IR 05000454/1987012

Insp Repts 50-454/87-12 & 50-455/87-11 on 870304-0630.Major Areas Inspected:Audits,Organization & Mgt Controls,Radiation Protection Procedures,Training & Qualification of New Personnel & ALARA

ML20235H289
Person / Time
Site:	Byron
Issue date:	07/06/1987
From:	Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235H264	List: IR 05000454/1987012 ML20235H260
References
50-454-87-12, 50-455-87-11, NUDOCS 8707150088
Download: ML20235H289 (20)

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O.S. NUCLEAR REGULATORY COMMISSION REGION III i Reports No. 50-454/87012(DRSS); 50-455/87011(DRSS)

l Docket Nos. 50-454; 50-455 Licenses No. NPF-37; NPF-66 l Licensee: Commonwealth Edison Company

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Post Office Box 767 Chicago, IL 60690  ;

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Facility Name: Byron Nuclear Power Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois Inspection Conducted: March 4 through June 30, 1987 Inspectors: . Gran 8 Date  ;

Approved By:

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7587 L. Robert reger, Chief //

Facilities Radiation Protection Date .

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Inspection Summary Inspection on March 4 through June 30, 1987 (Reports No. 50-454/87012(DRSS);

No. 50-455/87011(DRSS)

Areas Inspected: Routine, unannounced inspection of radiation protection i activities during refueling of Unit 1, including: organization and management I controls; audits; radiation protection procedures; training and qualification of new personnel; external exposure control; internal exposure control; radiation occurrence reports; ALARA; control of radioactive materials and contamination; reviews of previous inspection findings; an administrative excessive exposure incident; the startup radiation survey program for Unit 2; and allegations concerning radiation protection practice Results: No violations or deviations were identifie PDR ADOCK 00000454 o PDR l

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DETAILS Persons Contacted P. Andrews, Contract Health Physicist

• Bielasco, Station Health Physicist W. Burkamper,-Quality Assurance Supervisor L. Bushman, ALARA Coordinator

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K. Collins, Training Department

! *T. Didier, Radwaste Operation Engineer

• R. Flahive, Radiation / Chemistry Supervisor D. Goldsmith, Health Physics Group Leader

• F. Hornbeak, Tecnnical Staff Supervisor

• J. Pausche, Regulatory Assurance

• Pirnat, Regulatory Assurance

• R. Querio, Station Manager

• S. Sober, Health Physicist

• • R. Ward, Services Superintendent

• • E. Zittle, Regulatory Assurance The inspector also contacted several other licensee personne1' including technicians, engineering assistants, foreman, and members of the technical staf * Denotes those present at the exit meeting on March 19, 1987.

• • Denotes those present at the exit meeting on May 27, 1987. General This inspection, which began at 9:00 a.m. on March 4, 1987, was conducted to examine the licensee's radiation protection activities during the Unit I refueling and maintenance outage. The inspection included numerous plant tours, review of posting and labeling, radiation occurrence reports, personnel contamination reports, discussions with licensee and contractor personnel, independent radiation measurements by the inspector, a review of allegations concerning radiation protectio practices, and a review of the licensee's action concerning an administrative overexposure. The inspector also reviewed the completed portions of startup test Procedure No. SU-2.61.83, " Radiation Surveys During Power Ascension." Housekeeping was very goo > Licensee Action on Previous Inspection Findings (Closed) Open Item (454/86044-01; 455/86039-01): Effectiveness of worker adherence to radiation protection procedures and good health physics practices. Licensee corrective actions appear adequat Radiation protection awareness sessions were held with station and contractor employees. No cimilar violations of radiation protection procedures have occurred since these sessions. This item is considered-closed.

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4. Organization and Management Controls The inspector reviewed the licensee's organization and management controls for the radiation protection and radwaste programs, including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement these programs, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of these programs. Audits are discussed in Section Recent Rad / Chem personnel changes include:

• A Health Physicist from Nuclear Services was transferred to the Byron Health Physics Grou * A contract Health Physicist terminate * A Health Physics Foreman was assigned the staff responsibility for instrument The persons newly occupying the above positions are qualified in accordance with ANSI N 18.1-1971 for their respective position No violations or deviations were identifie . Audits The inspector reviewed audits of the radiation protection program conducted from July 1986. Extent of audits, qualifications of auditors, and adequacy of corrective actions were reviewe An onsite Quality Assurance audit of Rad / Chem instrument calibration was conducted on July 7, 1986. The one finding was that Rad / Chem radiation monitoring instruments were not being maintained in accordance with procedure According to the auditor this was a repetitive finding thus it appeared to represent a programmatic breakdow Corrective action was to relieve the contract Health Physicist of radiation instrument .

program responsibilities and to appoint a Health Physics foreman to run l the progra l

