ML051520248

Draft of Revision 1 of Inspection Input to Point Beach Nuclear Plant, Units 1 & 2 DRS Input to Integrated Report with R. Alexander and K. Riemer Notes

ML051520248
Person / Time
Site:	Point Beach
Issue date:	05/24/2004
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: ML051520248 (14)

Text

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UNITED STATES

-C 0 NUCLEAR REGULATORY COMMISSION P.0 , "L.r Region III - -.

LISLE, ILLINOIS 60532 -

June XX, 2004 MEMORANDUM TO: Patrick Louden, Chief Projects Branch7 /

Division of Reactor Projects FROM: Kenneth Riemer, Chief MA/

Plant Support Branch 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 E ach Lear Plant, Units 1 and 2, Inspection Report 50-266/04-03; 50-301/04-03. Specific:ally, focused on occupational radiation safety during the recent U1 R28 refueling ou ,\Jted to the licensee's radiological access control and ALARA programs. I hay tnis nput and have determined it is ready for distribution to the licensee and dissgi 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\Pt Beach Input to Report 04-03 RDA (REV 1).wpd To receive a copy of this document, Indicate lithe box: 'C Copy without attachmnent/enclosure E

• Copy with attachmentenclosure N

• No copy OFFICE Rill I Rill I I I NAME RAlexander: KRiemer DATE 06/ /04 06/ /04 l .

OFFICIAL RECORD COPY 40-1

Cover Letter

/ _ No input, no significant findings.

I/ / Input below, no color or green findings were identified.

^ / This report input documents one NRC-Identified finding of very low safety significance (Green), which was determined to involve a violation of NRC requirements. However, l K because of the very low safety significance and because the issue is entered into your corrective action program, the NRC Is treating this issue as a Non-Cited Violations (NCV) consistent with Section VL.A of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies t o the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington DC 20555-0001; and to the Resident Inspector at the Point Beach Nuclear Plant.

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. Inspector-ldentified and Self-Revealed Findings Cornerstones: Occupational Radiation Safety (OS)

Green. A finding of very low safety significance and an associated Non-Cited Violation were identified through an NRC-identified event, when on April 9, 2004, while installing steam generator nozzle dams, licensee staff increased supplied breathing air pressure in excess of procedural requirements while attempting to mitigate lost or diminished air flow to contract workers who were utilizing continuous flow, supplied air respirator "bubble hoods." The inspectors determined that the licensee failed to meet the requirements of 10 CFR 20.1703, when the licensee increased the air line pressure in excess of the procedural guidance, which further resulted In the licensee utilizing a respiratory protection device contrary to its National Institute for Occupational Safety and Heath (NIOSH) certification.

This issue was determined to be more than minor in that it could reasonably be viewed as a precursor to a significant event, and if left uncorrected would become a more significant safety concern. Also, the issue involves conditions contrary to licensee procedures and NRC regulations which impact protective equipment related to mitigating worker dose. Based on the inspectors' review of dose rates and contamination levels in the steam generator bowls, and worst case stay time estimates within the bowls, there were no radiological exposures in excess of

regulatory limits, nor was there a substantial potential for an overexposure.

Therefore, the finding was of very low safety significance. One Non-Cited Violation for the failure to maintain and use procedures for respiratory protection device use and utilizing a respiratory protection device contrary to the NIOSH certification in accordance with 10 CFR 20.1703 was identified. (Section 20S1.2)

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 Scope 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 radiatiorr 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 (ifnecessary) 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;

• Steam Generator Eddy Current Testing;

• 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 radi6logical 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. This included a review of the radiological

_-,,,"controls employed and resulting potential dose consequences related to the installation of steam generator nozzle dams early in the refueling outage. The inspectors completed their assessment ofthe nozzle dam installati on activities by conducting an in-office review of the-ifcensee's root cause evaluation for the evolution during the week of May 24, iUU.4 --

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 Introduction One NRC-identified Green finding and an associated Non-Cited Violation (NCV),

were identified when, on April 9, 2004, while installing steam generator nozzle

dams, licensee staff increased supplied breathing air pressure in excess of procedural requirements while attempting to mitigate lost or diminished air flow to contract workers who were utilizing continuous flow, supplied air respirator "bubble hoods."

