types of material to be stored. However, applicable administrative controls, to ensure proper storage within the constraints imposed by the safety evaluations, have not yet been established.
Licensee action on this will be reviewed during a subsequent inspection.
Item 3 (0perd It is not apparent that procedures for establishment of new radioactive and contaminated material storage areas provide for all applicable safety reviews (e.g. fire protection) prior to establishment of the area.
Licensee personnel indicated the procedures for establishment of new storage locations would be reviewed to ensure that all applicable reviews are performed consistent with NRC guidance (e.g. Generic Letter 81-38).
Findings As discussed in Item 2 (above), the licensee performed safety evaluations addressing maximum allowable quantity and type of materials to be stored.
It was not apparent that all applicable criteria from Generic Letter 81-38 were addressed in the safety evaluations (e.g. offsite dose / intake limits for routine operations).
Licensee action on this item will be reviewed during a subsequent inspection.
__
_ _ _ _ _ _ _.__ ____ ___________
..
___-_
_ _ _ _ _ _ _ _ _ _ _ _ _ _.
_
-
.
Item 4 (Closed)
All procedures for receipt of radioactive material did not ensure that appropriate surveys required by 10 CFR 20 would be performed within the time constraints specified therein.
Licensee personnel indicated security procedures would be revised to ensure radiation protection personnel are notified of receipt of radioactive material in a timely fashion to allow them to perform package surveys within 10 CFR 20 time constraints.
Findings The licensee revised applicable security procedures to provide for timely notification of Radiological Controls personnel to allow them to implement radioactive material receipt survey requirements of 10 CFR 20. This item is closed.
Item 5 (0 pen)
Procedures for release of material offsite do not discuss loose or fixed alpha contamination surveys of inaccessible areas, types of alternative surveys for "non-routine" material released (e.g. soil)
offsite; or lower limits of detection for this non-routine material.
Findings The licensee revised applicable procedures for release of material offsite to discuss alpha contamination, surveys of inaccessible areas and alternative " surveys" for "non-routine" material.
However, the licensee's program does not include guidance for performing analyses of "non-routine" type samples to ensure detection of radioactivity at specified lower limits of detection.
The licensee recognizes the need to establish a consistent sample analysis methodology in order to achieve a reasonable lower limit of detection of radioactive material.
Licensee action in this area will be reexamined during a future inspection.
Item 6 (Closed)
Procedures for " direct frisk" of material do not take into consideration mixtures of beta-gamma nuclides and counting efficiencies to be realized for variations in mixtures.
Findings The licensee's instrument counting efficiencies take into consideration current mixtures of beta-gamma nuclides found in the facility.
Licensee procedures now provide for periodic collection and evaluation of representative samples and evaluation of nuclide mixtures for purposes of identifying any changes which may necessitate revising instrument efficiencies. This item is closed.
..
.
__
_ - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _
..
.
}
Item 7 (Closed)
Procedures for counting alpha contamination smears do not address self-absorption corrections.
Findings The licensee performed an analysis of alpha self-absorption factors.
.
Appropriate factors were incorporated into applicable sample l
l counting and analysis procedures. This item is closed.
3.8 (Closed) Inspector Follow-up Item (50-293/86-19-11)
l
'
This item consisted of three sub-items. Two of the items were reviewed and found to have been addressed by the licensee (see Inspection Report No. 50-293/87-40). The following remaining item was reviewed:
Evaluate the capabilities of the well and open calibrators to cover the full range of instrument calibrations.
Findings The licensee purchased a new calibrator. The calibrator will provide usable dose rates up to 6,000 R/hr.
Procedures have been established for operation of the new calibrator. This item is closed.
3.9 (Closed) Inspectcr Follow-up Item (50-293/86-19-12)
.
This item consisted of four sub-items. Three of the four items were
]
previously reviewed and found to have been addressed by the
'
licensee.
(See Inspection Report 50-293/87-40). The following remaining item was reviewed:
Improve instrument counting QA/QC practices.
Findings The licensee revised applicable procedures to upgrade his instrument counting QA/QC procedures.
Procedure revisions include guidance for review of out-of-specification instrument source check data.
This item is closed.
3.10(Closed)InspectorFollow-upItem(heALARAprogram.
