ML20127D430
| ML20127D430 | |
| Person / Time | |
|---|---|
| Issue date: | 06/01/1988 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20127C592 | List: |
| References | |
| FOIA-92-252 NUDOCS 9301150222 | |
| Download: ML20127D430 (1) | |
Text
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ittl:0PANDLP FOR: Charles E. Norelius, Director Division of Radiation S6fety and Safeguards Region 111 TR0l1: Brian K. Grimes, Acting Director Division of Reactor inspection end Safeguaros, hRR SUBJEC1: RLSP0 fat 10 IYAlUATION MEMORANDUM - POTCHTIAL REGULA10RY OfTICIENCY PERTAINING TO VITAL E(UlH Lkl TAMPERING ,
This is in response to your met.,orandur; cf /pril 1,1988, in which you raised tot.ccrns about enforcement potential for 6 recent tampering incioent. We egree with your assessment of the incident and the actions you tock.
According to your roemorandum the TPI &clir+d to investigate the potent 1bl criniinal of fense under Ar Act Sr ction 236b. We assume, therefore, thbt the facts did not horr ht further investigation for crir:iriul prosecution purposes.
We have beer, inicrrird that the development of a rule is underway that would provide a basis for citing incitiduels for violations of regoletior s or license cor.ditiens and imposing individual civil penalties for future incidents of similar nature. Ih15 (tfort is in line with your suggestier.
Lecurity I ers l implementing 10 CFR 73.55 centially provide the necessory twchcr.isirs ,
to rerreve er ir ci\iduol's site access authorizations. With the strengthenine of access authori:ction trograms that should be re611:t t; stro, future perpetrators of simler acts should be prevented frer" 96ining access to any other sitt, provided "
that licensees are willing to decorrent all matters surrounding c termination or resignation and tr shrt that information.
We can aprreciate your f rustration with en issue urb es this, but we believe your office managed this incident prctetly end applied exactly tht. turiective cction that was appropriate.
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f -1 d - 's firinn L. Crittes, Acting Director Division of Reactor inspection und Sefeptrd , l'FR CONTACT: Robert Skelton (301) G 5208 9301150222 920807.
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. JUL 2 31987 Docket No. 50-155 Consumers Power Company ATTH: Dr. F. W. Duckman Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:
This refers to the routine safety inspection conducted by Mr. W. J. Slawinski of this office during the period May 18 through June 29, 1987, of-activities at Big Rock Point Nuclear Plant authorized by NRC Operating License No. DPR-6 and to the discussion of our findings with Mr. T. E. E1 ward and other staff inembers.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, independent iteasurements, and interviews with personnel.
No violations of NRC requirements were identified during the course of this inspection.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, Poriginal signed by V.D. WifeT*
W. D. Shafer, Chief Emergency Preparedness and :
Radiological Protection Branch
Enclosure:
Inspection. Report No. 50-155/87012(DRSS)
See Attached Distribution
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JUL 2 31987 i
Distribution cc w/ enclosure: l Mr. Kenneth W. Berry, Director
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. Nuclear Licensing
- T. E. E1 ward, Plant ;
Superintendent DCS/RSB (RIOS)
Licensing Fee Management Branch Resident Inspecter, RIII i Ronald Callen, Michigan ;
Public Service Commission '
Huclear Facilities and Environmental Monitoring !
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U.S. NUCLEAR REGULATORY COMMISSION REGION !!!
Report No. 50-155/87012(DRSS) !
I Docket No. 50-155 License No. OPR-6 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Tacility Name: Big Rock Point Nuclear Plant Inspection At: Big Rock Point Site, Charlevoix, Michigan Inspection Conducted: May 18 through June 29, 1987 4t Inspector: W. J. Slawins i 7 -I/~6 7 Date Approved By: L. H. Greger, Chief */ ~ 2 / ~ 6 7 Facilities Radiation Protection Date ,
Section inspection Summary inspection May 18 through June 29, 1987 (Report No. 50-155/87012(0RSSl}
Areas inspected: Routine, unannounced inspection of the radiation protection and portions of the radwaste management programs, including: organization and' management controls; training and qualifications; external and internal exposure controls and dosimetry; contamination control; ALARA; solid radwaste; and-transportation. Also reviewed were past open items and allegations concerning the radiation protection program.