Description On April 9, 2004, during the Unit 1 refueling outage, installation of steam generator nozzle dams was to take place per Work Order 0400042. -The-previous day the activity was identified as a Critical Path activity. The work commenced at 0417 hours0.00483 days <br />0.116 hours <br />6.894841e-4 weeks <br />1.586685e-4 months <br /> on April 9 (approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> into a 12-hour shift), following a

-- pre-job brief which Nuclear Oversight personnel noted as "less than adequate ,

due to poor communications, failure to document brief on an approved form, and lack of interaction of personnel at the brief." However, Nuclear Oversight personnel apparently did not raise these concerns to station management until.

after the shift had completed.

Upon start of the work, contractor personnel who were tasked with performance of the nozzle dam Installation assembled on the 8' elevation of Containment, and were dressed per the requirements of RWP 04-141. The ALARA plan and TEDE ALARA evaluation for RWP 04-141 determined that " the use of an airline/hood for this work is not ALARA. However, the Increase in dose due to the use of the airline/hood does not negate Its use when accounting for the additional time and energy needed to address the effects of external and internal contamination that will result when the airline/hood Is not used." A' Therefore, the RWP dress requirements included the use of continuous flow, supplied air respirator "bubble hoods" for whole body entries into the steam generator bowl. The "bubble hoods" and air lines had been staged at the 8' /g elevation and on the steam generator platforms at approximately 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> on April 7, 2004J)Athe-86 elevaion "bubbleohseds )

with assistance of radiation protection (RP) personnel, though the procedure . LMII HPIP 4.58 "Is-uance of Respiratory-Equipment!Land.associated-documentation required for the Issuance of the "bubble hoods" was not performed by the RP.e

,/J

) Up1on donning the "bubble hood," at least one contract personnel expressed Gconcerns about low air pressure within the hood while connected at the 8'

/7?

elevation. RP staff discussed this concern with the contract personnel, and expressed opinions that there would be more air flow at the steam generator platform level, though no formal Investigation of the air flow concern was performed. Subsequently, contract personnel and RP personnel proceeded to the fil>steam generator platforms. Upon arrival, the first contract worker connected to a

• foot air line on the platform for his entry into the 'B' steam generator and again he expressed concern about the air flow. However, he proceeded to prepare to enter the steam generator to install the 'B' cold leg nozzle dam, and requested that the RP technician on the platform wet him down with a liquid (409) cleaner),

in order to lubricate him and to facilitate the contract worker's entry into the steam generator. Neither station nor contractor procedures address the use of a wetting liquid to facilitate steam generator entry.

The RP technician wet down the contract worker, and he entered the 'B' steam generator. During the contractor's stay time in the generator (1:48 minutes), he noted continued dissatisfaction with the apparent low air flow in the hood and

dissatisfaction with his job progress. The worker exited the generator based on his concern with the low air flow, and the RP technician cut him out of the "bubble hood", which resulted In a minor personnel contamination event (PCE) documented by RP staff. (Of note, during a supervisory review of the PCE one day later, it was Identified thatrhA RP staff which responded to the worker's PCE did not perform nasal smears of directed by station procedures for this type of PCE. The licensee capture this-isue into its corrective action program as CAP 55565.)

