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Insp Repts 50-266/97-08 & 50-301/97-08 on 970505-09. Violations Noted.Major Areas Inspected:Review of High Radiation Area Controls,Solid Radwaste Program, Transportation of Radwaste & Radiation Protection Program
	ML20148L445
Person / Time
Site:	Point Beach
Issue date:	06/09/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20148L382	List: ML20148L445;
References
	50-266-97-08, 50-266-97-8, 50-301-97-08, 50-301-97-8, NUDOCS 9706190249
	Download: ML20148L445 (10)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION lli

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l Docket Nos: 50-266; 50 301

Licenses No: DPR-24; DPR-27

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Reports No: 50 266/97008(DRS); 50-301/97008(DRS)

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Licensee: Wisconsin Electric Power Company

Facility: Point Beach Nucisar Plant, Units 1 and 2

Location: 6610 Nuclear Road

Two Rivers, WI 54241

Dates: May 5-9,1997

Inspectors: R. Paul, Senior Radiation Specialist

K. Lambert, Radiation Specialist

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Approved by: G. Shear, Chief, Plant Support Branch 2

Division of Reactor Safety

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9706190249 970609 E

gDR ADOCK 05000266 I

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EXECUTIVE SUMMARY

Point Beach Nuclear Plant, Units 1 & 2 I

NRC Inspection Reports 50-266/97008; 50-301/97008

This announced inspection included a review of high radiation area controls, the solid

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radwaste program, transportation of radwaste, and the radiation protection program. The l

following specific observations were made:

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j * Continuing problems with high radiation area controls were identified as a contract i

painter entered several posted high radiation areas while on the Radiologically )

Controlled Area Entry Permit, which did not authorize entry into those areas. One

violation was identified (Section R1.1).

The inspectors identified a violation in which, the licensee failed to provide

recurrent training for contractor health physics technicians assigned to radwaste in

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accordance with Department of Transportation requirements (Section R8.1).

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As a result of the high radiation area problems, the licensee reconfigured access to

the radiologically controlled area, so that individuals pass by the health physics

station to inform a technician where they are going and the type of work to be l

performed. This has had a positive impact with ini eased communication between

1 workers and health physics (Section R2.1).

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The licensee effectively implemented the external dose program. ALARA reviews

were performed and identified radiological hot spots which could impact work being

performed. The licensee has good procedures in place to evaluate exposures from

hot particles (Section R1.2).

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The solid radwaste program was being implemented as described in the Process

] Control Program. The material condition of tanks and equipment in demineralizer

and processing radwaste tank cubicles was good (Section R1.3).

* The continuing training program for the licensee's health physics technicians was

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effectively implemented. However, the licensee identified, that contractor

technicians initial qualification cards were not completely signed-off and took

corrective actions (Section R5.1).

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A comprehensive audit of the health physics program identified several areas with

minor deficiencies and provided recommendations for improvement. Corrective

actions in response to recommendations are being implemented (Section R7.1).

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Report Details

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R1 Radiological Protection and Chemistry (RP&C) Controls I

R1.1 Hiah Radiation Area Boundarv incident l

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a. Inanection Scone (83750)

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The inspectors reviewed and discussed with licensee personnel an incident where '

an individual entered a posted high radiation area (HRA) in the radiologically I

controlled area (RCA) of the primary auxiliary building (PAB) to perform painting J

functions without proper authorization.

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b. Observation and Findinas

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On April 8,1997, the licensee identified that a contract painter entered the Unit 1

Mixed Bed Domineralizer cubicle on April 7,1997, which was posted as a HRA-

RWP (radiation work permit) required. Upon further review the licensee identified I

that additional posted HRAs had also been entered by the contract painter. These ;

areas were Spent Fuel Pool Domineralizer cubicle, Unit 1 Reactor Coolant Filter I

cubicle: Unit 2 Reactor Coolant Filter cubicle, and Reactor Coolant Pump Seal Water i

Supply Filter cubicle. Of these areas, only the Spent Fuel Pool Domineralizer Filter

cubicle was an actual HRA with a dose rate of 150 mrom/hr at 30 centimeters (cm) I

from the locked door. The contract painter crew had access to the RCA through

the licensee's Radiologically Controlled Area Entry Permit (RCAEP), which does not

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authorize entry into HRAs. The painters were not signed on to a specific RWP.