50-293/86-19-09)
Various weaknesses were noted in t Item 1 (closed)
Licensee to improve inter-and intra-departmental working relationships and communications regarding ALARA.
---_-_--___--a
. _ _ _ _ _ _ _ _ _ _ _ _ - _
_ _ _ _
_ _ _
_ - _ _
..
..
'
Findings The licensee has completed various actions as discussed under.
Follow-up Item 86-19-01 to improve communications.
In addition, the ALARA goals and ALARA performance of each department is widely distributed and prominently posted. The ALARA Comittee, consisting of section managers and chaired by the Station Manager, serves as a forum for all managers to discuss the ALARA program.
At the working level, the HP coordinators assigned to various departments ensure the' smooth flow of information between the ALARA engineers and the work supervisors.
These actions appear to be effective mechanisms for communication.
Item 2-(Closed)
The ALARA Oversight Comittee meetings are not effective and ALARA Committee meetings are too infrequent.
Findings In the previous 6 months there have been two Oversight Committee meetings and eight ALARA Committee meetings. The inspector reviewed the minutes of these meetings and discussed the meetings with selected attendees.
The existence of an Oversight Committee was in doubt early in 1987.
A policy change was drafted to eliminate this committee.
However, the committee was rechartered by the current Vice President and assigned responsibility for long range goals for the station and establishment of overall policies such as cost per person-Rem guidelines. The ALARA Committee on the other hand has concentrated on analyzing the station exposure status and implementing cost effective dose saving techniques.
For example, a specially designed boroscope has been purchased for the examination of the annulus drain line pipe. This is expected to save 10 person-Rem in each future outage.
Other similar items are on the ALARA Committee agenda. The inspector concluded that both committees are effective.
Item 3 (Closed)
The licensee needs to establish challenging section goals and additional initiatives for dose reduction and vigorous program follow-up and implementation to achieve these goals.
,
l Findings.
All ALARA goals are selected, and approved in accordance with station procedure No. 6.10-016 "ALARA Goals", including section goals, station goals and long range goals. These goals are established following INP0 guidelines and designed to achieve preplanned annual reductions over the long term. Written commitments have been made to INP0 regarding these goals.
i
_ _ _ _ _. _ _ _. _.. _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _... _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ -
- _ _ _ _ _ _ _ - _ _ _ - - _ _ _
.
..
.
.
The goals for each department are determined by the ALARA Committee which also approves adjustments to the goals.
Performance is tracked using the RIMS con.puter program with wide dissemination of the trend data.
Although the station has made a firm commitment to ALARA, set challenging goals, and is actively implementing dose saving measures, the success has been limited by the prolonged outage, and a large number of workers on site. The licensee is performing a critical examination of non-productive time in radiologically controlled areas.
In this context, the licensee's efforts are judged to be satisfactory.
Item 4 (Closed)
There is a need for complete development and implementation of ALARA procedures.
Findings The following ALARA' policies and procedures have been developed:
Policy Statement #20 (Rev. #1), " Corporate ALARA Program",
l
-
l effective 7/24/85, Nuclear Operations Procedure N0P 83 RC1, "ALARA Program",
-
effective 12/3/85, Station Procedure No. 6.10-013, "ALARA Job Reviews", effective
-
6/18/87, Station Procedure No. 6.10-016 "ALARA Goals", effective 2/4/87,
-
,
Station Instruction SI-RP.0100 "ALARA Daily Exposure Review",
-
effective 7/27/87,
Station Instruction SI-RP.0105 "ALARA Reports", effective
-
7/15/87,
-
Station Instruction SI-RP.0205 " Engineering Controls Use l
Criteria", dated 9/23/86 Station Instruction SI-RP.0315 "ALARA In-Process Review", dated
-
7/15/87 Nuclear Engineering Department Specification, " Design Guidance
-
Specification for Radiation and Contamination Reduction at q
Pilgrim Nuclear Power Station" draft.
!
<
l
.
..
.
With the exception of the draft Design Specification for Engineers, the remaining procedures and policies are fully in effect and implemented.
They provide comprehensive guidance for the conduct of the ALARA program.