The quick disconnect "Snap-Tite" connection from the "bubble hood" hose to the regulator air hose was examined by the RP staff and no obvious failures were identified. The RP Manager contacted the Outage Control Center (OCC) regarding a possible loss of breathing air, though the issue was not lqgged by Operations until 16 minutes after the contract worker had left the platform area. The RP technicia and RP supervision discussed the air pressure Issue in the field, and 1 If supervision 'pproved an Increase In the air pressure to support the needs of the I." _

contract workers. Subsequently, the RP technician increased the air pressure from a range of 20- 28 pounds per square Inch gage (psig) to approximately 60 -

64 psig. The increase of the air pressure violated HPIP 4.58, Step 4.5.7, which states "adjust air supply pressure so that air flow is between 6 and 15 cubic feet per minute [cfm]. For an air line length of 50 feet, a pressure range of 20 to 28 psig corresponds to a flow rate of 6 to 15 cfm."

Ten minutes after the first contract worker exited the steam generator due to diminished air flow, a second contract worker attempted to access the 'B' steam

-I generator (with the increased air flow into the "bubble hood"), but failed to enter -

.I t the generator after two attempfsdue in part to the individual's size; The second contract worker also requested the RP technician to wet him down. After doi LI so, the second contractor successfully entered the steam generator with ph ical assistance from the RP technician and another contractor on the platform. while inside the bowl (for 1:18 minutes), the contractor-reaizsdth-at-h-h-ad lost air flow, but he continued working until he_"believed he had 2 or.3 good breaths" at which point he exited the steam generator. Upon his exit, the contractor was cut out of the "bubble hood" which resulted In a documented PCE (though again nasal smears were not completed as required). The RP staff at the platform deterned that the "Snap-Tite" fitting on the hood hose had disconnected resultingihe ini the-loss of air flow.

RP personnel and the NMC project leader discussed allowance of the next contractor to complete the 'B' nozzle dam installations for approximately five minutes in the field, however, the OCC was not contacted relative to this second air line issue. After the air pressure was verified as acceptable and the air line connection was challenged, a third contract worker entered the steam generator and completed installation in approximately one minute.

During installation activities on the 'A' steam generator, two additional loss of air incidents occurred. In one instance, the contractor had partially entered the bowl when the "Snap-Tite" fitting contacted the manway and disconnected. The contractor immediately exited, the air line was reconnected, and the contractor re-entered the steam generator to complete the installation. In the second instance, an air supply line pinched against and was cut by equipment staged on the platform, resulting in diminished air flow. The RP technician taped the cut air line and asked the contractor if air flow was acceptable. The contractor indicated air

flow was acceptable several times and completed his installation activities. In neither occurrence was work stopped or investigated. At this point, an NRC inspector who was observing the nozzle dam installation activities via video monitors raised concerns about the breathing air problems to site management.

Subsequently, a formal investigation was initiated by the licensee which led to a formal root cause evaluation.

The licensee's Root Cause Evaluation (CAP55527/RCE 253, completed May 22, 2004) detailed more than 20 Inappropriate actions during the steam generator nozzle dam installation activities. In addition to the performance issues detailed above, the licensee's RCE identified other significant performance issues, including:

• The work planner did not use procedure NP 1.1.7, "Mhnaging Work Activity Risk," and associated forms in developing the work order for the nozzle dam installation/removal. Specifically, the work was categorized as "High -

Multiple Risks," which requires that 12 compensatory actions be considered in developing the work plan, including, in part, a look-ahead plan, utilization of high-risk pre-job briefing process, supervisory/management attendance at pre-job briefs, and critical step identification. However, no mitigation or assessment of risk for this activity was identified by the licensee's RCE.

• The April 3, 2004, mockup training for the nozzle dam activities was conducted in "street clothes" and did not (1) address the dress requirement concerns the contract workers raised during the job evolution; (2) identify air pressure/flow issues realized during the job evolution; (3) identify air line connection failures experienced by two workers during the evolution; and (4) identify issues surrounding two individuals which requested to be "wet down" to assist their entry into the steam generator bowl.

