IR 05000315/1988011
| ML17326B392 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/15/1988 |
| From: | Gill C, Grant W, Greger L, Michael Kunowski, Minns J, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17326B391 | List: |
| References | |
| 50-315-88-11, 50-316-88-13, NUDOCS 8807280212 | |
| Download: ML17326B392 (41) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/88011(DRSS);
50-316/88013(DRSS)
Docket Nos.
50-315; 50-316 Licensee:
Indiana Michigan Power 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:
May 9 through June 13, 1988 Inspectors:
C.
F. Gill, Team Leader R.
A.
ul, "Team Member
~.~ ((~<
M.
A. kunowski, Team Member Accompanying:
J.
L. Minns, Team Member Da e
Date Date 7(g /F Da e Approved By:
L.
R.
r ge, Chief Facilities Radiation Protection Section g-ra=8&'ate Ins ection Summar Ins ection'n Ma 9 throu h June
1988 Re orts No. 50-315/88011 DRSS
.
50-316/88013 (DRSS ) )
radiation protection and radwaste management programs including:
organization and management controls (IP 83522); training and qualifications (IP 83523);
external exposure controls (IP 83524); internal exposure controls (IP 83525);
control of radioactive materials and contamination (IP 83526); facilities and equipment (IP 83527);
outage exposure controls (IP 83729);
solid radioactive waste (IP 84522); liquid radioactive waste (IP 84523);
gaseous radioactive waste (IP 84524); transportation of radioactive materials (IP 86740);
licensee actions on previous inspection findings; and TMI/NUREG-0737 Items II.F.1, Attachments 1, 2, and 3, and II.B.3 (IP 25565).
SS072802i2 8807l5 PDR ADOCK 050008i5
Results:
'Extensive organizational, staffing, and procedural changes, due to the implementation of a radiation protection action plan developed to address certain programmatic weaknesses, are in various stages of completion.
The changes have the potential to improve long-term licensee performance in the radiological controls area.
No violations or deviations were identified.
However, programmatic weaknesses were identified in the respiratory protection/engineering controls program (Section 8) and regarding the circumstances surrounding an auxiliary building contamination event (Section 22).
DETAILS Persons Contacted
'. Allen, Radiation Protection Supervisor J. Fryer, Radiation Material Control Supervisor
"L. Gibson, Assistant Plant Manager, Technical Support
"M. Gumns, Administrative Compliance Coordinator P. Holland, Radiation Protection Supervisor M. Horvath, AEPSC Site gA Supervisor B. Jepkema, AEPSC Site QA Auditor J.
Kauffman, Construction Manager S.
Klementowicz, SGRP Project Health Physicist, AEPSC D. Krause, I8C Production Control Supervisor B.
Lauzau, Nuclear Safety and Licensing, AEPSC
- S. Lehrer, Radiation Protection Supervisor J.
Leichner, Radiological Support Nuclear Engineer, AEPSC J.
Long, Radiation Protection Training Specialist D.
Loope, Plant Radiation Protection Supervisor L. Matthias, Administrative Superintendent
~D. Noble, Health Physicist J. Paris, Administrative Compliance Coordinator J.
Rutkowski, Assistant Plant Manager F.
Rosser, Health Physicist D. Spencer, Senior Training Instructor/Supervisor H. Springer, ALARA Supervisor B. Svensson, Licensing Activity Coordinator D. Williams, Health Physicist
- J. Wojcik, Technical Superintendent, Physical Sciences J. Heller, NRC Resident Inspector L. Greger, NRC Region III, Chief, Facilities Radiation Protection Section W. Shafer, NRC Region III, Chief, Emergency Preparedness and Radiation Protection Branch The above individuals attended the exit meeting on May 27, 1988.
In addition to the above individuals, the inspectors contacted other licensee and contractor personnel during the team inspection.
- Denote those also attending a teleconference on June 13, 1988.
General This special team inspection was conducted to review the operational radiation protection and radwaste management programs.
Tours of licensee facilities were made to review posting, labeling, access and contamination controls, and to observe radiation protection aspects of work in progress.
Special attention was given to programmatic areas where weaknesses were previously identified by the NRC and others.
Some additional weaknesses were noted in the radiation'rotection program during this inspection with regard to the experience of the current Radiation Protection Manager (Section 4),
use of the condition reporting system (Section 4), radiation
worker training (Section 5), external exposure controls (Section 6),
internal exposure controls (Section 7), respiratory protection/
engineering controls (Section 8), contamination controls (Sections
and 11),
ALARA program (Section 13), circumstances surrounding an auxiliary building contamination event (Section 22),
and policies on containment outage surveying, posting, and radiation protection coverage (Section 23).
One purpose of the team inspection was to assess the impact on the radiation protection program of extensive organizational and programmatic changes which have taken place over the last year.
Further organizational, procedural, and facility changes are expected to be implemented within the next year.
Many of these completed/proposed changes are.due to the implementation of a radiation protection plan developed by the licensee partially in response to previous NRC concerns (Inspection Reports No. 50-315/87002; 50-316/87002 and Meeting Reports No. 50-315/87033; 50-316/87033)
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The organizational structure, management controls, proposed staffing levels, and upper management support appears adequate to establish and maintain quality radiation protection and radwaste programs.
However, during the transition period before new procedures are implemented and new personnel are fully integrated into the radiological controls operational program, the licensee may be more susceptible to pre-job planning deficiencies and RP job coverage errors than a well-established organization unit with well-understood implementing procedures.
One recent incident which may illustrate a possible example of deficient pre-job planning and RP job coverage is discussed in Section 22.
Minor problems were identified with the content of some specific procedures and interfaces between procedures; the licensee committed to correct the problems.
Corrective actions for previously identified concerns by the NRC and others appear to have been adequately implemented or are being addressed in a timely manner except for needed corrective actions relating to proceduralized survey criteria for release of items to uncontrolled areas, trai ning in the use of portable survey instruments, and possible release paths for contaminated material to uncontrolled areas.
These concerns were open items in Inspection Reports No. 50-315/86001; 50-316/86001 (Items No. 315/86001-05, 06, and 08; 316/86001-05, 06, and 08).
These items appear to be taking an inordinate amount of time to resolve.
The open items relating to an NRC Confirming Order and NUREG-0737 Items II.F. 1, Attachments 1, 2, and 3, and II.B.3 compliance have also remained unresolved for an extensive time (Inspection Reports No. 50-315/84017; 50-316/84019 and 50-315/85011; 50-316/85011);
however, licensee responsiveness to NRC initiatives regarding this matter appear adequate because failures to meet scheduled completion dates have in most instances been due to apparent unforeseeable circumstances.
Licensee Action on Previous Ins ection Findin s
(Closed 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 is being closed because these concerns have been incorporated into Open Item (315/85011-06; 316/85011-05).
(Closed)
0 en Item (315/84017-05.
316/84019-05):
Review SPING setpoints and calibrations.
This item is being closed because these concerns have been incorporated into Open Item (315/85011-06; 316/85011-05).
Closed Unresol ved Item (315/85011-05.
316/85011-04:
Obtain NRR concurrence on the locations of the steam relief/PORV monitors.
This item is being closed because this concern has been incorporated into Open Item (315/85011-06; 316/85011-05).
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.
During this inspection, the licensee stated that the compliance action items have been completed except for personnel training and NRR approval for variance requests.
The licensee expects to have all compliance action items completed by July 15, 1988 (with the possible exceptions of some items requiring NRR resolution).
This matter will be reviewed further during a future inspection.
Closed)
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.
The licensee has completed new hot tool crib and tool decontamination facilities.
In addition, procedural survey and hot tool handling requirements have been modified.
Radiation protection technicians survey all equipment and tools used on contaminated systems before the equipment and tools are returned to the tool crib.
This matter is considered closed.
Closed 0 en Item 315/86001-04.
316/86001-04:
Evaluate the apparent need to upgrade the ALARA program.
The licensee has evaluated the apparent need to upgrade the program and made some minor improvements.
The upgrade effort should be significantly enhanced by the acquisition of computer software, procedures, and equipment currently used by the Steam Generator Repair Project (SGRP).
The station's ALARA program is discussed further in Section 13.
This matter is considered closed.
0 en)
0 en Item 315/86001-06.
316/86001-06:
Evaluation of possible release path for contaminated material to uncontrolled areas.
Although an Action Request has been issued to resolve this matter, the response-due date has been changed twice; no significant action has been taken by the licensee since the item was opened about two years ago.
This matter was discussed at the exit meeting and will be reviewed further during a future inspectio (Closed)
Unresolved Item (315/87002-01 316/87002-01:
Resolve the acceptability of the qualifications of the Radiation Protection Manager (RPM).
The RPM has since been replaced; therefore, this matter is considered closed.
(Closed)
0 en Item (315/87002-02.
316/87002-02:
Develop a comprehensive radiation protection enhancement plan.
In February 1988, the Assistant Plant Manager - Technical Support submitted a Radiation Protection Action Plan to the Plant Manager.
This plan details activities for 1988 and 1989 for the improvement of the radiation protection program (see Section 4).
This matter is considered closed.
(Closed 0 en Item 315/87002-03.
316/87002-03:
Review licensee response to consultant staff-effectiveness recommendations.
The licensee's response to the consultant recommendations appears adequate; see Section 4.
This matter is considered closed.
(Closed)
0 en Item (315/87002-04 316/87002-04):
Develop a formal extended-duty schedule for health physicists during outages.
During the current Unit 2 SGRP outage, 24-hour radiation protection management and supervision is provided by the Plant Radiation Protection Supervisor and the health physicists.