A sample conducted by the inspector during this inspection shows the calibration of Rad / Chem survey instruments to be adequate. No other problems were note Onsite Quality Assurance surveillance reports of certain radiation protection activities, solid radwaste shipments, and training were selectively reviewed. These surveillance included observation of compliance with DOT shipping regulations and radiological protection requirements regarding solid radwaste shipments and a review of the ALARA training given to contract deconners prior to steam generator work, No problems were identified by the auditors who performed the surveillance. The extent of the audits and qualifications of the auditors appear adequat _ _ _ - _ _ - _ _ - _ _ - _ _ _ _ _ _ - _ _

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o -No violations'or deviations were identified.- l Radiation Protection Procedure The inspector reviewed the following radiation protection procedures'to 'l determine if. they.are consistent with regulatory requirements.and good i health physics practices. No problems were'note BRP-1140-1, Revision 6, Radiation Work Permit '

BRP-1200-A9, Revision 3, Acceptable Source Calibration Ranges fo GM Probes'

BRP-1200-A14,' Revision 1, High Range Pocket Dosimeter Source. Check-Settings BRP-1200-A15, Revision 1, Eberline E 530/HP! 270 Calibration Guide BRP-1200-A16, Revision 2, J. L' Shephard Calibration Unit Guide BRP 1200-A17, Revision 1, High Level Probe Calibration Guide BRP-1200-T4, Revision 2, Radiation' Exposure Authorization Work Sheet j-BRP-1200-T5, Revision 4, Radiation Exposure Investigation Form BRP-1220-7,-Revision 0, Personnel Neutron Monitoring l BRP-1230-1, Revision 3, Radiation Exposure Investigation BRP-1280-2, Revision 4, Response to High Radiation Monitor Alarms BRP-1300-T21, Revision 0, Indirect Bioassay Report

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BRP-1340-1, Revision 3, Personnel Monitoring for Internal Radioactiv I Contamination j BRP-1340-2, Revision 4, Whole Body Counting Routine Operation BRP-1340-6, Revision 0, Calculation of MPC-Hours and Organ Dose Based on-Whole Body Count Data from Acute Uptakes j

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BRP-1460-6, Revision 1, Operation and Calibration of the IPM-7 Whole Body Frisking Monitor BRP-1470-1, Revision 4, Routine Personnel Decontamination BRP-1470-4, Revision 1, Skin Dose. Equivalent Determination from Skin .,

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' Training and Qualifications of New Personnel The inspector reviewed the education and experience qualifications of new plant and' contractor radiation protection personnel, and training-provided to them. Also reviewed was. radiation protection training provided to.other contractor personne l The radiation protection staff has been augmented by approximately 70 contractor Radiation Protection personnel, including technicians and-

' control point clerk Training for. contractor technicians and clerks hired for the Unit 1 refueling / maintenance outage was' conducted'in February 1987. ,The one week (40-hour) training program was provided by the Byron station training department and Rad / Chem personnel. The-program covered station Rad / Chem procedure implementation.and health physics practices. A 50 point exam was.given after-completion of the training; a passing grade of 70% was required. The inspector selectively

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reviewed. lesson plans and completed exams; no problems were note The inspector. reviewed the resumes of the contract radiation protection personnel: senior technicians, junior technicians, control point clerks and supervisors. The senior technicians and supervisors appear.to meet-or exceed the selection criteria in ANSI 3.1-1978, and to have extensive operational nuclear. plant experience. The junior technicians and control point clerks appear to have training and experience commensurate with their assigned responsibilitie No problems were note No violations or deviations were identifie ! External Exposure Control The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in program to meet outage needs; use of dosimetry; planning and preparation for maintenance- i and refueling tasks including ALARA considerations; and required records,

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reports, and notification For the Unit 1 refueling / maintenance outage, the licensee has-established !

a satellite Radiation Work Permit (RWP)/ALARA office in a' trailer located i in the Unit 1 turbine building at the 401-foot leve All RWPs for wo'rk .)

in containment are located in this traile Workers who'want'to perform 1 work in containment are required to. read and sign their respective RWPs .j at the control desk in the traile Self-reading dosimeters and digidoses, ;

if required, are issued at containment access contro l The inspector selectively reviewed RWPs and associated radiation surveys,-

observed instruction provided to individuals when they sign RWPs, and observed work being performed under selected RWPs; no problems were

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l The inspector selectively reviewed exposure records including film badge, Thermoluminescence Dosimeter (TLD), and self-reading dosimeter result _

The records indicate that no person exceeded regulatory limits. The occupational external dose for the station for 1986 was 76. person-re The external dose for the station through May of 1987 including the outage is about 700 person rem. This large' dose was attributed by the licensee to the'large number of jobs performed during the Unit 1 refueling outage which included: . eddy current testing of all four steam geilerators;.100%

shot peening of all four steam generators; inspection of snubbers; removal-of snubbers and whip restraints;;and replacing of reactor coolant pump:

seal There were over'16,000 containment' entries m'ade during this outag Because of the unusually high dose for the first refueling outage the licensee was requested to supply a dose breakdown of outage. jobs for NRC review. ' This matter will be reviewed further in the near future (454/87012-01). 1 No violations or deviations were' identifie . Internal Exposure Control

