IR 05000305/1984005

IE Insp Rept 50-305/84-05 on 840507-10.Violation Noted: Gamma Calibr Not Calibrated Since Jul 1982,per TMI Item II.F.1.2

ML20151J148
Person / Time
Site:	Kewaunee
Issue date:	06/06/1984
From:	Greger L, Nicholson N, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151J125	List: IR 05000305/1984005 ML20151J118 ML20151J130
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-305-84-05, 50-305-84-5, IEIN-82-31, IEIN-83-59, IEIN-83-67, IEIN-83-68, NUDOCS 8406260031
Download: ML20151J148 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-305/84-05(DRMSP)

Docket No. 50-305 License No. DPR-43 Licensee: Wisconsin Public Service P. O. Box 1200 Green Bay, WI 54305 Facility Name:

Kewaunee Nuclear Power Plant (KNPP)

Inspection At:

Kewaunee Site, Kewaunee, WI Inspection Conducted: May 7-10, 1984 Inspectors:

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N. A. Nicholson d

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Date Approved By:

L. R. Gr ger, Chief Ih Facilities Radiation Date Protection Section Inspection Summ y Inspection on May 7-10, 1984 (Report No. 50-305/84-05(DRMSP))

Areas Inspected:

Routine unannounced inspection of the radiation protection program including internal and external exposure control, organization and staff qualifications, respiratory protection, training, contamination control, instrumentation and calibration, and a review of TMI Items II.F.1.2 and II.F.1.3 and selected I&E Information Notices.

The inspection involved 56 inspector-hours on ite by two NRC inspectors.

Results:

One apparent item of noncompliance was identified:

failure to calibrate the gamma calibrator in accordance with procedures (Section 9).

One unresolved item was identified concerning NUREG-0737 Item II.F.1.2.B.2.

(Section 10).

8406260031 840606 PDR ADOCK 05000305 G

PDR

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DETAILS 1.

Persons Contacted

D. Finlaw, Health Physics Technologist 1J. Giesler, Associate Engineer D. Hintz, Plant Superintendent 1R. W. Lange, Maintenance Supervisor 1M. Lewis, Assistant to the Nuclear Licensing and Systems Superintendent IC. D. Long, Assistant Radiation Protection Supervisor 1,3M. L. Marchi, Plant Technical Superintendent D. Morgan, Lead Radiation Technologist P. O'Brien, Nuclear Training Supervisor - Non-Technical 10. Padula, Plant Health Physicist 1,2R. Pulec, Regulatory Performance Supervisor 1,2M. Reinhart, Radiation Protection Supervisor 1,2J. Richmond, Plant Services Superintendent 1R. L. Helson, Senior Resident Inspector 1 Attended the May 10, 1984 exit meeting.

2Telecon discussion held May 17, 1984.

aTelecon discussion held May 18, 1984.

2.

General i

This inspection, which began at 8:00 a.m. May 7, 1984, was conducted to examine the radiation protection program during routine operaticns.

The inspectors conducted plant tours, making visual inspections of facilities and equipment, posting, labeling, and access controls.

Area posting and housekeeping were good.

The inspectors also reviewed the status of selected TMI Task Items.

3.

Organization and Management Controls The inspectors reviewed the licensee's organization and management controls for the radiation protection program including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement these programs, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of these programs.

No staff changes have been made during the past year.

The health physics staff includes the Plant Services Superintendent, the Radiation Protection Supervisor (RPS), assistant RPS, the plant Health Physicist, lead Health Physics Technologist (HPT), thirteen HP's, a radiation clerk, a lead radiation helper (RH), and four RH's.

Staff qualifications are addressed in Section 4.

Although all HPT's are responsible for general HP work, the staff is gradually becoming specialized.

Designated HPT's are assigned specific

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programs (e.g., respiratory protection, instrument calibration, TLD's, etc.)

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to be maintained on a functional level.

On-the-job cross training main-tains a reserve of cognizant HPT's for these programs.

i To ensure continuous radiation protection required by Administrative Control Directive (ACD) 6.1, seven HPT's are rotated through the evening and midnight shifts.

One HPT is on duty during each backshift.

Each HPT spends fourteen of forty-nine days on rotational duty, spending seven consecutive days on the evening shift and seven consecutive days on the midnight shift.

A qualified HPT on duty is authorized by ACD 6.1 to stop work in progress if a significant radiolot cal hazard exists.

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directive also provides the HPT with direct access to the plant manager

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j if necessary.

,l No apparent violations were identified.

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4.

Training and Qualifications

The inspectors ~ reviewed the training'and qualifications aspects of the licensee's radiation protection program including:

changes in responsi-

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bilities, policies, goals, programs, and methods; qualifications of newly hired or promoted radiation protection personnel; and provision of appro-priate radiation protection training for station personnel.