The contract painters possessed self reading dosimeters (SRDs) and

thermoluminescent dosimeters (TLDs), but did not possess a high range SRD or

electronic dosimeter as would be required for entry into HRA-RWP required areas.

Immediate corrective actions taken by the licensee were to temporarily suspend the

contract painters access to the RCA, send the painters TLDs for processing, and to

perform a root cause evaluation. The TLD results for the painter who entered the

HRAs were 30 mrem for the first quarter of 1997 and 20 mrem for the period April

1-8,1997. The painter's total dose of 50 mrem for 1997, was 20 mrem higher

than the nearest coworker's dose for the same periods.

Technical Specification (TS) 15.6.11 states, in part, that radiological control

procedures shall be written and made available to all station personnel. Health

Physics Manual Procedure HP 2.5.6, Revision 3, states that radiation workers are 1

responsible for complying with the requirements of the Radiologically Controlled i

Area Entry Permit (RCAEP). The RCAEP revised January 2,1997, states that

entering high radiation areas under this entry permit is an unauthorized work j

activity. Entry into an area posted as a high radiation area while on the RCAEP is a

violation of Technical Specification 15.6.11 (VIO 52-266/97008-01(DRS); 50-

301/97008-01(DRS)).

The licensee performed a common cause analysis to determine root causes of the !

continuing HRA boundary incidents. Preliminary results included the following root I

causes: (1) inadequate management expectations for worker performance; (2) lack 1

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of management support for the radiation protection program; (3) lack of

communication between health physics and the painters; (4) inadequate work

I oversight; and (5) lack of clear health physics procedures and policies. The 1

l licensee's immediate corrective actions to the common cause analysis were to )

, reconfigure the RCA access point so that individuals have to pass by a Health

Physics Technician (HPT) greater; require all newly trained radiation workers to

j attend an health physics orientation prior to unescorted access to the RCA, use of a

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HPT rover by health physics, and issue a memo to all personnel from the plant !

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manager on expectations for radiation workers. In addition, the licenses has '

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retrained all contract painters in radiation worker practices prior to restoring their I

access to the RCA.

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c. Conclusions I

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One violation was identified for entering a posted HRA while on the RCAEP. The

licensee performed a common cause analysis to determine root causes of the

continuing HRA boundary incidents. The licensee has implemented corrective i

I actions based on the preliminary results of the common cause analysis. I

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R1.2 External Dose Control and ALARA Imolementation

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j a. Insoection Scone (83750)

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The inspectors reviewed the licensee's program for controlling external dose to

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workers. This included a review of individual dose records, the process for i

evaluating lost or off scale SRDs or lost TLDs, comparison of SRD and TLD results,

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hot particle evaluations, and hot spot reduction programs.

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b. Findinas

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l The inspectors' review of selected individual dose records did not identify any i

doses that exceeded licensee administrative limits. The licensee's total dose for the

! first quarter of 1997 was 31.1 person-rem, with a 1997 goal of 185 person-rem,

j The licensee has procedures in place to evaluate lost TLDs and SRDs. A review of

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records revealed that the licensee has performed evaluations in accordance with

i procedures when dosimetry is lost. The licensee compared SRD and TLD doses in ,

accordance with procedures and performed evaluations when SRD/TLD ratios were

, outside the procedural limits. The licensee has good procedures in place to

evaluate and document exposures from hot particles. The licensee performs

- approximately 6 hot particle evaluations per year, with none performed recently.

The licensee files the evaluations in the employee's exposure file and does not

mairitain a log, therefore it is difficult for the licensee to retrieve the evaluations.

Locations of hot spots are reviewed as part of the ALARA review for jobs.

Protective measures such as shielding or flushing of hot spots were performed to

reduce dose rates when there could be an impact on worker doses.

c. Conclusions

! The licensee effectively implemented the external dose program. ALARA reviews

i were performed and identified radiological hot spots which could impact work being

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j performed. The licensee has good procedures in place to evaluate exposures from

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R1.3 Imalementation of the Solid Radioactive Waste Prooram

l a. Insoection Scone (86750)

! The inspectors reviewed the licensee's solid radioactive waste (radwaste) program

i as described in the USAR and the Process Control Program (PCP), and inspected

j demineralizer and processing radwaste tank cubicles.