Results: No violations or deviations were identitied.-
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DETAILS
- 1. Persons Contacted ,
R. Abel, Production and Plant Performance Superintendent
- H. Acker, Senior Engineer /ISI Coordinator
- R. Alexander, Technical Engineer C. Barsy, Senior Chemistry / Health Physics Technician
- J. Beer, Chemistry / Health Physics Superintendent
- R. Burdette, Senior Health Physicist
- T. E1 ward, Plant Manager
- G. Fox, ALARA Coordinator ,
- R. Garrett, Chemistry / Health Physics Supervisor '
O. Johnson, Health Physics Specialist ,
- L. Monshor, Quality Assurance Superintendent
- E. Raciborski, Planning and Scheduling Administrator !
- J. White, Maintenance Supervisor, field Maintenance Services West
- G. Withrow, Engineering and Maintenance Superintendent N. Choules, NRC Reactor Inspector T. Tella, NRC Reactor Inspector The inspector also contacted other licensee personnel in the Operations :
and Radiation Protection Departments. s
- Denotes those present at the exit meeting on May 22, 1987.
- Denotes those contacted by telephone during the period June 4-18, 1987. !
- 2. General t This inspection, which began at approximately 2:15 p.m. on May 18, 1987, was conducted to review the operational radiation protection program, solid radwaste, transportation, open items, and allegations concerning the radiation protection program. The inspector toured radiologically controlled areas and conducted external radiation surveys of selected plant areas using an NRC survey instrument (PIC-6A); survey-readings were in general agreement with posted licensee data. Area postings and general housekeeping were adequate.
- 3. Licensee Action _ on Previous Inspection Findings j (0 pen) Open Item (155/86009-01): Review documer.tation of corrective actions for radiological incident reports. Due to the limited number of incident reports generated since the previous inspection, conclusions regarding the effectiveness of radiological incident corrective actions documentation / implementation will be withheld pending further review (Section 4).
(0 pen) Open Item (155/86009-02): Review Radiation Work Permit (RWP) ;
program changes. Recommendations for RWP program improvements have been
- made and approved. This matter will remain open pending implementation
!? of the revised RWP program (Section 10).
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4 (Closed) Open Item (155/86009-03): Review improvements to ALARA program implementation and documentation. Weaknesses in the ALARA program primarily relate to RWP program deficiencies; therefore, ALARA program improvements will be reviewed in conjunction with the revised RWP program.
- 4. Organization and Management Cont rols The inspector reviewed the licensee's organization and management controls for the radiation protection and radwaste programs including changes in the organizationtI structure and staffing, effectiveness of procedures and other manage 0ent techniques used to implement these programs, and experience cor.cerning self-identification and correction of program implementation weaknesses.
Ef fective May 1,1987, Mr. David Hof fman was replaced as Plant Manager by Mr. T. E. E1 ward; turnover of responsibilities is nearly complete.
The Chemistry and Health Physics Superintendent remains as the Radiation Protection Manager and reports directly to the Plant Manager. The Chemistry / Radiation Protection Supervisor, General Engineer, ALARA Coordinator, and Senior Health Physicist all report to the Chemistry ar.d Health Physics Superintendent. The Chemistry / Radiation Protection Supervisor is responsible for the station's 12 Chemistry / Health Physics (C/HP) Technicians who perform both health physics and chemistry duties.
The Senior Health Physicist's responsibilities include radwaste and environmental monitoring; the General Engineer handles special projects as assigned and provides technical support to the Chemistry / Health Physics Department. A Health Physics Specialist, reporting to the ALARA Coordinator, provides administrative support for the dosimetry program.
There has been minimal turnover of the chemistry / radiation protection staff since mid-1985. Twelve C/HP technicians, the station's full complement, remain on staff and include six seninr technicians, one technician II, and five technicians. The last remaining technician trainee was promoted to technician in late 1986. All technicians are considered by the licensee as qualified in radiation protection procedures (Section 5).
The inspector reviewed the licensee's Health Physics Department functional Surveillance Program conducted pursuant to their Radiation Safety Plan.
This program, previously described in Inspection Report No. 50-155/86009, basically consists of informal surveillances of various health physics programmatic areas conducted by members of the Chemistry / Radiation Protection Department. This surveillance program, formally required by Section X of the Nuclear Operations Department Radiation Safety Plan, has been deleted from this section of the plan, revised, and added to Section !!. (Letter from B. D. Johnson to J. G. Keppler dated September 23,1985). Surveillances are. typically performed on a monthly-basis and have recently included reviews of station radiological posting, i material control and the RWP program. Several programmatic weaknesses have been identified during these reviews; however, corrective action i
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recommendations are not in all. cases formally addressed or their implementation adequately documented. The desirability of improving ,
documentation and followup of corrective actions was discussed at the exit meeting.
