IR 05000315/1987002
| ML17325A377 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/23/1987 |
| From: | Gill C, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17325A374 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.4, TASK-TM 50-315-87-02, 50-315-87-2, 50-316-87-02, 50-316-87-2, IEB-78-08, IEB-78-8, IEIN-87-039, IEIN-87-39, NUDOCS 8710280273 | |
| Download: ML17325A377 (79) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/87002(DRSS);
50-316/87002(DRSS)
Docket Nos.
50-315; 50-316 Licensee:
American Electric Power Service Corporation Indiana and Michigan Electric Company 1 Riverside Plaza Columbus, OH 43216 Licenses No.
D.C.
Cook Nuclear Plant, Units 1 and
Inspection At:
D.C.
Cook Site, Bridgman, Michigan Inspection Conducted:
July 16 through August 31, 1987 Inspector:
C.
F. Gill Dat Accompanying Inspec r
.
W.
Ogg Approved By:
L.
R.
rege
, Chief Facilities Radiation Protection Section Date Ins ection Summar Ins ection on Jul 16 throu h Au ust 31 1987 Re orts No. 50-315/87002 DRSS).
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p programs during a refueling and maintenance outage including:
status of the Radiation Protection Improvement Program; changes in organization, personnel, facilities, equipment, pro'grams, and procedures; audits and appraisals; planning and preparation; training and qualitications of new personnel; internal and external exposure control; control of radioactive materials and contamination, surveys, and monitoring; solid radwaste; radwaste transportation; and the ALARA program.
Also, certain TMI Action Plan Items, open items, radiation protection staff stability, the steam generator repair plan, control room ventilation system concerns, a contamination/injury event, an allegation, the licensee's response to IE Bulletin No. 78-08, and certain radioactive material shipment concerns identified at the Barnwell waste burial facility by State of South Carolina inspectors were reviewed.
8710280273 871023 PDR ADOCK 050003i5
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Results:
Five violations were identified (failure to properly label a
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radioactive waste shipment - Section 14, failure to follow radiation work permit requirements
- Section 17, failure to perform needed evaluations of radiation hazards present - Section 11, failure to follow the termination exposure reporting procedure - Section 18, and failut e to furnish termination exposure reports to the NRC within the required period of time - Section 18).
DETAILS l.
Persons Contacted
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Ackerman, Associate Engineer, AEPSC Blyth,, Assistant Shift Supervisor Brewer, Radiological Support Section Manager, AEPSC Burns, Site Coordinator, HNS Carteaux, Performance Engineering Supervisor Cassidy, Radiation Protection Technician Cross, Dosimetry Clerk, Palisades Cunningham, Radwaste Handling Supervisor, AEPSC Dannhardt, Radwaste Handling Supervisor Droste, Maintenance Superintendent Feinstein, Manager of Nuclear Safety and Licensing, AEPSC Flis, Senior Performance Engineer Ford, Radiation Protection Supervisor, NUMANCO Fryer, Radiation Material Control Supervisor Gibson, Assistant Plant Manager, Technical Support Gumns, Administrative Compliance Coordinator Holland, Radiation Protection Supervisor Holmes, AEPSC Site gA Auditor Hoppe, Radiation Protection Supervisor Horvath, AEPSC Site gA Supervisor Huerter, AEPSC Site gA Supervisory Auditor Jackson, Engineering Technologist Jepkema, AEPSC Site gA Auditor Johns, Radiation Protection Technician Kamback, Radiation Protection Supervisor, AEPSC Klementowicz, Radiological Support Health Physicist, AEPSC Kroeger, Manager of equality Assurance, AEPSC Kriesel, Technical Superintendent, Physical Sciences Lang, Radiation Protection Supervisor, NUMANCO Lauzau, Nuclear Safety and Licensing, AEPSC Leichner, Radiological Support Nuclear Engineer, AEPSC Lehrer, Radiation Protection Supervisor Long, Radiation Protection Training Specialist Loope, Plant Radiation Protection Supervisor MacRae, Radiological Support Scientist, AEPSC Manges, Nuclear Safety and Licensing, AEPSC McCormick, Performance Engineer McElligott, AEPSC Site gA Supervisory Auditor Mennucci, General Health Physicist, Palisades Postlewaite, Technical Superintendent Engineering Ramzy, Radiation Protection Senior Performance Engineer Rosser, Radiation Protection Performance Engineer Rutkowski, Assistant Plant Manager Scherer, Associate Training Instructor, Production Schroeder, Senior Radiation Protection Training Instructor Smith, Jr., Plant Manager Springer, Acting ALARA Coordinator
8"M. Terry, Administrative Compliance Coordinator G. Tollas, Assistant Shift Supervisor
"D. Williams, Radiation Protection Performance Engineer 8H. Young, Senior HVAC Engineer, AEPSC 8*J. Heller, NRC Resident Inspector
- B. Jorgensen, NRC Senior Resident Inspector The inspectors also contacted other licensee and contractor employees including radiation protection technicians and members of the technical and engineering staffs.
"Denotes those present at the exit meeting on August 7, 1987.
ODenotes telephone discussions between August 10 and 28, 1987.
8Denotes those present at the exit meeting via telephone on August 31, 1987.
General This inspection, which began at 8:00 a.m.
on July 16, 1987, was conducted to review the Radiation Protection Improvement Program and the radiation protection and radwaste programs during a refueling and maintenance outage.
The inspection included plant tours, review of postings, and labeling, radiological deficiency reports, personnel contamination reports, gA audits and surveillances, training records, shipping papers, certain licensee and contracted reports regarding radiation protection programmatic reviews, various plant monthly status reports, open items, discussions with licensee and contractor personnel, and independent radiation measurements by the inspectors.
The inspectors conducted numerous and frequent plant tours in the auxiliary and turbine buildings and the Unit 1 containment, observed work activities performed under the requirements of more than a dozen RWPs, and interviewed workers who had performed tasks authorized by other RWPs.
The inspectors also reviewed certain TMI Action Plan Items, the steam generator repair plan, control room ventilation concerns, a
contamination/injury event, an allegation, the licensee s response to IE Bulletin No. 78-08, and certain radioactive material shipment concerns.
The inspectors conducted radiation and contamination surveys of selected plant areas using NRC and licensee. survey instruments; except as noted in Section 11, readings were in general agreement with posted licensee data.
RWP procedural adherence problems and the desirability of improving access control are discussed in Section 17.
Housekeeping generally appeared adequate; however, during plant tours the inspectors noted isolated incidents of poor housekeeping similar to those found during gA backshift tour surveillances (see Section 15).
Licensee Action on Previous Ins ection Findin s
Closed)
0 en Item 315/84017-03 316/84019-03):
HVAC filten housing drain system bypass and fire protection system water leakage problems.
The corrective actions for this identified weakness (Inspection Reports No. 50-315/85024; 50-316/85024, Section 13) outlined in the licensee's response dated November 8, 1985, were reviewed.
All design changes are
completed and most of the procedural changes are approved; the other procedural revisions have been submitted for approval.
.The inspectors selectively reviewed procedural changes and inspected completed HVAC system installation modifications; no problems were noted.
This matter is considered closed.
0 en)
0 en Item (315/84017-04 316/84019-04):
High range iodine and particulate sampling system design concerns regarding provisions for continuous and representative sampling, adequacy of shielding for sample transport, and prevention of contamination of high range noble gas monitor with iodine.
This item remains open pending licensee completion and NRC review of NUREG-0737 Item 11.F. 1, Attachment 2, compliance documentation (see Open Item 315/85011-06; 316/85011-05).
0 en 0 en Item 315/84017-05 316/84019-05:
Review SPING setpoints and calibrations.
This item remains open pending licensee completion and NRC review of NUREG-0737 Item ll.F. 1, Attachment 1, compliance documentation (see Open Item 315/85011-06; 316/85011-05).
0 en Unresolved Item 315/85011-05 316/85011-04):
Obtain NRR concurrence on the locations of the steam relief PORV monitors.
An engineering justification of the acceptability of the present monitor locations was provided to NRR by the licensee in letter AEP:NRC:0678T, dated May 20, 1986.
This item remains open, pending resolution by NRR.
0 en 0 en Item 315/85011-06 316/85011-05:
Two weaknesses related to an NRC Confirming Order and NUREG-0737 compliance.
In letter AEP:NRC:0678N, dated August 8, 1985, the licensee addressed these weaknesses and stated that Open Items No. 315/84017-04; 316/84019-04 and 315/84017-05; 316/84019-05 are being entered into the compliance analysis report program which has been implemented for NUREG-0737 Items II.F. 1, Attachments 1, 2, and 3, and II.B.3.
The compliance action items are completed except for certain engineering studies, procedural revisions, calibration verifications, NRR approval for variance requests, personnel training, and response to inspector concerns.
The licensee expects to have all compliance action items completed by December 31, 1987.
This matter will be reviewed further during a future =inspection.
Closed)
0 en Item (315/85024-02 316/85024-02):
Extremity monitoring practices.
The licensee completed an evaluation of the current extremity dosimetry practice by the end of 1986 (Action Request
[AR] No. 1421).
Finger ring TLDs were first implemented in November 1986; two dozen sets of finger ring TLDs are received routinely each month and available for use, as appropriate.
Criteria currently used by the licensee's Dosimetry Section for determining the need for finger ring and other extremity dosimetry is based on information contained in NUREG/CR-4297.
Consideration is also given to information presented in NUREG/CR-4959, Performance Testing of Extremity Dosimetry, published June 1987.,
The licensee stated that finger ring TLDs are normally used whenever a job requires direct hand contact with significant radioactivity sources.
This matter is considered close (Closed 0 en Item 315/85024-06 316/85024-06):
Operation of the HNS DAW sorter.
The licensee met with HNS representatives to discuss the use of the HNS DAW sorter on September 3,
1986.
During that meeting, the licensee requested that HNS prepare recommendations to ensure that the DAW sorter is used in the most effective manner at D.C.
Cook.
On December 29, 1986, HNS addressed the following DAW sorter issues in a letter to the licensee:
DAW hardware and related operational and administrative environments, regulatory interfaces, work relations, and economic issues.
After several internal technical and economic reviews, the licensee decided on March 13, 1987, to discontinue use of the HNS DAW sorter and to remove it from the D.C.
Cook plant (reference:
Action Request
[AR] No. 1360).
The inspectors verified that the HNS DAW sorter has been removed from the licensee's facility.
This matter is considered closed.
Closed)
0 en Item 315/86001-01 316/86001-01):
Complete an internal assessment of radiation protection staff experience, stability, and morale.
The licensee completed this assessment on December 19, 1986, (reference:
Action Request
[AR] No. 1422).
See Section 5.
0 en 0 en Item 315/86001-03 316/86001-03):
Establish positive control over radioactive contaminated tools and equipment in the vicinity of the hot tool crib.
Although the licensee has initiated Action Request (AR) No.
1423 to complete a new hot tool crib facility; little progress had been made (see Section ll).
This matter will be reviewed further during a future inspection.
(0 en 0 en Item 315/86001-04 316/86001-04):
Evaluate the apparent need to upgrade the ALARA program.
The licensee had established an internal goal to upgrade or replace the present radiation protection/
ALARA radiation-exposure computer data-manipulation and report-preparation system by August 1988.
This and other apparent desirable improvements in the ALARA program are discussed in Section 12.
This matter will be reviewed further during a future inspection.
(0 en)
0 en Item (315/86001-06 316/86001-06):
Evaluation of possible release path for contaminated material to uncontrolled areas.
Although the licensee has assigned an action request for closure of this item, little progress has been made.
This matter will be reviewed further during a future inspection.
(Cl osed Unresolved Item 315/86013-01.
316/86013-01:
Verify/correct termination letter log data.
The licensee completed Action Request (AR)
No.
1438 in response to this item, this item is considered closed.
The review of AR No.
1438, apparent regulatory violations, and the need for the licensee to review the matter further are discussed in Section 18.
Closed 0 en Item (315/86013-02 316/86013-02:
Evaluate the current Quality Assurance (QA) radiation protection (RP) audit policy.
The AEPSC site QA Section has added an additional auditor position, plans to conduct a full RP/Radwaste audit each year, and significantly increased the number of RP/Radwaste surveillances (see Section 15).
This matter is considered close Closed) Unresolved Item (315/86013-03.
mislabeling of a radwaste shipment.
On Waste Burial Facility, a State of South licensee radioactive waste shipment was of 49 CFR 172.403(b)
and State of South Section 14.
316/86013-03:
Apparent October 22, 1986, at the Barnwell Carolina=inspector found that a
improperly labeled in violation Carolina regulations.
See (Closed)
Unresolved Item (315/86013-04 316/86013-04:
Document compliance with IE Bulletin No. 78-08, Radiation Levels from Fuel Element Transfer Tubes, commitments.
The licensee responded to this bulletin on August 11, 1978; the bulletin was subsequently closed in Inspection Reports No. 50-315/79023; 50-316/79020.
The licensee stated in their response letter that a special file of the radiation survey results would be assembled and maintained on future surveys.
During an earlier inspection (Inspection Reports No. 50-315/86013; 50-316/86013),
this file and other documentation of the licensee's adherence to their commitments were not readily available for the inspectors'eview.
During this inspection, documentation complied regarding seven surveys conducted from April 2, 1981 through April 5, 1986 (Action Request
[AR] No. 1437)
was available for review.
The inspectors selectively reviewed the survey documentation; no problems were noted.
The inspectors noted that the licensee apparently had adequate administrative control over access to appropriate plant areas during fuel transfer and plans to enhance the physical barriers in the near future.
This matter is considered closed.
Closed)
0 en Item 315/86025-03 316/86025-02):
Inspector was able to enter the auxiliary building (radiation area without signing in on the REM computer.
The door (No. 362) through which the inspector was able to enter the Unit 2 steam enclosure was modified to eliminate the problem on August 10, 1986, according to licensee records.