This matter is considered closed.
(Cl osed)
Unr esp 1 ved Item 315/87002-05 316/87002-05):
Review adequacy of corrective actions to prevent further violations of dosimetry requirements.
It appears that the licensee's corrective action has been adequate.
See Section
~
(Closed)
0 en Item (315/87002-06 316/87002-06:
Reduce potential for respirator cross-contamination.
No effective action has been taken by the licensee since this matter was first discussed with NRC inspectors.
nearly one year ago.
Numerous other concerns were identified during the current inspection regarding the respiratory protection/engineering controls program; see Section 8.
Because potential respirator cross-contamination will be reviewed as part of the more general programmatic weakness, this item is closed.
(Closed 0 en Item 315/87002-07 316/87002-07:
Reduce the number of leakage-containment devices and the amount of contaminated floor area in the auxiliary building.
As of March 31, 1988, the licensee has reduced the number of containment devices by a factor of two since August 1987.
During this same period, the licensee has continued efforts to reduce contaminated floor area; see Section 9.
This matter is considered closed.
Closed 0 en Item 315/87002-08 316/87002-08:
Improve tracking and trending program to identify and correct deficiencies in the personnel contamination prevention program.
The licensee has revised the procedure on identifying and tracking the causes of personnel contamination incidents.
The data is distributed to upper management in monthly reports.
Increased worker awareness, new protective clothing, and increased oversight by the radiation protection staff of workers at job sites apparently have resulted in a recent reduction in personnel contaminat,ion events.
See Section 10 for further discussio (Closed) Violation (315/87002-09 316/87002-09):
Failure to per form adequate contamination surveys.
The corrective actions outlined in the licensee's response dated November 23, 1987, were reviewed; no problems were noted.
As stated above for the closure of Open Item (315/86001-03; 316/86001-03),
the licensee has modified procedures on surveys and handling of hot tools.
Closed Unresolved Item (315/87002-10 316/87002-10):
Revi ew 1 icensee'
corrective action for gA-identified violations regarding inadequate, or failure to follow, instrument calibration procedures.
A review of documentation and discussions with licensee representatives indicate that the corrective actions which have been, or are planned to be, implemented appear to be adequate to prevent recurrence and meet the criteria of
CFR 2, Appendix C for self-identification and correction of problems.
This matter is considered closed.
(Closed)
0 en Item (315/87002-11.
316/87002-11):
Review adequacy of pre-job ALARA briefings given by job supervisors.
The licensee has bolstered the effectiveness of the briefings given to workers by posting ALARA dose-saving instructions with the RWPs at access control.
In addition, radiation protection job-coverage staff members review the ALARA instructions with workers prior to high-dose jobs (See Section 13).
This matter is considered closed.
(Cl osed)
Unresolved Item (315/87002-12 316/87002-12):
Take adequate corrective actions to prevent recurrence of violations identified in gA Audit Report No.
gA 87-11, Radwaste and Byproduct Material.
A review of documentation and discussions with licensee representatives indicates that the corrective actions implemented appear to be adequate to prevent recurrence and meet the criteria of 10 CFR 2, Appendix C for self-identification and correction of problems (see Section 15).
This matter is considered closed.
(Cl osed Violation (315/87002-13 316/87002-13):
Fai lure to properly label a radioactive waste shipment.
The licensee's corrective actions appear adequate to prevent recurrence.
The procedural deficiency causing the problem has been corrected.
Independent verification is now required on all radioactive waste shipments.
This matter is considered closed.
(Closed)
0 en Item (315/87002-14.
316/87002-14):
Improve laundry facility.
The licensee has signed a three-year contract for offsite laundry services (see Section 10).
This matter is considered closed.
Closed)
0 en Item (315/87002-15 316/87002-15):
Improve access control and develop positive control over RWP compliance.
The licensee modified access control by separating ingress and egress points.
This separation apparently relieved some of the congestion that may have reduced the time spent by workers in reviewing RWPs.
In addition, many RWPs now require workers to check in each day with the radiation protection job-coverage coordinator at the access control desk prior to beginning work on the RWP.
Other aspects of RWP compliance are discussed in Sections 5 and 23.
This matter is considered close (Clos'ed) Violation (315/87002-16.
316/87002-16):
Failure to comply with RWP requirements.
The corrective actions outlined in the licensee's response dated November 23, 1987, were reviewed; no problems were noted.
The radiation protection staff is conducting more frequent spot checks of work in progress and the training department is using actual instances of RWP noncompliance at D.
C.
Cook as didactic examples during Nuclear General Employee Training (NGET).
Although the licensee's radiation protection staff continues to observe and correct instances of RWP noncompliance and the NRC inspectors have observed several failures to adhere to RWP requirements, these instances and observations appear to be less prevalent.
(Closed) Violation (315/87002-17 316/87002-17):
Failure to meet the 30-day and 90-day reporting requirements of 10 CFR 20.408.
The corrective actions outlined in the licensee's response dated November 23, 1987, were reviewed; no problems were noted.
Closed Violation (315/87002-18.
316/87002-18):
Failure to adhere to radiation protection procedures on maintaining the Termination Letter Log and processing TLD badges after employment termination.
The corrective actions outlined in the licensee's response dated November 23, 1987, were reviewed; no problems were noted.
Closed)
0 en Item (315/87002-19.
316/87002-19:
Readdress concerns on adherence to and oversight of the Termination Letter Log procedure.
Licensee actions on this item are generally adequate.
See Section 6.
Closed 0 en Item 315/87002-21.
316/87002-21:
Improve the RDR tracking system and develop an RDR procedure.
The licensee has discontinued the RDR system and endorsed the use of Plant Manager Instruction (PMI) 7030, Condition Reports and Plant Reporting, as the methodology to report, assess, resolve, and trend radiological deficiencies (see Section 4).
This matter is considered closed.
Closed)
0 en Item (315/87002-22 316/87002-22:
Evaluate the option to electropolish the replacement steam generators'rimary side to reduce activated corrosion product plateout.
The licensee has decided not to implement the electropolish option.
This matter is considered. closed.
0 en) Unresolved Item 315/87002-23 316/87002-23:
Resolve CREVS operability concerns.
In Letter AEP: NRC: 0398/,
dated June 17, 1988, the licensee changed the control room habitability reanalysis completion commitment date from June 30, 1988 to September 30, 1988.
This matter will be reviewed further during a future inspection.
Or anization and Mana ement Controls IP 83522 83729)
The inspectors reviewed the licensee's radiation protection organization and management controls for the radiation protection program, including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement the program, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of the progra Recent radiation protection/radwaste personnel changes include:
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The Plant Radiation Protection Supervisor has been designated as the Radiation Protection Manager (RPM) and no longer holds the position of Emergency Planning Coordinator.
The Acting ALARA Coordinator has been appointed to the new position of ALARA Supervisor and reports directed to the Plant Radiation Protection Supervisor.
The most senior health physicist resigned and was replaced by a new hiree; a fourth health physicist position was added and filled by a new hiree.
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The radiation protection Engineering Technologist has been appointed as an Associate Health Physicist.
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The Technical Superintendent, Physical Science resigned and was replaced on March 1, 1988, by the person who had previously been the Plant Chemical Supervisor.
With the exception of the RPM appointment, the persons newly appointed to the above positions appear well qualified in accordance with ANSI N18.1-1971 for the respective positions, although the major turnover of professional and supervisory staff during the last year has the potential for a short-term negative effect on licensee performance.
(A possible example of negative effect on licensee performance is discussed in Section 22.)
Although the licensee's gA department concluded that the newly appointed RPM meets the qualification criteria of Technical Specification 6.'3. 1, which specifies that the RPM meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, NRC evaluations of his education and experience indicate weaknesses due to his lack of a bachelor's degree in a science or engineering discipline and his limited commercial nuclear power radiation protection experience.
The RPM's limited experience is exacerbated because the four health physicists assigned to the RPM's support staff do not appear to possess sufficient expertise and experience to provide assurance that the radiation protection program will be effectively managed during the transition period represented by the two-year RP improvement action plan.
During this transition period, before the new procedures are fully implemented and new personnel integrated into the revised RP program (see Section 2),
it appears highly desirable to augment the radiation protection staff with a well qualified RPM, even if such augmentation is implemented on a part-time consulting, basis.
This matter was discussed at the exit meeting and during subsequent telephone meetings; licensee corrective actions will be reviewed further during a future inspection.
(Open Item:
315/88011-01; 316/88013-01)
Four radiation protection supervisors, the ALARA Supervisor, the Training Specialist, four health physicists, and an associate health physicist 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 technicians (RPTs) are each assigned to primarily work in one of these functional areas
~
RPT staff stability and morale have improved significantly in the past year.
Two RPTs transferred (promotions)
and one RPT has resigned in the last year; these positions and preexisting vacant positions were filled by a mixture of experienced RPTs and recent Terra-Tech graduates.
Based on interviews and documentation review, it appears that the licensee's selection criteria for replacement RPTs has improved and a higher level of performance is being expected of the RPTs.
The inspectors noted that it appears utility RPTs have assumed the lead role in implementing the plant radiation protection program, while the contracted RPTs now generally are under the direction of utility RP supervisors and lead technicians.
Technician staff morale improvements are apparently due, at least in part, to better understood policies, goals, responsibilities, and authority and to better support from the professional, supervisory, and managerial staff.
Previous inspector concerns regarding RPT staff-effectiveness (Open Items No. 315/87002-03; 316/87002-03)
have been adequately addressed by the licensee.