According to the licensee, Administrative Procedure 5.15, " Investigation of Radiological Incidents," dated July 22, 1986, was recently reviewed for possible revision of the method of documenting corrective actions; however, '
the original procedure was considered adequate and not revised. The inspector reviewed the six Radiological Incident Investigation Reports generated from May 1986 to date. The reports were typically initiated for personnel contamination incidents and f ailure to follow RWP requirements.
Reports generated since late 1986 appear to show improved corrective action documentation; nevertheless, conclusions regarding the adequacy of report documentation and of the overall investigation system will be withheld pending further implementation and review of the system.
No violations or deviations were identified.
- 5. Tjraining and Qualifications The inspector reviewed the training and qualifications aspects of the ,
licensee's radiation protection and radwaste programs, including: '
changes in responsibilities, policies, goals, programs, and methods; qualifications of newly hired or promoted radiation protection personnel; and provision of appropriate radiation protection and radwaste_ training for station personnel. Also reviewed were management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses.
Chemistry / Health Physics technician training consists of both formal course work and on-the-job training. The licensee is seeking INPO accreditation for the training program. Courses continue to be presented at the Midland Training Center and. include a 12-week health physics '
fundamentals course and a three-week advanced chemistry / health physics course. Continuing training consists of various informal training >
sessions presented in-house every two to three weeks covering specialized topics. !
The licensee's on-the-job _ training program includes a qualific' tion
-program for technician advancement upon completion of practical factor tasks.- Technician advancement to the four defined technician levels (technician trainee, technician,' technician II, and senior technician) depends on successful demonstration of the practical factors tasks to apprcpriate supervisory personnel. Technical specification 6.2.2.d requires that a person qualified in radiation protection procedures be onsite while fuel is in the reactor. Based-on the licensee's training and qualifications program, technicians above the trainee level.usually meet this requirement. Administrative Procedure No. 1.7.1, " Chemistry and Radiation Protection Technician On-The-Job Training Program,"
outlines in Attachment 3 those practical factors tasks which must be successfully demonstrated before a technician can be considered 4
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" qualified in radiation protection procedures" and capable of providing back-shift coverage. This procedure was recently revised to include a more specific task breakdown, add other previously unrequired tasks, and better delineate the overall practical factors requirements. The licensee is transcribing previously completed practical factors task items for all technicians onto a newly revised task items list. However, the licensee has no systematic method for transferring previously approved tasks onto the more specific revised task list. Also, documentation of task completions on the revised system is incomplete, lacking task approval signatures and dates. This matter was discussed at the exit meeting and will be reviewed further during future inspections (0 pen item No. 155/87012-01).
Currently, all technicians are considered " qualified in radiation protection procedures" and eligible for shift rotation. The station's last remaining technician trainee was upgraded to technician in October 1986 and approved for shift rotation. Back-shif t coverage is usually provided by one technician working eight-hour shifts on weekdays and 12-hour shifts on weekends. Although meeting technical specification requirements for shift coverage, approximately 25% of the current technician staff do not meet ANSI N18.1-1971 experience requirements.
The 1 Rensee plans to continue this practice and allow technicians above the trainee level to be eligible for shift rotation, provided minimum practical factor? task requirements have been met.
No violations or deviaticns were identified.
- 6. External Exposure Control and Personal Dosimetry The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation weaknesses.
Exposure records for plant and contractor personnel for 1986 and 1987 to date, were selectively reviewed. A selective review of Forms NRC-4 or equivalent was made for those individuals whose whole body exposure exceeded 1.25 rem in a calendar quarter; no problems were noted. No exposures in excess of 10 CFR 20.101 or the licensee's quarterly administrative limits were noted. Total dose for 1986 was 94.6 person-rem by pocket dosimeter and 76,1 by TLD. This is well below the station's annual average of about 300 person-rem and is primarily due to the lack of a refueling or other major outage during the year. No individual received greater than 3.5 rem to the whole body during 1986.
Total dose for 1987 through April is about 193 person-rem by pocket dosimeter, the majority (95%) of this was accumulated during the recent refueling outage which ended in March. Maximum individual whole body 5
dose for 1987 thus far is less than 2.5 rem by pocket dosimeter. The licensee continues to review pocket chamber /TLD discrepancies exceeding 250 mrem and/or 25%. No problems were noted.
No violations or deviations were identified.
- 7. Internal Exposure Control and Assesstnent The inspector reviewed the licensee's internal exposure control and assessment programs, including: changes in facilities, equipment, personnel, and procedures affecting internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; required records, reports, and notifications; effectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program impicmentation weaknesses.
