IR 05000295/1988011

Insp Repts 50-295/88-11 & 50-304/88-12 on 880418-29.No Violations or Deviations Noted.Major Areas Inspected: Radiation Protection Program During Refueling/Maint Outage, Including,Organization & Mgt Controls

ML20155D515
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	05/26/1988
From:	Greger L, Michael Kunowski, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20155D513	List: IR 05000295/1988011 ML20155D507
References
50-295-88-11, 50-304-88-12, GL-82-12, NUDOCS 8806150225
Download: ML20155D515 (19)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-295/88011(DRSS); 50-304/88012(0!'.SS)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; OPR-48 Licensee: Commonwealth Edison Company Fost Office Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion Site, Zion, Illinois Inspection Conducted: April 18-29, 1988

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Inspectors: W S f!L6[88 '

Da t'e

[ 8 M7 M. A. Kunowski

' cv G,yhr'

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. ? Yll fA Approved By: L. Robert Greger, Chief 6b(/P[

Facilities Radiation Protection

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Dat'e Section Inspection Summary Inspection on April 18-29, 1988 (Reports No. 50-295/88011(DRSS);

No. 50-304/88012(ORSS))

Areas Inspected: Routine, announced inspection of the radiation protection program during a refueling / maintenance outage, including: organization and management controls (IP 83722); changes in organization, personnel, facilities, equipment, and procedures (IP 83729); planning and preparation (IP 83729);

training and qualifications of contractor personnel (IP 83729); internal and external exposure controis (IP 83729); control of radioactive materials and contamination (IP 83729); audits and appraisals (IP 83729); and the ALARA program (IP 83729). Also reviewed were previous open items (IP 92701) and a containment evacuation event (IP 83729).

Results: No violations or deviations were identified. During the Unit 1 maintenance / refueling outage, implementation of the radiological control program was generally good; however, improvements appear to be needed in the licensee's oversight and control of contractor activities. The station exposure for the outage exceeded that projected primarily because of significant unexpected wor {DR ADOCK0500g5 )

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DETAILS 1. Persons Contacteg

• R. Budowle, Assistant Superintendent, Technical Staff

• K. Hall, Health Physicist, Technical Services

• P. LeBlond, Rad / Chem Supervisor

• G. Plim1, Station Manager

• D. Principe, ALARA Coordinator

• T. Rieck, Superintendent, Services

• T. Saksefski, Regulatory Assurance

• C. Schultz, Quality Control

• T. VanDeVort, Quality Assurance

• V. Williams, Lead Health Physicist The inspectors also contacted other licensee and contractor employees, including rad / chem technicians and members of the technical staf * Denotes those present at the exit meeting on April 29, 1988.

2. Genera'

This inspection, which began on April 18, 1988, was conducted to review the radiation protection program during a refueling and maintenance outage, including organization and management controls, planning and preparation, qualifications and training, internal and external exposure controls, control of radioactive material and contamination, audits and appraisals, and the ALARA program. Also reviewed were open items and a containment evacuation event. The Unit I refueling / maintenance outage began on February 24, 1988 and is scheduled for completion the week of May 2, 1988. During plant tours, no significant access control, posting, or procedure adherence problems were identified; housekeeping was adequat . Licensee Action on Previous Inspection Findings (IP 92701 and 92702)

(0 pen) Open Items (50-295/85034-02; 50-304/85036-02 and 50-295/85034-03; 50-304/85036-03): Establish a radiation monitoring program and monitor sump runoff, respectively, for the interim radwaste storage facility (IRSF). The procedures developed for these purposes are undergoing on-site review by the licensee and will be reviewed by the NRC at a future inspectio (Closed) Open Item (50-295/86025-01; 50-304/86025-01): Improve optration of the laundry f acility, training of applicable personnel, and procedural adherence. The licensee has provided formalized stationman training, as described in Reports Nos. (295-87037; 304/87038). New properly sized motors have been installed in the laundry units and procedures have been revised to reduce the size of an average laundry load from 35 coveralls to 24. During this outage, licensee laundry was cleaned in vendor

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I wet-washing and' dry-cleaning units, and monitored for contamination with

' vendor-supplied monitors. According to licensee representatives, similar vendor equipment will be used for the upcoming Unit 2 outage. The

, licensee plans to purchase a laundry monitor by 198 (Closed) Open Item (50-295/87037-02: 50-304/87038-021: Improv6  :

documentation of Radiological Occurrence Reports (R0Rs). A review of RORs written in 1988 indicated documentation has improve (0 pen) Unresolved Item (50-295/87037-01; 50-304/87038-01): Review adequacy i.

of pipe chase survey frequencies and locations related to the performance of fire watches and performance tests (pts) in the area and appropriateness of RWPs governing such activities. This issue remains open pending modification of station procedure ZRP 1520-2 and review of implementation of the RWPs-governing the performance of routine and non-routine pt This matter is further discussed in Section 13(e).

