ML051520247
| ML051520247 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/24/2005 |
| From: | Kenneth Riemer Division of Reactor Safety III |
| To: | Louden P NRC/RGN-III/DRP/RPB7 |
| References | |
| FOIA/PA-2004-0282 IR-04-003 | |
| Download: ML051520247 (8) | |
See also: IR 05000266/2004003
Text
A UNITED STATES
9 C0
NUCLEAR REGULATORY COMMISSION
-.
Region III
LISLE, ILLINOIS 60532
MEMORANDUM TO: Patrick Louden, Chief (U /C
Projects Branch 7
Division of Reactor Projects
FROM: Kenneth Riemer, Chief
Plant Support Branch i
Division of Reactor Safety
SUBJECT: POINT BEACH NUCLEAR PLANT, UNITS 1 & 2
DRS INPUT TO INTEGRATED REPORT 50-266/04-03;
50-301/04-03
Attached is the report input for Point Beach Nuclear Plant, Units 1 and 2, Inspection
Report 50-266/04-03; 50-301/04-03. Specifically, this report focused on occupational radiation
safety during the recent U1R28 refueling outage as related to the licensee's radiological access
control and ALARA programs. I have reviewed this input and have determined it is ready for
distribution to the licensee and dissemination to the public.
Attachment: Input to Inspection Report 50-266/04-03;
50-301/04-03
CONTACT: Ryan D. Alexander, DRS
(630) 829-9853
DOCUMENT NAME: G:DRS\Point Beach Input to Report 04-03 RDA.wpd
To receive a copy of this document, Indicate in the box: C * Copy without attachmentlenclosure E = Copy with attachment/enclosure N * No copy
lOFFICE lR111 W] R~ll L
I8}i
NAME RAlexander:sd ?gn KRiemer 1,4
DATE 05/1S104 05P /04
OFFICIAL RECORD COPY
0-9
Cover Letter
/ No input, no significant findings.
Input below, no color or green findings were identified.
Title Page
Inspector: R. D. Alexander, Radiation Specialist
SUMMARY OF FINDINGS
ADAMS boilerplate - Inspectable area: Radiation Protection
Modify second paragraph as follows:
The baseline inspection was conducted by a regional radiation specialist inspector.
A. Insnector-ldentified and Self-Revealed Findings
Cornerstones: Occupational and Public Radiation Safety (OS)
None
B. Licensee-Identified Violations
None
REPORT DETAILS
2. RADIATION SAFETY
Cornerstone: Occupational Radiation Safety (OS)
20S1 Access Control to Radiologically Significant Areas (71121.01)
.1 Plant Walkdowns and Radiation Work Permit Reviews
a. Inspection Scone
The inspectors reviewed licensee controls and surveys for selected radiation areas, high
radiation areas and airborne radioactivity areas, as available, in the following
radiologically significant work areas within the plant and reviewed work packages which
included associated licensee controls and surveys for these areas to determine if
radiological controls (including postings and barricades) were acceptable:
- Primary Auxiliary Building; and
- Unit 1 Containment (all levels).
The inspectors reviewed the radiation work permits (RWP) and work packages used to
control work in these areas and other high radiation work areas to identify the work
control instructions and control barriers that had been specified. Electronic dosimeter
alarm set points for both integrated dose and dose rate were evaluated for conformity
with survey indications and plant policy. Workers were interviewed to assess their
knowledge of the actions required when their electronic dosimeters noticeably
malfunctioned or alarmed.
The inspectors walked down these areas to verify that the prescribed RWPs,
procedures, and engineering controls were in place, that licensee surveys and postings
were complete and accurate, and that air samplers (if necessary) were properly located.
The inspectors reviewed the RWPs and surveys for the steam generator nozzle dam
installation and eddy current testing activities which had the potential for creating an
airborne radioactivity area. The inspectors reviewed the RWPs to verify barrier integrity
and engineering control contingency plans were in place and to determine if there was a
potential for individual worker internal exposures of greater than 50 millirem committed
effective dose equivalent. This and other work activities/areas having a history of, or the
potential for, airborne transuranic isotopes were evaluated to verify that the licensee had
considered the potential for transuranic isotopes and provided appropriate worker
protection.
The inspectors assessed the adequacy of the licensee's internal dose assessment
process by reviewing personnel contamination event logs (and associated dose
assessments) for the refueling outage. As of April 21, 2004, no personnel
contamination events had resulted in dose assignments of greater than 10 millirem
committed effective dose equivalent.
These reviews represented four inspection samples.
b. Findings
No findings of significance were identified.