The licensee routinely performs whole body counts on radiation workers twice annually and whenever an intake is suspected. The inspector reviewed Radiation Protection Procedure No. RP-38, Revision 6, February 4, 1987,
" Policy for Whole Body Counting and Whole Body Count Evaluation" and reviewed the calculational method for determining MPC-hour uptakes.
No problems were noted. The inspector reviewed whole body count results for September 1986 through March 1987. Ninety-two individuals were counted during the last four months of 1986 and 190 were counted in 1987 through April 11. No result exceeding the 40 MPC-hour control measure was noted; followup counts were performed on individuals who displayed initial elevated counts.
No violations or deviations were identified.
- 8. Control of Radioactive Materials and Contamination The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated materials.
The inspector reviewed results of routine radiological surveys performed during 1987 through April in accordance with Radiation Protection Procedure No. 29. The surveys consist of external surveys and smears of various radiologically controlled (RCA) and non-radiologically controlled areas performed on a daily, weekly, or monthly basis, depending on the location.
Monthly surveys of additional high traffic areas outside the RCA were recently included in the procedure as a result of contamination found in the lobby of the access control building (Inspection Report No. 50-155/86014(DRP)). Survey data indicated general area smear results of controlled areas are typically below the station's 400 dpm/100 cm2 decontamination action level. The highest smearable l
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t contamination was consistently found at the reactor deck, a boundaried area. Other contaminated areas greater than 400 dpm/100 cm2 that are not readily decontaminated because of ALARA considerations are positively controlled by physical boundaries including locked doors.
A janitor is assigned area decontamination work two days per week; technicians assist in decontamination tasks as time permits. The janitor has received informal decontamination training from health physics supervision. Although the extent of contaminated areas is not tracked, the licensee estimates that 10-15% of the controlled area is boundaried. During the recently completed refueling outage, the licensee retained three full time contract decontamination technicians; this was not done during past outages. The licensee is satisfied with their efforts and will consider a similarly augmented decontamination crew for future outages.
The inspector selectively reviewed personnel contamination reports for 1986 and 1987 through April. The licensee reports all skin contaminations exceeding 100 cpm above background and tracks the data for ALARA purposes.
There were 33 personnel contamination incidents reported in 1985; over 50% occurred on the reactor deck. Sixty-nine incidents were reported for 1987 through April, nearly all occurring during the refueling and maintenance outage which ended March 11. Forty-two incidents occurred in January 1987 resulting primarily f rom f uel transfer operations and control rod drive replacements; however, nearly 50% of the January incidents were minor hand / foot contaminations less than 500 cpm. Whole body counts are required when skin contamination above the neck exceeds 1000 cpm or 50 cpm from a nasal smear. A skin dose determination is required when greater than 10,000 cpm are detected. According to the licensee, an inefficient fuel pool cleanup system leads to contamination control problems during refueling operations. To help rectify the problem, the licensee initiated operation of a supplemental underwater filtering system in the fuel pool shortly after the refueling outage concluded.
The supplemental system will run continuously at 250 gpm with variable (1-25 micron) particulate filters. If the new filtering system proves effective, the licensee will consider decontamination of the fuel pool cooling system piping and heat exchangers.
The station recently modified their egress controls and reinforced their frisking policy in an attempt to eliminate incidents of contamination found outside the RCA. Currently, all RCA egress is through access control only, unless specifically authorized by radiation protection. Two previously used RCA exits are no longer authorized egress points. Also, the RCA in the shop area was extended to allow access to the stockroom window from the RCA. These changes became effective April 1, 1987. The licensee removed a frisker from the sphere's 585-foot elevation, leaving no frisker routinely available to workers inside the sphere. The only permanent friskers in the RCA are located immediately outside the personnel hatch and at access control. Admittedly, sphere area radiation background levels are elevated and reduce the effectiveness of detecting lower levels of contamination; however, it appears desirable to reinstall a modified 7
shielded frishing booth at the 585-level to allow detection of gross contamination after exiting highly contaminated rooms which exist in the area. Conventional hand-held friskers continue to be the sole method of personnel contamination detection at access control. This method is not state-of-the-art and is highly dependent upon individuals performing adequate frisks and then reporting personnel contaminations which are identified. Instances of contamination detected outside the RCA (presumably f rom shoe contamination) have been identified by the licensee. Additionally, Audit Report No. Q1-87-02, conducted during february 2-6, 1987, indicated that approximately 50% of workers observed over the audit period were frisking improperly, it appears frisking methods, particularly at access control, are a programmatic weakness requiring attention by the licensee, including procurement of whole body friskers. These contamination control concerns were discussed at the exit meeting and will be reviewed during future inspections (0 pen item No. 155/87012-02).