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4. Organization t.nd Management Controls (IP 83722)

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The inspectors reviewed the licensee's organization and management controls for the radiation protection program including: chang e in the organizational structure and staffing, oversight of contractor activities

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during the Unit 1 outage, effectiveness of procedures and other management techniques used to implement these programs, and experience concerning self-identification and correction of program implementation weaknesse The organizational changes anticipated in the Rad / Chem Department have occurred (Inspection Reports No. 295/87037; No. 304/87038). The new Rad / Chem Supervisor possesses an operator's license and is a degreed engineer with more than ten years station and corporate technical and j supervisory experience; however, the individual ooes not have significant applied health physics or chemistry experience. The Rad / Chem Supervisor administers and has overall responsibility for health physics and chemistry group activities. This individual plans to attend a formal health physics /

radiation protection course in the near future. The station's Lead Health

Physicist reports to the Rad / Chem Supervisor and was recently appointed the Radiation Protection Manager (RPM). This individual meets Regulatory

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Guide 1.8, September 1975 requirements for RPM and supervises activities of the radiation protection group including resolution of day-to-day technical issues. The new RPM appointment satisfies Technical

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Specification 6.1.4 which requires that the Rad / Chem Supervisor or Lead Health Physicist meet the qualifications of RPM outlined in the aforementioned Regulatory Guid The RPM appears to have direct access j to the Station Manager for matters related to radiation protectio The station's Rad / Chem Technician (RCT) staff has remained fairly stable

during the last several years. Currently there are 34 permanent RCTs; one recently terminated employment. All RCTs but one have greater than two years of applicable experience and meet the selectica criteria stated

' in ANSI N18.1-1971 for technicians in responsible positions. The

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exception is approaching two years RCT experienc One vacated Rad / Chem Foreman position, resulting from an October 1987 transfer into the I station's ALARA staff, remains ope The licensee stated that contractor reliance for maintenance, repair and radiation protection activities was greater than in previous outages and ir.:luded contract groups not previously used at the station. Maintenance /

repair activities previously performed by station departments were assumed primarily by the reactor vendo Implementation of the radiological controls program was generally good; however, improvements appear necessary in the licensee's oversight and control of contractor activities as evidenced by the examples described in Sections 11 and 12. This matter was discussed with the licensee during the inspection and at the exit meetin No violations or deviations were identifie . Changes (IP 83729)

The inspectors reviewed changes in the station's organization, personnel, facilities, equipment, programs, and procedures that may affect radiation protection during the outage. Changes in organization and personnel are discussed in Sections 4 and A major change for this outage was the use of one vendor, Westinghouse Electric Corporation, to perform the majority of the maintenance, including that done on the reactor head. For previous outages, most maintenance tasks were performed by station personnel. Westinghouse also provided radiation protection technician support, through its Numanco, Inc., subsidiary; and respirator washing and protective clothing (PC)

laundry facilities through Hydro Nuclear Services, In During the outage, the station RCTs and rad / chem foreman were typically working at least 10-hour days, six days per week. Usually, one foreman was assigned to the radiation protection office (RCA access) and one to containment activities. The health physicists and engineering assistants also worked extended hours and provided backshift coverage. During peak outage periods, the ALARA office was continuously staffed except from 1:30 a.m. to 5:30 a.m. These working hours, although extensive, are generally within Generic Letter 82-12 guideline The station's laundry facility was augmented with vendor supplied wet-and dry-cleaning units; a mask cleaning unit was also provided. Trailers housing the three units were parked outside but connected to and accessed from the auxiliary buildin Two automated laundry frisker ( ALF) systems were also provided by the vendor and were used in the auxiliary building near the entrance to the trailer No violations or deviations were identifie . . . . -. -- - -_- .. - -

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6. Planning and preparation (IP 83729]

The inspectors reviewed the outage planning and preparation performed by the licensee, including: additional staffing, special training, increased equipment supplies, and job related health physics consideration The station's radiation protection group has been augmented with-79 contract health physics personnel consisting of 44 senior, 22 junior,

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and nine control point technicians, three shift supervisors, and a site coordinator. At the time of this inspection, all but approximately 12 radiation protection contractor personnel remained at the statio The inspectors vertf.ied that those technicians not meeting ANSI N18.1-1971 selection criteria were not providing radiation protection duties without proper supervision. For the outage, station rad / chem foremen coordinate radiation protection technician activities and monitor containment activities during peak periods. Also, members of the health physics and ALARA staffs periodically rove containment and provide near continuous station coverage, typically working 10 to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days, six days per wee Radiation protection participation in job planning and preparation includes ALARA training and pre-job briefings to station and contract workers, decontamination, installation of shielding, use of remote cutting and welding equipment and other ALARA measures, and ALARA and health physics participation in planning and daily outage meeting The ALARA program is discussed in Section 1 No violations or deviations were identifie . Trainino and Qualifications of New personnel (IP 83729)

The inspectors reviewed the licensee's selection criteria and the education and experience qualifications of contract radiation protection personnel. The training provided to the technicians by the licensee was also reviewe Licensee selection of contractor radiation protection technicians includes a review of resumes to determine conformance to ANSI N18.1-1971 criteria. According to the licensee, verification of resume accuracy is the responsibility of the contract technician vendor; however, the licensee's health physics staff selectively contacts facilities where contract technician candidates have recently worked. The inspectors informed the licensee of the desirability for 100*4 verification of contract personnel experience and qualifications through con?.ract vendor certification or equivalent and a licensee program for resume spot-checking. Selected resumes of contract technicians working at Zion during the current outage were reviewed by the inspectors; no problems were note After the contractor technicians arrived at Zion, they were required to complete Nuclear-General Employee Training (NGET), respiratory training, and training in Zion radiation protection administrative and implementing procedures. To be designated a senior technician, an individual must