This matter is considered cl osed.
Or anization and Mana ement Controls The inspectors reviewed the licensee's radiation protection organization and management controls for the radiation protection program, including changes in the organization structure and staffing, effectiveness of procedures and other management techniques used to implement the program, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of the program.
Recent radiation protection/radwaste personnel changes include:
The Plant Radiation Protection Supervisor resigned and was replaced by the Emergency Planning Coordinator, who holds both positions.
The ALARA Coordinator transferred to a position at another facility of the licensee; the ALARA Engineering Technologist is currently the Acting ALARA Coordinato ~
Two of the three radiation protection performance engineers (health physicists)
resigned and were replaced by new hirees.
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The Environmental Coordinator section has divided into two independent sections (Environmental and Radioactive Material Control
[Radwaste] Sections).
The Environmental Supervisor position was filled by internal promotion.
The current Radioactive Material Control Supervisor was previously the Environmental Coordinator.
The Technical Superintendent, Physical Science has been designated as the Radiation Protection Manager (RPM).
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One of the two radwaste handling supervisors has transferred to the Steam Generator Repair Project; the vacated position remains unfilled.
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One of the radiation protection supervisors has transferred to the Steam Generator Repair Project; because of a restructuring of the Radiation Protection Section, the vacated position has been deleted.
An Engineering Technologist position has been added to the Radiation Protection Section and one performance engineer position has been deleted.
The ET position has been filled by a senior radiation protection technician.
With the possible exception of the RPM appointment, the persons newly appointed to the above positions appear qualified in accordance with ANSI N18. 1 - 1971 for the respective positions; although such a major turnover of professional and supervisory staff has the potential for a short term negative effect on licensee performance.
Licensee management
'informed the inspectors that they shared the inspectors'oncerns regarding the appointment of the same person as both the Plant Radiation Protection Supervisor and the Emergency Planning Coordinator and stated that a replacement Emergency Planning Coordinator would be appointed as soon as possible.
Based on the licensee's prepared matrix which compares the individual's education and experience to the regulatory positions of Regulatory Guide 1.8 - 1975, it appears that the qualifications of the current RPM may not conform to the regulatory positions.
However, the
,inspectors informed the licensee that the Technical Superintendent, Physical Science could remain as the temporary RPM, pending resolution of this issue by NRR.
The inspectors also expressed their concerns to licensee management regarding the selection of the RPM regarding the Technical Superintendent, Physical Science's many other areas of responsibility which are unrelated to radiation protection, and thus have the potential to significantly detract from his duties as RPM.
This matter was discussed at the exit meeting and will remain an Unresolved Item pending NRR resolution.
(315/87002-01; 316/87002-01)
Four radiation protection supervisors, three performance engineers (health physicists),
and an engineering technologist (ET) report directly to the Plant Radiation Protection Supervisor.
Each radiation protection
supervisor has been assigned responsibility for specific functional areas; these areas are dosimetry, instrumentation, radiological controls, and radiological support.
Also, the 32 radiation protection technician (RPT) positions are each assigned to primarily work in one of these functional areas.
Staff stability is discussed in the next section.
The licensee's radiation protection staff is augmented during the outage by 197 contract personnel; these include persons from a contractor who supplies mostly RPTs and a contractor who supplies nuclear support technicians (Rad/Chem helpers).
The RPT contractor supplied a site coordinator, 16,radiation protection supervisors, 79 senior RPTs,
junior RPTs, 4 dosimetry clerks, and an I8C technician to maintain survey instruments.
Because the licensee did not temporarily promote any licensee senior RPTs to radiation protection supervisors for the outage, the contractor supplied all the additional radiation protection supervisors needed for this outage; thus some plant RPTs are working for contract supervisors.
Based on the licensee's confidence in the quality of the contract RP supervisors, little oversight by the plant supervisory staff is provided.
The nuclear"support technician contractor supplied a site coordinator, an assistant site coordinator, a technical assistant,
helpers for the containment crews, 19 helpers for the auxiliary building crews, and 8 helpers to clean respirators.
The helper crews worked under their own supervisors with little apparent plant supervisory oversight.
The licensee estimates that the radiation protection staff will need to be augmented after the current outage by 42 contract RPTs and 23 nuclear support technicians based on a recent consultant stu'dy of necessary health physics tasks.
The Radioactive Material Control (Radwaste)
Section consists of the section supervisor, an engineering technologist, and two radwaste handling supervisor positions (one of which is vacant)
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The radwaste systems are run by the Operations Department; all other duties are assigned to contract workers.
The contract workers during the outage consist of 17 radwaste workers, 10 wet laundry operators, four DAW segregation workers, three Freon tool cleaner operators, four dry cleaner operators, one radwaste shipping technician, and a demineralizer operator.
The licensee estimates that approximately 25 to 30 of these contract workers will remain on a continuing basis after the outage to perform routine radwaste section activities.
The following special studies were recently conducted by the licensee and consultants to assess the quality of the radiation protection program.
On February 9, 1987, an internal RP Program evaluation, based on a review of NRC Inspection Reports since the 1980 Health Physics Appraisal, identified weaknesses in several areas that have reappeared in NRC Inspection Reports since the appraisal, including staffing, coordination between the plant and corporate office, dosimetry, radiation work permits, contamination control, high radiation area control, air sampling, calibration wells, and the radiation monitoring syste ~
In March 1987, a consultant completed a Radiation Protection Program Assessment of the D.C.
Cook Plant.
This assessment concluded that although management is apparently committed to support the Radiation Protection Program, several obstacles are preventing realization of an integrated Radiation Protection Program, including inter and intra-departmental conflicts, communication shortcomings between and within departments, low station radiation protection personnel experience, the need to upgrade the ALARA program, poor radiological work area facilities and equipment, poor training of plant personnel regarding radiological awareness, and excessive reliance on contractor personnel.
. The assessment made numerous specific recommendations regarding organization and management, personnel selection, training and qualification, the ALARA program, and facilities/equipment.
On May 14, 1987, the Plant Radiation Protection Supervisor (PRPS)
sent to plant and corporate management a memorandum containing the results of an in-house review by the radiation protection supervisors (RPS)
and their staffs regarding procedural and programmatic problems.
The PRPS stated that the top tier procedural document; Plant Manager Instruction Procedure No.
PMI-60lO, is inadequate in that program requirements are poorly specified and company policy statements relative to radiation protection, ALARA, and respiratory protection are not included in the document.
The Instrumentation RPS list of programmatic problems included the fact that the root cause of numerous gA audit findings was the difficulty of implementing regulatory commitments because of the vague references to requirements in PMI-6010, excessive instrument repairs turnaround, excessive amount of time required between the request and approval of needed equipment, numerous calibration difficulties, a need to increase the engineering staff, a need to better assess potential airborne problems (S/G and containment),
and inadequate or nonexistent procedures.
The RP Training Specialist indicated that NGET training needed improvement, a procedure should be developed to give adequate guidance for the completion of Radiological Deficiency Reports, stronger disciplinary action is needed for blatant violations of procedures or good radiation protection practices, and the procedure writing/review process needs improvement.
The HP Services RPS noted numerous respiratory protection and dosimetry programmatic problems.
The Radioactive Material Control RPS indicated poor procedures, poor coordination between the RP and Environmerrtal group regarding radwaste shipments, a need for better training regarding radwaste shipping regulations, corporate/plant conflicts, and morale, radioactive source inventory, and source records retention (source receipt
.
documentation was destroyed because of an incorrect retention time in the RP Retention Schedule)
problems.
Recently, a consultant completed a three-month review of the current PMI-6010 and with plant assistance prepared a draft revision titled,
"Radiation Protection Plan."
If PMI-6010 is properly refined, revised, and implemented with regard to generating better lower tier operational procedures, at least some of the concerns expressed in the above May 14, 1987 memorandum may be adequately addressed.
In addition to the above reports, significant programmatic problems have recently been identified by gA auditors (see Sections 9, 11, 13, and 15),
Inspector interviews with various licensee supervisory and managerial staff indicated that management appears committed to improving the radiation protection program based, in part, on the findings of the above studies; however, these same interviews also indicated that the corrective actions for the weaknesses identified in the studies apparently need to be better coordinated to be effective.
A radiation protection improvement program initiated by the licensee in 1985 has not been effective in correcting some significant licensee weaknesses.
Without a more coordinated, comprehensive approach than has been taken to date, the current corrective actions appear likely to be similarly unsuccessful.
This matter was discussed at the exit meeting and will be reviewed further during a future management meeting with the licensee.
(315/87002-02; 316/87002-02)
No violations or deviations were identified by the inspectors.
5.
Radiation Protection Staff Stabilit On December 19, 1986, in response to Inspection Report Open Item Nos.
315/86001-01; 316/86001-01, the licensee completed an internal assessment (Action Request
[AR] No.
1422) of inspector concerns regarding radiation protection (RP) staff experience, stability, and morale.
The assessment resulted in the following conclusions/positive actions:
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To improve the overall experience levels of the RP staff, a
memorandum was sent from the Plant RP Supervisor to the personnel director expressing the desire to have technician vacancies filled by experienced individuals (commercial or navy), whenever possible.
Seventeen members of the RP staff transferred or res igned withi n the last three years; 12 of these individuals stated their reason for leaving as promotion or career advancement.
The total man-years of D.C.
Cook Plant experience increased from 1985 to 1986, and compensated somewhat for significant decreases from 1984 to 1985 due to a heavy loss of highly experienced personnel, including the Plant RP Supervisor, two RP supervisors, and two senior RPTs.
Staff morale was quite low during 1984 and 1985 due, in part, to the replacement of the Plant RP Supervisor and two RP supervisors with new hiree's.
The resultant changes in policies, organizational structure, and methods for conducting daily RPT activities decreased RPT morale further.
The practice of assigning contract RPTs to major projects rather than utility RPTs contributed to the decreased morale.
Since the above report was written, major professional RP staff changes, discussed in Section 4, occurred.
The resultant changes in policies, organization structure, and instructions for the conduct of RPT activities has apparently once again decreased staff morale.
The turnover rate for RPTs remains high; about 40K of the. positions are vacant or filled with technicians who have less than two years experience at the D.C.
Cook Plan The continuing poor RP staff stability represents a potential. negative effect on the efficiency of the radiation protection program.
It is, however, noted that approximately one-half of the recent RPT hirees have prior RP experience; continuation of this practice should gradually improve the effective experience level of the RPT staff.
As noted in recent Inspection Reports (No. 50-315/86001; 50-316/86001 and 50-315/86013; 50-315/86013),
the effect of reduced staff stability remains exacerbated by the licensee's continuing policy of heavy reliance on contract RPTs for job coverage.
As noted in the March 1987 consultant radiation protection program assessment report discussed in Section 4, most of the utility RPTs are from the Terra Tech cooperative program, which should result in a stable local work force.
The technical academic background provided by the Terra Tech program, coupled with structural on-job practical training, has the potential to provide technicians with a stable and challenging career path.
However, the consultant's report indicates that the program has not been successful because many of the Terra Tech technicians appear to have weaknesses regarding work ethic, desire to learn, maturity, and practical hands-on experience and confidence.
Other reports delineated in Section 4 imply that the above perceived programmatic failure in RPT performance, if well founded, is mostly due to past poor practices regarding the training, supervision, and management of the RPT staff.
The reports indicate that morale problems were contributing factors in producing a generally ineffective RPT staff.
The morale problems were identified in the reports as due, in part, to inadequate or poorly written RP procedures; frequent changes in the RP professional, supervisory, and managerial staff; and continual changes in RP policies and organizational structure.
(Although the inspectors did not independently confirm the validity of the consultant's perceptions, they did note significant licensee reliance on contract RPTs in apparent preference to licensee RPTs.)
The special internal licensee and consultant studies discussed in Section 4, contain numerous other recommendations for improvement of staff stability, effective experience, morale, and effectiveness; it appears highly desirable for licensee management to carefully consider these staff effectiveness recommendations when formulating any future radiation protection enhancement plans.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(315/87002-03; 316/87002-03)
No violations or deviations were identified by the inspectors.
~Chan es The inspectors reviewed changes in organization, personnel, facilities, equipment, programs, and procedures that could affect the outage radiation protection program.
During the current refueling and maintenance outage, the plant RPTs and radiation protection supervisors are providing continuous coverage by working twelve-hour days, five days per week.
The licensee's radiation protection staff augmentation by contract personnel is discussed in
Section 4.
The RP outage organization was under the nominal direction of the Plant RP supervisor and the Job Coverage RP Supervisor.
Almost without exception, the RP crew chiefs for the various outage groups were contract RP supervisors or contract senior RPTs; the outage groups included surveys, respiratory protection, radwaste, auxiliary building day/night job coverage, containment access control day/night coverage, reactor coolant pump and steam generator job coverage, control point coverage, and containment rovers.
Based on numerous and frequent NRC plant tours in the auxiliary and turbine buildings and Unit 1 containment, the observation of work activities performed under the requirements of over a dozen RMPs, and the post-job interviews with workers who performed tasks not directly observed by the NRC inspectors, it appeared that RP job coverage was adequate with the exceptions noted in Section 17.
During the outage, the licensee does not require that a radiation protection performance engineer (health physicist)
be on-duty or assigned by a formal on-call duty schedule.
This matter was discussed during the.
exit meeting and will be reviewed further during a future inspection.
(315/87002"04; 316/87002"04)
Except for limited licensee oversight of the contract RPTs and the lack of official on-duty/on-call HP's, the changes in the RP program made by the licensee to accommodate the outage appear to provide the needed shiftly RP coverage.
No violations or deviations were identified.
Plannin and Pre aration The inspectors reviewed the outage planning and preparation performed by the licensee, including:
additional staffing, special training, increased equipment supplies, and related health physics considerations.
Health physics personnel participated in preplanning meetings and were aware of major radiation jobs in advance of the outage.