Also reviewed were management techniques used to implement these programs and experience concerning self-identification and correction of program implementation

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weaknesses.

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i No significant programmatic changes were noted.

Qualifications of the health physics (HP) staff were reviewed.

Five onsite HP management /

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supervisory personnel meet the Radiation Protection Manager (RPM) quali-fications of Regulatory Guide 1.8; these personnel include the Plant Services

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Superintendent, the Radiation Protection Supervisor (RPS), the assistant RPS,

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the plant Health Physicist, and~the'1ead HPT.

All thirteen HPT's meet or j

exceed the ANSI N18.1-1971 qualifications for technicians.

The HP staff i

has a total of 196 years of nuclear experience, averaging eleven years per-

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person, excluding the HP helpers and clerk.

s The Plant Services Superintendent stated new HPT's with prior' nuclear experience complete a minimum of six months on-the-job training before they are assigned to shift work.

Inhouse sessions and offsite short

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courses offered by vendors comprise the ongoing HPT proficiency training.

In response to an INP0 commitment, the licensee has proposed an inhouse

l applied health physics training program for the HPT's, radiation helpers,

and clerk to be initiated around June 1984.

Topics addressed will be.

covered in classroom sessions, self-study exercises, and field work. The

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inspector reviewed 'the proposed outline; no problems were identified.

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The training department conducts a sixteen-hour radiation protection training session for new hires and an annual four-hour retraining session y

for plant staff.

An inspector reviewed the lesson plans; this training-appears to meet 10-CFR 19.12 requirements.

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No apparent violations were identified.

5.

External Exposure The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including total exposures accumulated through the outage, dosimetry exchange methods, measures taken regarding lost badges, and the TLD quality assurance (QA) program.

An inspector reviewed a summary of estimated doses for the year.

An esti-mated total of 123 person-rem was reported for the period of January 1-April 30, 1984, the greatest dose contribution resulting from the outage.

Final individual doses for the entire outage were not available; this will be reviewed during a future inspection.

Both vendor and inhouse TLD's are exchanged monthly during the midnight shift by HP staff.

Vendor TLD's are color-coded by the inhouse staff for rapid identification. At the time of the inspection, TLD's for WPS personnel are clipped to their security badges and are maintained at the guardhouse, a low background area.

Contractor TLD's are kept outside the radiation protection office in designated individual rack holders identified by names and TLD badge numbers.

Personnel wear two TLD's, one evaluated by KNPP and one by an outside vendor.

Currently, official records are based on the vendor's results except in cases where results of lost vendor badges are not available and inhouse

TLD results are reported.

Inhouse TLD badges are routinely used for current dose tracking.

The licensee uses a TLD reader, Eberline TLR-5, to analyze TLD's on a monthly or more expedient basis, as necessary.

Before analyzing each batch of TLD's, the licensee analyzes chips of a known exposure to verify instrument operability.

As part of a QA program with the vendor, selected sets of TLD chips are exposed to differing strengths of Cs-137 sources to achieve a range of exposures.

Both parties count a set and results are compared.

Inhouse TLD results were higher than those of the vendor according to January and February records reviewed by the inspector.

No significant trend was noted.

Dose comparisons between the TLD's and pocket dosimeters are made and reviewed by HP management.

Based on records reviewed for February-April 1984, most results agree within twenty percent.

Significant discrepancies are flagged and investigated by HP management.

No apparent violations were noted.

6.

Internal Exposure Control The inspectors reviewed the licensee's internal exposure control and assessment programs, including changes to procedures affecting internal exposure control and personal assessment; determination whether engineering controls and assessment of individual intakes meet regulatory requirements; and required records, reports, and notifications.

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The inspectors selectively reviewed wholegbody count results for 1984 to

e date, including coatractor personnel who had completed their work at the j

station.

No results exceeding the 40 MFC hoyr control measure were noted.

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? ~ During a previous inspection (50-305/82 207 it' was noted that Procedure

~\\t (RC-HP-32I) could not be used to compute MPC-hoars from whole body / organ burdens, and that the Airborne Evaluation Sheet used to compute worker stay

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times had incorrect MPC's listed for certain%. topes.

The Procedure has been revised and she MPC's listed kn the Evaluation Sheet have been corrected.

During this inipection the licensee was able to determine MPC-hours based

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the revised procedure) gi.'en to them on several hypothetical problems (m.Ing \\

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.The inspecu rs also reviewed portions of contractor training in internal dosimetry calculations.

Several quest}ons were; raised concerning the

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accuracy of some of the material.

The licensee wi1 Q uview this matter with the contractor for clarification, y

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Respiratory Protection

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The inspectors reviewed the h {nsee's respirat ry grotection program s

including equipment and faci t es, testing methods for respirator wear, medicab walifications and eq'uipnient mai,ntenance'.'