The plant's radiation protection staff is augmented during the outage by 54 contract RPTs, 12 nuclear support. technicians (rad/chem helpers),
and eight dosimetry clerks (the SGRP has its own independent radiation protection staff to provide coverage for that segment of the outage).
When the SGRP assumes the outage lead (scheduled for late June 1988),
the plant radiation protection staff expects to be augmented by only 35 contract RPTs, which has been the usual number for routine tasks during non-outage periods.
The plant radiation protection staff was augmented by 22 nuclear support technicians (NSTs) until recently; this number was reduced reportedly because the SGRP augmentation was expected to accomplish many of the routine NST tasks.
Licensee representatives indicated to the inspectors that the policy of separation of project and plant personnel and tasks has resulted in less NST support for the routine plant radiation protection tasks than desirable which resulted, in part, in a reduced plant decontamination effort.
In response to inspector concerns, the licensee indicated that the number of NSTs would return to the previous level by the first of next year.
The Radioactive Material Control (Radwaste)
Section consists of the section supervisor, two engineering technologists, one radwaste handling supervisor, and a recently added RPT.
The radwaste systems are run by the Operations Department; all other duties are assigned to contract workers.
The contract work force (radwaste)
during the outage consists of 12 radwaste workers, two Freon tool-cleaner operators, one DAW segregation worker, one radwaste shipping technician and two demineralizer operators.
During a previous inspection (Inspection Reports No. 50-315/87002; 50-316/87002),
the inspectors noted that the Radiological Deficiency Reporting (RDR) system appeared to have been degrading for some time.
It was also noted that it appeared highly desirable to develop a formal RDR procedure and to significantly improve the system to track and trend root causes to correct programmatic problems and prevent recurrences (Open Items No. 315/87002-21; 316/87002-21).
In response to this concern,
. the licensee discontinued the RDR system and endorsed the use of Plant Manager Instruction (PMI) 7030, Condition Reports and Plant Reporting, as the methodology to report, access, resolve, and trend radiological deficiencies.
Although,the condition reporting system receives a higher level of management attention than the RDR system, and the significant radiological deficiencies generally seem to be properly entered into the condition reporting system, PMI-7030 has not been adapted to deal with radiological concerns.
Specifically, the condition reporting system does not have cause and preventive action codes which are well suited for tracking and trending radiological concerns, the radiation protection staff is not always adequately involved with the investigation of incidents, and the radiation protection staff often is not required to concur on the adequacy of proposed corrective actions.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(Open Item:
315/88011-02; 316/88013-02)
As noted during a previous inspection (Inspection Reports No. 50-315/87002; 50-316/87002),
a radiation protection improvement program initiated by the licensee in 1985 was not effective in correcting some significant licensee weaknesses.
It was also noted that without a more coordinated, comprehensive approach than had been taken to date, the current corrective actions appeared likely to be similarly unsuccessful to correct programmatic problems recently identified by the NRC and others (Open Items No. 315/87002-02; 316/87002-02).
A licensee-NRC management meeting was held on December 10, 1987 (Meeting Reports No. 50-315/87033; 50-316/87033)
to discuss NRC concerns over continuing weaknesses in management control that affect the radiation protection program.
The licensee presented a program to resolve the weaknesses, including having the Assistant Plant Manager assume personal direction of the Technical-Physical Science Department for an interim period.
As a result of this tenure, the licensee implemented a comprehensive RP action plan to address several areas of weaknesses, including RPM selection, professional staff development, technical staffing levels, procedure revisions, control of radioactive, material, radiation worker training, radiation work permits, access control layout, and protective clothing handling.
Interviews, observations, and documentation reviews indicate that the licensee generally is making satisfactory implementation progress.
At the exit meeting for this inspection, the licensee stated that the action plan is intended to be a dynamic, rather than a static, management tool; thus, NRC concerns identified during this inspection and programmatic concerns identified by others will be used to modify the radiation protection action plan, as appropriate.
No violations or deviations were identified.
Trainin and ualifications (IP 83523 83729)
The inspectors reviewed the training and qualifications aspects of the licensee's radiation protection, radwaste, and transportation programs, including:
changes in responsibilities, policies, goals, programs, and methods; qualifications of newly hired or promoted radiation protection personnel; and provision for appropriate radiation protection, radwaste,
~ and transportation training of plant personnel.
Also reviewed were management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses.
I An inspector reviewed Plant Manager Procedure No.
PMP 2070.TRN. 111, Revision 1, Radiation Protection Technician (RPT) training Program.
The training program was also discussed with the radiation protection Training Specialist.
The procedure establishes training requirements, methods and responsibilities necessary to ensure that the RPT training program provides theoretical knowledge and practical skills necessary
.
for RPTs to perform their jobs in a safe and efficient manner.
A'll D.
C.
Cook employed RPTs are required to participate in the training program.
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.
The RPT training program also has a continuing (requalification)
training plan which is being implemented; it includes additional training necessary due to plant modifications, procedural changes, and NRC bulletin and information notice concerns.
The licensee's training program appears to adequately 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 or 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
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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, the licensee does not allow waivers for the contract technicians for field OJT, including accompanying qualification tests.
The training program for RPTs defines approximately 240 tasks or modules to be completed for qualification.
Of the 32 licensee RPTs, to date, five have completed all qualification tasks; the remainder have 'completed an average of 77K of the tasks, with eight of those needing less than ten sign-offs for full qualification.
Representative training records, exams, and lesson plans were reviewed and found adequate.
An inspector attended and reviewed the Nuclear General Employee Training (NGET) classes for both the relatively experienced and inexperienced radiation workers, including respiratory protection training.
The inspector found that the NGET program remains essentially as discussed
in Inspection Reports No. 50-315/87002; 50-316/87002.
Although topics required by 10 CFR 19. 12 were covered in adequate detai 1, it appears desirable for the licensee to consider enhancing the NGET radiological controls training in some areas, including instruction concerning risks from occupational radiation exposure (Regulatory Guide 8.29), instruction concerning prenatal radiation exposure (Regulatory Guide 8. 13),
and hands-on training such as working with simulated contaminated material and use of radiation survey meters.
The latter two areas are discussed in more detail below.
A course handout was the booklet entitled, Radiation Protection Handbook ALARA.
Although the booklet is well written and contains useful, practical ALARA information, some of that information is not well emphasized in the NGET course.
The respiratory protection training course seemed to cover the important subject matter in Regulatory Guide 8. 15 and NUREG-0041 with the exception of donning respirators (see Section 8).
During a previous inspection (Inspection Reports No. 50-315/86001; 50-316/86001),
the inspectors noted that the licensee requires personnel entering high radiation areas (HRAs) to use portable radiation survey meters; however, it appeared there was no specific qualifications required by the licensee for the employees who used those meters.
The only instruction given to personnel before the use of the meters was during NGET where the use of a meter was demonstrated and a meter was passed among the training class.
The inspectors informed the licensee that the program did not appear to support qualification of all meter users without additional training (Open Items No. 315/86001-08; 316/86001-08).
In response to this NRC concern, the licensee began to conduct one-hour classes on the proper use of radiation survey meters for those workers requiring unescorted access into HRAs.
The Job Coverage Office maintained a list of personnel who had successfully completed this"class and denied unescorted access into HRAs to all unlisted personnel.
Based on the licensee response to the NRC concern, the Open Item was closed (Inspection Reports No. 50-315/86013; 50-316/86013).
However, during the current inspection, the inspectors found that the special one-hour course is no longer taught, that survey meter training has reverted to the inadequate NGET presentation, and that anyone who has successfully completed NGET may obtain a meter and be granted unescorted access to HRAs.
This matter was discussed at the exit meeting and will be reviewed further during a
future inspecti on.
(Open Item:
315/88011-03; 316/88013-03)
The licensee's radiation protection action plan (see Section 4) states that one of the elements contributing to the overall poor level of performance in the radiological controls area was assessed to be the level of training of the plant workers.
In response to this assessment, a training module has been developed aimed at improving the radiation workers knowledge of health physics and practical knowledge of radiation protection practices.
Based on interviews, observed work in progress, and reviews of recent condition and problems reports, the inspectors concluded that the licensee still has a significant problem with regard to poor radiation worker practices.
It appears that the licensee should implement the proposed two-day radiation worker training course and train all appropriate personnel who have radiologically controlled area (RCA)
access.
Discussions with licensee representatives indicate that the training course is scheduled to be offered only to selected groups of
plant workers.
It would appear to be a significant programmatic weakness if the course is not scheduled to be taken by a,broader selection of plant and contract workers.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(Open Item:
315/88011-04; 316/88013-04)
The inspector reviewed the qualifications of the NGET/respiratory protection training instructors; they have significant radiation protection in-plant experience and appear well qualified.
The inspector also selectively reviewed examination results of the two courses; the failure rate for 1987 appears to be approximately five percent.
No problems were noted.
No violations or deviations were identified.
External Ex osure Control and Personal Dosimetr IP 83524 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 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.
Revision of current dosimetry procedures is scheduled to be completed in July 1988.
After completion of the SGRP around December 1988, the plant plans to revamp the entire external dosimetry program, changing from the currently used vendor-processed TLD system to a system which the station will process.
In addition, dose history records of individuals, regulatory dose-distribution reports, and termination letters will be generated with the PRISM computer system now used by the SGRP.
During tours of the plant and from discussions with individuals, it appears that the licensee's corrective action for previously identified, improper placement of personnel dosimetry (Unresolved Items No. 315/87002-05; 316/87002-05)
has been effective.
For corrective action, the radiation protection group issued a policy statement (dated November ll, 1987) that explained dosimetry placement requirements.