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have the necessary experience and score above 80% ou a health physics problem-solving exam and a station procedures exam. Junior technicians must score at least 70% on both tests. Control point technicians, primarily responsible for dose card time-keeping and observing workers to ensure proper PC removal, were administered both tests but not required to achieve minimum scores. Training of the technicians was coordinated by the licensee and conducted by two contractor representatives who had worked at Zion previously. The inspectors reviewed the 20 question problem solving exam and the 10 question procedures exam; questions ranged in difficulty and overall were moderately difficul Prior to the start of tb3 outage, the licensee's radiation protection and ALARA groups conducted ALARA awareness training sessions for all contractors (Section 15).

No violations or deviations were identifie . External Exposure Control and Personal Dosimetry (IP 83729)

The inspectors reviewed the licensee's external exposure control and personal dosimetry program, including: char.ges in facilities, equipment, personnel, and procedures and adequacy of the dosimetry program to meet outage need There have been no significant changes in the licensee's external exposure measurement and control program since previously reported

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(Inspection Reports No. 295/87037; No. 304/87038). While the station's exposure of approximately 675 person-rem for 1988 to date has nearly exceeded the 1988 annual goal of 680, the station appears to be making strong efforts to keep exposures ALARA, particularly through training and job planning (Section 15). For 1987, the station's total dose expenditure essentially met their goal of 650 person-re During this outage, the licensee purchased an additional 50 electronic dosimeters and used them extensively, including on the reactor head repair jo These dosimeters were used in addition to the routinely used thermoluminescent dosimeter (TLD) and self-reading dosimeter (SRD).

The licensee had previously evaluated this new model of electronic dosimeter during the last Unit 2 refueling outage (Reports No. 295/87037; No. 304/87038) and plans to eventually substitute them for SRDs in certain jobs requiring multiple dosimetr During this inspection, licensee representatives stated they were very satisfied with the performance of the naw electronic dosimetry syste To initially record daily SRD dose, the licensee uses dose card White cards are used by workers on the two day shifts and colored cards are used by workers on the night shift. The cards are colored differently to aid in data entr To further enhance dose tracking capabilities, the licensee plans to modify its computer software. Progress on the modification will be reviewed at a future inspectio No violations or deviations were identifie _ _ _ _ - . - - . - _ . . - - - - - _ . _ .

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' Internal Exposure Controls (IP 83729)

The inspectors reviewed selected aspects of the licensee's internal exposure control and assessment programs including: determination whether engineering controls, respiratcry equipment, and assessment cf 3 intakes meet regulatory requirements, and planning and preparation for '

maintenance and refueling tasks including ALARA considerations. The .

respiratory protection program is discussed in Section 1 RWPs, air activity surveys, and MPC-hour determinations for 1988 to date I were selectively reviewed; no significant problems were noted, RWPs appeared to adequately reflect the respiratory protection requirements for the jo Provisions are made during the respirator issuance and "

return cycle for MPC-hour accountabilit The inspectors reviewed the licensee's program for containment air sampling during the outage. General area low volume air samplers are normally in continuous operation on the 617-and 560-levels of containment and a continuous air monitor (CAM) is maintained on the 592-leve Samples are pulled and analyzed at least once per shift. A SPING sample point located at the 617-level near the equipment hatch also monitors the general containment atmosphere. The CAM and SPING alarm setpoints are set sufficiently low (about three times background) to i alert the licensee of potential problems. Job specific particulate anc iodine grab air samples are obtained during activities involving cutting, grinding, welding, and other work on highly contaminated materials, or

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that involve opening of process lines. This includes air samples drawn  ;

from the steam generator manways and HEPA filter exhausts and CAMS positioned on steam generator platforms. Generally, the containment air  :

sampling methods and equipment in use during the refueling outage are adequate and comply with station Procedure ZRP 1810-5, "Containment Air  :

Sampling During a Refueling Outage." .

Shortly before the outage commenced, the station installed and made operational a new "Fastscan" whole body counter and associated -

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hardware / software. The unit is located in the service building and is operated primarily by station RCTs. According to the licensee, the new system has operated satisfactorily and has virtually eliminated the

backlog and downtime problems associated with their older lay-down

counter The older unit is being maintained as a backup to the new .

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' system and for it's locational, organ specific, detection capabilitie Calibration of the fastscan system will be reviewed during a 'uture inspection (0 pen Item 295/88011-01; 304/88012-01).

No violations or deviations were identified.

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1 Respiratory protection Program (IP 83725, 83729)

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The inspectors toured the respirator storage and distribution facility

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located at the auxiliary building entrance and the vendor supplied respirator cleaning facility (trailer), and discussed the respiratory

protection program with members of the station's training and health

physics staffs and with workers issuing and cleaning respiratory

, protection equipment.