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l The inspector reviewed the licensee's internal exposure control and assessment programs, including: changes to procedures affecting internal exposure control and personal exposure assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling including ALARA considerations; and. required records, reports, and notification ,

Whole Body Count (WBC) results from January 1, 1987, to date, were reviewe No results approaching the 40 MPC-hour evaluation level were noted. Reports generated by the WBC contractor are reviewed by the Health Physicists (HPs)

to assure abnormalities and results exceeding the. license's investigation level are identifie Calibration data of the standup Canberra Fast Scan WBC indicated no problems; nor have daily check source readings (Co-60 and  ;

Cs-137) identified instrument drift or abnormalitie ;

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The WBC computer converts maximum permissible body burdens (MPBB)

to MPC-hours when the prescribed investigation level (3% MPBB for a single isotope; 5% MPBB total) is reached. The conversion has been proceduralized and will be included in CECO's Standard Radiation Protection Procedure Air sample data for 1987 to date were selectively reviewed;. no problems were note During plant tours, filtered auxiliary ventilation systems were observed in use in various cubicles where maintenance work was ongoin No violations or deviations were identifie I

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10. Control of Radioactive Materials and Contamination The inspector 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 material The inspector reviewed records of routine and special radiation and contamination surveys conducted since January 1, 1987. All surveys, routine and special, are reviewed by an HP foreman for completeness and any unusual conditions. No problems were note The inspector selectively reviewed survey instrument, portal monitor and 4 air sampler calibration record Instruments, monitors, and samplers appeared to be calibrated in accordance with procedures. Calibration ranges reflected applicable ranges encountered in the fiel Responses were within tolerance levels. A computer tracking system is used to identify instruments and samplers requiring calibration within the upcoming mont No problems were noted.

l The active RWPs were selectively reviewed. RWPs contained current survey l information. Approvals and ALARA reviews were included where require Administrative exposure limits are use Personnel contamination reports (PCRs) were reviewed for 1987 to dat Due to the outage, the number of personnel contaminations have increased, 87 have been recorded in 1987 through March 17. A significant number of the personnel contaminations (about 35) occurred after the initial entry  !

into the steam generators on February 27, 1987. In accordance with Westinghouse procedures, the initial steam generator entires were made following a hydrogen peroxide flush. High levels of loose, apparently easily transportable, contamination was detected on the generator platforms and on the generator jumpers after the initial entries into the generators. The PCRs appear to have resulted from this ,

loose contamination in the generator Rad / Chem management recognized the problem and stopped the steam generator work to reevaluate the RWP requirements and to formulate i corrective actions. An ROR (87-03) was written to document the Radiation Protection Department's concerns and the actions taken to mitigate the ,

contamination events. Discussions were held with Rad / Chem Management, I the contract generator jumper management, and the contract rad protection managemen Corrective actions included:

• Steam Generator (S/G) jumper RWP requirements were changed from a single set to a double set of protective clothing under a plastic rain sui __-_-_-_ -

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• A one piece 8-mil plastic rain suit replaced a lighter gauge two piece sui * RWP requirements for non-jumpers on the S/G platform would be j plastic suits in addition to cloth coverall .l

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• A contract Radiation Protection Technician (RPT) will help the !

S/G jumpers suit-u * A contract RPT will cut all workers coming off the S/G platform out of their plastic gea * All breathing air supply hoses were replace * S/G platforms were decontaminate * Negative airflow was verified in S/ * RPTs who cut S/G workers out of plastic gear will wear paper I coveralls over a standard set of protective clothin J The workers were found contaminated at the contamination check stations at the step-off pads when exiting containment. The contamination checks consisted of a hano and shoe frisk at the step-off pad followed by an l

automatic whole body frisk by at the IPM-7 monitors. The contaminated individuals were decontaminated using appropriate measures at the decontamination facility in the auxiliary buildin Individuals who had facial or nasal contamination were whole body counted (WBC). None of the WBCs were above one percent of maximum perraissible body burde Corrective actions appeared to be effective as PCRs from S/G work decreased to not more than one or two a day. The licensee tracks PCRs to identify repetitive violations and violator No other problems with PCRs or PCR tracking were note No violations or deviations were identifie . Radiation Occurrence Reports

'I Radiation Occurrence Reports (RORs) for 1987 to date were reviewe l The licensee trends occurrences to determine repetitive violations and violators. Five RORs have been written through March 19, 1987. The inspector noted that the licensee continues to provide sufficient management attention to followup and investigation of ROR No violations or deviations were identifie . Maintaining Occupational Exposures ALARA 1 l l The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including: ALARA considerations for maintenance and refueling outage; worker involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting the _ _ - _ _ _ _ - _ - .