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Licensee equipment includes full-face mask respirators, air supplied hoods,

'uod self-contained-breathing apparatus (SCBA's); no half-face respiratcrs

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or rebreathers are used.

The-nasks andthoodsfare NIOSH approved, based I,

onidentifyjngNIOSknumbers! ' Masks'onditc_ aFe available in three sizes.

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'Al[ inspector accompani*2 an HPT on a roul'ine ' check of inplant emergency

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use SCCA's; no prob 5M ',wre noted.

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Inpla t supplicj We) thing' air hhp's ha've unique fittings designed solely for respiratof use. An adap.er requiytd to compl @,the link between the hookup a((1-the filtration cdi t, is Pepl[at the

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an HPT furnishes the adanter Tor the hookup an,r6diation protection office;dremain c' art, Whil'e in use.

Air' quality cht'&s of plant air are conducted on a s

rotating basis at indiviria(1 hookup luedions in accordance with RC HP-32G.

Selected records reviddd b) the inspector 1rdicated results of parameters tesi.ed(gases, hydrocarbons, oils)'we're@ithinlevelsspecifiedbythe abop procedure.' '%

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Th9 licensee uses a corn oil emulsion for mask fit testing. The inspector toured,the test booth which is operated under pesitive precsure and equipped with yntipterlock system. Methods for dsterminirs protection factors are outline 9 in RC-HP-32J; protection factors are ascigned in accordance with 10 CFR t.0 Appendix A.

The inspector reviewed kC-HP-32J and noted that certaikexercises, such as running in place or deep bending, that signifi-cantly. challenge the mask fit were not included in'the fit testing; the licensee agreed to revise this procedure to include such exercises (0 pen Item 305/84-05-01). ' Medical testing, including pulmonary function evaluation and physical examination, is conducted by mc Mc.1 personnal at a local

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Selected individyd,1iles of contractor and WPS personnel were s~

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reviewed for completion of fit testing and medical authorization; no-significant problems were noted.

Requalification is conducted annually.

Respirator authorization is entered for each qualifying individual on the crew dose report, a computerized tracking system of cumulative quarterly exposures is updated by the'HP staff semi-weekly.

Before assigning the individual to an RWP which requires respirator use, the HP staff verifies the individual is respirator qualified.

An HPT observes all jobs requiring respirator use.

Routine mask maintenance is conducted on an as-needed basis.

The masks are inspected annually and all degradable parts are replaced.

The inspector toured the new mask cleaning area, which is equipped with a dishwasher, drying racks, and instrumentation for smear counting.

An inspector observed the cleaning operation which appeared to be conducted in accordance with RC-HP-320.

No apparent violations were identified.

8.

Contamination Control The inspectors reviewed the licensee's program for control of radioactive materials and contamination including access controls, decontamination facilities, protective clothing, and survey review.

All entries and exits from the controlled area are made through one access control-point outside the radiation protection office.

Personnel entering pick up a pocket dosimeter and record their name, TLD, and RWP numbers, entry and exit times, and dosimetry readings at the access control log.

The inspectors noted an adequate supply of frisking instruments was located in a low background area; HP personnel appeared to be aware of the instrument limitations and routine functional characteristics.

Two adjoining decontamination showers are adjacent to' access control; contaminated personnel can enter the showers directly through~a' door from the controlled area.

The inspector noted an adequate supply of decontamina-tion materials was available; the lead HPT described appropriate methods used for decontamination. A nearby sink is used for hand and arm contami-nation.

According to licensee representatives, no whole body contaminations have occurred within the past year.

A well maintained supply of protective clothing.is available.from racks at access control.

Laundry facilities adjacent to access control minimize the travel route for transfer of contaminated clothing.

During plant tours the inspectors noted that personnel wore applicable protective clothing in the controlled area.

An inspector reviewed selected in plant surveys conducted in May 1984.

Levels greater than'100 dpe/100cm were highlighted, indicating appropriate HP. review.

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No apparent violations were noted.

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9, Instrument Calibration

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The licensee demonstrated the calibration of a teletector beta gamma instrument using the Multiple Source Gamma Calibrator.

The instrument

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appeared to be calibrated in accordance with Procedure RC-HP-428 (Instrument Calibration. Procedure for the Detector).

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Selected portable monitoring equipment was reviewed for adherence to the

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, calibration schedule and' procedures.

In addition,several instrument

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' calibrations were reviewed for technical adequacy.

No problems were

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noted.

' A review of the licensee's use of the Model 1000 Multi-Source Gamma

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Calibrator indicated that, for certain instruments, the single key interlock system is bypassed so that the calibrator door remains open during the calibration. Although this is not a prohibitive operating condition of the machine, the licensee was requested to in:orporate safety precautions in the operating pr>a dure (RC-HP-45) during this condition (305/84-05-02).