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A review of procedures and discussions with licensee representatives disclosed the lack of a written station policy addressing the acceptance of respiratory protection training received at CECO plants and the necessity and frequency of respirator re-training. Station training department persor.nel indicated that Zion site-specific respirator training is desirable and should be required regardless of previous training because of equipment differences and availability at the various static.s. This viewpoint appears to be consistent with corporate guidance, NSHP RP Guidance 1310-1, Respirator Trainin Training department personnel stated that site-specific respirator training is also necessary because of the la:k of consistency among the respiratory training programs at the various Ceco stations. They further stated that the radiation protection department had orally agreed to issae respirators only to individuals who have completed Zion site-specific respirator trainin However, when several individuals within the radiation protection department were queried by the inspectors on this matter, they were unaware of it. Also, the station's administrative procedure on training, ZAP 2-52-1, and the radiation protection implementing procedures do not contain such restriction The inspectors cursorily reviewed and discussed the site-specific respiratory protection training program and viewed a brief video on PC/ respirator removal. The inspectors noted that the respirator removal method being taught by NGET instructors was different from that shown in the NGET video and also noted minor discrepancies between the video and Procedure ZRP 1330-1, "Wearing Protective Clothing," concerning PC removal. At the exit meeting, the licensee agreed to clarify and formalize requirements regarding site-specific respirator training and the frequency of re-training and rectify the apparent discrepancies in instructions on respirator and PC removal. This matter will be reviewed at a future inspection (0 pen Item No. 295/88011-02; 304/S8012-02).

Respiratory protection equipment is maintained and issued at the mask room located at the entrance to the auxiliary building. During this outage, the room is manned 24-hours per day by stationmen specifically instructed to perform relevant task To obtain respiratory protection equipment from the rad / chem department, the prospective user must submit their NGET card or equivalent to the stationman working the mask roo The NGET card is checked for current medical qualification (annual) and mask fit approval (three years) stickers applied to the back of the cards and that respiratory protection training for the type of equipment requested is noted on the card. As previously mentioned, however, the issuer does not necessarily verify that respiratory protection training is station specific. The issuer also verifies that full-face respirator users are clean shaven around the area of the seal. After verification is complete, masks are issued by serial number and documented in a respiratory equipment log book indicating individual assigned, work location, RWP number, and date/ time out. When returned after use, stationmen verify that the returned equipment is the same as that issued and survey for the presence of smearable and fixed contaminatio Any smearble contamination on the inside of a respirator or around outer seal areas is reported to rad / chem supervision. An appropriate (time-in)

entry is then made in the log book and the users NGET card is returne The inspectors observed NGET card verification and mask surveys being performed; no problems were note O

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During the outage, a vendor supplied and operated respiratory protection wet washing and drying facility is used. After washing / drying, respirators are checked for contamination, sanitized and individually stored in plastic bags for issuance. No problems were noted with respirator cleaning, dryirg, or sanitizing methods. Afterwards, masks are inspected by rad / chem to ensure integrity and assembly. An arbitrary 6-month shelf-life is placed on open canister For this outage, the licensee set-up a short-term respirator storage area located in the auxiliary building PC equipment and change area. During lunch or other break periods, respirator users that egress containment are required to transfer their bagged respirators to an RCT stationed at the south exit of the crosstown area. The RCT smears the masks. double bags them, and marks the wearer's badge number on the ba Bagged masks are then hung on boards in the short-term storage area for reuse after breaks. Rad / Chem supervision is notified if smears of masks indicate any smearable contamination on the inside surfaces, around outer seal areas, or greater than 5000 dpm on outside surfaces. The inspectors verified general compliance with these requirements but did note several instances where worker badge numbers or other identifying information was not denoted on bagged respirators. During several plant tours, the inspectors did not observe any instances of respirators being incorrectly used or stored, or unaccounted fo No violations or deviations were identifie . Radiation Occurrence Reports (90Rs)

The inspectors reviewed Radiation Occurrence Reports (RORs) generated in 1988 through April 17. There were 50 RORs written during this period, about one-half remain open pending further licensee investigation and corrective action. RORs are normally assigned to the licensee's health physics staff for followup and corrective action recommendation and routed to licensee management for review and concurrence. It appears the licensee gives sufficient management attention to ROR followu RORs are typically written for f ailure to follow RWP requirements, contamination control problems, and for discovery of radiological control practices contrary to accepted or established licensee method The RORs were selectively reviewed for significance and adequacy and timeliness of corrective actions. Problems identified in closed RORs appear to be adequately addressed, documented, and corrected. The inspectors noted that about 20*. of the RORs generated in 1988 were written for minor infractions which could probably have been more readily resolved through less formal channels and did not appear to have the radiological significance for ROR initiation as intended by procedur This matter was discussed at the exit meetin Several RORs generated during the outage were written against contract personnel for failure to follow procedures and for identification of activities which did not conform to pre-established or arranged radiological control practices. Two such events are described below, a third is described in Section 12. These events appear to indicate a need for improved oversight of contractor activitie i