A subsequent gA surveillance of this action found it to be generally effective; however, the gA auditors recommended that the requirements be updated to account for placement of dosimetry on the new protective clothing coveralls which have chest pockets.
In addition, on several occasions, NRC resident inspectors have found TLDs attached to the
"modesty garments" now worn under the new protective clothing.
Presumably, these TLDs were inadvertently left on the garments by the previous wearers.
These instances of misplaced TLDs appear to be an undesirable consequence of the requirement in the policy letter that TLDs be worn inside protective clothing and self-reading dosimeters (SRDs)
be worn outside the clothing.
Licensee representatives stated that incipient revisions to radiation protection procedures would account for placement of SRDs and TLDs in pockets on the outside of protective clothing coveralls.
A recent review by the licensee of lost TLDs indicated that of approximately
.16,800 TLDs issued annually, 200-300 are lost.
Although the licensee considers the number of lost TLDs to be low, the station is considering requiring individuals who lose more than one TLD in a year to undergo NGET retraining.
A gA audit conducted in September-October 1987, found several problems with the dosimetry program, apparently indicative of a general lack of procedural compliance and supervisory oversight.
As corrective actions for these problems and for problems previously identified by NRC inspectors (Violation 315/87002-17; 316/87002-17, Violation 315/87002-18; 316/87002-18, and Open Item 315/87002-19; 315/87002-19),
the licensee has reassigned supervisory personnel in the dosimetry group and revised procedures.
Discussions with employees and a review of selected procedures and records indicated that the licensee's corrective actions were generally adequate; however, several procedures have not yet been approved by the station's review committee.
No violations or deviations were identified by the inspectors.
7.
Internal Ex osure Control and Assessment IP 83525 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; 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's whole-body count and calibration program is discussed in Inspection Reports No. 50-315/87002; 50-316/87002; no significant changes have occurred in the program.
Review of the licensee's records indicated that no exposures in excess of the 40 MPC-hour control measure occurred in 1987 or 1988 to date.
Procedures for operating the whole-body counter (WBC) were available at the counting facility and the WBC operators were aware of the procedural requirements for whole body counting and reporting criteria.
An inspector reviewed the licensee's whole body counting procedure (No.
12 THP 6010. RAD.409, Assessment of Whole Body Count Results)
and the method of relating an individual's whole body counting data to regulatory requirements (MPC-hours).
The inspector requested the radiation protection staff to use the procedure to convert WBC data to MPC-hours for an example given by the inspector; the results of the staff's conversion was incorrect in a conservative direction by a factor of three.
After discussion with the inspector, the licensee stated that the procedure would be revised to ensure correct MPC-hour computations are performed -.
This matter would be reviewed further during a future inspection.
(Open Item:
315/88011-05; 316/88013-05)
The inspector also reviewed the licensee's WBC Procedure No.
12 THP 6010. RAD.468, Calibration of the Fastscan Whole Body Counting System, and the most recent calibration of this system.. It appears the
.system was calibrated in accordance with the procedure.
During the review of the procedure, the inspector noted that there does not appear to be a
requirement for evaluating calibration results when differences are observed.
The procedure should define an acceptable error for calibration results and require an evaluation of the results when they fall outside the acceptable error.
This matter was discussed with the licensee who stated the procedure will be revised to include this information.
This matter will be reviewed further during a future inspection.
(Open Item:
315/88011-06; 316/88013-06)
Air sample data were selectively reviewed.
Air samples appear to be counted and evaluated in accordance with Procedure No.
12 THP 6010. RAD.203, Analysis of Airborne Radioactivity.
The procedure appeared adequate for use to determine air sample results, and the routine grab air sampling appears adequate.
Special air samples are collected to establish RWP requirements and job conditions.
With the exception of an identified
,
weakness discussed in Section 22, it appears the licensee adequately uses air sample results to establish RWP requirements for use of respirators and protective clothing.
The inspectors observed contract technicians counting, analyzing, and quantifying air sample results in the counting room.
The technicians were questioned about the use of the counting equipment and requested t'o explain the bases for the use of different parameters required to compute air sample data results.
The technicians demonstrated sufficient knowledge to adequately perform their functions.
The discussion of the respiratory protection/engineering controls program is in Section 8.
No violations or deviations were identified.
8.
Res irator Protection/En ineerin Controls IP 83525 The inspectors reviewed selected aspects of the licensee's respiratory protection/engineering controls program, including respirator accountability, cleaning and maintenance, fit-testing, and training; results of that review are discussed below.
Also, workers with respirators were observed to be following proper procedures on the use of the respirators.
Several workers were questioned on aspects of the respiratory protection program; answers were appropriate.
Accountabi lit During a previous inspection (Inspection Reports No. 315/87002; 316/87002), it was noted that workers are required to place used respirators in specially designated drums located throughout the auxiliary building. It was also noted, however, that this method for return of'espirators allowed for cross-contamination (Open Items No. 315/87002-06; 316/87002-06).
Dur ing the current inspection, it was determined that the licensee has not taken adequate corrective action to resolve this matter.
Additional observations on the licensee's accountability method were also mad By procedure, workers are to bag respirators after use for eventual return to the radiation protection group who clean, repair, and rebag each respirator before reissuance.
By policy, the workers are to place the bagged respirator into any of the designated 55-gallon drums.
The drums are lined with a plastic bag and instructions are stenciled on the drums stating that only bagged respirators are to be placed within the drums.
In addition, signs affixed to the top of these drums state that the drums are not for trash.
Once a day, reportedly, contractor workers remove the drum liners containing the respirators and take them to the respirator washing facility.
After washing, the respirators are placed in one large bag and taken to the repair facility, where they are examined, repaired if necessary, and individually rebagged.
Discussions with several employees who were emptying drums containing used respirators indicated that unbagged respirators and trash are often found in the drums.
During several tours of the auxiliary building, inspectors also observed unbagged respirators and trash in these drums.
In addition, the inspectors observed two unbagged and unattended respirators on the floor in a contaminated area.
(Licensee representatives stated similar instances are not common.)
The followup by the licensee indicated the two respirators had been left on the floor in the contaminated area several days ago.
These observations by the inspectors support the concern that cross-contamination of respirators is possible with the licensee's current method of respirator accountability.
Cleanin and Maintenance Interviews with licensee representatives and a review of respirators ready for distribution indicate that respirator cleaning, inspection, maintenance, and storage is generally adequate.
Observations of fit-testing indicated that technicians performed the tests in accordance with procedures and Section 6. 11 of ANSI Z88.2-1980.
Technicians accurately described the test booth system and the test methodology to one of the inspectors.
A review of the technicians'ualification documentation indicated they had completed all of the training requirements.
quantitative fit-test results are periodically reviewed by radiation protection management.
~Trai ni n The station's respiratory protection program requires that all workers who will be or have been wearing respirators receive initial and annual retraining on respiratory protection (see Section 5).
This training consists of an approximately 90-minute long lecture and demonstration session; however, the training does not include giving the worker "hands-on" practice in donning, wearing, and removi ng the= respirator.
Licensee representatives in the tr aining department stated that workers are not allowed to practice wearing respirators during the lecture/demonstration session because there
i s no mechani sm to ensure that workers are medically cer tifi ed to wear respirators.
Morkers do not don a respirator in the training program until fit-testing.
The time and space constraints of fit-testing make it an inappropriate arena for training respirator users.
It appears that,.this training could best be done during the lecture/demonstration training session.
e.
En ineerin Controls The licensee currently uses five 3-stage and eleven 2-stage portable ventilation units.
Use is also made of several glove boxes, metal-walled temporary containment structures (see Section 9),
and herculite or plastic tents.
In discussions with licensee representatives, the inspectors noted that there are no formal procedures on the use of these engineering controls.
For example, the licensee uses a
temporary, metal-walled enclosure facility located on the 650'evel in the auxiliary building for machining certain components.
A portable ventilation unit located outside the enclosure and connected to it by an "elephant trunk" hose is used to filter the air exhausted from the enclosure.
The licensee usually operates the ventilation system only when machining is being done, and either the persons doing the machining or the RPT covering the job starts the system.
However, there is no specific mechanism, such as an RMP requirement or procedure check list, to ensure responsibility is designated for starting the system.
The inspectors noted that the radiation protection job-coverage group has informally assumed control over the use of portable ventilation systems (see also Section 13).
f.
Audits A gA audit conducted in September-October 1987 identified several problems with the respiratory protection program.
The identified problems reportedly have been corrected.
Corrective actions included revision of the respiratory protection procedures.
Overall, the respiratory protection/engineering controls program appears to be adequate; however, inspector observations regarding respirator accountability', practical training, and inadequate formalization of the use of engineering controls indicate weaknesses that should be addressed to improve the effectiveness of the program and to bring it to the level of current industry standards and regulatory guidance.
As an initial response to the perceived accountability weakness, the licensee stated that one of the two proposed facility changes that would centralize respirator cleaning, repair, and distribution is expected to be implemented in 1989.
Until the facility change is made, the licensee plans to revise the procedural respirator distribution and return requirements.
The licensee also has plans to develop procedures on the use of engineering controls.
These matters will be reviewed further during a future inspecti on.
(Open Item:
315/88011-07; 316/88013-07).
No violations or deviations were identified by the inspectors.
Control of Radioactive Materials and Contamination IP 83526 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.
For the past several years, NRC inspectors have identified and discussed with the licensee the poor controls of contaminated material in the auxiliary building, especially in the vicinity of the hot tool crib.
During this inspection it was noted that the licensee has seriously addressed this recurring problem and has made significant improvements in this area; it now appears the licensee has implemented adequate radiological controls over contaminated material in the auxiliary building.