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Inspector review of RWPs and discussions with the ALARA_ staff and Rad / Chem management indicate ALARA activities appear to have been addressed for both the Unit 1 outage and the Unit 2 startup. However the 700 person-rem dose incurred for the Unit 1 outage is unusually j high for a first refueling outage and casts doubt on the adequacy of the ALARA preparations. As noted in Section 8 this matter will be reviewed during a future inspectio The ALARA group which consists of the ALARA coordinator and a consultant health physicist still appears to be understaffed and needs to be strengthened to effectively complete their tasks. This matter was discussed at the exit meeting and will be reviewed during future inspection (454/86044-02; 455/86039-02).

No violations or deviations were identifie . Surveillance; Plant Tours i

Based on several plant tours, the inspector noted: (1) No persons l were observed violating procedural or regulatory requirements; this '

included observations of workers performing activities at the containment ,

I control point and under the requirements of several different RWP !

l (2) Independent radiation surveys performed by the inspector indicated !

j radiation areas were posted as require J No violation or deviations were identifie . I&E Information Notice l

IE Notice No. 86-107: Entry into PWR Cavity with Retractable Incore Detector Thimbles Withdraw Byron Station utilizes both procedures and Radiation Work Permits (RWPs)

to control high radiation exposure jobs. Of primary concern are:

BAP 1450-1, Access to Containment BAP 1450-2, Access to High Radiation Areas BAP 1450-3, Access to Reactor Cavity Incore Area BAP 1450-T2, Containment Entry Checklist (For Mode 1, 2, 3 and 4)

BAP 1450-3, " Access to Reactor Cavity Incore Area" is the primary procedure that pertains to this IE Information Notic The procedure includes various " Cautions" and " Notes" along with specific steps that i are required for reactor cavity incore area access. Two keys are required l for access to the area; the first is under the direct control of the ,

Production Superintendent and the second is under the direct control of i the Rad / Chem Superviso This matter was discussed with licensee personne They are aware of this Information Notice and of the continued problems in the industry ']

i regarding recurring events where workers are allowed to enter the reactor j cavity incore area when the incores are withdraw The licensee's J

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precautions and procedures appear adequate to prevent unauthorized personnel entry into the Reactor Cavity Incore Are No problems were note No violations or deviations were identifie . Unit 2 Startup Tests The inspector reviewed the results of two startup surveys for Unit 2 i completed in 198 SV 2.61.83 Radiation Surveys During Power Ascension conducted January 26-28, 1987 at 3% power. Test results were reviewed; no problems were noted. Test discrepancies j have been resolve ,

SV 2.61.83 Radiation Survey During Power Ascension conducted on March 7, 1987 at 48-52% power. Test results.were reviewed. More than 20 Radiation Base Points (RBPs)

exceeded the. acceptance level for neutrons. Test discrepancies are in the process of being resolve The completion of this test (100% power) and resolution of the discrepancies will be reviewed during a future inspections (455/87011-01).

No violations or deviations were identifie . Noble Gas Contamination __

During the past several months, a small number of plant workers, mostly security guards, have become contaminated with what appeared to be noble gas daughter products while walking through the plant. The contamination was detected by the IPM-7 whole body frisker. Investigation by Rad / Chem department determined the contamination to be daughter products of radon, an inert naturally occurring radioactive ga In response to the security guards radiological concerns, the licensee held short discussions about noble gas daughter product contamination and its attraction to polyester uniforms at all guard mounts during a 24-hour, 3-shift da According to the licensee, they will hold another session with the guards in the near  !

futur No violations or deviations were identifie . Allegation Followup Discussed below are four separate allegations / concerns brought to the attention of NRC Region III. These allegations were evaluated during this inspection, including reviews of procedures, radiation work permits (RWPs) and interviews with licensee and contract radiation protection staff l 10  ;

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. An anonymous telephone call was received in Region III from a contractor worker concerning the use of protective clothing at Byron Station. His concern was that conflicting instructions were given l to plant workers concerning protective clothing requirements. The i worker stated that to his knowledge no one had been contaminated l because of the conflicting instructions. The allegation is restated below along with a discussion of the inspector's findings (Allegation No. RIII-87-A-0026 (Closed)).