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'ROR No.88-026 On March 18, 1988, a worker performing insulatien removal in preparation for ISI work inside the missile barrier was found by the licensee to be wearing electronic dosimetry in a location different from that dictated ,

by licensee health physics practices. The worker's primary (TLD) and secondary (SRD) dosimetry were appropriately located in the anticipated most conservative exposure area, atop the worker's head; however, an alarming electronic dosimeter used primarily to alert the licensee of approaching administrative exposure limits, was located on the worker's upper arm instead of atop his head, even though the worker's dosimetry placement was reportedly checked by contract technicians providing intermittent job coverage on that and previous days. Although no licensee procedures apparently were violated (neither the RWP nor relevant procedures address electronic dosimetry placement) or regulatory exposure limits exceeded, the worker's SRO registered a 380 mrem exposure which

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exceeded the workers 300 mrem administrative limit for the day. The exposure was discovered after the worker was instructed by the contract job coverage technicia.1 to read his SRD. The worker's electronic dosimeter registered about 240 mrem and alarmed as the individual was leaving the work area. According to the licensee, this was the only administrative overexposure that occurred during the outag ROR No.88-041 On April 8,1988, two laborers received 260 and 215 mrem whole body exposures respectively, while cleaning the reactor head using methods contrary to those verbally agreed to prior to the start of the jo The RWP for the activity encompassed a broad spectrum of reactor head work and did not specifically address the cleaning aspects. According to the licensee, contract and licensee foreman agreed to clean the reactor head using a vacuum with extension pieces. The vacuum equipment was previously used to perform similar work and if performed as agreed, was projected to entail about 50-70 mrem for each laborer. Unbeknownst to the licensee, a contract supervisor apparently decided to expedite the job and instructed the laborers to wipe down the reactor head by hand and not wait for the ,

vacuum to be set-up by the licensee. This exposed the laborers to higher'

dose rates than were anticipate Summary These events and resultant unnecessary exposures may have been averted had the licensae provided better oversight of contractor activities and been more explicit in the RWPs governing the jobs. These matters were discussed at the exit meetin No violations or deviations were identifie .

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12. Containment Evacuation Event Background Information During the outage, the licensee identified boron crystals in three separate locations around the reactor vessel head closure studs and subsequently determined the problem to be associated with control rod drive (CRD) housing weld failures. To rectify the protiem, the licensee and reactor vendor decided to cut-off certain spare anc part-length CRDs below the leakage area and weld caps over the cut-off portions. The job commenced under RWP No. 80406A on or about March 28, 198 The job was performed by the reactor vendor with continual radiation protection coverage provided primarily by contract RCT Radiolt c: invironment and Event Description Smearat s 'sta/ gamma :ontamination levels on the reactor head were generalb, about 100,000 dpm, with maximum contact dose rates about 3R/hr. General containment area air sampling / monitoring equipment was set-up and operated pursuant to procedure ZRP 1810-5 (Jescribed in Section 9). Job specific work area air samples were obtained throughout various phases of the job. Worke~ 'erforming aspects of the job which involved welding, flame cutting, u ng o- 5 eating were equipped with supplied air, full-face respiratco . cts c u ering the activiti.5 were normally stationed about 15-feet from the work activity, (immediately outside the area requiring respiratory protection) but could easily viev the workers, provide instructions, and perform surveys as necessar Three CRDs were cut using remotely operated equipment and two were subsequently capped using a robotic welder. According to the licensee, shielding and other ALARA measures were used whenever possible, including local HEPA filtered exhaust systems which were set-up and used during cutting and cap welding operations. No problems reportedly occurred during the cutting oc welding operation On the evening of April 3,1988, the particulate char.1el of the containment SPING (617-level) alarmed high as did the CAM located on the 592-level. The alarm setpoints on the SPING and CAM are set sufficiently low (about three times background) to a'2rc the licensee to potential problems. The containment was evacuated and additional air samples were obtained. Air samples pulled from various general containment areas and in the general vicinity of the reactor head during and subsequent to the event showed maximum concentrations of about 0.5 MPC Co-60. All individuals evacuated from containment and those working in the vertical pipe chases at the time of the event were whole body counted, no internal deposition or significant external contamination was identified. The event was reported to the NRC resident inspector and documented internally in ROR No. 88-4 Apparently, after capping (welding) two of the CRDs, the reactor vendor determined that "touch-up" grinding / polishing on the cap welds was necessary. This evolution was not previously anticipated or specifically planned by the licensee; rather it was decided upon at the job sit The

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contract RCT providing radiation protection coverage for the job allowed the evolution on .the two capped CRDs to be performad even though the technician indicated he was initially reluctant to allow use of an air-operated grinding tool; reportedly, no other suitable type of grinding tool was available.. According to the RCT, the worker completed the "touch-up" work on the two capped CRDs; then without the RCTs concurrence proceeded to perform similar grinding on the u.. capped CR The SPING reportedly alarmed shortly thereafte ,

Root Cause Licensee and NRC investigation determined the event to be caused by use of the air-operated, grinding tool (which exhausted air onto the reactor head surface) coupled with a failure to use available local ventilation filtration systems during the grinding / polishing evolutio The elevated containment airborne activity ..s apparently caused when the air discharge from the. grinding tool blew the loose contamination atop the reac+.or head into the containment atmosphere. This scenario was validated by air sample results which showed similar radionuclide content (predominantly Co-60, some Mn-54, and the absence of fission products) to that seen on smears of the reactar head. The loose activity withi the uncapped CRD, although significantly higher (about 3E6 dptr) than gueral reactor head areas, was composed of various fission products, and therefore apparently was not the source of the elevated airborne concentrations.