• Three different RP department evaluations of CY 2003 Operating Events (OE), relative to the loss of supplied breathing air due to separation of air line quick disconnect fittings, failed to adequately assess the station's susceptibility to similar occurrences. Specifically, OE031454, OE048685, and OE01 0321 were evaluated by the licensee but were closed for reasons including "fittings are from a different manufacturer," "fittings are taped,"

and "procedures and controls are adequate to minimize susceptibility to this event." However, the fittings described in the OE are of similar design as those used for "bubble hood" air line connections at Point Beach and no actions were taken to physically challenge the "Snap-Tite" fitting during the evaluations.

The licensee's evaluation identified the root cause of these events as:

Oversight by Supervisors/Managers during work planning development and task execution did not assure compliance with procedures and processes, resulting in an inadequate work plan being developed and approved for use.

Additionally, the licensee identified four significant contributing causes:

(1) Work Order Processing per NP 10.2.4 and Outage Management Planning per NP 10.2.1 does not include logic ties (IF this, THEN that) to drive use of appropriate procedures during work plan development.

(2) Program Engineering personnel and Radiation Protection personnel did not use and/or follow Work Order Processing, Risk Assessment, Briefing, or Radiation Protection procedures in preparing for and during execution of the steam generator nozzle dam project.

(3) Training for steam generator nozzle dam Installation was not adequate to identify the error-likely situations that existed upon the start of work.

(4) Communications to the OCC of safety significant events was not delivered and Nuclear Oversight identification of an inadequate briefing was not delivered in a timely or effective manner.

The licensee's corrective actions Included: (1) site-wide stand-down to discuss these and related events with station/contractor staff; (2) independent team assessment the station's procedures and processes relative to the use of supplied air respiratory devices (and implementation of procedural and equipment changes, as necessary); (3) development of a complete nozzle dam removal plan in accordance with the applicable work planning procedures, including NP 10.2.1; (4) full mock-up training for the nozzle dam removal, including bubble hood use and air pressure requirements; and (5) development of a specific procedure for nozzle dam installation/removal activities, including lessons learned, supervisory oversight requirements, stop work authority, communications protocol, and external operating experience. <v During the NRC inspectors' in-office review of the RCE, then identified that when the RP staff increased the air line pressure to approximbtzv 60 psig, the-resuiting lowr_ enj'the,"bubble-hi)vod ld have i aVproxImateIyi324 f The National Institute for Occupational Safety and Heath (NIOSH) certification requirements for continuous flow, supplied air respirator "bubble hoods" are described in 42 CFR 84, Subpart J. Specifically, Table 8 of Subpart J, requires, in part, that for the "bubble hoods" used during the evolution (Type C, loose fitting hood), the air supply hose with air regulating valve shall permit a flow of not less than 6 cfm, and the maximum flow shall not exceed 15 cfm. Therefore, in addition to the procedure violated, the inspectors determined that when the RP staff Increased the air pressure to approximately 60 psig, the licensee was utilizing a respiratory protection device contrary to the NIOSH certification for the device, which is a violation of 10 CFR 20.1703,5 se ofividual respiratory protection

/ equipment. -

Analysis The-inspectors determined that the licensee failed to meet the requirements of 10

'sCFR 20.1703, when the-licensee Increased the air line pressure in excess of the

, , I *4 procedural guidance in HPIP 4.58"Which furtbr resulted in the licensee utilizing a af-I, respiratory protection device contrary to its NIOSH certification. This issue could 1/', reasonably be viewed as a precursor to a significant event, and if left uncorrected would become a more significant safety concern. Also, the issue involves conditions contrary to licensee procedures and NRC regulations which impact protective equipment related to mitigating worker dose. Therefore, the issue was determined to be more than minor and represents a finding which was evaluated using the significance determination process (SDP) for the Occupational Radiation Safety Cornerstone.