According to.
the licensee, job priorities were established, sufficient information was given to the radiation protection section to supply adequate job coverage for noncritical path activities, there was sufficient available manpower to cover the jobs, and interdepartmental cooperation was adequate.
The additional RP staffing for the outage is discussed in Section 4.
The contract RPT selection process included a verification of resumes, including discussion with previous employees for contract RPTs not well-known by plant personnel, and an entrance examination.
The entrance examination consisted of 20 practical questions concerning basic health physics knowledge; those persons applying for positions as senior and junior RPTs were required to pass with examination scores of 80K and
?OX respectively.
The inspectors reviewed the quality of the examination and selectively reviewed examination records.
The examination questions were of minimal to moderate difficulty, the number of questions below
the norm of 50 to 100 questions, and the examination questions somewhat limited in scope; no problems were noted concerning the examination records.
The inspectors selectively verified that those technicians not meeting ANSI N18. 1-1971 selection criteria were not providing radiation protection duties without proper supervision.
Training is discussed in Section 8.
Based on interviews with licensee representatives, the supply of portable instruments, portable ventilation equipment, protective clothing, and respiratory protection equipment for the outage appears generally adequate with some brief exceptions which occurred early in the outage.
Evidence that job planning and preparation is influenced by radiation protection includes the assignment of two RPTs to work with the Planning Department and one RPT to work with the Technical Physical Sciences Outage Coordinator, containment decontamination and shielding prior to allowing outage work to begin, and radiation protection and ALARA participation in all planning and outage meetings with the possible exception of pre-job worker briefings (see Section 12).
No violations or deviations were identified.
Trainin and ualifications The inspectors reviewed the training and qualification aspects of the licensee's radiation protection program including education and experience qualifications of new plant and contractor radiation protection personnel and training provided to them.
Also reviewed were management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses.
An inspector discussed the nuclear general employee training (NGET)
program with the NGET associate training instructor.
Relatively inexperienced radiation workers receive initial NGET training which consists of eight hours of classroom training in radiation protection, site-specific security, and industrial safety and four hours of practical factors training such as the use of step-off pads and the donning/removal of protective clothing.
An examination score of 70% is required for the
=general radiation protection test, 80% is required for the site-specific and practical factors tests, and each worker must adequately demonstrate that he can correct all deficiencies noted by the instructor on the
item Anti-C removal and frisking evaluation check-off sheet.
Relatively experienced radiation workers may be allowed to take a challenge general radiation protection test.
If the worker scores at least 80% on the challenge test, he may complete NGET training by taking the short site-specific course and test; however, if the worker scores less than 80%,
he must take the same NGET course as the inexperienced radiation workers.
Annual NGET requalification consists of a two to three hour site-specific classroom training session on radiation protection, security, and industrial safety; a written test with an 80% passing grade; and instructor assurance that each student understands the correct answer to each question that the worker initially answered incorrectly.
The inspector found no problems with the licensee's NGET progra An inspector reviewed the May 7, 1987 revision to licensee Procedure No. 12-PMP-2070-111,
"Radiation Protection Technician Training Program,"
.
and discussed the program with the senior radiation protection training instructor and the radiation protection training coordinator.
They stated that the revision to the program was made primarily to conform to INPO guidelines and that the program was expected to be INPO accredited in the near future.
The program appears to be comprehensive in all phases, including fundamentals, higher skilled jobs including transportation and emergency tasks, and on-the-job training (OJT).,
The OJT includes a
practical qualification examination which must be passed and documented.
Each individual's qualification status is tracked.
The inspector reviewed a representative sampling of the qualification cards on file; no problems were noted.
It was noticed that one individual who did not pass was allowed to do self-training and later passed the qualification test.
A licensee's representative stated that if the OJT candidate does not obtain the procedure and have it in hand before he begins the task, he is immediately disqualified.
The revised radiation protection technician (RPT) training program also has a Continuing (requalification) Training Plan scheduled to be fully implemented within about a year; it includes additional training necessary due to plant modifications, procedural changes, and NRC bulletin and information notice concerns.
The Radiation Protection Training Specialist stated that all the incumbent technicians attended a gaseous/liquid waste requalification training course in May/June 1987.
The course covered technical specifications, procedural, calculational, and documentation requirements.
The licensed's revised training program appears to better define contract RPT training requirements as well as those for contract decontamination/
radwaste handling (nuclear support technicians)
employees.
Contract personnel are not required to participate in the full radiation protection technician training program and are considered to belong to one of two groups:
outage contract and long-term contract technicians.
Outage contract personnel perform well-defined duties during outages.
Long-term contract personnel are contracted for an extended period of time, but are also restricted to performance of specific plant duties.
Training for contract technicians is generally restricted to their assigned tasks, in addition to an overview of pertinent radiological protection activities.
Newly-contracted technicians who are skilled may be granted waivers to skip both classroom and laboratory training for many prerequisites.
Skill, however, must be demonstrated by documented material or by satisfactorily passing a waiver examination.
However, a training instructor stated that the licensee does not allow waivers for the contract technicians for field OJT, including accompanying qualification tests.
The licensee's modern and well-equipped new training building, as well as the new training program, appear to indicate a serious intent for quality training.
A licensee representative showed an inspector the large training
e
laboratories where, for example, a fluorescent material is used to simulate radioactive contamination, actual calibrations of instruments are performed, and real radiation monitoring components; pumps, and valves are used.
The licensee representative stated that training will be expedited due to the fact that the whole body counter, security processing, and training will all be in one building.
An inspector also attended the calculational methodology portion of a licensee's special training seminar given for senior radiation protection personnel.
This beta dosimetry course was held on August 4-5, 1987.
The training appeared informative and useful, particularly in preparation for the steam generator replacement outage.
Licensee training representatives stated that they are developing a list of training tasks related specifically to the steam generator replacement outage.
Six training sessions are to be gi,ven before the outage begins to qualify technicians in these specific tasks.
Representative training records and examinations were reviewed and found to be adequate.
Ouring plant tours, violations of RWP protective equipment requirements appear to indicate a need for more emphasis on RWP compliance during NGET and RPT requalification training.
No violations or deviations were identified.
External Ex osure Control and Personal Oosimetr The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including:
changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine and and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses.
Exposure records of plant and contractor personnel for 1987 to date were selectively reviewed; no exposures greater than
CFR 20. 101 limits were noted.
The total whole body dose for 1986 was 673 person-rem which is somewhat less than the national average for PWR plants and about equal to the licensee's average for the last five years.
It is noted that although the national PWR plant average dose has decreased by about 45K since 1981, the O.C.
Cook Plant annual dose has remained virtually unchanged; these statistics and the ALARA program inadequacy implications are discussed further in Section 12.
The 1987 plant goal is to reduce person-rem exposure by at least 15K from the 1986 level; thus the 1987 total dose goal is approximately 570 person-rem.
The 1987 total dose through the end of July is 445 person-rem, based on reported self-reading dosimetry data.
For those individuals whose whole body exposure exceeded 1.25 rem in a calendar'uarter, NRC Form 4's, Occu ational External Radiation Ex osure
.
~Hister
, or the equivalent were selectively reviewed; no problems were noted.
The total number of 1987 administrative exposure extensions through the end of July is 103.
Procedure No.
THP 6010.RAD.710, TLD Issue and Record Establishment, requires that an Authorization for Occupation Exposure to Ionizing Radiation Form be completed and signed by the appropriate personnel before permission is granted for any worker to exceed the administrative whole body exposure limit of 1.0 rem/quarter.
An inspector selectively reviewed completed authorization forms; no problems, were noted.
A licensee dosimetry representative stated to an inspector that the present TLD used is outdated (not state-of-the-art).
The licensee plans to contract for a dosimetry service which utilizes a newer and more versatile TLD.
The new dosimetry program is expected to be operational for the steam generator repair (SGR) project and to be adopted plantwide.
The service contract includes specialists from the University of Michigan who will train and assist licensee staff in the implementation of the use of the new TLD (Panasonic-800)
prior to the beginning of the SGR project.
The inspectors reviewed the licensee's current dosimetry program to verify compliance with NRC requirements (Form NRC-5) which specify that whole body doses be determined using a maximum absorber thickness of 1000 mg/cm when eye protection (> 700 mg/cm ) is provided and a maximum of 300 mg/cm2 without eye protection.
The licensee's dosimetry program employs the use of a 2-chip TLD system; one chip with a tissue equivalent absorber thickness of 7 mg/cm
, the other chip with 285 mg/cm
.
The licensee evaluates whole-body gamma-exposures through the tissue equivalent absorber of 285 mg/cm2; eye protection is not routinely required.
For mixed beta/gamma fields, a computer algorithm calculates 7 mg/cm2 and 285 mg/cm2 dose equivalents.
No problems were noted.
During an earlier inspection (Inspection Reports No. 50-315/86001; 50-316/86001),
the inspectors frequently observed workers wearing thermoluminescent (TLD) and self-reading (SRD) dosimeters improperly; the most common improper placements were on chains worn around the workers'eck.
In response to inspector concerns, on September 30, 1986, the RPM sent a policy memorandum to upper-level plant managerial and supervisory staff to establish definitive guidelines concerning the proper location and orientation of personnel dosimetry, including prohibiting the wearing of dosimetry on neck chains.
The senior NGET training instructor stated that these guidelines have been incorporated into the NGET training program, including a new video segment in proper wearing of personnel dosimetry.
This corrective action was apparently inadequate to prevent recurrence in that gA Surveillance Report (S/R)
No. 12-87-32, dated March 11, 1987, noted that contrary to Procedure No.
PMP 6010. RAD.001, Radiation Protection Manual, dosimetry was not consistently worn in accordance with the September 30, 1986 policy memorandum; in a majority of the cases found, personnel were wearing their dosimetry on chains.
During plant tours, the inspectors also noted personnel who were wearing dosimetry on chains.
The licensee has issued Action Request (AR) No.
1468 in response to gA Report S/R No. 12-87-32.
Also, on August 4, 1987, the Plant Radiation Protection Supervisor issued to all RP personnel a memorandum which reiterated the plant policy that all procedures shall be followed.
This matter is considered an
'nresolved Item pending further NRC review of the effectiveness of the recent licensee corrective actions.
(315/87002-05; 316/87002-05)
No violations were identified by the inspectors.
Internal Ex osure Control and Assessment The inspectors reviewed the licensee's internal exposure control and assessment programs, including:
changes in facilities, equipment, personnel, respiratory protection training, and procedures affecting internal exposure control and personal assessment of individual intakes relative to regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs, and experience concerning self-identification and correction of program implementation weaknesses.
The licensee conducted 6436 whole body counts (WBCs) in 1986; through July, 3622 WBCs were conducted in 1987.
The inspectors selectively reviewed WBC records and evaluations of MPC-hours; no result exceeding the 40 MPC-hour control measure w'as noted.
(Two persons received greater than one percent maximum permissible body burden (MPBB) in 1986; through.
July, six positive WBCs (MPBB's all less than 10%) have been identified in 1987).
In addition to initial, termination, and routine periodic WBCs, the licensee requires a
WBC for an individual with personnel contamination above the shoulders if detectable by hand-held friskers.
The program to control internal exposures during outage activities includes engineering controls, airborne sampling and contamination surveillance, and use of approved respiratory devices and protective clothing.
Whole body counting is used to supplement the monitoring program to ensure its effectiveness.
The engineering controls include use of portable ventilation units with filters to exhaust and clean air from certain areas in the containment when possible radioactive airborne producing work is performed.
A selected review of air sample and smear survey results was made.
No problems were noted.
In preparation for the current outage and for the steam generator repair project, the licensee moved the Canberra FASTSCAN stand-up type whole body counter (WBC) out of a trailer into the dosimetry, suite of the new training building.
An inspector reviewed the tissue equivalent phantom whole body, lung, and thyroid calibration records for this counter; no problems were found.
It was noted that all sources are traceable to the National Bureau of Standards.
A new Canberra ACUSCAN II WBC also was purchased and is now fully operable in the lower level of the office building.
The sensitive counter utilizes a traveling germanium-lithium (Ge-Li) detector.
The counter can perform a scan, then indicate the geometric location of the maximum activity.
The operator may then direct the detector to take a longer count in that maximum activity area for
better quantitative information.
The licensee appears to utilize the manufacturer's manuals adequately.
No problems were identified with MBC standardization and calibration.
O.C.
Cook Nuclear Plant has a mutual arrangement with Palisades Nuclear Generating Plant for emergency whole body counting.
The staging area where vital personnel are expected to assemble in an emergency is the lower level of the new office building.
The new MBC there can be used in emergency situations, environmental conditions permitting.
An inspector reviewed the respirator cleaning, testing, and recertification facility operated by the licensee's contractor; no problems were noted.
Precleaning includes a gross smear of each respirator to preclude hazardously contaminated respirators cross-contaminating other respirators.
The facility itself is surveyed (frisk/smeared)
once each day.
Each respirator has its own number and Kardex file.
Visual inspection of the respirators for physical damage appears adequate.
The limit for transferable contamination on a cleaned respirator is 50 dpm inside and out.
The final clean, certified, and sanitized respirator is placed in a plastic bag and sealed.
There were no problems noted with the respirator cleaning facility.
Partially in response to an outside audit finding, the licensee recently implemented a respirator accountability program.
The primary purpose of this program is for the licensee to be able to identify individuals who have recently worn respirators which, upon inspection, are suspected to have malfunctioned during use.
Licensee representatives stated that when apparently defective respirators have been used, the work activities of these individuals are reviewed, the individual interviewed, and the individual whole body counted, as appropriate.
As noted above, the respirators are numbered, the traceability to the individual is apparently adequate, and the method for mechanical malfunction visual inspections and contamination surveys of used respirators appears adequate; however, interviews with plant personnel indicate there is substantial potential for used respirators to become cross-contaminated.