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-Summary and Corrective Action Two HEPA filtered local ventilation systems (1000 and 500 cfm respectively)

set-up in containment and readily available for use during the reactor head operations were not used during the "touch-up" work. Neither tne RWP nor the ALARA review or pre-job meeting minutes specifically addressed l the use of the ventilation system. Also, there are no procedures or precautions governing the use of air operated tools in highly smearable

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areas. It does not appear that any licensee procedures or regulatory requirements were violate This event arci the two previously discussed in Section 11 are examples that indicate the apparant need for strengthening licensee oversight, controls, and communications with contractors, including contract RCT These matters were discussed at the exit meeting. The corrective actions taken as a result of the containment evacuation event will be reviewed l during a future inspection (0 pen Item 295/88011-03; 304/88012-03).

1 Control of Radioactive Materials and Contamination (IP 83729)

The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including: changes in instrumentation, equipment, and procedures; effectiveness of survey methods, practices, equipment, and procedures; effectiveness of methods of control of l radioactive and contaminated materials; management techniques used to L implement the program; and experience concerning self-identification and l correction of program irrplementation weaknesses.

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. Whole Body Frisking Prior to the outage, the station purchased and made operational two additional IPM-7 whole body frisker unit One new unit was installed at the auxiliary building exit on the 617-level, the other placed in the auxiliary building near the containment exi In addition, the licensee installed a Nuclear Enterprises prototype walk-through portal monitor at the guard house to supplement the two IRT monitors normally used and to test the prototype uni According to the licensee, the prototype monitar has detection capa'ilities o superior to.their older units and has functioned satisfactorily throughout the outage. The licensee eventually plans to replace their IRT portal monitors with a production version of the prototype unit.

The station's principle ingress and egress control point to the radiologically controlled area (RCA) is located at the 617-level of the auxiliary building adjacent to the radiation protection offices. Whole body contamination monitors are situated such that workers exiting containment must pass through an IPM-7 frisker in

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their street clothes prior to leaving the RC Individuals leaving the RCA must also pass through an IRT portal monitor located just outside the auxiliary building exit, Laundry Facilities For the outage, the licensee contracted PC and respirator cleaning to a vendor. The licensee's laundry facilities were not used during the outage. Vendor trailers were set-up outside but connected to the auxiliary building, facilitating laundry collection and distribution. The trailers are maintained at negative pressure with respect to the outside atmosphere and positive to the auxiliary building. The vendor's equipment includes two wet-wash and dry cleaning units and two automated gas flow proportional laundry monitors. Prior to the outage, the vendor wet-washed the licensee's existing supply of PCs; new PC's were also purchased for the outag The vendor set-up and calibrated the laundry monitor; alarm setpoints were established by the vandor in accordance with licensee instructions. The inspectors reviewed the monitor calibrations and i setpoint determination and discussed them with the licensee. During the early stages of the outage, the monitor alarm setpoint was established at 230 nCi using a mixed Co-60/Cs-137 point source. The setpoint was subsequently reduced to about 175 nC1, which is also the current settin It appears that a laundered coverall containing a hot particle on it's inside surfaces, with an activity equivalent to the current monitor alarm setpoint, could go undetected since the

, particle would be attenuated by the clothing and most PCs are not

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monitored inside-ou (About 10% of laundered clothing is monitored inside-out.) This could produce a significant skin dose should the f

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particle remain affixed to the inside of the PC and worn for several hour This matter was discussed during the inspection. The station plans to purchase a laundry monitor in 1988. It will be used (alarm setpoint and monitoring methods) in accordance with recently issued corporate guidance. This guidance was reviewed by the inspectors; no problems were noted. These matters were discussed at the exit meeting and will be reviewed during a future inspection (0 pen Item 295/88011-04;.304/88012-04). The laundry vendor reportedly will remain onsite for a couple weeks after conclusion of the outag c. Personnel Contamination / Hot Darticle Incidents Personnel contamination event reporting methods, procedures and skin dose determinations remain as previously described (Inspection Reports No. 295/87037; 304/87038). The inspectors selectively reviewed personnel contamination incident reports generated from November 1987 to date. There were 112 personal contamination incidents reported in 1988 through April 20; 227 were reported for calendar year 1987. Most of the 1988 contamination events occurred in March during peak outage activities and involved low-level contamination caused primarily by improper radiological work practices. The number of contamination events reported thus far in 1988 is similar to that reported during peak activities during outages in 1986/87. A reduction was noted however, in the number of contamination events reported during non-outage periods in 1988. In an effort to communicate the importance of proper adherence to radiological controls, the licensee's health physics staff sent letters to supervisory personnel of those contract groups responsible for the majority of the outage contamination event Also, the licensee tracks repetitive groups and individuals and can take more stringent disciplinary action if warrante Fourteen hot particle events were reported in 1988 through April 19; several of those events were reviewed by the inspectors. The majority of hot particles consisted of cobalt and other activation products with activities ranging up to about 136 nanocurie Skin dose calculations performed by the licensee showed that no 10 CFR 20 exposure limits were approached; a representative calculation was independently verified by the inspectors. No problems were note Contamination events are normally reviewed and investigated by

, members of the station's health physics staf Records of these

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investigations were selectively reviewed by the inspectors and noted to be adequate; however, in many instances the licensee's documentation did not include the assumptions used in determining the duration of hot partic~ie exposure. These assumptions are critical to the skin dose assessmen The desirability to better document these assumptions was discussed at the exit meeting and l will be reviewed during a future inspection (0 pen Item 295/87011-05; 304/88012-05).