Allegation: Radiation protection technicians working in the RWP trailer tell workers the protective clothing requirements of RWP's, but other radiation protection technicians inside the plant (at the I job site) tell workers different protective clothing requirement l Discussion: During this inspection; the inspector verified, by a selective review of approximately 25 RWPs written for outage j activities, that RWPs for major work activities contain'an as.turisked '

caveat in the protective requirements section which gives control point radiation protection technicians discretion to modify the l protective clothing requirements when radiological conditions chang i For most work activities the protective clothing / equipment requirements at the job site are the same as specified by the RWP; however, changing conditions may require changes in protective requirements at the job site. After making any changes in requirements, control point technicians are directed to contact radiation protection supervision so the RWP can be modified if necessary. This is an acceptable practice. Because neither the caller's name or specific jobs were provided, the inspector could not judge the adequacy of the specific radiological protection provided. However, no problems were identified during the general review of protective clothing provided for work performe Finding: While the general allegation was substantiated, no violations of regulatory requirements were identified, and the licensee's practice of changing RWP protective clothing / equipment requirements in accordance with changes in job site conditions is acceptabl b. A contractor who was working for a firm doing work at Byron Station I visited Region III and expressed a concern over his unnecessary exposure to radiatio The individual contacted the Region III i Office on several subsequent occasions with additional radiation protection concerns. (Allegation No. RIII-87-A-0037(Closed)). J I

Allegation: The alleger was assigned to a job on an incorrect RWP 1 and thus was not provided with respiratory protection. Because of this mistake he was contaminated on his face and internally but no ROR was written by the licensee for the incident. He further stated that he had received excessive external exposur l l

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Discussion: The alleger indicated that he was assigned to assist l another work crew in the removal.of shot peening equipment from

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the Unit 1 containment area. The job in question involved hauling ;

a dust cup and filter, which were packaged in a sealed vinyl bag i inside a cloth bag; up from the containment 401' level to the {

426' level and placing them into a concrete lined drum. ~The alleger I stated that a worker at the 401' level was wearing a fullface respirator and rain gear while the crew he was working with on !

the 426' level were wearing neither. The alleger indicated that 1 a radiation protection technician (RPT) indicated they should be l wearing face masks (respirators), j l

. Review of the licensee RWPs showed two RWPs pertaining to the job to l which the alleger referred. RWP 70684 covered change out, replacing, and transfer of shot peening vacuum filters and dust cups for personnel on the 401' level. It required, in addition to a full set of protective clothing, a fullface respirator and a rain sui The respirator and rain suit were required-due to the high levels of removable contamination on the 401' level of containmen RWP 70625A covered moving, setup, and teardown of shot peening equipment, it was the RWP under which the alleger was working, and required a standard set of protective clothing including rubbers, coveralls, gloves and a hoo From the alleger's description it appears that the workers on the 401' and the 426' levels were dressed !

in accordance with their respective RWP requirements. There were no l RWP requirements for respirators; nor were there indications from surveys or air sample data that a need for respirators on the 426'

level existed; nor was there a need to write an ROR since the correct RWP was utilize Licensee personnel interviewed indicated that it is possible that the alleger was incorrectly informed subsequent to the job that he had been on the incorrect RWP; further review by both licensee and NRC personnel showed the alleger was on the correct RWP and was provided with appropriate protective equipment for his assigned wor Some personnel working on the other associated RWP (No. 70684)

were provided mock-up training and additional protective equipment (respirators) which were not required for personnel, including the 1 alleger, working under RWP 70625 The entire cloth bag and its contents were intended to be put in the drum. However, because the cloth bag would not physically fit into the drum, the inner vinyl bag was removed from the outer cloth bag and put in the drum. The alleger apparently had trouble untying the cloth bag, so the RPT removed the vinyl bag from the cloth bag and placed it in the drum, reportedly pushing the bag into the drum with his feet. The actions by the RPT in this event appear to have been appropriate under the circumstance __ - -

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l The alleger indicated that a rush of air passed his face when the l RPT pushed the bag containing the filter and dust cup into the j concrete lined drum. A frisk of the alleger's face initially showed apparent contamination and alarmed the frisker. According to licensee personnel this alarm was determined to be caused by high background in the area. However, the alleger was escorted to the l automatic whole body frisker (IPM-7), a whole body monitor with a greater sensitivity, and he passed through without an alar The alleger asked for and received a whole body count (WBC) to assess any possible uptake of radioactive materia Licensee records of the initial count showed a small amount of Co-60 (8 nanocuries of Co-60 which is equal to 0.7% of a body burden). A followup WBC after showering showed approximately the same results. The following day's WBC revealed nothing detectable above backgroun The presence of 8 nanocuries, or 0.7% of a body burden, detected on a whole body count is not indicative of a significant uptake, that nasal smears should have been taken, or that respiratory protection should have been worn. The NRC's 40 MPC-hour control level, which requires a report and corrective action to prevent recurrence, is approximately 55 nanocuries for Co-60. The NRC quarterly limit for internal Co-60 deposition (lung) is approximately 700 nCi. This limit corresponds roughly to the 1250 mrem NRC quarterly limit for external radiation exposure. Since the Co-60 initially detected on the whole body counts of the alleger apparently did not reach the lung and therefore was eliminated from his body relatively quickly, the dose for the internal Co-60 was equivalent to significantly less than 10 mrems external dos The alleger inferred that the 52 mrem (licensee's records show 42 mrem)