According to the licensee representatives, early in the current outage it was common for workers to discard used respirators in contaminated material containers in which the respirators could become cross-contaminated with other respirators, protective clothing, and other contaminated material; the corrective action taken by the licensee was to require that respirators be discarded into special respirator-only containers; however, licensee personnel. indicated this corrective action is incomplete because cross-contamination between respirators is still possible.
This matter will be reviewed further during a future inspection.
(315/87002-06; 316/87002-06)
An inspector selectively reviewed records and interviewed licensee representatives regarding the requirements of Procedure No.
THP 6010.RA0.408, Control of Airborne Radioactivity Exposure.
Personnel data file records were also selectively reviewed regarding medical approval, respirator training, mask fit, and whole body counts.
No problems were noted.
No violations or deviations were identified.
Control of Radioactive Materials and Contamination The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including:
adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated materials.
In July 1986, the licensee began the auxiliary building reclamation project which had the goal of reducing the auxiliary building contaminated floor area from approximately 53,000 square feet to about 20,000 square feet (ten percent of total floor area) within one year.
As areas are decontaminated, appropriate surfaces are painted, and process leakage is repaired or contained.
By the end of 1986, the auxiliary building contaminated floor area decreased to 28,000 square feet.
The value was further decreased to 21,500 square feet by the end of June 1987; however the value was increased to 26,000 square feet by the end of July 1987, in part, due to the difficulties associated with maintaining the project during outage conditions.
During plant tours, the inspectors noted many leakage containment devices; licensee representatives stated that there were currently 636 leakage containment devices, due partially to a maintenance backlog for repairing contaminated process system leakages.
At the exit meeting the inspectors stated that it appeared desirable for the maintenance of the contaminated liquid process systems to be such that the licensee obtain their 1987 goals of reducing the number of leakage contamination devices to 200 and the auxiliary building contaminated floor area to less that 10,000 square feet.
This matter will be reviewed further during a future inspection.
(315/87002-07; 316/87002-07)
There were 468 personnel contamination incidents in 1986 and 400 personnel contamination incidents in 1987 through the end of July.
(The increase in rate of personnel contamination incidents may be due, in part, to the recent installation of more sensitive portal monitors.)
The licensee had a 1987 goal of reducing the number of personnel contamination incidents to 100.
The licensee defines a personnel contamination incident as one where an individual has skin or clothing contamination equal to or greater than 100 cpm above background using a frisking device, or any detectable counts on nasal or mouth swabs.
There were approximately twice as many clothing as skin contaminations to date in 1987.
The inspectors noted that root causes such as protective clothing contamination leaching, hot particles, inadequate RWP dress requirements, inadequate pre-job surveys, contaminated step-off pads, failure to use frisking booths upon exiting contaminated areas, RWP violations, and poor RP work practices are not
e
adequately tracked and trended to identify and correct programmatic deficiencies.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(315/87002-08; 316/87002-08)
A gA surveillance (Report No.
S/R 12-87-23)
was conducted in February 1987 to verify that personnel contamination incidents are documented in accordance with Procedure No.
THP 6010.RAD.600, Personnel Decontamination Incident Reporting.
The following procedural violations were noted by the auditors:
~
Contrary to Step 6.3.3, a whole body count (WBC) was not performed when a contamination greater than 100 cpm on the shoulders or above was documented in Incident Report No. 512, dated October 3, 1986.
'On October 10, 1986, a
WBC was performed on the individual; no contamination was detected.
Contrary to Step 6.2, appropriate sections of Form 12 THP RAD.600-1, Personnel Contamination Incident, were not completely filled out in 24 of the 64 reports reviewed.
The above failures to follow the requirements of Procedure No.
THP 6010.RAD.600, which are identified in gA Report No.
S/R 12-87-23, are apparent violations of Technical Specification 6.11 which requires adherence to radiation protection procedures.
Corrective actions have been taken to preclude recurrence.
Thus, the apparent violations of Technical Specification 6.11 appear to meet the criteria of
CFR 2, Appendix C for self-identification and correction of problems.
Therefore, a Notice of Violation is not being issued at this time.
During plant tours, the inspectors performed radiation and contamination surveys of tools, equipment, and areas in the auxiliary building.
In general, independent surveys of radiation areas were in good agreement with licensee posted results; however, on July 20, 1987, the inspectors found an object outside a posted contaminated area with smearable contamination levels above that permitted by procedure.
A review of radiological deficiency reports (RDRs) revealed that the licensee had recently identified three similar occurrences (see Section 19).
Procedures No.
12 THP 6010. RAD.404, Establishing Posted Areas, and No.
12 THP 6010.RAD.200, Routine Radiation and Contamination Surveys and Establishing Posted Areas, require any area in which the removable contamination on any accessible surface or equipment exceeds 500 dpm/100 cm~
beta-gamma to be posted as a contamination area.
Contrary to the above, the inspectors or the licensee found equipment with removable contamination greater than 500 dpm/100 cm~ beta-gamma located outside designated contamination areas in the auxiliary building, in that:
On March 10, 1987, three chain falls with removable contamination of about 6000, 3000, and 1400 dpm/100 cm~ beta-gamma, respectively, were issued for use from the hot tool crib on the 633-foot elevation to two workers.
As a result of the fai lure to adequately survey the chain falls before issuance, the hands of both workers became contaminated.
On March 18, 1987, a steam generator eddy current probe with removable contamination of about 350,000 dpm/100 cm~ beta-gamma was found on the clean side of the 609-foot elevation decontamination/
laydown area.
On April 15, 1987, a steam generator tube marking tool with removable contamination of 'about 130,000 dpm/100 cm~ was found near the 609-foot elevation decontamination/laydown area.
On July 20, 1987, a pressure gauge with removable contamination of about 1000 "dpm/100 cm~ was found on a cart adjacent to the 609-foot elevation decontamination/laydown area.
Failure to adequately evaluate removable contamination levels on the above equipment to ensure compliance with 10 CFR 20.101(a)
and
CFR 20.103(a)
is a violation of 10 CFR 20. 201(b) which requires adequate evaluations of radiation hazards present.
Other violations of this type were identified in Inspection Report Nos.
(50-315/86001; 50-316/86001),
(50-315/85024; 50-316/85024),
and (50-315/85011; 50-316/85011).
Although the first three of the above events were identified by the licensee, the corrective actions for the earlier events discussed in the referenced Inspection Reports were not adequate to prevent the subsequent events.
Thus, the latter occurrences do not satisfy all the criteria for self-identification and correction described in 10 CFR Part 2, Appendix C, "General Policy and Procedures for Enforcement Action."
(Violation: 315/87002-09; 316/87002-09)
During a previous inspection (Inspection Reports No. 50-315/86001; 50-316/86001)
in April 1986, the inspectors discussed with the RPM the apparent poor control of contaminated material at the 633-foot elevation of the auxiliary building in the vicinity of the Freon tool decontamination area, the hot tool crib, and the hot tool crib decontamination area.
The RPH was aware of the above radioactive material control problems and presented the inspectors with his draft plan to consolidate the various individual areas of this portion of the auxiliary building so that the flow of contaminated material into the area, its decontamination, storage, and reissue are under strict radiation protection control.
The inspectors stated to licensee management that it appears that the plan, as presented to the inspectors, has merit and it, or a similar positive control reconfiguration of area, is desirable and should be pursued.
On December 10, 1986, the Technical/
Physical Sciences Department assigned Action Request (AR) No.
1423 to the RP Section for completion of the modification; however, actual construction is not expected to begin until mid-October 1987.
As noted in the above paragraph and in Section 17, the hot tool crib area continues to be under inadequate RP control.
This matter represents poor responsiveness to NRC initiatives (Open Item Nos.
315/86001-03; 316/86001-03)
in that its resolution appears to be taking an inordinate amount of time.
A gA Audit (Report No. QA-87-07 dated March 31, 1987)
was conducted, in part, to verify that documentation and activities associated with the Measuring and Test Equipment (M8TE) Program in the Radiation Protection (RP) Section are conducted in accordance with Plant Manager Instruction Procedure No.
PHI-6010, Radiation Monitoring and Protection, and subtier
procedures.
During this audit, it was found that the requirements of PMI-6010 are not being adequately delineated; implementation of the existing requirements, in s'ome instances, requires actions to be performed although no procedural guidance exists; and the absence of guidance in PMI-6010 or subtier procedures for the RP Section MME control program has resulted in a program in which the adequacy of implementation and consistency of practice are primarily dependent
=on the people implementing the program.
The auditors found that the existing program is insufficient to comply with the requirements for MSTE program as set forth in ANSI N18.7-1976 and ANSI N45,2-1977.
For this reason, the auditors found the RP Section's M8TE control program to be ineffective.
Problems identified by the auditors included six examples of failures to, follow procedures and 23 examples of inadequate procedures governing RP instrument calibrations, failure to list 14 types of calibration records on the Records Retention Schedule as required by Procedure No.
PMI-2040, Information Management, and inadequacies in PMI-6010 guidance which the auditors stated resulted in 11 calibration sources without NRC certification and numerous deviations from licensee commitments ANSI N18.7-1976 and ANSI N45.2-1977.
The above QA audit findings resulted in the issuance of two condition reports, although some of the minor deviations were corrected during the audit.
The inspectors reviewed the proposed corrective actions in response to the QA findings and interviewed the QA auditors, the QA Supervisor, members of the RP Section staff, and several members of the licensee's supervisory and managerial staff regarding the specific findings of this audit and related concerns which are expressed in the special consultant and internal licensee reports discussed in Section 4.
The responses of the RP Section to the QA findings were apparently not timely, thorough, or technically sound in that the corrective actions for both condition reports were disapproved by the QA auditors; a condition report was written because the second round responses to the original condition reports were not completed by the scheduled date; and some corrective actions in the second round response to one of the original two condition reports were also disapproved by the QA auditors.
The scheduled due date for the next round of corrective action responses was after the onsite exit meeting on August 7, 1987.
However, on August 4, 1987, the Plant Radiation Protection Supervisor issued to all RP personnel a memorandum which reiterated the plant policy that all procedures shall be followed.
The above failures to have adequate procedures and to follow procedural requirements, which are identified in QA Report No. QA-87-07, are apparent violations of Technical Specification 6. 11 which requires adherence to an adequate radiation protection procedures, violations of Technical Specification 6;S.l.a which requires adherence to and adequate record retention and calibration procedures, and violations of Technical Specification 6. 10. l.d which requires proper retention of calibration records.
Although the initial efforts to resolve the adequacy of the RP section's responses to the audit finding were inadequate, at the onsite exit meeting on August 7, 1987, the AEPSC QA Site Supervisor 23 and the Plant Radiation Protection Supervisor informed the inspectors that adequate corrective actions to prevent recurrence would soon be in effect.
This matter is considered an Unresolved Item pending completion of licensee corrective actions and NRC review to determine if the apparent violations of Technical Specifications 6. 11, 6.8. l.a, and 6. 10. 1.d appear to meet the criteria of 10 CFR 2, Appendix C for self-identification and correction of problems.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(315/87002-10; 316/87002-10)
One violation with four examples was identified by the inspectors.
Maintainin Occu ational Ex osures ALARA The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA, including:
changes in ALARA policy and procedures; ALARA considerations for maintenance and refueling outage; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them.
Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of implementation weaknesses.
The inspectors reviewed the ALARA organization, the qualification and experience of its members, and the effectiveness of the organization in instituting dose-saving programs during outages.
The ALARA Coordinator transferred to a position at another of the facility licensee; the ALARA Engineering Technologist is currently serving as the Acting ALARA Coordinator.
The other members of the staff include a full-time clerk, a contact technician during normal operations, and six contract technicians during the current outage.
As discussed in Inspection Reports No. 50-315/86001; 50-316/86001, it appears that the effective implementation of the ALARA program requires significant upgrading in computer capabilities, numerical goal setting by subgroup and subtask, and adequate detailed historical records to research dose-saving techniques.
The licensee plans to upgrade computer capabilities in 1988; however, no contract for this effort has yet been issued.
The inspectors selectively reviewed portions of the ALARA profile book, job history files, pre-job meeting minutes, and the ALARA file tracking system; no problems were noted.
Although the ALARA pre-job briefing of task supervisory personnel seems generally adequate, inspector interviews with various licensee personnel indicate that the pre-job briefings given to workers by the supervisors need improvement regarding ALARA dose-saving instructions; specific concerns and possible corrective actions were discussed with the Acting ALARA Coordinator.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection (315/87002-11; 316/87002-11).
The six contract technicians working on the ALARA staff during the current outage are each assigned primarily to one of the six following major jobs:
steam generator in-service inspection (eddy current) activities, primary coolant pump work, refueling activities, steam generator sludge lancing, scaffolding work, and valve repair.
Each technician was to attend all
pre-job briefings, follow the work activity. to completion, and prepare a report summarizing their observations, lessons learned, and suggestionz for future similar tasks.
The inspectors reviewed the one report which had been completed (steam generator in-service inspection).
The report appeared thorough, comprehensive, and the suggestions may result in significant future dose-savings.
This pilot program would appear to be quite successful if the lessons learned and suggestions are properly followed.
The inspectors discussed with the licensee the desirability of continuing the program.
As discussed in Section 9, although the D.C.
Cook plant total whole body dose for 1986 was somewhat less than the national average for PWR plants, the national average has decreased by almost a factor of two since 1981, while the Cook annual total dose showed no significant decrease.
- This appears to portend a need for renewed ALARA efforts by the licensee.
As the March 1987 consultant Radiation Protection Program Assessment (see Section 4) states, part of the reason D.C.
Cook has maintained annual total exposure less than the national PWR average is due to the relatively lower dose rates in the plant.
The March 1987 consultant's report made numerous recommendations regarding the apparent need to improve the, ALARA program; although the inspectors did not independently confirm the validity and appropriateness of all the consultant recommendations, most are similar to NRC findings discussed with the ALARA Coordinator during previous inspections.