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. State of Illinois Effluent Monitoring System Controls r -The inspectors reviewed selected aspects of the stack sampling skid

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used by' the State of Illinoi This skid and associated computer equipment, nitrogen cylinders, and repair equipment are housed in a recently constructed building adjacent to the fuel building. An area radiation monitor is installed inside the building near the skid and a meter and warning beacon are mounted outside near the doors to the buildin "Caution Radioactive Material" signs are posted on two panels of the skid. According to licensee representatives, the skid is an automated gaseous effluent sampling and monitoring system that samples exhaust from the station's two stacks, downstream of the station's own stack sampling and monitoring system. After passing through the skid, the exhaust

, sample is returned to the stacks through heat-traced line Licensee representatives indicated that shortly b fore the system was operational,(approximately February 1987), several meetings were held with'the technical staff person involved with construction of the building, the station's radiation protection staff, and the State of Illinois employee responsible for the syste Reportedly, at these meetings, the licensee specified that any radioactive waste associated with the skid be given to the licensee for proper disposal and that the licensee should be notified prior to work on potentially contaminatea components. Licensee representatives did not know if maintenance had been performed on potentially contaminated portions of the system within the building but did state that they monitored work on a portion of system located outside the building on one occasion. A licensee representative related that during initial set-up work on the pitot tubes in the stack, the licensee had assisted. The licensee was not specifically aware if any radioactive material had been removed from the station by the State, but stated that since the exhaust samples were analyzed in the skid and waste disposal was readily provided by the licensee, it was unlikely. The licensee stated that the area outside the building is routinely surveyed by the licensee. During this inspection, the licensee surveyed the interior of the building; no dose rates or contamination levels above background were found. At the exit meeting, the licensee agreed to assess the radiological conditions associated with use and maintenance of the skid and to reinforce to the State that any maintenance on the sample lines or any handling of samples or other potentially radioactive material shall be done in accordance with applicable station radiation l protection procedures. This matter will be reviewed again during a future inspection (0 pen Item No. 295/88011-06; 304/88012-06). Pipe Chase Surveys

The licensee intends to modify station Procedure ZRP 1520-2 to L require that the vertical pipe chase entry area (landing) at the i 617-level be surveyed weekly during all modes of operation so as

! to evaluate the radiological conditions associated with the

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performance of routine fire watches in the area. This proposal l appears appropriate.

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The licensee plans to continue to use RWP No. 80006A (Type I) for the performance of routine. pts in the vertical . pipe chases as long as the pts do not involve climbing or otherwise accessing areas subject to unknown or changing radiological conditions. The licensee proposes to use RWP No. 80067A (Type II) for the performance of routine and non-routine pts in the vertical pipe chase which may involve access to areas of unknown or significantly changing radiological condition In the latter case, a recent survey is required to be obtained (pursuant to ZRP 1001-1) prior to entry or an RCT must accompany the entry. These issues will remain open as described in Section No violations or deviations were identifie . Audits and Appraisals (IP 83729)

The organization, staffing, and qualifications of the station's quality assurance group remains essentially as previously described (Inspection Reports No. 295/87037; 304/87038). Since the last inspection, one QA auditor attended a two-week vendor offered radiochemistry course which included fundamentals of nuclear physics. The station plans to have new auditors and those qualified to conduct radiation protection audits attend the course.

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The inspectors reviewed records of surveillances of radiation protection program areas and ' activities conducted in 1988 to date. Four such surveillances were conducted and included containment access controls, respiratory protection equipment issuance / return, and RWP and ALARA reviews. No problems were f dentified in the surveillance report No audits of radiation protection activities have been performed since June 198 No violations or deviations were identifie . ALARA (IP 83729)

The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA, including; changes in ALARA policy and procedures, ALARA considerations for the Unit 1 outage, worker awareness and involvement in the ALARA program, and the establishment and realization of goals and objective The ALARA organization remains as previously described (Inspection Reports No. 295/87037; 304/87038). During this outage, the ALARA office maintained extended hours (Section 5) and was augmented with a 19 person work force to install temporary shielding and to decontaminate work area Additional equipment purchased and methods / innovations used by ALARA to reduce exposures during the outage included the following: 1) purchase and use of four 500 cfm and two 1000 cfm portable HEPA ventilation units and two 1000 cfm charcoal filter ventilation units; 2) metal-reinforced ventilation hose was purchased and used with the ventilation units; 3) a transfer container was fabricated and used to reduce dose during the handling of spent honing brushes used in steam generator tube eddy