The station's principal ingress and egress control points to the radiologically controlled area (RCA) are located inside the entrance to the auxiliary building (control station).
Radiation Protection Technicians (RPTs) observe the ingress control point and are in close proximity to the egress station.
RPTs are instructed to respond to alarming PCM-18 friskers.
The control points are used for all worker ingress/egress.
Persons wearing protective clothing (PC) and modesty garments (hospital greens)
worn under the PCs are required to perform a hand-held frisk of hands and feet after removing the PCs and crossing the SOP.
Before the modesty garments are removed, workers are also required to perform a frisk using the PCM-18 whole-body contamination monitor located in the containment access control (CAC) area which is normally a control point not under direct RPT observation.
Once past this monitor, the workers don their personal clothing and are required to perform another survey in one of three PCM-18 whole-body contamination monitors located at the auxiliary building egress control point.
After this frisk, workers are required to pass through one of the gamma-sensitive portal monitors (Gamma-10)
located in the gatehouse.
The required use of whole-body contamination monitors by workers before and after donning their personal clothing, is a good radiological control practice.
In addition, the practice of maintaining a single RCA access and egress station strengthens the contamination control program.
The inspectors discussed with the licensee the operation, monitor alarm setpoint methodology, and calibration procedure for the two whole-body portal monitors located in the gatehouse.
Calibrations are performed in accordance with Plant Procedure No.
12 THP 6010.RAD.573, Calibration of the Gamma-10 Portal Monitor.
The procedure requires the minimum detectable activity (MDA) of cesium-137 for each monitor be calculated; the MDA ranges from 150-175 nanocuries.
Calibrations are performed every six months.
The inspectors reviewed the most recent calibrations; no problems were noted.
The inspectors noted that the licensee permits a person to leave the site after alarming the gatehouse portal monitor if contamination is not detected on a subsequent personal contamination survey by a hand-held frisker.
This practice could result in not identifying internal
~contamination or hidden hot particles unless a whole-body count is performed.
This matter was discussed with the licensee and will be reviewed further during a future inspection.
(Open Item:
315/88011-08; 316/88013-08)
" The inspectors also discussed the operation and calibration procedure for the five Eberline Model PCM-1B whole-body contamination monitors.
The relevant calibration procedure is Plant Procedure No.
12 THP.6010 RAD.697, Eberline Personnel Contamination Monitor Calibration.
The calibrations are performed using a nominal 100 pCi technetium-99 (100 cm~ area)
standard.
Detector efficiencies for the standard range from 6-9X.
The inspectors reviewed calibration records for selected monitors.
It appears the PCM-1Bs are calibrated at the required frequencies and in accordance with procedural requirements.
As discussed in Inspection Reports No. 315/87002; 316/87002, the licensee has a goal of reducing the auxiliary building contaminated floor area to 20,000 ft~ (10K of the total auxiliary building floor area).
At the end of 1987, the contaminated floor area was 30,123 ft~.
By the end of March 1988, the area had been reduced to 25,673 ft~.
The inspectors noted the apparently large number of leakage containment devices installed throughout the auxiliary building (see Section 23).
This observation has been made previously by the NRC (Inspection Reports No. 315/87002; 316/87002)
and others.
The licensee has a goal to reduce the number of leakage containment devices to 200.
At the end of 1987, 456 devices were inplace in the auxiliary building.
By the end of March 1988, the number of devices had been reduced to 350.
The licensee's contamination control and monitoring efforts may be a factor in reducing the number of personal contamination events (see Section 10).
During a previous inspection (Inspection Reports No. 50-315/86001; 50-316/86001),
the inspectors noted that Plant Manager Procedure No.
PMP 6010.RAD.001 contained contaminated object release limits which implied that items with low level, but detected, radioactivity could be released into an unrestricted area.
The licensee was informed that there are no allowances in 10 CFR 20 which permit detected radioactive material to be unconditionally released to an unrestricted area (see IE Information Notice No. 85-92, Surveys of Wastes Before Disposal from Nuclear Reactor Facilities),
and that the procedure should be revised to reflect the requirements of 10 CFR 20 (Open Items No. 315/86001-05; 316/86001-05).
This matter was considered closed in Inspection Reports No. 50-315/86013; 50-316/86013 because the licensee contended that the procedure had been properly revised.
However, during the current inspection, an inspector noted that Table IX.D-1 of PMP 6010.RAD.001 implies that items with low level, but detected, radioactivity could be released into an unrestricted area.
In response to the inspector's concern, the licensee agreed to revise the procedure.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(Open Item:
315/88011-09; 316/88013-09)
No violations or deviations were identified.
10.
Personal Contamination Events IP 83526)
Plant Procedure No.
THP 6010 RAD.600, Revision 4, Personnel Decontamination and Incident Reporting, requires a Personnel Contamination Incident Report to be completed when personnel contamination (skin and/or clothing) is detected equal to or greater than 100 cpm above background using a hand-held frisking device, or any detectable counts on nasal or mouth swabs.
There were 719 personnel contamination incidents in 1987 and 468 incidents in 1986.
The increase of personnel contamination events may be due, in part, to the installation of more sensitive whole-body contamination monitors.
During the last radiation protection inspection in mid-1987, the inspectors noted that many possible causes for personnel contamination such as protective clothing leaching, hot particles, inadequate RMP dress requirements, inadequate pre-job surveys, contaminated step-off pads, failure to use frisking booths upon exiting contaminated areas, RMP violations, and poor RP work practices were not being adequately tracked and trended to identify and correct programmatic deficiencies (Open Items No. 315/87002-08; 315/87002-08)
~
In response to the inspectors'oncerns, internal gA audits, and independent audits of the program, the licensee reviewed and revised procedures and policies to adequately
'delineate requirements, provide guidance and clearly state the plant policy that all procedures would be followed.
The licensee also revised the procedure on identifying and tracking the causes of personnel contamination events (PCEs).
In addition, the licensee phased out all licensee-owned protective clothing, contracted to have the leased contaminated protective clothing washed at a commercial offsite nuclear laundry, required modesty garments (hospital scrubs) to be worn under protective clothing, and increased the efforts of an existing program to decontaminate/paint plant areas.
All of the above, combined with increased worker cognizance of radiation protection policies and the need to adhere to those policies have apparently resulted in the reduction in the number of personnel contamination events (PCEs) in 1988 to date.
Through June 12, there has been 101 plant PCEs in 1988; the SGRP reportedly has had
PCEs through June 16.
Increased management attention also may have affected a reduction in the number of individuals who have multiple personal contaminations.
In the last half of 1987 approximately 150 people were contaminated more than once, several were contaminated at least six times.
Through May 11, 1988, only one plant worker has been contaminated twice.
This reduction is apparently attributable to increased supervisory involvement and worker cognizance of and adherence to radiation protection procedures.
The inspectors discussed with the licensee the desirability of maintaining a low level of multiple personal contaminations and the need for plant management to ensure that multiple personal contaminations were not indicative of the specific individuals'oor radiation work practices or of generic programmatic problems regarding poor radiation work practices.
The licensee does not have a definitive policy for determining discrete radioactive particles (hot particles).
Identification of hot particles appears dependent upon the effort the individual RPT who is conducting the survey decides to expend in order to isolate the particle or by the
ease with which the contamination is removed from the skin/clothing; no specific methods are prescribed to narrow the area of contamination to determine if a discrete particle exists.
Mithout the development of a more specific determination methodology, it is difficult for the licensee to know if there is a significant plant hot particle problem.
Thus, although the licensee stated that 30 hot particles were identified in 1987 and six were identified, through May 11, in 1988, the actual number of discrete particles involved in PCEs is uncertain.
This matter is also discussed in Section 11.
No violations or deviations were identified by the inspectors.
Skin Dose Assessment and Hot Particle Events (IP 83524 83526 The inspectors selectively reviewed the licensee's skin dose assessment of personal contamination events recorded for 1987 and 1988 to,date.
A skin dose assessment is performed for all contamination events in accordance
~
with the criteria described in Procedure No.
12 THP 6010 RAD. 108, Dose Determination For Contamination of the Skin.
A skin dose is performed if 30,000 cpm is measured using a
GM pancake probe and if the contamination has a skin residence of at least one hour (approximately equivalent to a skin dose of approximately 100 mrem).
As part of the dose assessment, the procedure requires that if the contamination is not caused by a discrete particle, the sum of the activity detected by the
cm~ probe be divided by 15 to compute dose to 1 cm~ of tissue.
The use of this factor assumes the contamination is spread uniformly over 15 cm~, which is a nonconservative assumption because the contamination is unlikely to be spread uniformly and may be concentrated over a considerably smaller area.
This matter was discussed with the licensee who stated that for those PCEs which require skin dose assessments, RPTs will be using specially modified hand-held friskers to identify discrete hot particles, or the highest
cm~ area of skin contamination, for use in computing the skin dose.
This revised survey technique will be incorporated into Procedure No.
12 THP 6010.RAD.108 and the factor of 15 criteria will be deleted.
A review of the licensee's skin dose assessment for an individual who was exposed to a radioactive particle located on his clothing showed that the licensee-computed dose was about 3.5 times higher than the inspector's assessment.
The licensee's dose assessment for this case was computed using an in-house methodology.
After the licensee and the inspector discussed the difference, the licensee discovered the VARSKIN computer code program for skin dose assessment was available onsite.
Using this program, the licensee reassessed the dose to the individual; the reassessed calculations were in good agreement with the inspector's.