During this inspection, the inspectors discussed with the Acting ALARA Coordinator, and others, the consultant recommendations, the features of other licensee's ALARA programs with which the inspectors are familiar, and ideas for improvement developed by the Acting ALARA Coordinator and his predecessor.
Unless adequate management support and resources are devoted to upgrading the ALARA program, significant future dose-saving opportunities may be missed.
Any improvements to the ALARA program should be incorporated into the Steam Generator Repair Project.
No violations or deviations were identified by the inspectors.
Solid Radioactive Waste The inspectors reviewed the licensee's solid radioactive waste management program, including:
determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality assurance programs; adequacy o'f required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesses.
Through July 16, the licensee has shipped 6520 cubic feet of solid radwaste in 1987, compared to 18,650 cubic feet shipped in 1986, and 29,260 cubic feet shipped in 1985.
The licensee generally maintains a
very low volume of waste in storage (less than 1,000 cubic feet);
therefore, the volume of waste shipped corresponds closely to the volume of waste generated.
The continuing reduction is due, in part, to the licensee s conscientious efforts to minimize solid radwaste volume by judicious use of radwaste process equipment, waste segregation, and dry active waste (DAW)
compaction.
Recent innovations include use of a demineralizer instead of the waste evaporator for some waste streams, use of more efficient process equipment for cleaning contaminated mop heads, the upgrading of the compaction ratio of the station contaminated trash compactors, purchase of a steam-vacuum floor cleaner, reduced use of Herculite, less use of non-reuseable mop heads, and reduced material entering the RCA.
The 1987 goal of reducing radwaste generated by at least 20K from the 1986 level (down to approximately 15,000 cubic feet)
seems reasonably attainable.
A review of the monthly radioactive waste status reports indicates that the licensee has done an effective job in minimizing the amount of solid radwaste temporarily stored onsite.
The inspectors toured the radwaste process and solid radwaste storage facilities; no significant problems were noted.
The inspectors reviewed Revisions No.
5 and No.
6 of the Radioactive Waste Process Control Manual, Procedure No.
PMP 3150.PCP.001, as reported in the Semiannual Radioactive Effluent Release Reports for January 31 through June 30, 1986 and July 1 through December 31, 1986, respectively; no significant problems were noted.
In addition to the problems regarding the radwaste/shipping program in'dicated in Section 4 above, the annual QA Radwaste Audit resulted in a number of findings.
A QA Audit (Report No. QA-87-11 dated June 2, 1987)
was conducted to verify that documentation and activities associated with radioactive waste processing, radioactive waste shipments, radioactive material shipments, and radioactive material receipts conducted by the Technical-Physical Science Department were in accordance with PMI-3150, PMI-6010, and applicable subtier procedures.
During this audit, it was found that the requirements of PMI-3150 and PMI-6010 are not adequately delineated; PMI-3150 and PMI-6010 do not adequately distinguish between the requirements applicable to radioactive waste and radioactive material shipments.
In addition, the auditors found that sufficient guidance is not provided to ensure consistency in the performance of radioactive material shipments and the implementation of the requirements of PMI-3150 and PMI-6010 is not consistent.
The auditors stated that procedural requirements were not being implemented, in part, because the personnel performing the activities covered by these procedures were not fami liar with the requirements and personnel responsible for supervising these activities did not ensure procedural compliance.
The auditors concluded that due to the lack of implementation of procedural requirements, lack of guidance in these procedures, arid inconsistency in the implementation of these requirements, it cannot be assured that all applicable regulations for radwaste shipments are being met or will be met in the future; thus, the Radioactive Material Receipt, Packaging and Shipment Program is considered to be ineffectiv o
~ ~
Problems identified by the auditors included numerous inadequacies in the Solid Waste Handling and Drumming Procedure (No.
THP 6010.RA0.303)
and the Shipment of Radioactive Materials Procedure (No.
THP 6010.RAD.304)
.
due to insufficient guidance in PMI-3150 and PMI-6010, numerous violations of both of these procedures and the Radioactive Waste Process Control Manual Procedure (No.
and contrary to the Radiation Protection Section Records Retention Schedule, records of radioactive material received and radioactive material shipments were not being sent to the Plant Master File Vault in the required time.
Although some of the minor deviations were corrected during the audit, ll of the findings resulted in the issuance of condition reports.
The inspectors reviewed the proposed corrective actions in response to the QA findings and interviewed the QA auditors, the QA Supervisor, members of the RP and Radioactive Material Control (Radwaste)
Section's staff, and several members of the licensee's supervisory and managerial staff regarding the specific findings of this audit and related concerns which are expressed in the consultant and internal licensee reports discussed in Section 4.
The responses of the RP and Radwaste Sections to the QA findings were apparently not timely, thorough or technically sound in that some of the corrective actions taken in response to the 1985 and 1986 annual QA audits were inadequate to prevent recurrences and the responses to all 11 condition reports for the associated 1987 QA findings were found unacceptable by the QA auditors.
The scheduled due date for next round of corrective action responses was after the onsite exit meeting on August 7, 1987.
On August 4, 1987, the Plant. Radiation Protection Supervisor issued to all RP personnel a memorandum which reiterated the plant policy that all procedures shall be followed.
The above failures to have adequate procedures and to follow procedural requirements, which are identified in QA Report No. QA-87-11, are apparent violations of Technical Specification 6. 11 which requires adherence to and adequate radiation protection procedures, violations of Technical Specification 6.8.1.a which requires adherence to and adequate record retention and log entry procedures, and violations of Technical Specification 6.8. l.g which requires adherence to and adequate process control program implementation procedures.
Although some of the violations are recurrences of violations identified in earlier QA audits and the initial efforts to resolve the adequacy of the RP and Radwaste Sections'esponses to the audit findings were inadequate, at the onsite exit meeting on August 7, 1987, the. AEPSC QA Site Supervisor and the Plant Radiation Protection Supervisor informed the inspectors that adequate corrective actions to prevent recurrence would soon be in effect.
This matter is considered an Unresolved Item pending completion of licensee corrective actions and NRC review to determine if the apparent violations of Technical Specifications 6. 11, 6.8.1.a, and 6.8. l.g appear to meet the criteria of
CFR 2, Appendix C for self-identification and correction of problems.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(315/87002-12; 316/87002-12)
No violations or deviations were identified by the inspectors.
14.
Trans ortation of Radioactive Materials The inspectors reviewed the licensee's transportation of radioactive materials program, including:
determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation,,
and notifications; and experience concerning identification and correction of programmatic weaknesses.
The inspectors selectively reviewed portions of the solid radwaste shipment records to date in 1987.
The information on the shipping papers appears to satisfy NRC, DOT, and burial site requirements.
The licensee had 39 shipments in 1986 and 14 shipments through July 17 in 1987 consisting of 18,650 and 6,520 cubic feet, respectively.
The shipments in 1984 and 1985 consisted of 17,440 and 29,260 cubic feet, respectively.
The increased volume generated and shipped in 1985 was primarily due to activities associated with the Unit 1 ten-year ISI refueling outage, the Unit 2 steam generator repair outage, and five maintenance outages.
An inspector also observed the loading, labeling, and survey of an LSA truck shipment consisting of 88 drums (DOT 17-H containers);
no problems were noted.
The inspector also verified that the licensee survey instruments had valid calibration stickers and were recently source checked.
Independent measurements by the inspector of radiation level and smear surveys agreed reasonably well with those of the licensee.
Shipping documents for the shipment contained the required information and signatures and generally were in good order.
Although the licensee was not required by NRC Regulation
CFR 71.97 to send prior notification to the State of South Carolina for this LSA shipment, a voluntary prior notification was sent.
However, the licensee did not include in the prior notification list all of the prominent radionuclides which are required by the licensee's prior notification form; tritium was left off the list.
A licensee representative stated that for future shipments all the prominent radionuclides including pure beta emitters would be listed.
On October 22, 1986, at the Barnwell waste burial facility, a State of South Carolina inspector found that exclusive use radioactive shipment No. 1086-248-A, classified as Radioactive Material, n.o.s.
and transported from D.C.
Cook to Barnwell in a HN-200 shipping cask, was improperly labeled as Yellow-II in that the radiation survey conducted by the state inspector determined a transportation index of 1.5.
A Yellow-III label is required by 49 CFR 172.403(b) to be affixed to packages of radioactive material if the transportation index is greater than 1.0.
The transportation index is defined by 49 CFR 173.403(bb)(1)
as the number expressing the maximum radiation level in millirem per hour at one meter (3.3 feet) from the external surface of the package.
The State of South Carolina, in a letter dated October 27, 1986, notified the licensee of the above violation.
The licensee, in a letter dated November 10, 1986, informed the State of South Carolina that corrective measures had been taken in that:
(1) misinterpretation of 49 CFR 172.403(b)
and a procedural deficiency resulted in the mislabeling of the shipping cask; (2) 49 CFR 172.403(b)
has been reviewed by personnel involved with the shipment of radioactive material; (3) Procedure No.
THP 6010.RAD.304, Shipment of Radioactive Materials, did not address the transport index as a
requirement of labeling; and (4) the procedural deficiency has been corrected.
The State of South Carolina, in a letter dated November 20, 1986, informed the licensee that the licensee's corrective actions are satisfactory.
The NRC inspectors verified the correction of the procedural deficiency.
Failure to adhere to 49 CFR 172.403(b) is a violation of 10 CFR 71.5 which prohibits transport of any licensed materials outside the confines of a plant or other place of use or delivery of licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Transportation in 49 CFR Parts 170-189.
The licensee's corrective actions appear adequate to prevent recurrence.
(Violation:
315/87002-13; 316/87002-13)
The above violation is the third recent transportation violation (see Inspection Reports No. 50-315/86001; 50-316/86001)
which appears to support the concerns raised by some of the internal licensee and consultant reports (see Sections 4 and 13 above) that a significant potential exists for further transportation violations.
This matter was discussed with the QA auditors, the QA Supervisor, members of the RP and Radioactive Material Control (Radwaste) Sections'taffs, and several members of the licensee's supervisory and managerial staff.
One violation was identified.
Audits and A
raisals During a previous inspection (Inspection Reports No. 50-315/86013; 50-316/86013)
an inspector questioned whether the scope of the annual radiation protection QA audit was broad enough to comprehensively assess overall program adequacy.
The AEPSC Site QA Section had divided the audit of the radiation protection program into five segments; one audit segment was conducted each year.
The inspector questioned whether the past performance of the radiation protection section warranted an audit schedule that takes five years to complete.
The inspector also discussed with the AEPSC Site QA Supervisor the apparent desirability of maintaining a
QA surveillance program which could, in a timely manner, accommodate special QA surveillances of the radiation protection program in problem areas identified by organizations other than QA, including those identified in condition reports, radiological deviation reports, personnel contamination incident reports, and Radiation Protection Section monthly reports or by the NRC and INPO.
The licensee's QA surveillance program did not appear to have this degree of flexibility.
In response to the inspector's concerns, the licensee added a gA auditor position to the AEPSC Site gA Section staff, increased the number of annual radiation protection (RP) audits, and expanded the RP surveillance program.
The inspectors reviewed the resumes of the three gA auditors who presently specialize in RP audits/surveillances and interviewed the auditors; the technical background of the auditors indicates that they are well qualified to assess technical performance, compliance, and personnel qualification and training in the areas of radiation protection/
radwaste/radioactive shipments.
The AEPSC Site gA Section is scheduled to conduct two RP audits in 1987 and five in 1988.
The number of planned RP non-Technical Specification (T/S) required surveillances for 1987 has increased significantly over the number for 1986; unscheduled RP surveillances have also increased considerably in 1987 compared to a similar period in 1986.
The inspectors reviewed the 1987 planned surveillance and the 1987 and 1988 planned audit schedules in the areas of radiation protection/radwaste/radioactive shipments; no problems were noted.
I In addition to the required T/S surveillances, the licensee conducts a formal, scheduled gA surveillance program involving an additional 104 surveillances per year (approximately a dozen are related to RP/radwaste/
radioactive shipments).
Also, two surveillances covering work-in-progress are to be conducted during the period between audit cycles.
On April 24, 1987, the gA auditors began conducting weekly backshift surveillance (plant tours) which include procedural compliance for work-in-progress, compliance to RP requirements, and housekeeping.
For the current outage, three contractor gA auditors were hired to increase the number and frequency of backshift tours.
During numerous and frequent plant tours, the inspectors noted isolated incidents of poor housekeeping similar to those found during gA backshift tours, including discarded protective clothing in general access areas, overfilled storage cabinets and bins, tools and carts left in general access areas, and clutter in the auxiliary building 609'econtamination/laydown area and the 633'ot tool crib area.
On August 4, 1987, the inspectors informed the AEPSC Site gA Supervisor that certain surveillance reports appear to lack sufficient detail to adequately quantify and qualify the findings; the Supervisor agreed with the inspectors and issued a memorandum of instruction to the gA auditors.
The inspectors also discussed the apparent desirability of requiring responses to certain gA audit/surveillance recommendations and that some "recommendations" appear to represent Technical Specification violations and should result in condition reports.
Generally, however, the inspectors found the majority of the surveillances reviewed both technical sound and well written.
The inspectors informed the appropriate licensee supervisory and managerial personnel that certain recent gA audits/survei llances represented significant programmatic weaknesses in the areas of RP/
radwaste/radioactive shipments (see Section ll of Inspection Reports No. 50-315/86013; 50-316/86013 and Sections 9, 11, and 13 of this report).
The significant findings discussed in the referenced Inspection Report sections indicate that the licensee was justified in increasing the gA audits/surveillances of RP/radwaste/radioactive shipments.
As noted in Sections 11 and 13, the gA auditors are generally unwilling to
accept inadequate or incomplete proposed corrective actions.
With the implementation of adequate corrective actions, the number and significanqe of the programmatic problems should eventually decrease significantly.
No violations or deviations were identified by the inspectors.