This matter was discussed at the exit interview.

The inspectors also noted that.-the calibrator had not been ca!ibrated since

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July 1982.

The licensee's P.rocedure (RC-HP-40J) requires a yearly calibra-tion using an NBS traceable' condenser R-Meter and chambers.

Failure to calibrate the source gamma calibrator since July 1982 is noncompliance with the licensee's procedures (RC-HP-40J).

(Noncompliance 305/84-05-03)

10.

TMI Action Plan Items II;F[1.1.B.2 and II.F.1.2.D.2 a.

Noble Gas Effluent tionitor-(II.F.1.1.B.2)

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The licencee has installed two SPING-4 extended range noble gas effluent offlina monitors. 'One SPING-4 samples the containment /

shielding building vent Stack and the other samples the auxiliary building vent.

Each monitor contains three noble gas detectors (low, intermediate, and high ranges). The monitors readout in the Radiation Safety Office and the Radioanalytical Facility near the Technical Support Center.

Clarification Item 4(b) requires the use of procedures or calcula-tional methods for converting instrument rea< lings to release rate per unit time based on, among others, radionuclide spectrum distri-bution.

In Procedures EP-RET-2B and RC-HP-58B the licensee refers to calculational methods for converting instrument readings to release rates; however, the methods do not properly take into account the radionuclide distribution as a function of time after shutdown.

This matter was discussed with the licensee,on May 15, 1984; licensee personnel stated a review would be made of this matter and the proce-dures would be revised where necessary to meet the requirement.

This task action item remains open.

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Sampling and Analysis of-Plant Effluents (II.F.1.2.B.2)

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Clarification Item 2 for this Task Action Item requires that radiation exposures not exceed 5 rem whole body and 75 rem extremities during sample removal, replacement, and transport for the duration of the accident.

Clarification Item 4 requires that continuous sampling of

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l plant gaseous effluent for post-accident releases of radioactive iodines and particulates also be provided.

The licensee developed i'

Procedure HP-RC-58B to meet both requirements.

However, the licensee

did not use the design basis shielding envelope described in Table

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II.F.1-2 of NUREG-0737 when concluding that radiation exposures would not exceed 5 rems whole body and 75 rems extremity during removal, replacement, and transport of the filter collection media.

Instead,

the licensee used a design basis accident condition specific to their facility.

This appears to be in coinflict with the specifications of NUREG-0737.

The licensee was requested to resolve this matter by notifying NRR of their analysis assumptions.

This matter remains unresolved pending NRR's review of the licensee's submittal (305/84-05-04).

An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a devia-tion, or a violation.

11.

I&E Information Notice Followup The inspectors reviewed selected I&E Information Notices to determine if topics discussed were addressed in the health physics program.

I&E Information Notice 82-31.

Overexposure of Diver During Work in Fuel Storage Pool.

No procedures for diving operations exist.

Licensee representatives agreed to proceduralize practices currently in use for dives (0 pen Item 346/84-05-05).

I&E Information. Notice 83-59.

Dose _ Assignments for Workers in Non-Uniform-Radiation Fields.

The lead HPT determines if additional dosimetry (TLD's)-

for parts of the body exposed to a higher field are necessary based on surveys of the work-site.

Required additional dosimetry is noted on the RWP; these TLD's are issued by the health physics office.

I&E-Information~ Notice 83-67.--

Emergency Use Respirator Material Defect

~Causes Production of Noxious Gases.

Combustion product gases were released because of a valve seat defect with the Bio-Pak 60-P.

These respirators were used by the licensee from late 1979 to 1981; the' licensee disposed-all Bio-Pac:60-P respiratcrs in 1981 and does not currently have any onsita.

I&E. Information Notice 83-681 Respirator User Warning:

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Contained Breathing Apparatus Air Cylinders.

Defective neck seals ~manu-factured by two separate vendors were causing cylinders to'ruture.

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licensee uses MSA 401 cylinders, not those: identified by this notice.

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Exit Meetina

"The' inspectors. met with-licensee representatives (denoted in Section 1) ati the' conclusion of the onsite. inspection on May 10,-1984;. subsequent telecon-

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contacts were made May 15-18, 1984.

The scope and findings of the inspection were summarized.

In response to the inspector's comments, licensee representatives:

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Acknowledged the item of noncompliance (Section 9).

b.

Stated RC-HP-32J would be revised to include exercises more challenging to the respirator mask fit (Section 7).

c.

Stated safety precautions would be incorporated into RC-HP-45 (Section 9).

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Acknowledged the design basis shield envelope differs from that of NUREG-0734, Item II.F.1.2, and will request a deviaticn from Nuclear Reactor Research (NRR) (Section 10).

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Agreed to preceduralize current divina practices (Section 11).

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