he received during the job was excessive. The administrative dose limit on RWP 70625A was 100 mre Previous transfers of filters and dust collector cups resulted in a 10-20 mrem average dose; however, i in this case the transfer was complicated by difficulty in untying i the draw string on the cloth bag which was necessitated because the concrete lined drum was undersized. The difficulty perhaps should have been anticipated; however, no significant internal or external <

exposure resulte No regulatory concerns were identifie Finding: The alleger's concerns that he was assigned to work under an incorrect RWP and therefore was not provided respiratory protection, i that an ROR should have been written, and that he received excessive l radiation exposure were not substantiated. He apparently received a -

small intake of radioactive material; however, the intake was well within regulatory limits and was not indicative of a significant exposure. Additional concerns with radiological work practices were expressed by the alleger. While, if valid, those concerns may represent less than perfect performance by licensee radiation protection personnel, they do not represent significant radiation i

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protection program deficiencies and therefore were not necessarily a reviewed in detail. No violations of regulatory requirements were )

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Allegation: The alleger stated that about one week prior to the !

previous incident involving transfer of the dust cup and filter l another boilermaker doing a similar job was on the wrong RW l l

Discussion: The RWP in question, RWP 70625A, sign-in sheets were reviewed for the time period in question. The worker named by the alleger was signed in on RWP 70625A a day before and two days after the alleger's inciden No record of the named individual working i under either RWP 70625A or RWP 70684 one week earlier was_foun The exposures recorded for this individual were 5 mrem and 20 mrem, respectively. This named worker apparently performed the same task as the alleger, was working on the right RWP, and also did not receive excessive exposure to radiatio Finding: The allegation was not substantiate Allegation: The alleger stated that he had been involved in an incident in October 1986 when he and two other contractors were assigned to clean a resin tank with high pressure water. The two l other workers and the RPT all wore respiratory protection while the alleger did no When a hose broke on the cleaning equipmen he was sprayed with water. The RPT wiped his eyes and sent him to the first aid statio Discussion: The licensee maintains a log of tanks cleaned, when they were cleaned, and workers who performed the cleaning. There are also RWPs written for each tank cleaning involving radioactive material. The above records were reviewed for the period of September through December 1986. The alleger's name did not appear in any of these records. The alleger was contacted in an attempt to clarify his allegation and the lack of his name in the licensee's log for tank cleanings. The alleger stated that he was not in the immediate area of the tank cleaning (tank room) but rather was stationed in the corridor outside of the room containing the tank (spent resin tank or concentrate storage tank) manning a communication line to an individual operating the pump supplying the high pressure cleaning water. The other individuals were all in the room containing the tank being cleaned. Since the corridor outside these tank rooms was not an airborne area and since clean demineralized water was being used to clean the tank, it does not appear that respiratory protection was necessary for the allege The hose that broke reportedly contained clean demineralized water -

and therefore did not present a radiological hazar The alleger did not recall that he was contaminated in the incident, which'is to be expected due to his job location and the use of clean demineralized j spray wate ;

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Finding: While the allegation appears to be true, no violations of regulatory requirements or other licensee improprieties were identifie Allegation: Babcock and Wilcox (B&W) remote control equipment to be used for Steam generator work, described as " Roger the Robot," wa delivered to Byron Station in a contaminated conditio When the equipment was unloaded the fuel building trackway was contaminate It was roped off and later cleaned u Discussion: " Roger the Robot" is remote control equipment used by B&W for steam generator work. Cases containing this equipment were found slightly contaminated externally upon arrival at Byron Station. Contamination up to 1000 dpm/100 cm2 was detected on the outside of the shipping containers. (Up to 22,000 dpm/100 cm2 removable contamination is permitted by DOT on the outside surface of shipping containers.) However, as a conservative precaution the shipping containers,' which were stored in the fuel building tracking, were roped off to prevent any spread of low level contaminatio The containers were then decontaminated. .No contamination was found in the fuel building trackwa Finding: The allegation was not substantiated, c. A Region III Senior Radiation Specialist received a telephone call from a radiation protection contract worker who had formerly worked at Byron during the Unit 1 outag The contractor said he had concerns about the mismanagement of the contractor radiation protection organization he had worked for during the refueling -

outag The subject of the call and the followup discussions are <

presented below (Allegation No. RIII-87-A-0046(Closed)). j

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Allegation: Respiratory protection policies were inadequat Respirators were overused which caused a slower work pace and longer ,

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time spent in radiation areas. There was not a firm policy on j respirator removal, thereby increasing the potential for personnel >

contamination. There were many complaints about the respirator I policy and respirator fatigue; but no corrective actions.