The licensee was then requested by the inspector to compute skin dose for two hypothetical hot particle incidents using different radioisotopes at a skin depth of 7 mg/cm~ averaged over 1 cm~ at varying shielding thicknesses.
Using the VARSKIN computer code, the assessment was performed; the licensee and NRC calculations were in good agreement.
The licensee stated that the VARSKIN computer code program will be used for further dose assessments and will be incorporated into Plant Procedure No.
THP 6010.RAD.108.
The VARSKIN computer code used for computing the radiation dose to the skin is described in NUREG/CR-4418,
"Dose Calculation for Contamination of the Skin Using the Computer Code VARSKIN," and is widely used in the nuclear power industry.
'As part of the overall contamination control program, the licensee should develop a specific hot particle program which includes:
specific guidance to radiation protection technicians to alert them to methods for controlling hot particles; specific guidance which delineates particle detection, removal, quantification and analysis; and requirements for performing pre-job evaluations and protective measures for tasks with potential for hot particles contamination.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection.
(Open Item:
315/88011-10; 316/88013-10)
No violation or deviations'ere identified.
12.
Facilities and E ui ment (IP 83527)
The inspectors reviewed the facilities and equipment used by the licensee for radiation protection activities to determine whether they are as described in the FSAR and are adequate to support the radiation protection program.
Improvements in the hot tool crib/tool decontamination and assess control facilities and laundry processing are discussed in Section 3.
The facilities and equipment which have been procured for the SGRP are discussed in Section 4 of Inspection Reports No. 50-315/88012(DRP);
50-316/88014(DRP).
The inspectors discussed with the licensee various inaccurate descriptions in the FSAR of plant facilities-and equipment; the licensee stated that corrections are planned when the FSAR is next scheduled to be updated.
13.
Maintaini n Occu ational Ex osures ALARA IP 83728 83729 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 outages; 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'eview concentrated on changes made to the ALARA program since the previous radiation protection inspection in mid-1987 (Inspection Reports No. 50-315/87002; 50-316/87002).
Observations and relevant aspects of the licensee's ALARA program are discussed below.
a ~
~Staffin During non-outage periods, the plant ALARA group is staffed by the ALARA supervisor, a clerk, and a contracted RPT (assigned primarily to the temporary shielding program); the SGRP has an independent ALARA group (see Section 4 of Inspection Reports No. 50-315/88012(DRP);
50-316/88014(DRP).
During the current Unit 2 outage, the plant ALARA staff has been somewhat increased by the part-time assignments of the Associate Health Physicist and the Training Specialist.
During the previous outage (Inspection Reports No. 50-315/87002; 50-316/87002),
six contract technicians assigned to the ALARA group were each designated to cover one of six major jobs, essentially from start to finish.
Because of financial consideration, this intensive job coverage by the ALARA staff was not repeated for this outage; however, the licensee reportedly..used information gained from the previous coverage in planning and conducting similar jobs during this outage.
During outage and non-outage periods, development and implementation of engineering controls, such as portable HEPA/charcoal ventilation units and temporary containment structures, are the responsibility of the job-coverage radiation protection supervisor and his technicians.
Pre-job briefings are the responsibility of the work groups'irst-line supervisors, with assistance from the job-coverage radiation protection staff.
(At many facilities, these responsibilities are assigned to the ALARA group.)
Goal s Representatives (ALARA coordinators)
of each of the station's major work groups (such as maintenance, operations, and construction)
work with the ALARA supervisor to develop goals and review job orders for inclusion of ALARA considerations.
The station does not set an annual person-rem total goal for upcoming years.
Instead, for 1987 and 1988, the licensee has established that the year-end total should be 15K less than the total for the previous year after consideration of the amount of time spent in outages.
The licensee calculates the average monthly dose rates for both outage and non-outage periods from selected portions of the previous year's data.
Based on the projected outage/non-outage ratio, the licensee establishes monthly goals which are 15% less than the associated monthly averages for the previous year for each of more than 50 sub-departmental work groups.
The monthly goals are adjusted at the end of the month if the outage/non-outage ratio differs from that estimated.
At the end of each month, the ALARA group compiles and distributes a
tabular/graphic report of the dose incurred during the month.
The success of the dose-total reduction efforts of each department are reviewed at the semiannual meeting of the ALARA committee, chaired by the Plant Manager.
For 1987, the licensee's dose total was 666 person-rem, which was reportedly a 17K reduction from the 1986 total of 673 person-rem after the actual outage/non-outage ratio is considered.
As of April 30, 1988, the station had accumulated less than 40 person-rem, excluding the dose incurred on the SGRP.
Meetin s/Reviews Pre-job reviews are conducted by the ALARA subcommittee for jobs where the estimated exposure is 1.5 person-rem or greater.
The ALARA supervisor chairs the subcommittee and department ALARA representatives are voting members.
The reviews are recorded as meeting minutes and posted with the RWPs at access control for the workers to read.
In addition, the job supervisor attends the review, prepares the initial ALARA checklist that is used by the subcommittee during the review, and briefs the workers on the specific ALARA recommendations of the subcommittee.
Also, the radiation protection
job-coverage group reviews the ALARA considerations with work groups for potentially high-dose jobs.
Post-job reviews are conducted by the ALARA subcommittee for jobs with actual exposure greater than 1.5 person-rem.
One of the inspectors attended the post-job review for the installation and removal of a metal shield used during the removal of a stuck reactor head stud.
The review appeared to be an informative exchange that accomplished the intended purpose of the meeting.
Overall, attendee comments indicated that despite the delay caused by an inaccurate diagram the job went well.
In addition, a
visit by the ALARA supervisor, and others involved with the job, to the vendor's facility in Tennessee and mock-up training of workers apparently contributed to the success of the use of the shield and the removal of the stud.
The inspector, however, did have several concerns/observations regarding the meeting.
Several attendees stated that the communication system used during the shield installation was poor.
In reply, several members of the ALARA subcommittee stated that a
more effective system had been available for use.
The availability of this more effective communication system should have been established during preparation for the job.
The inspector noted that a recommendation for the use of this equipment had been made previously in a report on one of the six jobs that received intensive ALARA coverage during the last outage.
The inspector also noted that a formal mechanism apparently does not exist to promptly forward to plant management important issues that arise during the job and discussed at the post-job review.
For instance, one of the attendees at the above post-job review stated that the vendor involved with the stud removal suggested that the threads in the other stud holes be cleaned before reinstallation of the reactor head to reduce the possibility of another stuck stud.
The ensuing discussion by the ALARA subcommittee indicated that this suggestion may not have been forwarded to upper management.
Another issue that apparently should have been forwarded to management is the discovery that the diagram of the reactor head flange had an incorrect important dimension.
Members of the committee appeared unsure whether this diagram was drawn only for the removal of this particular stud or whether the incorrect value was on other related diagrams which might be used for other jobs.
ALARA Su estions/Im rovements The licensee solicits dose-saving ideas from workers.
Action on tenable ideas is tracked by the ALARA supervisor and is reviewed by the full ALARA committee.
Several suggestions under review or being acted upon include a revision of a filter-change procedure to list all necessary tools and equipment, development of a plan or procedure revision to specify low-cobalt components for plant design changes and replacement parts for primary system components, removal of RTD bypass lines, installation of permanent reactor head shields, and modification of reactor cavity floor plate covers to improve seals.
In addition, acting on experience gained at other utilities, the job-coverage radiation protection supervisor had sheet metal funnels fabricated for the elephant trunks of the portable filtered ventilation units to enhance suction for special applications.
It appears that the licensee has an effective ALARA suggestion program which produces reasonably achievable dose-saving suggestions/
improvements.
e.
Audits Since the previous radiation protection inspection in mid-1987, several licensee-initiated reviews of the ALARA program have been conducted.
In November 1987, a detailed gA audit identified several deficiencies regarding temporary shielding paperwork, consistency and redundancy of the ALARA program descriptions in the station's administrative and implementing procedures, and development of a record retention schedule.
These items apparently have been corrected and are considered closed by the gA auditors.
In April 1988, a
follow-up review of the licensee's radiation protection program by a consultant concluded that the ALARA program did not appear to have made as much progress as the rest of the radiation protection program since the initial program review by the consultant in March 1987.
The consultant attributed this to a perception that plant management and workers consider ALARA primarily a responsibility of the radiation protection group.
The consultant added however, that this observation did not indicate a lack of management commitment or improvements.
Although the inspector's review of the ALARA program did not affirm or contradict the consultant's attribution, the inspector did note that progress was being made to increase worker awareness and management support of the ALARA program.
As the ALARA supervisor gains more experience and receives additional training, and with the planned assimilation of the dose-tracking program and aspects of ALARA procedures currently used by the SGRP, the quality of the station's ALARA program should increase.
No violations or deviations were identified by the inspectors.
14.
Outa e Plannin Pre aration and Chan es IP 83729)
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.
The inspectors also reviewed changes in organization, personnel, facilities, equipment, programs, and procedures that could affect the outage radiation protection program.
The inspectors concentrated their review on the plant's radiation protection program.
The readiness of the Project Radiological Protection/ALARA Group (PRPAG) to provide adequate RP support to the SGRP is discussed in Section 4 of Inspection Reports No. 50-315/88012(DRP);
50-316/88014(DRP).
During the current outage, the plant RPTs, professional HP staff, 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.
Contrary to previous outages, the plant RPTs have assumed
.the lead in implementing the outage RP coverage, while the contract RPTs generally wor k under the direction of plant RP supervisors and lead technicians.
Based on plant tours in the auxiliary and turbine buildings and Unit 2 containment, the observation of work activities, and the post-job interviews with workers who performed tasks not directly observed by the inspectors, it appeared that RP job coverage was adequate with the exceptions noted in Section 22.