.2 Job-In-Progress Reviews
a. Inspection Scope
The inspectors observed the following four activities that were being performed in
radiation areas, airborne radioactivity areas, or high radiation areas for observation of
work activities that presented the greatest radiological risk to workers:
- 1B Reactor Coolant Pump Motor Lift;
- Reactor Vessel Head Lift; and
- Cono-Seal Bullet Replacement.
The inspectors reviewed radiological job requirements for these four activities, including
RWP and work procedure requirements, and attended ALARA pre-job briefings.
Job performance was observed with respect to these requirements to verify that
radiological conditions in the work areas were adequately communicated to workers
through pre-job briefings and postings. The inspectors also verified the adequacy of
radiological controls (including required radiation, contamination, and airborne surveys);
radiation protection job coverage (including audio/visual surveillance for remote job
coverage); and contamination controls.
Radiological work in high radiation work areas having significant dose rate gradients
was reviewed to evaluate the application of dosimetry to effectively monitor exposure to
personnel and to verify that licensee controls were adequate. In particular, the steam
generator eddy current activities and cono-seal bullet replacement involved evolutions
where the dose rate gradients were severe which increased the necessity of providing
multiple or repositioned dosimetry and/or enhanced job controls.
These reviews represented three inspection samples.
b. Findings
No findings of significance were identified.
.4 Radiation Worker Performance
a. Inspection Scope
During job performance observations, the inspectors evaluated radiation worker
performance with respect to stated radiation protection work requirements and
evaluated whether workers were aware of the significant radiological conditions in their
workplace, the RWP controls and limits in place, and that their performance accounted
for the level of radiological hazards present.
These reviews represented one inspection sample.
b. Findings
No findings of significance were identified.
.5 Radiation Protection Technician Proficiency
a. Inspection Scope
During job performance observations, the inspectors evaluated radiation protection (RP)
technician performance with respect to radiation protection work requirements and
evaluated whether they were aware of the radiological conditions in their workplace, the
RWP controls and limits in place, and if their oversight of radiological activities was
consistent with their training and qualifications with respect to the radiological hazards
and work activities.
These reviews represented one inspection sample.
b. Findings
No findings of significance were identified.
20S2 As Low As Is Reasonably Achievable Planning And Controls (ALARA) (71121.02)
.1 Inspection Planning
a. Inspection Scone
The inspectors reviewed the U1 R28 refueling outage work scheduled during the
inspection period and associated work activity exposure estimates for the following four
work activities which were likely to result in the highest personnel collective exposures:
- U1R28 RP Coverage [RWP No. 04-104];
- Bottom Mounted Instrumentation Inspection [RWP No. 04-133];
- Nozzle Dam Installation/Removal [RWP No. 04-141]; and
- Steam Generator Eddy Current Testing [RWP No. 04-142].
These reviews represented one inspection sample.
b. Findings
No findings of significance were identified.
.2 Radiological Work Planning
a. Inspection Scope
For those activities identified in Section 20S2.1, the inspectors reviewed the ALARA
evaluations, exposure estimates, and exposure mitigation requirements in order to verify
that the licensee had established procedures, and engineering and work controls that
were based on sound radiation protection principles in order to achieve occupational
exposures that were ALARA.
The interfaces between radiation protection, operations, maintenance, planning,
scheduling, and engineering groups were evaluated by the inspectors to identify
interface problems or missing program elements. The inspectors evaluated if work
activity planning included consideration of the benefits of dose rate reduction activities
such as shielding provided by water filled components/piping, job scheduling, and
shielding and scaffolding installation/removal activities. Finally, the inspectors evaluated
the integration of radiological job planning activities (pre-job ALARA reviews) into work
procedure and RWP documents.
These reviews represented three inspection samples.
b. Findings
No findings of significance were identified.
.3 Verification of Dose Estimates and Exposure Tracking Systems
a. Inspection Scope
The inspectors reviewed the licensee's process for adjusting exposure estimates or
re-planning work, when unexpected changes in scope, emergent work or higher than
anticipated radiation levels were encountered. This review included a determination if
adjustments to estimated exposures (intended dose) were based on sound radiation
protection and ALARA principles, rather than adjustments to account for failures to
adequately control the work. The frequency of these adjustments was reviewed to
evaluate the adequacy of the original ALARA planning process. In particular, the
inspectors reviewed and discussed with the RP staff the In-Progress ALARA reviews
conducted for the bottom mounted instrumentation inspection and steam generator
nozzle dam installation/removal RWPs.
These reviews represented one inspection sample.
b. Findings
No findings of significance were identified.
.4 Job Site Inspections and ALARA Control
a. Inspection Scope
The inspectors observed the four activities identified in Section 20S1.2 that were being
performed in radiation areas, airborne radioactivity areas, or high radiation areas for
observation of work activities that presented the greatest radiological risk to workers.