On f ebruary 13, 1987, operators transferring water which had been processed through a demineralizer to the outdoor treated waste hold tank filled the tank to overflowing. Water apparently leaked f rom the manhole gasket and f r oze along the tank sides and on the concrete pad beneath. The licensee estimates that 10 to 25 gallons of liquid leaked from the gasket area with a total activity of about 7 to 17 uCi. Resultant contaminated soil was excavated and placed in onsite storage pending disposal as radwaste (Inspection Report No. 50-155/07009(DRSS)). Both maintenance activities associated with the leaking gastet and aspects of personnel errors associated with " erflowing the tank are being pursued by the site's NRC Resident '.ospector. The radiological aspects of this incident are subject to further review (0 pen Item No. 155/87012-03).
No violations or deviations were identified.
- 9. Maintaining Occupat_ional Expo _sures ALARA The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including: changes in ALARA policy and procedures; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them. Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses.
The formal ALARA program is administered by an ALARA Coordinator, no other personnel are assigned direct responsibilities under (nis program; however, chemistry / health physics technician support is ava lable. No formal ALARA training program currently exists; although an ALARA training program for the health physics and engineering staf f is being developed by the licensee's Hidland Training Center together with Palisades Station.
The training program is anticipated to be developed in 1987 and should be available to Big Rock Point employees.
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4 For 1986, total plant exposure by pocket dosimeter and TLD was 94.6 and 76.1 person-rem, respectively; meeting the plant's goal of 100 percon-rem.
This is considerably less than the station's 303 person-rem average over the previous five years; however, unlike previous years, no refueling outage occurred. For 1987, the ALARA goal for total plant exposure is 200 person-rem. Through April 1987, total plant exposure by pocket dosimeter is 193.7 person-rem; 183.6 person-rem was accumulated during the 69-day outage which began January 2. For the 1981 refueling outage, in which work similar to the 1987 outage was performed, total exposure v about 191 person-rem. Approximately 15 person rem was accumulated cut i eg the 1987 outage for jobs which were not performed in 1985.
Exc;, ding the exposures attributed to jobs performed solely in 1987, a minor (12%) dose savings was realized for the-1987 outage.
Audit Report No. QT-86-2, documenting results of an April 1986 audit by thm plant's QA department, identified one finding regarding the ALARA program. The finding involved deficient implementation of administrative controls and documentation associated with ALARA work packages and included underestimation of pre-job exposures and incomplete documentation of ALARA post-job reviews. A Deviation Report was initiated to track -
resolution. At management's request, a surveillance was performed of the station's ALARA and RWP programs by a licensee QA auditor. The surveillance was conducted September 15-24, 1986, and identified several observations related to overall program inadequacies. Some of the observations noted 'n the surveillance report concerned worker failure to read and understand RWPs, lack of procei mal direction for RWPs and ALARA, and an overall attitude of indiffe ? toward RWP and ALARA programs. The surveillance report also questioned whether sufficient staffing was devoted to RWP/ALARA programs. Similarly, a previous INPO audit identified problems with implementation of the ALARA program, primarily relative to associated RWP program weaknesses.
During the inspector's cursory review of the formal ALARA program and discussiorm with licensee personnel, the inspector found that weaknesses in proper.f implementing and documenting the ALARA program apparently stem from inadequacies in the RWP program and cp;2 rent lack of sufficient ALARA staffing during outages. The licensee i wently concluded a review of the RWP program and is currently planning extensive revisions to the program. The implementation of the revised RWP program and its effect
- on the ALARA program will be reviewed during later inspections (Sections 3 and 10).
No violations or deviations were identified.
- 10. Radiat'on Work Permit Program The RWP program is the principal mechanism used to identify radiological work conditions, specify radiation safety requirements, ensure required-work briefings are conducted, and provide a means of exposure tracking.
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As discussed in Section 9,-previous licensee QA audits and surveillances identified a general weakness in the RWP program. For example, the QA surveillance conducted in September 1986 identified the following:
- Failure of workers to read and understand RWPs and sign associated exposure entry logs
- No independent reviews of RWPs
- General RWPs exceeding their expiration date(s)
- Frrors in completing RWPs
- Attitude of indifference toward the RWP program In a followup informal health physics surveillance conducted in February 1987, many similar weaknesses were identified; however, certain aspects of the program showed some improvement. The surveillance noted no improvement in worker attitudes toward the RWP program and identified an overall insufficient attention to detail. The surveillance report outlined several recommendations to improve the program.