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 RPTs to work with the Planning Department and the Technical Physical Sciences Outage Coordinator, containment decontamination and shielding prior to allowing outage work to begin, and radiation protection and ALARA participation in planning and outage meetings.
No significant problems were noted with the exceptions of a post-job review (see Section 13) and a contamination incident (see Section 22).
No violations or deviations were identified.
15.
Solid Radioactive Waste (IP 84522 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 of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesses.
Through May 20, the plant has shipped about 2450 cubic feet of solid radwaste in 1988.
The goal for 1988 is 9400 cubic feet of solid radwaste,'ompared to 16,380 and 18,650 cubic feet shipped in 1987 and 1986, respectively.
The continuing reduction is due, in part, to the licensee's conscientious efforts to minimize solid radwaste volume by use of radwaste process equipment, waste segregation and compaction, and limiting material brought into the RCA.
The inspectors toured the radwaste process and solid radwaste storage facilities; no significant problems were noted.
The inspectors reviewed Revisions No.
7 and 8 of the Radioactive Waste Process Control Manual, Procedure No.
PMP 3150.PCP.001, as reported in the 1987 Semiannual Radioactive Effluent Release Reports; no significant problem were noted.
The 1987 gA Radwaste audit (Report No. gA-87-11 dated June 2, 1987)
resulted in a number of findings.
Some of the licensee's initial responses to these findings were not adequate and correction action
'had not been completed prior to the end of the last radiation protection/
radwaste inspection (Inspection Reports No. 50-315/87002; 50-316/87002).
Since some of the findings appeared to be recurrences of findings identified in earlier QA audits involving apparent violations of Technical Specifications requiring adherence to radiation protection procedures, this matter was considered unresolved (Unresolved Items No. 315/87002-12; 316/87002-12).
QA Audit No. QA-88-03, conducted January 4, 1988-February 9, 1988, reviewed responses and corrective actions to QA Audit QA-87-11 findings to verify that committed corrective/preventive actions were accomplished and to assure that problems had not recurred.
Audit Report No.
QA-88-03 concluded that the previous findings and/or concerns noted in Audit Report No. QA-87-11 had been adequately addressed and were adequate to prevent recurrence.
The apparent violations of Technical Specifications 6. 11, 6.8. l.a and 6.8.1.g appear to meet the criteria of
CFR 2, Appendix C for self-identification and correction of problems.
This matter is considered closed.
No violations or deviations were identified by the inspectors.
Li uids and Li uid Radioactive Wastes IP 84523 The inspectors reviewed the licensee's reactor liquids and liquid radwaste management programs, including:
determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether reactor liquids meet chemical and radiochemical requirements; determination whether liquid radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notification; determination whether process and effluent monitors are maintained, calibrated, and operated as required; and experience concerning identification and correction of programmatic weaknesses.
An inspector reviewed selected records of radioactive liquid effluent sampling and analysis for 1988 and the semiannual effluent reports for 1987.
The pathways sampled and the analysis performed appear to comply with Technical Specification Table 4. 11-1.
Total liquid radioactive effluent (excluding tritium) in 1987 was 0.98 Ci per reactor unit, an increase from 0.22 Ci per unit in 1986, but below the 1. 1 Ci per unit in 1985.
No problems were identified in the review of selected records.
The records showed that releases were maintained within applicable limits.
Since about October 1986 the licensee has been using a combination of demineralization and evaporation to process liquid waste.
The goal was to maintain cleanup quality while reducing solid radwaste volume.
This goal has been attained since liquid releases were well within the
CFR 20 concentration limits and the 1987 volume of solid radwaste shipped was the lowest since 1976.
No violations or deviations were identified.
17.
Gaseous Radioactive Waste (IP 84524)
The inspectors reviewed the license e's gaseous radwaste management program, including:
determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether gaseous radioactive waste effluents were. in accordance with regulatory requirements; adequacy of required records, reports, and notifications; determination whether process and effluent monitors are maintained, calibrated, and operated as required; and experience concerning identification and correction of programmatic weaknesses.
An inspector reviewed selected records of radioactive gaseous effluent, sampling and analysis for 1988 and the semiannual effluent reports for 1987.
The pathways sampled and the analyses performed appear to comply with Technical Specification Table 4. 11-2.
No problems were identified in the review of selected records.
The records showed that releases were maintained within applicable limits.
Total curies of noble gas released in 1987 were about 300 curies per reactor unit, up from the 165 curies per unit released in 1986.
This increase is attributed to continued problems with Unit 2 steam generator tube leaks and renewed problems with fuel cladding for both units.
Replacement/repair of the Unit 2 steam generators is scheduled during the current outage.
No violations or deviations were identified.
18.
Effluent Control Instrumentation IP 84523 84524 An inspector reviewed calibration records and selected setpoints for essential service water, blowdown, blowdown treatment, and liquid radwaste monitors; low range noble gas monitors for lower containment; and gland seal exhaust, steam jet air ejector, and unit vent radiation monitors.
The instruments have been calibrated and setpoints calculated on a timely basis.
Although a new Eberline liquid radwaste effluent monitor (RRS-1001)
has been installed, the old Westinghouse monitor (R-18) still has the setpoint function required by Technical Specifications (T/S) pending approval of a T/S amendment request.
Most of the old Westinghouse monitors are no longer being used to meet T/S requirements.
Until recently both the Eberline and the Westinghouse monitors were being maintained even though the Eberline monitors were the ones required by Technical Specifications.
Maintaining the dual monitoring systems had unnecessarily used manpower and other licensee resources.
The only channel that is now monitored by both systems is the liquid radwaste monitor discussed earlier in this section.
Calibration procedures have been reviewed, rewritten if necessary, and according to the licensee are now workable and effective.
Data is being developed for an improved calibration procedure for the Sping 3/4 units.
No violations or deviations were identified.
Primar and Secondar Coolant Radiochemistr IP 84523 An 'inspector selectively reviewed the licensee's reactor coolant and secondary chemistry and radiochemistry results for the last half of 1987 and March, April and May of 1988 to determine compliance with technical specification requirements for chemistry and radiochemistry limits and surveillance frequencies.
The inspector reviewed primary coolant system data for'chloride, fluoride, gross beta-gamma and dose equivalent I-131.
The inspector also reviewed secondary system data for gross activity determination and dose equivalent I-131.
The selective review and discussion with licensee personnel indicated that all parameters for both primary and secondary systems remained less than applicable Technical Specification limits throughout the review period.
No violations or deviations were identified.
20.
Air Cleanin S stems (IP 84524)
Technical Specifications require filter testing of the control room emergency, ESF, and fuel storage pool ventilation systems.
The in-place leakage test criteria specified both for DOP testing of HEPA filters and for freon testing of charcoal adsorbers is equal to or less than one percent penetration.
The laboratory test criteria for carbon sample removal efficiency for radioactive methyl iodide is equal to or greater than 90 percent.
A selective review of surveillance test data, covering the period from the last inspection of this area (Inspection Reports
, No. 50-315/87013; 50-316/87013)
showed that the surveillance for the above ventilation systems had been timely and met test criteria.
Also, records of hours of filters usage show that the 720-hour Technical Specification limit was not reached between the routine required 18-month surveillance tests.
No violation or deviations were identified.
21.
Trans ortation of Radioactive Materials IP 86740 An inspector reviewed the licensee's transportation of radioactive materials program, including:
determination, of 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 inspector selectively reviewed portions of the solid radwaste shipment records to date in 1988.
The information on the shipping papers appears to satisfy NRC, DOT, and burial site requirements.
The licensee had 40 shipments in 1987 and seven shipments through May 20, in 1988.
No violation or deviations were identified.
22.
Auxiliar Buildin Contamination Event w
n a
5-
b ut ourtee Bet ee M y 1 17,
8, a
o f
n individuals who had entered into, or worked in the auxiliary building and Unit 2 containment were identified to have low levels of shoe and personal contamination.
During this period, Unit 1 was operating at 80 percent power, Unit 2 was shutdown for outage activities, and several RWP jobs were in progress in the auxiliary building and Unit 2 containment, including work in the dry fuel transfer canal on the 650'evel.
On May 17, 1988, several whole-body contamination monitor alarms, eight personal contamination events, and routine masslinn smears indicating higher than usual contamination levels prompted the Plant Radiation Protective Supervisor to secure all entry into the RCA and initiate an investigation to determine the cause of the contamination problem.
During this investigation the licensee noted that between May 15-17, 1988, workers entered the dry fuel transfer canal on several occasions to perform various maintenance activities.
During this period all air samples taken in the auxiliary building were less than 25/
MPC beta-gamma, contamination levels ranged up to 10,000 dpm/100 cm~
on the crane located on the 650'evel of the auxiliary building, and lesser contamination levels were found on the lower auxiliary building floors.
The primary isotopes found on the smears were cobalt-58 and 60, niobium-95, cesium-134 and zirconium-95.
Smears taken from the fuel transfer canal ranged up to 160 mrad/hr/100 cm~.
Based on this information, the workers were required to wear plastic suits, full face respirators, rubber boots, double gloves, and full protective clothing (PCs).
The licensee initially assessed that the auxiliary floor contamination and personal contamination events may have been the result of loose contamination found on May 15, 1988, which had spread to the clean side of the step-off-pad (SOP) where personnel removed their PCs after egress from the fuel transfer canal area.
The license also found that during this period,. the weir gate between the fuel pool'nd the reactor cavity fuel transfer canal was dry and open, the containament equipment hatch leading to the auxiliary building was open most of the time, the containment purge was isolated on numerous occasions, and the upper internals in the vessel were exposed and dry.