The licensee's use of engineering controls to achieve dose reductions was evaluated to
verify that procedures and controls were consistent with the licensee's ALARA reviews,
that sufficient shielding of radiation sources was provided for and that the dose
expended to install/remove the shielding did not exceed the dose reduction benefits
afforded by the shielding.
These reviews represented one inspection sample.
b. Findings
No findings of significance were identified.
.5 Radiation Worker Performance
a. Inspection Scope
Radiation worker and RP technician performance was observed during work activities
performed in radiological areas that presented the greatest radiological risk to workers.
The inspectors evaluated whether workers demonstrated the ALARA philosophy in
practice by being familiar with the work activity scope and tools to be used, by utilizing
ALARA low dose waiting areas, and that work activity controls were being complied with.
Also, radiation worker performance was observed to determine whether individual
training/skill level was sufficient with respect to the radiological hazards and the work
involved.
These reviews represented one inspection sample.
b. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES (OA)
40A6 Meetings
.2 Interim Exit Meetings
Interim exit meeting was conducted for:
- Occupational Radiation Safety ALARA and access control programs inspection
with Mr. G. VanMiddlesworth on April 23, 2004.
KEY POINTS OF CONTACT
Licensee
G. VanMiddlesworth, Site Vice President
S. Thomas, Radiation Protection Manager
B. Carberry, Radiation Protection - ALARA
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened. Closed, and Discussed
None
LIST OF DOCUMENTS REVIEWED
20S1 Access Control to Radiologically Significant Areas
CAP 055366; Worker Received Electronic Dosimeter Dose Alarm; dated April 5, 2004
CAP 055587; SIG Nozzle Dam Installation Dose Exceeded Estimate; dated April 11,
2004
CAP 055951; Incore Thermocouple Guide ("Bullet Nose") Inadvertently Lifted with
Reactor Head; dated April 22, 2004
CAP 055986; Evaluate Use of RP Greeter at Containment Hatches During Outage
Periods; dated April 23, 2004 [NRC-Identified Issue]
HP 3.2; Radiological Labeling, Posting, and Barricading Requirements; Revision 39
(January 23, 2004)
HPIP 3.52; Airborne Radioactivity Surveys; Revision 30 (June 20, 2003)
PCE No. 04-02-018; Personnel Contamination Event (PCE) Report; dated April 8, 2004
PCE No. 04-02-019; Personnel Contamination Event (PCE) Report; dated April 9, 2004
PCE No. 04-02-020; Personnel Contamination Event (PCE) Report; dated April 8, 2004
RWP No.04-104; RP Coverage; Revision 0
RWP No.04-113; Reactor Head Lift; Revision 0
RWP No.04-122; Reactor Coolant Pump Maintenance; Revision 0
RWP No.04-133; BMI Inspection; Revision 0
RWP No.04-141; Nozzle Dam Install/Remove; Revision 0
RWP No.04-142; Steam Generator Eddy Current Testing; Revision 1
vX - *
RWP No.04-171; NRC Walkdowns for U1R28; Revision 0
RWP No.04-182; Replace Cono-Seal Bullet; Revision 0
20S2 As Low As Is Reasonably Achievable Planninq And Controls (ALARA)
ALARA Review No. 2004-0012; Level 3 Pre-Job ALARA Review for BMI Inspection
(RWP No.04-133); dated April 6, 2004
ALARA Review No. 2004-0017; Level 3 Pre-Job and In-Progress ALARA Reviews for
Nozzle Dam Install/Remove (RWP No.04-141); dated April 2 and 11, 2004
ALARA Review No. 2004-0018; Level 3 Pre-Job ALARA Reviews (Revisions 0 and 1)
for Steam Generator Eddy Current Testing (RWP No.04-142); dated March 16 and
April 12, 2004
ALARA Review No. 2004-0027; Level 3 Pre-Job ALARA Review for Replace Cono-Seal
Bullet (RWP No.04-182); dated April 22, 2004
JIT Briefing Activity MM-8480D3; Just In Time Briefing for Reactor Vessel Head Lift;
dated April 21, 2004
HPIP 4.40; TEDE ALARA Evaluation; Revision 0 (February 6, 2002)
NP 4.2.1; ALARA Program; Revision 11 (November 19, 2003)
Point Beach Nuclear Plant U1R28 Estimated RWP Dose Spreadsheet; dated April 6,
2004
TEDE ALARA Evaluation for RWP 04-141; dated April 3, 2004
TEDE ALARA Evaluation for RWP 04-182; dated April 22, 2004
LIST OF ACRONYMS USED
ALARA As Low As Is Reasonably Achievable
U1R28 Point Beach Unit 1's 28th Refueling Outage
RP Radiation Protection
RWP Radiation Work Permit