As a result of these licensee identified weaknesses, an RWP Task Force was established for the purpose of improving the RWP system; the task force consisted of individuals from each department that has significant involvement in RWD work. The task force has nearly completed their review and an overhaul of the RWP program is planned. Plans call Jor more explicit and detailed RWPs and improved job preplanning. -It also appears that RWP program training is necessary. Implementation of the revised program is planned to begin in June 1987. The RWP/ALARA program modifications were discussed at the exit meeting and will continue to be reviewed during subsequent inspections.
No violations or deviations were identified.
- 11. Solid Radwaste The inspector reviewed the licensee's solid radioactive waste management program, including: adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the quality assurance program; adequacy of required records, reports, and notifications; rnd experience concerning identification and corrections of programmatic weaknesses.
Solid radwaste handling, compaction, and storage facilities are located in the radwaste building outside the protected area. The building is bounded by a-lockable chainlink fence; keys are positively controlled by the Ch 9'stry/ Radiation Protection Department. High activity resins and filters are loaded into HICs and dewatered; HICs are' stored in vaults in the radwaste building pending shipment. Dry active wastes (DAW) are either compacted in 55 gallon drums or placed-in steel boxes. The licensee currently uses a conventional compactor yielding approximately 250' pounds 10
b of waste per drum and anticipates increasing its compaction ability, using compaction disks, to about 280 pounds. Also, the licensee is considering the use of a vendor supplied super compactor to further reduce volumes.
QA Audit No. QT-86-2, conducted in April 1986, included a limited review of the station's radwaste shipping and packaging program. The audit identified two observations primarily concerning incomplete proceduid instructions for radwaste shipping. The audit observations appear to have been adequately addressed and corrected.
The station generated about 1400 cubic feet of radwaste in 1986 and about 1550 cubic feet in 1987 through April; the majority was comprised of non-compacted DAW. Approximately 900 cubic feet of non-compactible DAW was generated in March 1987 resulting exclusively from outage . -
activities.
The inspector toured radwaste handling and storage facilities and discussed
- radwaste handling with a licensee representative. No significant problems j were noted.
No violations or deviations were identified.
- 12. Transportation of Radioactive Materials The inspector reviewed the licensee's transportation of radioactive materials program, including: determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications;-and experience concerning identification and correction of programmatic weaknesses.
The inspectar selectively reviewed portions of the solid radwaste shipment records for 1986 and 1987 to date. The information on the shipping papers appears to satisfy NRC, DOT, and burial site requirements.
The station made three solid radwaste shipments _in 1986 and four in 1987 through May 16 totaling about 1500 and 1600 cubic feet respectively. l The majority of shipments were to the Barnwell, South Carolina site.
Trending data shows a steady decline in the_ volume of radwaste shipped annually since its peak of about 5000 cubic feet in 1981. The licensee indicated no transportation incidents or significant problems occurred in the last year.
No violations or deviations were identified.
- 13. Allegation Follswup Discussed below are allegations concerning the radiation protection program at Big Rock Point which were evaluated during this inspection.
The evaluation consisted of record and procedure review and interviews with licensee personnel.
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- a. The Big Rock- Point Resident Inspector's office received information i i*garding concerns with planning and ALARA practices at the station during the-1987 refueling outage. The concerns were clarified in telephot.e conversations sith the individual on June 17 and 29, 1987.
The allegation and_i mpector's findings are discussed below.
(Allegation No. PRI-87-A-0057(Closed)) ' ;
Allegation: Poor planning and ALARA practices resulted in excessive ,
and unnecessary radiation exposure to Field Maintenance Services-(FHS) workers involved in ISI weld examinations in the steam drum area.
As a result, several crewmen reached their quarterly exposure limit and were transferred to other non-nuclear locations. Specifically, the concern was directed toward improper exposure distribution and lack of planning associated with scaffolding construction.
Discussion: The subject of the alleger's concern involved ISI weld preparation work performed in the steam drum area during.
outage activities in January 1987. Prior to performing actual weld preparation work, consisting of cleaning, brushing, and grinding,-
scaffolding was constructed in the area. Scaffolding construction was initiated January 5, 1987, and was completed on or about January 9, 1987. Scaffolding was erected by the same work group that perfurmed the weld preparations (i.e. , FMS crew), reportedly to alleviate complaints of poorly constructed scaffolding which surfaced during the previous performance of this work during the station's 1985 outage.