l Discussion: The licensee requires respirator users to don and

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remove their respirators at containment access contro This policy lj was established in order to better supervise respirator wearer donning and removing respirators (under the direction and observation- l of the access control point RPTs.) Based on discussions with licensee j and contractor personnel, the inspector found no evidence of worker R complaints concerning respirator use, removal or fatigue. It appeared the longer time spent wearing the respirator (to and from access control) was compensated for by more frequent break periods. No l regulatory concerns were identified. While the inspector was unable i

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to conclude that. respirators were over used thereby increasing radiation exposures, he discussed this matter with the licensee, ,

stressing that overuse of respirators can increase radiological and I nonradiological hazards, and therefore respirator use should be I limited to those situations when engineering controls are not '

practicable to limit airborne radioactivit Finalng: In general the allegation of inadequate respiratory policy was not substantiated. This is a subjective area where varying implementation methods can be used to achieve the goal of limiting internal exposures. While the licensee may not have always utilized l the best respiratory practices, their practices were not in l violation of regulatory requirement ]

j Allegation: Radiation protection technicians (RPTs) were given work l assignments inconsistent with their qualification j Discussion: The alleger gave two specific examples. The first being an administrative overexposure in the 1A Letdown Heat Exchanger Room on March 24, 1987, which he alleges was caused by.a Senior RPT turning the job over to an unqualified Junior RPT with the approval of  !

management. This administrative overexposure is discussed further in Section 18 of this report. The Senior RPT involved has been terminated and was not interviewed. However, discussions with other l contract RPTs, CECO Radiation Chemistry Technicians (RCTs), and 1 managers of both organizations did not substantiate the allegation l that the job was turned over to an unqualified Junior RPT. The second l example was that an unnamed RPT left his work area when his digidose '

alarmed at 80 mrem but reported 99 mrem as his dose for the jo Station procedures require both Self Reading Dosimeter (SRD) and digidose readings to be recorded. The higher of the two is used to limit further dose until TLD results are receive The 99 mrem was presumably the SR0 recorded dos Since SRDs typically read high and l the individual may have incurred some additional dose exiting the area '

after his digidose alarmed, such variation is not unexpecte The RPT did not exceed the administrative limit set for the jo A general allegation was also made that Senior and Junior RPTs do the same work, only the pay rate differs. The licensee maintains qualification sheets on all contract RPTs. The qualifications are based on the RPT's experience, training, and oral and written examinations. The alleger did not name specific individuals; however, no evidence was found that showed RPTs, including control point technicians, were doing work for which they were not qualifie Finding: The allegation was not substantiate Allegation: Supervision of contract RPTs was inadequate.

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l 0i_scussion: No examples were given by the allege The inspector l discussed this matter with selected contract RPTs and their {

supervisors. These individuals did not support the allegatio I Finding: Due to the general nature of the allegation and' lack.of supporting examples this allegation could not be substantiate (See Summary Comment below.)

Allegation: Coordination between licensee and contracted RPTs was poo Discussion: Since no specific examples were given this matter was discussed with the management of the station radiation protection organization and first line managers of work groups. In general the individuals indicated that they felt the coordination of licensee and contract RPTs was very good. Additionally, the inspector's observations during his inspections of refueling activities indicated cooperation between the licensee and the contractor RPTs was acceptabl Finding: Due to the general nature of the allegation and lack of supporting examples this allegation could not be substantiate (See Summary Comment below.)

Allegation: Often there were inadequate or no ALARA pre-job briefings given before potential big dose tasks were begu Discussion: The alleger provided one example involving a radiography exposure on or about March 25, 1987, to support his allegation. He stated that no ALARA pre-job briefing accompanied the radiography'and the containment was evacuated inside the bioshield (missile shield)

because he, on his own initiative, alerted the containment RPTs shortly before the radiography source was exposed. While radiological safety for radiography is the regulatory responsibility of the licensed radiographer, licensee records indicate that the licensee also took measures to control radiological safety for the radiography operation on March 23, 198 An RWP was initiated for the job and an ALARA

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checklist completed. The ALARA checklist and RWP indicated that a l-more extensive ALARA review was not needed due to the limited potential for personnel doses; additional shielding was recommended and reportedly installed in the vicinity of "D" steam generator to allow work at that location to continue during the radiography; other affected areas were to be evacuated. This action by the licensee appears to have been appropriate. Radiography is not the type activity for which pre-job briefings or ALARA reviews are normally conducted since only the  ;

radiographer and his assistant (s) are normally involved. Other l personnel are evacuated from areas of potentially high dose rate j According to licensee personnel interviewed, physical movement of l the radiography device by the radiographer onsite was accompanied l l

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by RPT's since, even shielded, the radiography source created high enough radiation fields to alarm sensitive plant radiation monitors, ,

and therefore the licensee RPT foreman was aware of the use of the l radiography source. Licensee personnel denied that the alleger )

precipitated evacuation of personnel during the radiography operation l l

The inspectors general review of outage ALARA pre-job reviews and briefings'found no problems. Work activities involving significant dose potential appear to have been adequately reviewed and pre-job briefings conducte )

Finding: The allegation concerning inadequate pre-job briefings was not substantiated based on the example given by the alleger; nor did the inspector's general review of outage ALARA pre-job reviews and briefings identify any significant problem The inspector was also j unable to confirm the validity of the alleger's claim to have been '

responsible for causing evacuation of personnel from an area of significant radiological hazar (See Summary Comment below.)