4.0 Corrective Action Process 4.1 General The inspector reviewed the adequacy, implementation and overall effectiveness of the licensee's corrective action process for self identified radiological occurrences, events, or program weaknesses.
4.2 Radiological Occurrence Reports (ROR)
The inspector reviewed the adequacy, implementation and overall effectiveness of the licensee's ROR Program. This program provides a mechanism to document and track to resolution radiological occurrences, events or program weaknesses.
Evaluation of licensee performance in the area was based on discussions with cognizant personnel, review of original RORs and independent observations by the inspector.
The following documents were reviewed:
Various Radiological Occurrence Reports for 2987, Various Radiological Occurrence Repnrts Monthly Summary
Reports, Various ROR Trend Reports, Various Open ROR Status Reports, l
Various monthly Radiological Assessor Reports,
'
Various reports of the Independent Radiological Oversight Committee.
Findings Within the scope of this review, no violations were identified.
The following positive observations were identified:
The licensee has established a Radiological Occurrence Report (ROR) program for use in documenting and tracking to resolution identified radiological concerns.
The concerns are included in one of 26 categories.
4
. _ _ _ _ - _ _ _ _ _ _ _ _ _ _
_
..
.
Monthly trend summary reports of R0Rs are provided to senior management. The summary reports include graphical summaries of trends.
The licensee has established a two week target date for
resolution of R0Rs. A status summary of open RORs is provided to senior management on a monthly basis.
Licensee Radiological Control personnel were encouraged to document all identified weaknesses, including unplanned exposures of personnel, by issuance of an ROR.
Station personnel are provided training on the ROR Program in general employee training.
!
A total of about 1100 Radiological Occurrence Reports
!
(RORs) have been issued in 1987.
Approximately 50% of the RORs are associated with minor contamination events.
'
The majority of RORs reviewed documented minor breakdowns in radiological controls.
Licensee incident / event corrective actions were generally l
aggressive. Corrective actions noted included cessation
'
of work activities, suspension and termination of personnel, written reprimands and retraining of personnel.
Corrective action included worker and supervisor meetings with Station Management to discuss concerns prior to allowing workers to return to work.
Conclusion Within the scope of this review, no violations were identified.
The overall quality of RORs and corrective actions taken have substantially improved.
R0Rs are generally resolved in a timely manner. Senior management actively monitors the R0R Program. Aggressive corrective action is generally taken for identified deficiencies, particularly in the area of personnel performance weaknesses.
4.3 Other Corrective Actions Programs The inspector reviewed and discussed other licensee initiatives for monitoring implementation and effectiveriess of the Radiological Controls Program.
The following was noted:
The licensee uses two Radiological Assessors tc monitor radiological work activities. The assessors meet weekly with j
senior management to discuss findings / observations. Monthly assessment reports are provided to senior management.
_
_ _.
..
,.
.
.
Oversight of in-field activities by the Assessors was considered aggressive and thorough.
The iicensee uses the Radiological Assessors to perform
independent reviews of selected areas (e.g. resin spills, control of maintenance contractors).
Reports of the special reviews are provided to senior management._.The Assessors.
I visited other utilities in an effort to identify positive I
attributes for review and potential use by the licensee.
The licensee continues to maintain the Independent Radiological Oversight Committee. This committee provides recommendations for program improvement to senior management.
,
The licensee has established a performance excellence team (PET). The PET meets every two weeks to review identified problems and concerns. The PET tracks 9 areas as performance indicators. The. number, significance and recurrence of Radiological Occurrence Reports is discussed at the PET meeting.
The licensee's PET has instituted a number of new initiatives to enhance performance monitoring.
These include review of the magnitude of " rework" and development of indicators to monitor " rework" as well as review of the number of jobs scheduled to be worked but not actually worked. These items provide an indication of worker productivity which may ultimately affect station exposure.
Conclusion Within the scope of this review, no violations were identified.
The licensee was actively using independent methods of verifying the implementation, adequacy and effectiveness of the Radiological Controls Program throughout all station organizational areas (e.g. maintenances operations).
New initiatives by senior management (e.g. Performance Excellence Teams) appear to be functioning to aggressively monitor station performance indicators and improve overall performance.