A pre-job ALARA review was completed for each of two ISI jobs in the steam drum area, one for the lower and one for the upper steam drum room. The licensee performed a pre-job ALARA review, estimating doses of approximately 7 rem for scaffolding erection and approximately 14 rem for weld preparation activities, (An RWP contained incorrect information concerning the estimated dose to complete the work. This did not result in any increased personal doses, but'could have~ led to a perception of increased personal doses since the RWP dose information was considerably lower than the ALARA pre-job estimate.) Scaffolding construction is relatively labor-intensive and requires workers to-physically' hoist-up the pieces of scaffolding using ropes, about 50 feet from the recirculation pump room floor to the steam drum area. Scaf folding construction consumed about 18 person-hours, about six of the 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> was_ expended hoisting-up the pieces.
The licensee did not dry-run scaffolding. construction or have blueprints or photographs of previously constructed scaffolding or other training aids to streamline the process. Use_of-such aids may have expedited the work and produced some dose savings. Although there was no specific training provided for scaffolding construction, the workers were reportedly- reasoi. ably experienced in such construction and rigging work. The actual total exposure received for scaffolding work was about 6 person-rem which was about -1 rem less than predicted.
According to the alleger, the staff 31 ding job took longer, therefore worker radiation doses increasu . b mause incorrect scaffolding was hoisted to the work floor befort 4, error was discovered. Licensee Y -
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personnel interviewed denied this allegation, but did acknowledge that the job could have been completed more expeditiously had the workforce been better trained. While the veracity of the allegation was not resolved, the dose savings which could have been achieved, were the allegation correct, appears to be a maximum of about 10%
of the 6 person-rem expended on scaffolding erection. Inasmuch as the licensee acknowledged the need for improvements in future similar scaffolding erection, no further NRC action appears warranted.
The licensee has a mechanism in their ALARA program for directly soliciting worker concerns and recommendations for job improvements according to licensee personnel, no previously unconsidered recommendations to substantially reduce overall job exposure were made for this job. The alleger claims that one of the FMS workers submitted an ALARA recommendation through his job supervisor concerning the recent scaffolding work. The licensee's ALARA coordinator stated he had not received an ALARA recommendation from an FMS worker during the recent outage and that ALARA recommendations should be submitted directly to him rather than to the job supervisor.
He further stated that he would review the need to improvg methods for soliciting ALARA recommendations. This matter will be reviewed further during a future inspection (0 pen Item 155/012-05).
As many as nine FMS workers may have been involved in the scaffolding construction work and subsequent weld preparations during their temporary assignment at Big Rock in January and February 1987.
The licensee's TLD analyses show no FMS worker received a whole body exposure exceeding licensee quarterly administrative limits; however, several workers approached the limits and were transferred to other non-nuclear assignments.
To improve future similar tasks, the licensee plans to use photographs taken after the scaffolding was constructed as a training aid and to more closely track times and exposures for all ISI work. Construction of permanent scaffolding was considered, but will reportedly not be erected.
Finding: The alleger's primary concern appeared to be that the-crew performing weld preparations also was required to erect the scaf folding, and in so doing,-they received additional radiation exposure such that some of them had to be sent to non-nuclear jobs because they approached the licensee's quarterly dose limit (2500 mrem). In the June 17, 1987 telephone conversation, the alleger was informed that the licensee's failure to distribute the total radiation dose over a larger number of workers and therefore-eliminate the necessity to transfer workers to non nuclear jobs because they approached the quarterly dose limits, was not contrary to NRC regulations or guidance.
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The alleger's additional concerns of poor ALARA practices which resulted in excessive exposures appears to be only partially correct.
ALARA planning was performed for this work, and while the licensee has acknowledged that improved preparations for future similar scaffolding work should be utilized, the pre-job dose estimates were reasonably accurate. While the ALARA practices could have been better, they did not violate regulatory requirements.
- b. An anonymous caller te'.ephoned the NRC Region III office and expressed his concerns regarding activities at Big Rock-Point. . The alleger subsequently met with a Region III Pnysical Security Inspector, clarified his concerns, and made additional allegations including radiation protection program matters. The individual's allegations relating to the radiation protection program at Big Rock Point and the inspector's findings are discussed below or have been addressed in Section 13.a above. (Allegation No. RIII-87-A-0042(0 pen))
Allegation: High radiation area door keys may be signed out by one person then given to others without an accurate record of who has used the keys. The person returning the key would, at times, be someone other than the person that signed out the key. Also, the alarm on the recirculation pump room door (high radiation area.
door) could be easily circumvented by tying off the contact switch, which he believed to be a common practice.