Facilities and E ui ment The inspectors toured radiation protection facilities, observed radiation protection equipment in use, and discussed plans for improving access control facilities and equipment with the health physics staff.
Newly procured or planned equipment and facilities which should enhance the radiation protection program include:
(1) five state-of-the-art portal monitors have replaced less sensitive portal monitors; (2) the compaction ratio of the licensee's contaminated trash compactors have been upgraded; (3) a Canberra Series-35 Multi-Channel Analyzer was placed in service in July 1987, thus giving the radiation protection section the ability to perform isotopic analysis; (4)
a Tennelec gas flow proportional counter is currently being placed in service pending procedure approval; (5) purchase orders have been requested for the procurement of laboratory cabinets and counter-tops for the instrument issue room, RP counting laboratory, and the calibration facility; this improvement will provide working surfaces supportive of contamination control; (6) the recent completion of a new-office building should provide a better working environment for RP/radwaste staff members; (7) the new training building is discussed in Section 8; (8) the new TLD program is discussed in Section 9; (9) the new whole body counter is discussed in Section 10; (10) the purposed hot tool crib modification is discussed in Section ll; (11) the proposed modification of the RCA access control facility is discussed in Section 17; (12) the licensee's consideration of using a
contract laundry facility is discussed in Section 17; and (13) the proposed new containment access and steam generator storage buildings are discussed in Section 22.
Surveillance - Plant Tours The inspectors conducted numerous and frequent plant tours in the auxiliary and turbine buildings and the Unit 1 containment for the purposes of examining the licensee's performance of radiation protection and contamination control practices, observed work activities performed under the requirements of more than a dozen RWPs, and interviewed workers who had performed tasks authorized by other RWPs.
The inspectors conducted radiation and contamination surveys of selected plant areas using NRC and licensee survey instruments; except as noted in Section ll, readings were in general agreement with posted licensee data.
Housekeeping generally appeared adequate; however, during plant tours the inspectors noted isolated incidents of poor housekeeping similar to those found during gA backshift tour surveillances (see Section 15).
Other relevant observations are discussed below.
Laundr Sort Area The inspectors observed work at the protective clothing (PC) sorting and wet-laundry facility.
Three technicians manned the apparently very busy sorting/laundry operation.
Several questionable practices were observed by the inspectors; The sorting hood was piled high with PCs and the sorting technician's face was near the unlaundered clothing items; he was not wearing a respirator.
A technician at the table adjacent to the hood was handling laundered clothing although there was no clear line of demarcation between the laundered and unlaundered clothing areas.
Another technician was using air under pressure to expand and test laundered household rubber gloves, the inspectors expressed concern that no air sample was being run (contamination of a glove turned wrong-side-out (hot-side-in) at the step-off pad can remain inside the glove throughout the laundry process).
Air sample records for May and June 1987 indicated only two air samples per month (one minute grab samples)
were taken in this area.
The possible need for more frequent air sampling was discussed with RP supervisors who stated that the inspectors'oncerns about the present laundry sort facility and air sampling would be reviewed.
Before the end of the inspection, a continuous air monitor was installed at the laundry sort facility.
An inspector reviewed a licensee audit which had recommended improved PC frisking and searches for hot particles; these recommendations have not been implemented to date.
An inspector reviewed laundry workers'hole body counts (WBC) for the past one and one-half years; there were no intakes evident.
During the exit meeting, the licensee stated that a laundry contract has been let for offsite laundering.
The transition to offsite laundering is expected in about 90 days.
The need to improve the present laundry facility during the interim period was discussed at the exit meeting and wi 11 be reviewed further during a future inspection.
(315/87002-14; 316/87002-14)
On July 20, 1987, the inspectors observed two workers at the laundry sort area performing activities governed by the restrictions of Radiation Work Permit No.
0030, wet laundry facility, not wearing taped hoods as required by the RWP.
This is a violation of Technical Specification 6.8. l.a which requires adherence to radiation work permit procedures, and Procedure No.
THP 6010.RAD.406, Radiation Work Permit, which requires individual workers to properly wear anti-contamination clothing as specified by radiation work permits.
(Violation:
315/87002-16; 316/87002-16)
The 633'-Level Freon Tool Decontamination Station In this area on July 20, 1987, the inspectors observed several unlabeled bags of tools and bags with labels containing neither dose rate nor contamination information.
While lack of labeling of bags containing low levels of radioactive material is allowed by 10 CFR 20.203, it is not a good practice because it requires measurements or evaluations to ensure acceptably low levels of
radioactivity.
While radiation measurements made by the inspectors did not determine the presence of excessive quantities of radioactive material, the licensee does not have written procedures governing this area.
For other references to the plant's apparent lack of sufficient written procedures, see the discussions of internal studies in Section 4 of this report.
The labeling weakness noted in this paragraph is related to Open Item 315/86001-03;.
316/86001-03 (see Section 3).
A Problem at the 609'-Level Decontamination Station On July 20, 1987, the inspectors smear-surveyed a sampling of tools on a cart which apparently had been cleaned and released.
One tool smeared 425 dpm per 100 cm~ and other items on the carts gave an even higher reading on a portable survey instrument.
A licensee representative wrote a Radiological Deficiency Report for the cart and smeared all the items on it, including the cart.
He found another tool, a level indicator, with 1000 dpm per 100 cm~ smearable contamination.
This is contrary to Procedure No.
PMP 6010.RAD.001,Section VIII which requires contamination on release items to be less than 500 dpm per 100 cm~.
For additional information refer to Section 11.
RWP E ui ment Re uirements Deficient at U
er Reactor Cavit An inspection for conformance to RMP No.
0493, Reactor Head Stud Tension Tasks, dress/protective equipment requirements was made on July 21, 1987, by an inspector at the upper reactor cavity where the work was being done by four contract machinists.
When the workers exited the cavity at the end of the shift, the inspector noted that three of them were not wearing beta eye protection required by the RMP.
Two of them stated to the inspector that they did not know the beta eye protection was required by the RMP.
For that task, it was also noted that three RP technicians (RPTs)
had been detailed for 100K job coverage, including dress/undress in plastics assistance.
However, apparently because of misunderstanding that the bubble hood was adequate beta protection, the RPTs did not enforce the RMP requirement by delaying the plastic suit dress-out until beta eye protection could be procured.
Failure to follow Radiation Protection Procedure Nos.
THP 6010.001,Section XIII, and
THP 6010.RAD.406, Radiation Mork Permit, which require that workers know, understand and follow the requirements of radiation work permits is a violation of Technical Specification 6.8. 1.a which requires adherence to radiation work permit procedures.
(Violation:
315/87002-16; 316/87002-16)
Access Control Stations The inspectors noted that there is often congestion and poor traffic flow at the access control stations; the physical layout appears to cause confusion and bottlenecks.
A licensee consultant had a similar finding in their Radiation Protection Program Assessment (see Section 4).
The licensee has developed.plans to upgrade the physical layout of the access control area.
The inspectors reviewed the
proposed plans for the auxiliary building access control modification and found they did not appear to adequately address the major access control weakness.
The licensee's consultant also stated in his
'report (see Section 4) that the proposed modification would provide only marginal improvement.
At both access control stations, radiation work permits are posted on the walls and are easily seen by workers as required by Procedure 12 THP 6010.RA0.406.
However, workers do not sign-in on an RWP.
Instead, according to licensee personnel, radiation workers are informed in NGET training that before inserting their computer card and punching in their self-reading dosimeter reading, they are to have read and understood the RWP.
A significant percentage of the PCR's (e.g.,
25K of a sampling of PCR's during February and March 1987)
and of RDR's, as well as the two RWP violations identified by the inspectors during this inspection indicate that licensee workers often apparently do not know, understand, and follow the requirements of the RWP's.
Radiation workers'ames are entered into the RWP computer program to indicate that they are qualified by training, respirator fit and test, by health examination, and by craft to enter a controlled area, as appropriate.
It appears beneficial for the licensee to establish a positive control mechanism by which it can be assured that workers read and understand their RWP requirements.
Also, a worker should be confronted by the job-coverage RP technicians if the worker shows up at the job site without RWP required protective equipment, which was not done in one of the cases discussed above.
In the exit interview, the inspectors discussed access control and RWP compliance and control concerns.
These matters will be reviewed further during future inspections.
(315/87002"15; 316/87002"15)
Contaminated E ui ment Stora e Area CESA The resident inspector performed a radiation/contamination survey of the CESA during June 1987 and reported low dose rates and no
" transferable contamination.
The CESA was inspected by a radiation specialist during this inspection.
The CESA building is maintained locked and the inspector noted that the requirement to check out the key was apparently done according to procedure by th'e accompanying technician.
The area was orderly, clean, and free of apparent occupational hazards.
Radiation and fixed contamination levels were low.
A concrete curb had been designed into the pad construction to prevent surface water ingress.
In the outer foyer, the necessary radiation detection instruments are kept ready, including an air sampler.
No problems were found with the CESA.
One violation with two examples was identified.
Radiation Ex osure Termination Re orts Procedure 12 THP 6010.RAD.741, Termination Exposure Reporting, requires that the Termination Letter Log be maintained to assure compliance with
CFR 20.408.
During an earlier inspection (Inspection Reports No. 50-315/86013; 50-316/86013),
the inspector reviewed the Termination Letter Log entries for the previous several months.
The log appeared to be poorly maintained with numerous errors and indications of apparent failures to follow Procedure
THP 6010.RAD.741.
Examples included the apparent failures to adhere to procedural requirements to properly maintain the Termination Letter Log, to promptly send TLDs for early readings upon employment termination, and to promptly process TLDs and assign exposures.
These errors and apparent procedural violations were discussed with the RPM and the appropriate radiation protection supervisor and performance engineer.
Based on log entries, the inspector identified several apparent violations of the radiation exposure termination reporting requirements of 10 CFR 20.408.
However, the licensee contended that erroneous log entries were responsible for at least some of the apparent violations.
The matter was further discussed at the exit meeting and was considered an Unresolved Item (Nos.
315/86013-01; 316/86013-01)
pending licensee verification/correction of the data contained in the Termination Letter Log.
On February 20, 1987, in response to the unresolved item, the licensee completed an internal assessment (Action Request
[AR] No.
1438) which concluded that four violations of 10 CFR 20.408 requirements had occurred.
The termination exposure reports on four individuals who terminated
.
employment on April 10 and 11, 1986, were furnished to the NRC 91 days after employment termination.
These represent a violation of
CFR 20.408(b) which requires a report of individuals'adiation exposures, incurred during the period of employment or work assignment in the licensee's facility, be furnished to the NRC no later than 90 days after the date of termination of employment or work assignment.
Due to the licensee's failure to adequately address Unresolved Items No. 315/86013-01; 316/86013-01, additional failures to meet the 90-day reporting requirement, although not identified, may exist.
This matter was discussed at the exit meeting.
(Violation:
315/87002-17; 316/87002-17)
Radiation Protection Procedure No.
THP 6010.RAD.741, Termination Exposure Reporting, requires that the termination letter log be properly maintained, and specifies that TLD badges be sent to the vendor for readout within one week from termination notification, that TLD badges be promptly processed, and that the results be promptly transmitted to the licensee.
Contrary to the above, a selective review of the termination letter log from March through September 1986 found the following procedural adherence failures:
The termination letter log was not properly maintained in that more than 100 incorrect log entries were found regarding the dates of:
termination, TLDs sent to the vendor for readout, TLD results received by the licensee, and the
CFR 20.408 termination exposure report required issuance.
I
'
~
More than 100 log entries showed that TLD badges were sent to the vendor for readout more than seven days after the termination date.
~
About 100 log entries showed that the TLO badges were not being processed and reported to the licensee promptly by the vendor in that the period of time between sending the TLOs to the vendor and the receipt of the TLD results by the licensee ranged from more than two weeks to about two months.
The above failures to adhere to the requirements of Procedure No.
THP 6010.RAD.741 are violations of Technical Specification 6. 11 which requires adherence to radiation protection procedures.
(Violation:
315/87002-18; 316/87002-18)
The selective review of the licensee's termination letter log for the March-September 1986 period also identified more than 600 log entries which showed that the required termination exposure reports were issued more than the 10 CFR 20.408 allowable 30 days after the TLD results were received by the licensee from the vendor.
CFR 20.408(b) requires a
report of individuals'adiation exposures incurred during the period of employment or work assignment in the licensee's facility to be furnished to the NRC within 30 days after the exposure of the individual has been determined by the licensee.
During an earlier inspection (Inspection Reports No. 50-315/86013; 50-316/86013),
among the failures to properly maintain the Termination Letter Log, the inspector noted that the licensee records the date of exposure determination as the date each individual's termination exposure record letter to the NRC is signed.
Although the inspector informed the licensee that the date of exposure determination should be considered to be the date the TLD results are received by the licensee from the TLD process vendor, assuming promptness criteria of Procedure No.
THP 6010.RAD.741 are properly followed regarding TLO processing, the licensee (AR No.
1438) failed to use'this information while verifying/correcting the Termination Letter Log.
Thus, the licensee failed to identify more than 600 log entries discussed above which indicate the
CFR 20.408 allowable 30-day requirement was not met.
This is a violation of 10 CFR 20.408(b).
(Violation:
315/87002-17; 316/87002-17)
Examples of the failures of AR No.
1438 to adequately address inspector concerns include:
(1) incorrect exposure determination dates; (2) inadequate administrative control over the Termination Letter Log; (3) no effective means of promptly establishing the termination date; (4) apparently the TLD process vendor was not adequately notified of the TLD process promptness criteria requirements of the licensee as incorporated into Procedure No.
THP 6010.RAD.741; (5) the licensee's review of the Termination Letter Log apparently only reviewed the entries for several months, the review should have included all log entries; (6) Procedure No.