Summary Comment: Several of the alleger's concerns could not be substantiated because of a lack of specific examples. Subsequent )

attempts to cor, tact the alleger were unsuccessful. While the inspector's general review of the areas of concern did not disclose any significant problems, it is possible that if poor management of the contractor radiation protection program existed as alleged, it i may have contributed to the apparent high total dose for the outage. As noted in Section 8 above, the matter of exposure control for the outage will be reviewed further during a future inspectio d. A former worker at Byron Station called Region III with a concern about the adequacy of radiation safety procedures and practices utilized during the maintenance outage (AMS No. RIII-87-A-0050).

Allegation: Employees were required to enter a radiation controlled area earlier than necessary and were unnecessarily exposed to radiatio Discussion: The alleger was contacted but did not supply any specific examples (dates, times locations, other workers involved, or radiation levels) to substantiate this alleged shortcomin This i allegation was reviewed in general; no evidence was found to support )

i l Finding: Due to the general nature of the allegation and lack of supporting examples this allegation could not be substantiated. (As noted in Section 8 above, the matter of general exposure control for the outage will be reviewed further during a future inspection.)

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18. Radiation Exposure Exceeding Administrative Limits i

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On March 23, 1987, a contract worker received a radiation exposure in excess of his administrative limit of 500 mrem whole bod The worker received a dose of about 720 mrem (whole body) while working in the IA Letdown Heat Exchanger Room. The worker was part of a crew whose task was to clean the heat exchanger flange and bolt holes, install a gasket and install the tube bundle into the shel In addition to the normal dosimetry, the RWP required a. high range self reading dosimeter (SRD)

and an electronic (digidose) dosimeter. Prior to installation, the tube bundle was covered with lead blankets and plasti It was necessary to remove the lead blankets and the plastic to slide the gasket over the tube bundle. Radiation reading of the tube bundle with the lead blankets in place were 300-350 mr/hr; with the lead removed the !

radiation was 850-1000 mr/hr. To facilitate the installation of the gasket and the insertion of the tube bundle one worker was in closer proximity to the tube bundle than were his fellow workers. The worker indicated that neither he nor his co-workers heard his digidose begin alarmin They discovered the alarming digidose upon completion of.their work and exiting the room. The contract radiation protection technician (RPT) was monitoring the crew from the doorway and apparently based his exposure time estimates on dose rates taken of the tube bundle when it was shielded by the lead blankets. The RPT stated the noise in the room also prevented him from hearing the worker's digidose alarm. ' Based on what work the crew told him they were going to do and the dose rate he thought they would be in the RPT instructed the workers to exit the room either when their dosimeters alarmed or he would stop work in an hour and a hal The licensee's investigation of the incident concluded:

• The RPT had a recent survey of the room with dose rates showing the unshielded tube bundle on which he should have based his time estimate for dose control but instead he used an older survey showing the tube bundle in a shielded conditio * The RPT should have periodically checked workers exposure by reading the SRDs or the digidose * The RPT should have observed the workers every 15-20 minutes which would have shown him the possible increased exposure possibilitie * The administrative overexposure was caused primarily by the inattentiveness of the RP l The RPT had been evaluated as a competent Senior Technician and had recently been commended for doing an excellent containment surve However, he apparently failed to perform adequately on this jo l, l The RPT's employment was terminated March 25, 1987 because of this )

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The lice'nsee's investigation and resolution of this matter' appears adequat This appears to be an-isolated incident rather than a programmatic breakdow No violations or' deviations-were identifie . Exit Meeting-The inspector met with licensee representatives (denoted.in Section 1)'

on March 19, April 10 and May 27, 1987. The inspector discussed the scope and findings;of the inspection. The inspector also-discussed the likely informational _ content of'the inspection report with regard to-documents or processes reviewed:during the inspection. The license identified no such documents / processes as proprietary. In response to certain matters discussed.by the inspector, the' licensee: Acknowledged the-inspector's comments.concerning. improving communications'between radiation protection and contractor workers to ensure workers are familiar with the reaso'ns.for' protective requirement Acknowledged the inspector's . comments concerning the ALARA group -

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