Discussion: Technical Specification 6.12.2 requires that high radiation areas (> 1 R/hr) be provided with locked doors to prevent unauthorized entry, keys be maintained undtr the administrative control of the Shift Supervisor on duty and/or health physics supervision, and doors remain locked except during periods of access by personnel under an approved RWP. Administrative Procedure No. 5.8, "High Radiation Area Key and Access Control" states that the Shift Supervisor is responsible for high radiation area key custody and control. The procedure further states " keys are signed out in the Shift Supervisor's office and returned after use. During outages and in instances where high radiation areas are kept open '
for several shifts or days, key responsibility may be transferred
- by the key recipient's notification of the Shif t Supervisor."
A high radiation door key log is maintained in the Shift Supervisor's office and contains columns for recording key number, key type, person signing out key, and date and person returning the key.
The inspector selectively reviewed the logbook for 1987 and noted several instances.where the individual returning the key was not specified, was someone other than the person who signed the key out, or a question mark was entered in the key return column. A Shift Supervisor (SS) indicated that keys may be transferred to another 1
individual provided the SS is notified and approves _the transfer; however, the log has no provision for documenting ~ transfer responsibility. This is a weakness which should be corrected. In accordance with Administrative Procedure No. 2.1.4, " Plant status 14
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and Equipment Control," Shif t Supervisors stated they _ release keys and allow transfer to individuals they personally know to be advanced radiation workers (i.e. , radiation protection technicians, certain operators / engineers and supervisory personnel) or those that have arranged for radiation protectio. coverage. A list of plant advanced radiation workers is not available; however, because of the relatively small size of the plant staff, the operators reportedly know all personnel qualified to be issued keys. During outages, the plant provides a list of qualified contract workers to Shift Supervisors.
The recirculation pump room is a locked high radiation area that has audible and visible local and control room alarms which actuate when its door (gate) is opened. The technical specifications do not require alarms on high radiation area doors; the alarms are used to alert the control room of entries into certain high radiation-(> 1 R/hr) areas. The gate opens outward (towards the individual entering) which causes an electrical contact arm to also swing outward and activate the alarm. The individual opening / closing the gate is responsible for notifying the control room prior to entry and af ter
, exiting. A phone is maintained on the wall outside the room for such purposes. The local alarm actuates only while the gate is in the open position but continues to sound in- the control room, regardless of gate position, until acknowledged by the operator, During periods when continual or frequent access to the room is required, the alarm's contact arm is tied back and a gate watch controls entry; the licensee reported this to be a routine practice, especially during outages.
The alarm cannot be easily circumvented unless the entry gate is opened; this was confirmed during conversations with radiation protection department management. After the alarm is actuated, the alarm's contact arm can be tied off to prevent continuous alarming in the area. Defeat of the alarm is acceptable when access to the room is controlled by an authorized gate watch.
Finding: While the allegations were substantiated, they do not represent violations of regulatory requirements, and are generally acceptable practices. Improvements are desirable concerning the licensee's administrative controls over HRA keys. This matter was discussed at the exit meeting and will be reviewed further during a future inspection (0 pen Item No. 155/87012-04).
Allegation: There was an insufficient supply of large-sized protective coveralls available at times during the 1987 refueling outage; contamination control can be jeopardized when the small-sized coveralls pull loose at-the taped wrists and/or ankles.
Discussion: The licensee acknowledged that-protective clothing shortages may have existed at limited times during the 1987 refueling outage; however, they stated that they were unaware of any personal contamination directly attributable to the wearing of under-sized coveralls. The licensee has. plans to increase supplies l of large-sized protective coveralls for the next refueling outage.
l This matter will be reviewed further in a future inspection (0 pen Item 50-155/87012-06).
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Findino: While the allegation was substantiated, the licensee had already identified the weakness and planned corrective measures for the next refueling outage. No regulatory requirements were violated.
No violations or deviations were identified.
- 14. Exit Meeting The inspector met with those noted in Section 1 on May 22, 1987 to discuss 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 by the inspector during the inspection. The licensee identified no such documents / process as proprietary. In response to the inspector's comments, the licensee:
- a. Acknowledge the inspector's comments concerning the desirability of improving documentation and followup of corrective actions for the health physics functional surveillance program (Section 4).
- b. Acknowledged the need to devise a method for transferring a technicians previously approved practical factors tasks onto the revised task list and complete the documentation (Section 5).
I c. Agreed to consider reinstalling a frisker/ shielded frisking booth at I
the 585-foot elevation of the sphere and consider obtaining a whole fbW body frisker at access control (Section 8).
- d. Acknowledged the need to improve high radiation area door key controls (Section 13).
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