THP 6010. RAD. 741 considers the 90-day
CFR 20. 208 requirement, but not the 30-day requirements; and (7) the "corrected" Termination Letter Log entries still'contain numerous apparent errors,
such as indicating that the termination exposure letter was sent to the NRC before the individual's TLD was processed by the vendor and the licensee notified. It appears necessary for the licensee to readdress the inspector concerns, the acceptability of Procedure No.
THP 6010.RAD.741, and the administrative control over adherence to the procedure.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(315/87002-19; 316/87002-19)
Procedure
THP 6010.RAD.741, Termination Exposure Reporting, containing Form 12 THP RAD.741-1, Termination Letter Log, was issued for use on January 9,
1985.
Plant Manager Instruction Procedure No.
PMI 2040, Information Management, states that Records Retention Schedules are the official documents which specify the established retention periods and should cite the regulatory requirement for records retention and also states that the Original guality Assurance records shall be retained in the Master Plant File.
The Radiation Protection Retention Schedule, dated October 7, 1985, did not include a requirement for retention of completed Form 12 THP RAD.741-1.
However, the next revision of the Radiation Protection Records Retention Schedule, dated June 18, 1987, states that the Termination Letter Log entries (Form THP RAD.741-1) are gA documents, must be retained for the life of the plant, are required to be retained by Technical Specification 6. 10.2, and are to be microfilmed annually with the original hardcopy records destroyed upon verification and acceptance of microfilm and associated index in the Master Plant File Vault.
During an earlier inspection (Inspection Reports No. 50-315/86013; 50-316/86013),
the inspector noted, as discussed above, that the Termination Letter Log (Form 12 THP RAD.741-1) entries from March through September 1986 appeared to contain erroneous information and indicated violations of 10 CFR 20.408.
During the current inspection, the inspectors selectively reviewed the "corrected" log entries in an attempt to verify the adequacy of the corrective action; however, the licensee initially stated that the original log entries could not be located so that the inspectors could compare the two sets of log entries.
On August 7, 1987, the licensee concluded that the original documents had been destroyed sometime after the original documents were reviewed by the inspector on September 15, 1986.
Only because the inspector had maintained photocopies of some of the original Termination Letter Log entries could a partial followup of Unresolved Item Nos.
315/86013-01; 316/86013-01 be conducted.
Since the licensee deemed it appropriate on June 18, 1987, for the Radiation Protection Records Retention Schedule to state that the Termination Letter Log entries (Form THP RAD.741-1) are gA documents, must be retained for the life of the plant, are required to be retained by Technical Specification 6. 10.2, and are to be microfilmed annually with the original hardcopy records destroyed upon verification and acceptance of microfilm and associated index in the Master Plant File Vault, it seems appropriate that the October 17, 1985, Radiation Protection Records Retention Schedule should have also identified the gA nature of the documents.
The licensee was informed by the inspectors that time period between revisions of the RP Retention Schedule seemed excessive and that it appears appropriate to
update the schedule as each new gA document type is established.
Other problems associated with the RP Retention Schedule are discussed in Section 4 (source receipt documents destroyed),
Section 11 (calibration records not listed on RP Retention Schedule),
and Section 13 (records of radioactive materia)
received and radioactive material shipments not sent to the Plant Master File Vault in the required time).
Pending further review the adequacy of and adherence to record retention procedures, this matter is considered an Unresolved Item.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(315/87002-20; 316/87002-20)
Two violations were identified.
Radiolo ical Deficienc Re ortin S stem The licensee established their Radiological Deficiency Reporting (RDR)
system by a policy memorandum, dated November 4, 1985, from the Plant Radiation Protection Supervisor (RPRS) to the Radiation Protection Supervisors (RPS).
The memorandum states that the RDR system is to track and trend violations of radiological practices and p'rocedures in order to correct programmatic problems and prevent recurrences.
The RDR forms list 23 sub-categories of radiological deficiency root causes divided into the following six general categories:
written job order/radiation work permit, communication, planning, equipment, training, and personnel.
In this format, 518 RDRs were issued in 1986; most were attributed to personnel errors.
On May ll, 1987, the new PRPS issued a memorandum to RP personnel which modified the RDR policy; the new directive states that RDRs should only be written for events which pose a legitimate hazard to the health and safety of plant personnel, including RMP violations, improper control of radioactive material, violation of entry requirements for posted area, and personnel contaminations that result from a poor work practice or lack of contamination control.
The memorandum also instructs RP personnel that it is not necessary to issue an RDR if it involves an isolated occurrence with an individual, such as a person observed exercising poor Anti-C removal or frisking techniques.
This second memorandum appears to artificially reduce the number of RDRs, is contrary to initial RDR criteria and purpose, and reduces the ability to RDR system to identify and resolve programmatic problems.
Through the end of July, 122 RDRs had been identified in 1987; the reduced RDR generation rate appears to be partially due to the new policy memorandum.
This significant change in policy is apparently another example of the continued RP policy changes which have decreased staff morale (see Section 5).
The inspectors selectively reviewed the 1986 and 1987 Monthly Radiation Protection Reports sent to the Plant Manager by the PRPS regarding the RDR root cause tracking and trending system data.
This system appears to have been significantly degrading for some time.
Because of the uneven RDR policy and the poor RDR informational content of recent Monthly Radiation Protection Reports, it appears highly desirable to develop a formal RDR procedure and to significantly improve the system to track
\\
e
and trend root causes to correct programmatic problems and prevent recurrences.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(315/87002-21; 316/87002"21)
The following RDRs apparently represent examples of a significant lack of contamination control in the auxiliary building; Section 11 discusses further their relationship to the generally poor plant contamination control performance:
RDR No. 87-36:
On March 10, 1987, three chain falls were issued to two individuals from the hot tool crib on the 633-foot elevation; tools issued from the hot tool crib are to be free of removable contamination.
Upon exiting the work area, both individuals were determined to have hand contamination of 150 and 350 ccpm, respectively.
The chain falls were identified as being issued with removable contamination of about 6,000, 3,000, and 1,400 dpm/100 cm~
beta-gamma, respectively.
The root cause of the incident was failure to adequately survey the chain falls.
RDR No. 87-43:
On March 18, 1987, a steam generator eddy current probe with removable contamination of about 350,000 dpm/100 cm~
beta-gamma was found on the clean side of the 609-foot elevation decontamination/laydown area.
The probe was bagged/labeled and decontaminated.
The probe left a removable contamination residue of 80,000 dpm/100 cm~ beta-gamma on the clean side of the decontamination/laydown area, and because the probe was not initially identified as contaminated, two contract deconners were whole body counted to assure that no internal personnel contamination occurred.
The root cause of the incident was failure to properly survey, bag, and label the probe before it left containment.
~
RDR No. 87-96:
On April 15, 1987, a steam generator marking tool with removable contamination of about 130,000 dpm/100 cm~ was found near the 609-foot elevation decontamination/laydown area.
The tool was doublebagged/labeled and disposed of as radioactive waste.
The licensee was unable to identify the person responsible or the reason that the contaminated tool was left outside a designated contaminated area.
20.
Hot Particulates Defective Fuel and Iodine S ikin An inspector discussed NRC Information Notice No. 87-39, "Control of Hot Particle Contamination at Nuclear Power Plants," with licensee personnel, pointing out the notice's correlation of dose from personnel contaminations to defective fuel, the need to train technicians to survey aggressively in order to distinguish discrete particle contamination from normal distributed contamination, and the need to use sensitive personal contamination monitors at supervised locations to prevent workers from carrying such contamination to their homes.
The licensee's Unit 1 reactor coolant Dose-equivalent Iodine-131 exceeded
le
a Technical Specification limit of one microcurie per gram (peaked at 1.72 microcuries per gram) during a controlled shutdown on April 8, 1987.
The licensee met the applicable Technical Specification LCO Action Statement during the event.
The plant has a history of similar spiking events which are recorded in Licensee Event Reports (LER 81-049,82-004, 13, 18, 75, 78, and 79).
Defective fuel is apparently indicated by these iodine spikes.
In the upcoming Unit 2 steam generator replacement, hot particle surveillance will be important to minimize the spread of the particles and resultant personnel doses.
A selective review of the licensee's personal contamination records showed that four out of 21 personnel contaminations for January and part of February 1987 were discrete particles.
This sampling'along with eight other personnel contamination incident reports for skin contamination showed that the licensee has both corrosion product particles and degraded fuel particles.
The licensee has a calculational procedure for skin dose from hot particles; the procedure appears adequate.
It is the licensee's practice to perform skin dose evaluations for skin contaminations which could exceed 10 mrem skin dose.
According to licensee personnel, a
procedure is currently being drafted addressing identification of discrete particle radioactivity.
The fact that the RP Section has received, installed, and calibrated a
new Canberra Series-35 GeLi spectrometer in July 1987 should enhance the early identification of radioactive discrete particles.
A recent radiation protection supervisory in-house audit recently recommended increased hot particle surveys of protective clothing (see Section 17).
No violations or deviations were identified.
Steam Generator Re air Pro ect Unit 2 steam generators have exhibited corrosion-related damage since 1983, apparently due to intergranular stress corrosion caused by a caustic environment.
The licensee has utilized all volatile secondary water chemistry throughout the lifetime of the Unit 2 steam generator, and began utilizing on-line boric acid addition to neutralize the alkaline environment in an attempt to slow the rate of tube corrosion.
Repair by the tube plugging has enabled effective operation, although the power is currently limited to 80K in or der to allow operation at lower operating temperature to retard the rate of tube degradation.
Because the need to plug additional tubes will apparently continue, and the Technical Specification plugging-limit may be reached, the utilitywill replace all Unit 2 steam generator lower assemblies and modify components in the upper assemblies in an approximately one-year outage beginning about April 1988.
The scope of the repair project includes:
removal of top portions of the concrete steam generator enclosure shields, cutting the upper assembly shell plate, lifting the upper assembly through the opened concrete enclosure, and transferring it to the railroad bay and/or to other storage/modification areas under consideration.
The lower assemblies, after being capped to reduce contamination spread, will be
similarly removed and transferred to a newly constructed onsite steam generator storage facility.
. Reinstallation includes placing the new lower assemblies in place, then mating them to the modified upper assemblies.
New buildings/facilities are nearing completion, including the containment access building, fabrication shop/warehouse, security access building, and steam generator storage facility.
The inspectors reviewed the radiation protection organization to be utilized for the SGR project.
The SGR project is managed by the licensee's corporate office through the SGR Project Manager (corporate office) and the SGR Site Manager.
The SGR Project Health Physicist has a dual reporting role:
to the SGR Site Manager for activities solely affecting the SGR program, and to the Plant Radiation Protection Supervisor for activities interfacing with other plant operations.
The SGR Radiation Protection Supervisor, one of five group-supervisors under the Project Health Physicist and a former group supervisor at the plant, indicated to the inspectors that joint corporate-plant work is being accomplished smoothly.
The inspectors reviewed the radiological control aspects of the SGR project as described in the licensee's Steam Generator Repair Report with special attention to:
(1) Section 2,
Replacement Component Design; (2) Section 3, Repair Program, including 3.8, Radiological Protection Program; and (3) Section 7, Environmental Evaluation.
The inspectors found no significant problems with the radiological monitoring program of Section 3.8 or the environmental release monitoring and control of Section 7.
The estimated collective dose for the SGR project is 1733 person-rem.
The inspectors questioned whether the licensee planned to electropolish the replacement steam generator primary sides to reduce plateout of activated corrosion products during plant life and therefore reduce future radiation levels and worker radiation doses during maintenance activities.
This matter will be reviewed further during a futur e inspection (315/87002-22; 316/87002-22).
22.
As noted in Section 9, the licensee has proposed buying an improved TLD badge/system which first will be used for the SGR project.
The SGR Radiation Protection Supervisor stated that the utility has consummated all contracts including contracts for assistance and training by TLD experts from the University of Michigan who will accelerate implementation of the new TLD program.
The supervisor stated that within a few months the TLD program should achieve the accreditation of the National Voluntary Laboratory Accreditation Program (NVLAP) of the National Bureau (NBS).
The SGR Radiation Protection Supervisor has a difficult task ahead of him in attaining the correction factors for each TLD chip (Health Physics Vol. 49, No.
5 (November),
pp.
873-881, 1985).
The inspectors also discussed SGR RP technician training.
The licensee's representative described the training, which is as reported in Section 8.
Contaminated In ur Incident On July 23, 1987, a contractor employee fell and apparently suffered a
back injury while working in Unit 1 lower containment, a contaminated
S
'
'
C area with smearable contamination generally in the range of 10,000 to 15,000 dpm/100 cm~.
A licensee senior radiation protection technician, trained as an emergency medical technician (EMT), assumed the leadership of extricating the injury man.
Using apparently sufficient care, he removed most of the injured employee's contaminated protective clothing and wrapped him in clean herculite.
The EMT detailed two RP technicians (RPTs) to expediently drive ahead to the Mercy-Memorial Medical Center to assure that all was set up for the arrival of the injured man.
The EMT assisted the paramedics in donning protective clothing and traveled with the paramedics in the ambulance instructing them en route concerning personal contamination care.
At the hospital, all was in readiness including the medical staff properly dressed out.
The EMT removed the herculite from the injured employee, and a
RPT smear-surveyed
. the entrance hallway.
After the doctor examined the patient and had the extrication devices removed, he gave permission for an RPT to perform a complete whole body survey and to decontaminate if necessary.
All readings were less than the 100 ccpm detectability limit of the survey instrument used.
The EMT then directed the removal of the hospital staff's P.C.'s and completed a whole body survey on all the participating hospital staff; whole body frisks indicated no contamination.
23.
A RPT bagged all items used to be returned to D.C.
Cook.
Then a detailed survey was performed of the hospital entrance hallway and examination room; no contamination was detected.
The smears were taken back to the plant for a second low-level counting which also showed no detectable contamination.
At the plant, the ambulance was surveyed, found clean and was released to clean area.
The inspectors noted that all documentation including offsite notifications required for this accident, classed as an Unusual Event, was apparently properly done.