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current testing; ano 4) extensive use of shielding and decontaminatio The ALARA group made extensive use of the ALARA photo-library and job files when conducting ALARA reviews and pre-job meetings. Numerous photographs were taken during the outage and will be added to the librar The ALARA group provided ALARA awareness training to contractors prior to the outage. The training consisted of lectures, class discussions, and videos on "Radiological Effects," "Communication Breakdown," "Pre-job Meetings," "ALARA Awareness," and on the use of the whole body contamination monitors. Contractors were also instructed in the station's RWP progra As stated i.: Section 8, the station's 1988 exposure totals thus far (based on SRD data) is approximately 675 person-rem; the goal initially projected for the calendar year was 68 Licensee representatives in the ALARA office attributed the unexpectedly high dose total to the performance of significant unplanned outage work and other planned outage work that required more extensive efforts because of equipment problems or the need for additional repair About 670 person-rem is attributed to Unit 1 outage activities; the pre-outage goal was 32 This goal was based on a normal 15-week refueling outage. Unplanned outage activities included repairs of the canopy seal weld on three control rod housings, testing of the 16 large-bore steam generator snubbers (Reports No. 295/88009; 304/88010), and repairs to RTD bypass manifold isolation valves. According to SRD data, unplanned work accounted for approximately 228 person-rem including 128 person-rem attributed to reactor head weld repairs. Planned jobs that accounted for unexpected dose included additional area and equipment decontamination, steam generator tube eddy current testing and sleeving, ISI, and RWP surveying. Planned activities contributed a total of approximately 448 person-rem; 123 person-rem over the pre-outage estimate of 32 According to the ALARA coordinator, cooperation between work groups was sufficient and management support for ALARA measures was excellent. The inspectors reviewed documentation related to the implementation of the ALARA program during the outage to ensure the required procedural measures were performed and suf ficient ALARA measures were taken. Based on this review and on discussions with employees, it appeared that the licensee's ALARA program functioned as intended, met regulatory and procedural requirements, and was effectively implemented during the outage even though pre-outage exposure goals were exceeded.

l Once per week, the ALARA group measures and plots the values for the area of contaminated floor in the auxiliary building, excluding the cubicle The 1988 goal for contaminated areas is 6000 ft 2 during outages and 1000 ft2 during non-outages. During this outage, the licensee exceeded

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the goal with a peak of approximately 8000 ft2 during the middle of the l outage; however, this area was reduced to near 6000 ft 2 during the final l weeks of the outag No violations or deviations were identified.

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1 Licensee Event Report (LER) Followup (IP 92700)

Through direct observations, discussions with licensee personnel, and review of records, the following event report was reviewed to determine that reportability requirements were fulfilled, that timely corrective action was accomplished, and that corrective action to prevent recurrence had been accomplished. The LER listed below is considered closed:

LER No. 295/87-001-00, "Explosive Gas Mixture in Hold Up Tank Due to Missed Technical Specification Surveillance Caused by Procedural Deficiency," dated February 6, 1987, was previously reviewed and is described-in Inspection Reports No. (295/87037; 304/87038). As a result of the previous review, the licensee agreed to revise the LER to identify the correct timeframe of the violation and clarify the' root cause determination and corrective actions. The revised LER No. 295/87-001-01, dated March 22, 1988, appears to adequately document the necessary clarifications and corrective action '

17. Tours and Independent Measurements During tours of the Unit I containment, the fuel building, and the auxiliary building, the inspectors noted that radioactive material controls, access controls, postings, and housekeeping were adequat Observations of ingress and egress activities at the containment main control point and other S0P areas indicated that workers were adhering to PC and frisking requirements. Observations were also made of workers performing outage activities, including the installation of drip pans on the recirculation pumps; workers appeared to be adhering to RWP and procedural requirements. Portions of a filter change-out in the auxiliary building was observed and noted to be performed with due regard for radiological controls and ALAR The inspectors performed direct radiation surveys of equipment and-selected areas in the auxiliary building and around outdoor storage areas; survey results were consistent with posting Smear surveys were performed in the auxiliary building; no detectable contamination was foun No violations or deviations were identifie . Exit Meeting (IP 30703)

l The inspectors met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on April 29, 1988. The inspectors l summarized the scope and findugs of the inspection and also discussed

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the likely informational content of the inspection report with regard to l

documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents / processes as proprietar In response to certain items discussed by the inspectors,

! the licensee: Acknowledged the inspectors' comments concerning the apparent need to better control and strengthen oversight / communications over

contractor outage activities (Sections 4, 11 and 12).

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b. Agreed to clarify and formalize requirements regarding site specific respiratory protection training and retraining and rectify apparent training discrepancies concerning PC and respirator removal methods (Section 10).

c. Acknowledged the inspectors' comments concerning RORs written in 1988 and use of the ROR system (Section 11).

d. Acknowledged the inspectors' comments concerning laundry menitoring methods and automated monitor alarm setpoints (Section 13(b)).

e. Acknowledged the inspectors' comments concerning the desirability to better document the assumptions used to determine the duration of exposure for hot particle and significant skin contamination events (Section 13(c)).

f. Acknowledged the inspectors' comments concerning radiological controit exercised over the Illinois Department of Nuclear Safety Effluent Monitoring facility (Section 13(d)).

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