5.0 Plant Tours
The inspector toured the Radiological Control Areas at various times during the inspection. The following areas were reviewed:
housekeeping contamination control radioactive and contaminated material control
personnel frisking and dosimetry j
posting, barricading and access control (as appropriate) of
radiation and high radiation areas
_ _ _ _ _ _ - _ _ _ _ _ _ _ _
,.
..
l
adequacy and implementation of radiation work permits ALARA controls respiratory protective equipment issuance and use radiological surveys The review was with respect to criteria in applicable regulatory requirements and licensee procedures.
Licensee performance in these areas was determined by observation of on-going work, discussions with personnel and review of documentation.
Within the scope of this review, no violations were identified.
Licensee performance in each of the above areas was found to have generally improved.
Within the scope of this review, the following item for improvement was identified:
At about 10:00 p.m. on November 3,1987, the inspector observed
'
set-up for insper. tion and replacement, if necessary, of reactor thermocouple located about two feet below the Reactor Head Flange.
The set up included removal, via pump down, of about two feet of water between the reactor vessel and inner bellows. The inspector noted a weakness in ALARA controls in that a worker manually inserted a suction hose into the water to be drained. Sludge, that had accumulated in this area, was suctioned out with the water. The sludge was later determined to have a contact dose rate of up to 10 R/hr.
Inspector discussions with a Radiation Protection Supervisor indicated that he assumed that a long handled tool would be used to position the hose to keep the hose away from the hands and body.
The inspector discussed this with the licensee's Radiation Protection Manager.
The licensee's Radiation Protection Manager concurred with the inspector's observations and indicated this matter would be reviewed and appropriate actions taken.
6.0 Radiation Work Permits The licensee has a Radiation Work Permit system to assure compliance with 10 CFR 20. Technical Specification 6.8 and Regulatory Guide 1.33.
Weaknesses noted with this system in NRC Inspection Report, open item No.
86-19-04 included:
frequent use of Priority "A" processing; a large number of RWPs issued but not worked and failure to cancel RWPs when work is completed. This is a RIP related item.
The current status of the R'WP system was determined from interviews with control point technicians, HP Coordinators, the Senior HP Operations Supervisor, Radiological Operations Group Leader, Chief Operations Engineer, review of issued RWP, and tours of work areas.
i
_ - - _ _ _ _ _ _ _ _ - _
..
+
.
.
Under the current system all RWP requests are channeled through the HP Coordinator assigned to the group performing the work.
The Coordinator then processes the request through the ALARA and Radiological Operations (Rad OPS) to ensure that an RWP is available when the work is scheduled to begin. Once issued, the RWP remains active until the Coordinator notifies Rad OPS that work is complete.
In spite of these controls, up to 50% of the issued RWPs are often unused.
It appears that the lead time required to obtain an RWP causes the work groups to request RWPs for work that is later cancelled or rescheduled.
The status of all RWP's is tracked by a computer program called Radiological Information Management System (RIMS).
Each week the Senior Rad OPS Supervisor reviews the complete RIMS list of RWPs with the coordinators and cancels unused and completed RWPs.
The licensee stated that a new system is under consideration to issue RWPs with a fixed duration (e.g. I shift) rather than conducting a weekly purge of unnecessary RWPs.
The use of "A priority" RWPs by the operating group has been limited.
The Chief Operations Engineer advised that use has been restricted to minor repair on critical systems.
Furthermore, the Operations Department is developing a special procedure specifically for the repair of-leaks to minimize the spread of contamination. This special procedure will be coordinated with the RWP procedure to reduce the use of "A priority" RWPs.
1he inspector noted that the licensee has taken action to improve the use of RWPs but that the system is inherently cumbersome and inefficient.
The licensee has been actively seeking ways to improve the system through discussions with other stations and written suggestions from the HP technicians and staff.
However, changes to the RWP system have been postponed until the current outage is complete to minimize the impact on worker safety.
Upgrades in the RWP system will be reviewed in a future inspection.
7.0 Exit Meetings The inspectors met with licensee personnel denoted in Section 1 of this report on November 5, 1987. The inspectors summarized the purpose, scope and findings of the inspection. No written material was provided to the licensee.
. - _ _
.__ ______ - -_ - ___ _ -