The inspectors also interviewed the EMT and reviewed the written narratives prepared by the EMT and the two RPTs who responded to the incident; no problems were found.
Control Room Emer enc Ventilation S stem CREVS)
The inspectors reviewed the status of the licensee's response to a survey conducted by NRR and NRC consultants on September 15-18, 1986 which, in part, was to access the ability of the Units 1 and
CREVS to maintain their respective control rooms habitable under accident conditions.
The survey findings were transmitted to the licensee by a letter dated February 2, 1987.
The survey team concluded, in part, that:
b.
The present system appears subject to signal failure,, e.g.,
single normal intake, emergency recirculation, and toilet exhaust dampers and a single Clz detector for each unit.
Interconnection of drains between each air handling unit and between each reactor's air handling units may present a
common mode failure.
C.
Technical Specifications prepared for the control room may require some changes to be consistent with the D.C.
Cook TMI Action Item III. D. 3. 4 anal ys i s.
d.
Present operation of the control ventilation system is such that it appears imperative that the mechanical equipment room be maintained.
positive to a degree that infiltration into the room is not a problem.
Merely maintaining it slightly positive does not appear to be enough.
If this room is negative, sources of unfiltered air in this room would include 2000 cfm of normal makeup and inleakage through the drain in the idle air handling unit.
A definitive pressure should be established for the equipment room.
An appropriate value might be 1/8 inch water gauge.
e.
It does not appear that the toxic gas analysis presented as part of the III.D.3.4 analysis reflects actual system operation.
Since the SER was issued on NUREG-0737, TMI Action Item II.0.3.4 in 1982, the licensee has altered in at least two instances the amount of filtered makeup flow, the amount of filtered recirculation flow and the amount of assumed unfiltered inleakage into the control room envelope.
The licensee's 50.59 evaluations should be reviewed to ensure the 50.59 discussions demonstrated that:
(1)
The consequences of accidents previously evaluated in the safety analysis report were not increased by the changes made in makeup flow; and (2)
the margin of safety as defined in the basis of Technical Specifications -3/4.7.5. 1 was not reduced.
g.
The training manuals need to be updated to describe the present operating system.
Some of the information contained in them is very out-of-date.
h.
The analysis of the flow data from the two units indicate there appears to be an interaction between the Unit 1 and Unit 2 control rooms.
Flow appears to go from Unit 2 to Unit l.
Survey Items No. a, b, c, d, e, and h are the subject of ongoing discussions between the licensee and NRR, although the licensee is not in complete agreement with the details of some of the survey findings.
The inspectors discussed the status of these items with the licensee and NRR; the resolutions of these items seems to be progressing satisfactorily.
Survey Items No. f and g are discussed in Inspection Reports No. 50-315/87004(DRP);
50-316/87004(ORP).
The resident inspectors concluded that Lesson Plan RO-C-A59, Auxiliary Building and Control Room Ventilation, had been adequately updated in October 1986 to correct Survey Item No.
g (Open Item Nos.
315/87004-04; 316/87004-04).
The resident inspectors also noted, with regard to Survey Item No. f that the licensee performed analyses of the effects of specific adjustments in that the two specific cases questioned by the NRC survey team are documented in the licensee's Licensee Event Report (LER) 315/85007, which discusses system adjustments in response to adverse test findings on February 22 and again on March 10, 1985.
Subsequently, also as documented in LER 315/85007, the licensee developed a matrix which can be used (each time control room
envelope filtered and unfiltered inleakage are determined by periodic testing) to establish whether this combination of measured values remains in compliance with. regulatory limits (Open Item Nos.
315/87004-03; 316/87004-03).
However, the resident inspectors apparently did not review licensee records to confirm that the licensee had not altered the CREVS before the events described in LER 315/85007, without an adequate
CFR 50.59 evaluation being performed nor was the validity of the compliance claims made by the licensee in response to TMI Action Item III.D.3.4, Control Room Habitability, independently verified; these matters were beyond the scope of the open item.
The Control Room Emergency Ventilation System (CREVS)'onsists of a nominal 6000 cfm pressurizer/cleanup filter unit which is designed to maintain the Technical Specification (T/S 4.7.5. l.e.3) positive
~ 0625 inch water gauge (wg) pressure in the control room (CR) with minimum outside makeup air; the remaining capacity of the pressurizer/
cleanup filter unit is used in the recirculation mode.
The filter unit is located in an equipment room which is outside the CR pressure boundary; however, balancing dampers have been installed to maintain the equipment room and the adjacent computer room at a,slight negative pressure to minimize unfiltered inleakage'.
The inspectors inspected the CREVS; reviewed associated design drawings and procedures; and discussed with the licensee the NRR survey findings, the circumstances surrounding the events described in LER 315/85007, and the licensee's analysis regarding the response to TMI Action Item III.D.3.4 and LER 315/85007.
It appears that although the licensee's response to III.D.3.4 (letter AEP:NRC:00398C dated February 9, 1981) claims to use the atmospheric dispersion model specified by the Section 6.4 of the Standard Review Plan (NUREG-0800), the licensee actually used a much less conservative model.
Because of the use of the NUREG specified methodology would apparently yield postulated DBA-LOCA doses in excess of regulatory limits (10 CFR 50, Appendix A, GDC-19), the inspectors notified the licensee and NRR of the apparently erroneous licensee claims.
It was also discovered by the inspectors that until 1985, the surveillance test (T/S 4.7.5. l.e.3) to demonstrate the CREVS can maintain a
CR positive pressure of.0625 inch wg was apparently conducted with a makeup flow of approximately 6000 cfm rather the DBA makeup flow rate of less.than 1000 cfm; this apparent error was found by the licensee during the review of corrective actions associated with LER 315/87005, thus the licensee is unsure that the CREVS could have maintained the required CR positive pressure before the 1985 CREVS readjustments and CR boundary sealing enhancements.
This matter is considered an Unresolved Item, pending further review to verify that all survey findings are adequately resolved, all necessary
CFR 50.59 evaluations have been adequately completed, the licensee has complied with all commitments made in response to NUREG-0737, TMI Action Item III.D.3.4, the CREVS could have maintained the T/S required CR positive pressure before the corrective actions were taken in response to LER 315/87005, and the current CREVS will meet the system design
V
requirements (10 CFR 50, Appendix A, GDC-19) considering the apparently inappropriate atmospheric dispersion calculational methodology used by the licensee.
The regulatory significance of the licensee apparently testing (T/S 4.7.5.l.e.3)
the CREVS in the wrong mode of operation between startup and 1985 must also be assessed (315/87002-23; 316/87002-23).
24.
Alle ation Followu Discussed below is an allegation concerning whole body counting at D.C.
Cook and Palisades which was evaluated during this inspection.
The onsite evaluation consisted of record reviews and interviews with licensee personnel.
(AMS No. RIII-87-A-0040 (Closed))
("
)
"""'he Palisades and D.C.
Cook plants are indicative of whole body counting errors at one or both plants.
As evidence of his anomalous WBC results, the alleger stated that there were five instances where his whole body count results increased between his termination WBC at one of the two plants and his incoming WBC at the other plant; and further that over a four-week period repeated whole body counts at D.C.
Cook plant showed his Cs-137 internal disposition to remain constant at 26 nCi, then to decrease to zero four months later upon termination, only to increase to 14 nCi three months later on an incoming WBC at the Palisades Plant.
Discussion:
It was determined that the individual has worked as a contract laborer at both the D.C.
Cook and Palisades plants on a temporary bases for several years.
The licensees'rocedures are to whole body count both permanent and temporary radiation workers at the beginning and termination of employment, at routine intervals and as necessary because of incidents.
At his first recorded entrance count (at D.C.
Cook), the alleger showed trace levels of Cs-137.
Over the next four years the D.C.
Cook records show occasional low Cs-137 levels, less than 5 nCi.
He was away from the plant for approximately nine months',
and then in the two years following, his counts at both D.C.
Cook and Palisades showed levels near 20 nCi.
The only radionuclide seen was Cs-137 throughout the individual's periods of employment, and it was seen at very low levels.
At these low count rates relatively large statistical uncertainties exist (two sigma uncertainties typically range from 10K to 100K).
When the uncertainties are considered, all but two of the allegers whole body counts are consistent with expected biological decay (and therefore are not indicative of WBC errors).
One of the two remaining inconsistent results, although recorded as zero nanocuries on June 25, 1986, was actually 18 a 5 nanocuries.
Due to a temporary change in licensee policy, all whole body count results less than the equivalent of one MPC-hour were recorded as zero for a short time period including June 25, 1986.
This licensee policy, since discontinued, was not inconsistent with NRC regulations (10 CFR 20.103).
The 18 nanocuries whole body count result for June 25, 1986 is consistent with the preceding (January 30, 1986)
and following (November 11, 1986)
whole body count results.
That leaves one remaining inconsistent whole body count result, 17 + 3 nanocuries on March 25, 1985 at the Palisades plant.
The alleger.
had previously been whole body counted upon termination at the D.C.
Cook plant on July 9, 1984 and showed 8 t 2 nanocuries at that time; he reportedly did not work at any nuclear facility during the intervening time period.
While this single whole body count result appears inconsistent with the previous D.C.
Cook whole body count result, it is not sufficient evidence on its own to indicate whole body counting equipment problems, in particular since routine NRC inspections review the whole body counting programs at both the Palisades and D.C.
Cook plants and these inspections have not identified problems.
The inspectors discussed with the alleger the possibility that his Cs-137 intake could have been due to exposure to licensed material including medical sources, industrial sources, or known accident environmental releases; the inspectors concluded, based on the alleger's statements, that he had not been exposed to licensed material during this period.
There is further reason to believe that the June 25, 1986 whole body count result at Palisades is a valid measurement.
Internal radioactivity, except for natural K-40, is seen very infrequently in nuclear power plant workers.
The frequency (essentially all his whole body counts) in which Cs-137 has been seen in the alleger is anomalous for nuclear power plant workers in general, as well as for workers at the D.C.
Cook and Palisades plants.
It appears likely that the alleger is taking Cs-137 into his body in some manner unrelated to his work activities at the Palisades or D.C.
Cook plants.
One such possibility may be from ingestion of significant quantities of wild game, which typically feed in uncultivated areas; Cs-137 levels from atmospheric fallout are higher than in cultivated areas.
Articles (Vol. 44, No.
3 (March), pp. 272-274,. 1983; Vol. 25, No.
(November),
pp 515-526, 1973) in the Health Physics Journal have reported Cs-137 levels in deer ranging from 5 pCi/gm to 45 pCi/gm.
The inspectors determined by calculational method that the range of contamination reported in the deer by the Health Physics Journal can produce a whole body burden of the same order of magnitude as that found in the alleger's body.
Since there appears to be no other credible explanation of the alleger's whole body burden and since the alleger stated that he hunts and eats deer meat, it appears reasonable to assume that the source of the alleger's intake of Cs-137 was deer meat.
25.
Exit Meetin The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the onsite inspection on August 7, 1987, and by telephone on August 31, 1987.
Further discussions were conducted with the Plant Manager, and others, by telephone through October 5, 1987.
The inspectors summarized the scope and findings of the inspection.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents or processes as proprietary.
In response to certain matters discussed by the inspectors, the licensee:
e
Acknowledged the, inspectors'oncern regarding the qualifications and multiple responsibilities of the interim Radiation Protection Manager.
(Section 4)
Acknowledged the inspectors'oncerns over the licensee's failure to formulate and effectively implement a comprehensive radiation protection enhancement plan.
(Section 4)
Acknowledged the inspectors'ontinuing concern regarding radiation protection staff stability, effective experience, and morale, (Section 5)
Stated that the desirability of establishing a formalized on-duty/on-call health physicist duty schedule will be reviewed.
(Section 6)
Stated that a contract maintenance crew would remain onsite after the current outage, in part, to reduce the backlog of contaminated liquid process system leakage work requests.
(Section ll)
Acknowledged the inspectors'oncern regarding the ability of the current personnel contamination incident tracking and trending system to adequately identify root causes and prevent recurrences.
(Section ll)
Acknowledged the apparent violation regarding failures to adequately evaluate radiation hazards present.
(Section 11)
Acknowledged the inspectors'oncern regarding the adequacy of the ALARA pre-job worker briefings and the apparent need to incorporate recommended ALARA program improvements.
(Section 12)
Stated that all prominent radionuclides would be listed on future radwaste shipment prior notification forms.
(Section 14)
Acknowledged the apparent violation regarding failure to properly label a radioactive waste shipment.
(Section 14)
Acknowledged the inspectors'oncerns regarding the adequacy of the present, laundry facility and stated that a contractor laundry facility (offsite) to replace the onsite facility was under active consideration.
(Section 17)
Acknowledged the inspectors'oncerns regarding the positive controls over RMP compliance and the present RCA access control facility.
(Section 17)
Acknowledged the apparent violations regarding failures to comply with RMP requirements.
(Section 17)
Acknowledged the apparent violations of the termination exposure reporting procedure.
(Section 18)
Acknowledged the apparent violations of the
CFR 20.408 radiation exposure report submittal requirements.
(Section 18)
Acknowledged the inspectors'oncern regarding the adequacy of the initial licensee review of the radiation exposure Termination Letter Log and its associated administrative controls.
(Section 18)
Acknowledged the inspectors'oncern regarding the adequacy of and adherence to record retention procedures.
(Section 18)
Acknowledged the inspectors'oncern regarding the ability of the current radiological deficiency report (ROR) tracking system to provide an adequate basis for identification of programmatic radiation protection problems and the need to develop a formal RDR procedure.
(Section 19)
Acknowledged the inspectors'oncern regarding the adequacy of corrective actions taken in response to gA Audit/Surveillance findings.
(Sections 9, ll, 13, and 15)
Acknowledged the inspectors'egulatory concerns regarding the operability of the Control Room Emergency Ventilation System.
(Section 23)
i'ceK-~'o~
0