The inspectors determined utilizing Manual Chapter 0609, Appendix C, "Occupational Radiation Safety SDP," that the finding did not involve ALARA/work controls. Further, based on the inspectors' review of (1) dose rates

and contamination levels in the steam generator bowls, (2) licensee dose evaluations, and (3) worst case stay time estimates within the bowls, there were no radiological exposures in excess of regulatory limits, nor was there a substantial potential for an overexposure. Additionally, the licensee's ability to assess dose was not compromised. Consequently, the inspectors concluded that the SDP assessment for this finding was of very low safety significance (Green).

Finally, the inspectors identified that a~t4Iw.-cross-cutting areas were affected e V. by these events. Specifically, the root cause of inadequate supervisory oversight and the contributing cause relative to procedure use and adherence were'the

%9 result of poor Human Performance. The contributing cause relative to the station's use and evaluation of operating experience relates to Problem g 8 Identification and Resolution. Last, a lack of a questioning attitude relative to the \

cause of the apparent low air flow and the use of a lubricating fluid for personnel \ ,

N entry into the steam generators, Nuclear Oversight's slow response in raising concerns about the pre-job brief, and the one contractor's failure to immediately SW leave the steam generator bowl upon loss of air, all reflect issues relative to the (;

establishment of a .+ i- X '

W~s 'DC-MFof t vs 2 Z*. t-_V ., ,

Enforcement Title 10 of the Code of Federal Regulation, Part 20.1703 requires, in part, that if a licensee permits the use of respiratory protection equipment, the licensee shall:

8 (1) use only equipment that is tested and certified by the National Institute for NZj Occupational Safety and Heath (NIOSH), unless authorized by the NRC; and (2)

'4' implement and maintain a respiratory protection program that includes written S procedures regarding the storage, issuance, maintenance, repair, testing, and quality assurance of respiratory protection equipment. Contrary to the above, on April 9, 2004, the licensee increased the air line pressure of the "bubble hoods" employed during steam generator nozzle dam installation activities, beyond the procedural requirements of HPIP 4.58, "Issuance of Respiratory Equipment," (to

. Bapproximately 60 pounds per square inch gage), which additionally resulted in the t

Ii licensee utilizing a respiratory protection device contrary to the NIOSH certification and without NRC authorization. However, because the licensee l sdocumented this issue in its corrective action program (CAP 55527/RCE 253),

' conducted a full evaluation into the causes of the events, took corrective actions 9 )to address staff knowledge of procedural adherence prior to nozzle dam removal activities, and the violation is of very low safety significance, it is being treated as a Non-Cited Violation (NCV 05000266/2004003-XX; 05000301/2004003-XX).

.4 iRadiation Worker Performance ial. 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

^/ntrnlr~n th_ MA/ t orn l -- 1inn:s- ntThato. 4nneA- r:n-^ nr utr WUMoPIaM, Mui nvvF- wrULIsI~ WII 11imb IIn pIMace, anL Udl oneir Mna 1 prllidlluu acc;unikvu 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 RP technician performance with respect to radiation protection work requirements arid 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 Reasoriably Achievable Planning And Controls (ALARA) (71121.02)

.1 Inspection Planning

a. Inspection Scope 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 Scone 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.. RE-EXIT - Week of June 14, 2004 KEY POINTS OF CONTACT Licensee G. VanMiddlesworth, Site Vice President S. Thomas, Radiation Protection Manager B. Carberry, Radiation Protection - ALARA K. Zastrow, Root Cause Assessment Coordinator, Kewaunee Nuclear Plant LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened. Closed, and Discussed 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; S/G 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 4.58; Issuance of Respiratory Equipment; Revision 13 (March 19, 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 RCE 2531CAP 55527; Industrial Safety Issues and Poor Work Practices During Nozzle Dam Installation; dated May 22, 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 RWP No.04-171; NRC Walkdowns for U1 R28; Revision 0 RWP No.04-182; Replace Cono-Seal Bullet; Revision 0 20S2 As Low As Is Reasonably Achievable Planning 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 U1 R28 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 28t Refueling Outage RP Radiation Protection RWP Radiation Work Permit