As a result of these conditions the license determined that the contamination migrated from the containment building and dry fuel transfer canal into the auxiliary building during 'those times when the containment purge fans were isolated because the auxiliary building fans were operating and taking suction from the containment.
The containment purge system should be operated such that the containment pressure remains negative with respect to the surrounding areas during those times when the containment is open to the auxiliary building, and especially when there is a potential for migration of radioactivity.
The inspectors interviewed health physics personnel concerning this incident; reviewed logs, air sample and survey records; and discussed, the licensee's investigation results with the licensee.
No violations of regulatory requirements were identified by the inspectors during their review of this incident.
However, several programmatic weaknesses were identified which appeared to contribute to the incident's occurrence and magnitude.
These weaknesses include:
Requirements are needed to prevent degrading radiological conditions as a result of altering containment air flow systems during outage activities.
This contamination event was caused because the containment purge fan was isolated when the vessel intetnals were exposed and dry, and while the fuel transfer canal gate and containment equipment hatch were open.
During this event the transfer canal was dry and known to have high loose contamination levels.
Pre-job planning and coordination needs strengthening.
Although the actual spread of contamination was physically caused by altering air flow systems in the containment, it appears there was insufficient coordination between departments and undefined responsibilities for ensuring contamination control measures were considered and implemented for such evolutions as containment snubber removal and fuel transfer canal operations.
During these evolutions, it appeared the licensee was not fully aware of the potential for the resultant contami nation incident.
~
Poor communications between plant personnel during this period contributed to the incident.
Operations personnel did not consistently inform radiation protection personnel when the containment purge fan was isolated.
On one occasion, radiation protection personnel were informed the purge system would be isolated for about 45 minutes.
Radiation protection personnel questioned operations personnel about the reason for isolating the purge system while the containment equipment hatch was open, and although there appeared to be no satisfactory explanation, the hatch remained open for about 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> while the purge system was isolated.
Also, it appears radiation protection personnel did not recognize that the fan was off for longer than expected due to an internal communication problem.
~
Fuel transfer canal pre-job surveys should include analysis for alpha activity.
Although both job-specific smear surveys and air samples were taken before and during fuel transfer canal work, none was analyzed for alpha activity.
The knowledge of the complete isotope mix is essential for proper selection and assessment of respiratory protection equipment and determination of engineering controls.
The potential for alpha activity in the fuel transfer canal was apparently not considered during pre-job planning nor during the jobs to determine if additional precautions were needed.
The above weaknesses were discussed at the exit meeting on Hay 27, 1988, and during a telephone conference with the licensee on June 13, 1988.
This matter will be reviewed further during a future inspection.
(Open Item:
315/88011-11; 316/88013-11)
No violations or devi ati ons were identi fied.
23.
Plant Tours/Observations The inspectors conducte d numerous tours in the training, auxiliary, and turbine bu> ldsngs; Unit 2 containment; and the SGRP access control facility to examine and observe training, respirator-fit testing, and whole-body counting facilities; radiation protection and contamination control practices; and RWP work activities.
Numerous workers and other licensee personnel were interviewed during the tours.
The inspectors also conducted radiation and contamination surveys of selected plant areas and equipment using NRC and licensee survey instruments; dose rate readings and removable contamination levels were in general agreement with licensee posted survey data and limits on removable contamination levels.
Of about 80 smears taken of equipment, tools, step-off pads, and horizontal structural surfaces in gene'ral access areas, only two smears indicated removable contamination slightly above the licensee's limit.
These results indicate generally adequate control on contaminated equipment.
Other relevant observations are discussed below.
Housekeeping generally appeared adequate; however, as noted in Section 8, the inspectors observed trash in barrels designated for return of respirators, numerous leakage-containment devices installed throughout the auxiliary building, and two unbagged respirators lying on the floor in a contaminated area.
In addition, the inspectors observed uncontained leakage of a liquid onto a ventilation system filter housing.
The licensee promptly contained the leakage after being informed by the inspectors.
b.
RWP Adherence
'I As stated in Inspection Reports No. 50-315/88014(DRP);
50-316/88016(DRP),
an unattended survey meter was observed in Unit'2 containment by the resident inspectors and a NRC/Region III Radiation Specialist.
Discussion with a nearby worker indicated that the meter was his and that he had put it down before stepping onto an adjacent catwalk to perform work.
RWPs for containment outage work require workers to possess and use dose-rate meters while in containment.
According to licensee representatives, RWPs are written with this requirement to ensure that Technical Specification 6. 12. 1 is not violated.
This technical specification requires that personnel in a high radiation area (HRA) be provided with or be accompanied by one or more of the following:
(1) a radiation monitoring device which continuously indicates the radiation dose rate in the area; (2)
a radiation monitoring device which continuously integrates the radiation dose in the area and alarms when a preset integrated dose is received; or (3) an individual qualified in radiation protection procedures with a radiation dose-rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the RWP.
At the time of the observation by the inspectors, the containment was posted as a
HRA at the entrance (equipment hatch),
although licensee representatives stated that only a few areas within containment were actually HRAs.
The few areas actually exceeding 100 mrem/hr were not posted locally.
Licensee representatives stated that they believed it was more efficient to post the entire containment as a high radiation area and to require workers to use dose-rate meters during entry than to post individual areas within containment or provide the RPT coverage necessary for the positive controls required by the third option of the technical specification.
This practice appears counterproductive to the ALARA philosophy in that workers in containment are not warned by postings of. increased radiation fields.
It is a poor practice to post the entrance to a substantial area as a
HRA if only a few small regions are actually HRAs.
Good posting programs focus on making workers aware of the local radiological working environment so they can minimize their exposures.
Also, based on inspector observations of the inappropriate use of a dose-rate meter by a worker in containment and of the lack of adequate training given to workers on the use of dose-rate meters (see Section 5), it does not appear that the licensee's policy of requiring all workers entering containment to use dose-rate meters is effective.
It appears that workers are desensitized to the need for diligent HRA work habits by their knowledge that only a few areas in containment are actually HRAs.
fai lure to locally post the actual HRAs could lead to unnecessary radiation exposures as a result of this desensitization.
Guidance concerning posting of radiological hazards locally versus at building. entrances was provided to all power reactor licensees in IE Information Notice No. 84-82.
The licensee claimed that the need to move the reactor upper internals during reactor head repairs would require frequent resurveying and posting of high radiation areas if the licensee did not consider the entire containment as a high radiation area.
This does not appear to be a valid justification.
Good health physics practice dictates that possible changes in radiological conditions brought about by changes in work activities/job scope or the movement of equipment, such as the reactor upper intervals, be coordinated with the radiation protection job-coverage technician or containment technician to ensure proper radiological assessment.
This matter was discussed with the licensee and wi 11 be reviewed further during a future inspection.
(Open Item:
315/88011-12; 316/88013-12)
~Fni ski n t
Observations of personnel conducting personnel contamination frisks with hand-held detectors indicated generally adequate performance of frisks.
r d.
~Po st i n The NRC inspectors found doors to extremely high radiation areas posted and locked as required.
Except as noted in Section 23.b above, no problems were identified with postings and controls for high radiation areas.
Postings of other areas and equipment were adequate; however, the inspectors observed that duct tape was used to demarcate the potentially contaminated area on the 650'levation of the auxiliary building (refueling floor) after the apparent migration of contamination from the fuel transfer canal (see Section 22).
Statements prohibiting entry into the areas without donning paper shoe covers were written with black mar ker on the tape.
Apparently, the tape was used instead of the visual yellow and magenta warning tape because of the size of the area involved and the urgency in demarcating the area, in which the contamination was low-level but unevenly dispersed.
The inspectors expressed concern that the duct tape was inadequate to warn workers of the potentially contaminated area.
The licensee acknowledged the'nspectors'oncern and began deconning the areas and removing the tape during the last days of the onsite inspection.
No violations or deviations were identified.
The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the onsite inspection on May 27, 1988, and by telephone on June 13, 1988.
Further discussions were conducted with the Assistant Plant Manager-Technical Support and others, by telephone through July 13, 1988.
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 and processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents or processes as proprietary.
The following matters were discussed specifically by the inspectors:
a I The lack of licensee progress concerning proceduralized survey criteria for release of items to uncontrolled areas, training in the use of portable survey instruments, and possible release paths for contaminated material to uncontrolled area.
(Sections 2, 3, 5, and 9).
b.
The RPM's qualification weaknesses.
The licensee stated that qualified assistance for the RPM would be procured.
(Section 2)
c.
The apparent need to adapt the condition reporting system to more effectively resolve and prevent recurrences of radiological deficiencies.
(Section 4)
d.
The generally satisfactory licensee progress regarding implementation of the RP improvement action plan.
The licensee responded that the action plan wi 11 be modified periodically in response to programmatic weakness identified by the NRC and others.
(Section 4)
e.
The generally poor radiation worker practices and the apparent need to have a broader selection of plant and contract workers take the radiation worker training course.
(Section 5)
Inspector-perceived weaknesses regarding the respiratory protection/
engineering controls program.
(Section 8)
g.
Inspector concerns regarding the lack of an effective hot particle program.
(Section ll)
h.
Inspector concerns regarding ALARA post-job reviews.
(Section 13)
i.
Inspector-perceived weaknesses regarding the circumstances surrounding a recent auxiliary building contamination event.
(Section 22)
j.
Inspector concerns regarding the adequacy of containment outage surveying, posting, and RP coverage.
(Section 23)
36