j b. Observations and Findinas

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j The licensee's radwaste included Dry Active Waste (DAW), evaporator

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concentrates, spent resins, and process stream filters. Spent resins and filters were

i dewatered onsite, using a vendor system, and DAW was sent to an offsite

] contractor for processing. Waste not immediately sent for processing was stored in

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the radwaste area or immediately outside the PAB truck bay in sea land vans,

which were appropriately posted and secured. The 10 CFR Part 61 sampling and

i analysis program was conducted in accordance with the PCP and Radioactive

Materials Handling Manual, Procedures RDW 18.1.1 and 18.2. The inspectors

observed generally good housekeeping and appropriate posting and labeling in the

, radwaste storage and processing areas.

The inspectors observed a spent resin transfer from a radwaste holding tank to the

radwaste shielded High Integrity Container (HIC), verified that the dewatering

l system was operated in accordance with procedural requirements, and that system l

l operators were knowledgeable about the system. During the transfer, an

! unexpected high alarm sounded and the transfer was automatically shutdown when

the high level shutoff valve isolated the transfer. The reason for the high !

! water / resin level in the HIC was the inability of the radwaste dewatering pump to

j maintaln the same flow rate of the slurry pumped from the holding tank. No resin >

j or water was spilled because the shutoff valve operated as designed. The licensee

j wrote a condition report for this event to evaluate the adequacy of existing transfer

i procedures and to determine if they can safely transfer resin to the HIC while

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controlling the slurry level in the HIC below the high level alarm setpoint. The

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inspectors also noted during their pre-job briefing for the transfer evolution, that

specific contingencies concerning actions to be taken if significant problems arose

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during the transfer were not discussed.

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l The inspectors toured all radweste domineralizer and processing radweste tank

l- cubicles. The cubicles were accessible as the spent resins had been transferred to

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a holding tank (controlled as HRA). The inspectors verified that the integrity and

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material condition of the tanks were good and that there were no visible indications

of resin leakage from the tanks. The licensee had recently initiated a program to

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periodically inspect infrequently accessed cubicles and rooms to access system

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c. Conclusions

The inspectors concluded that the solid radwaste program was being implemented

as described in the PCP. The material condition of tanks and equipment in

demineralizer and processing radwaste tank cubicles was good.

R2 Status of RP&C Facilities and Equipment

R2.1 General Tours of Primarv Auxiliarv Buildina (83750)

The inspectors performed several inspections of activities in the PAB, including

several demineralizer cubicles (Discussed in Section R1.3 above), and observed

radiation worker practices. Radiological posting and boundaries in the PAB were

generally well maintained and housekeeping was good. Observed workers

demonstrated knowledge of radiological conditions. Personnel were wearing the

appropriate dosimetry.

The licensee reconfigured access to the RCA, so that individuals pass by the HP

station to inform a HPT greater where they are going and the type of work to be

performed. From discussion with workers and HPT greeters,it appeared that this

change has had a positive impact with increased communication between HP and

workers.

R5 Staff Training and Qualification in RP&C

R5.1 Technician Trainino

a. insoection Scone (83750)

The inspectors reviewed training programs for licensee technicians and contract

technicians. This included a review of training records, and discussions with

technicians.

b. Observations and Findinas

The licensee has not hired any HPTs for approximately 6 years. The licensee has a

program in place to provide continuing training to the HP staff. A review of training

records indicated that the continuing training program for licensee HPTs was

effectively implemented. However, the licensee identified, through a self

assessment, that contractor technicians initial qualification cards were not

completely signed-off. The licensee's review indicated that while the cards were

not signed-off, the technicians have performed the duties campetently. The

licensee intends to complete the qualification cards after the technicians adequately

perform the tasks in question. Until the sign-offs are complete, technicians will be

prohibited from independently performing those tasks not signed-off.

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c. Conclusions

The technician training program was effectively implemented except for the

documentation of contractor qualification cards. This had been identified by the

licensee and corrective actions were implemented.

R7 Quality Assurance in RP&C activities

R7.1 Health Physics Denartment Audit

a. Insoection Scone (83750)

The inspectors attended an exit meeting where the preliminary results of an HP

department audit were presented. This was a comprehensive audit which included

a program review of radiation contamination monitoring, RWP control and

processing, waste disposal, dosimetry and ALARA, respiratory protection,

radiological environmental program, instrument calibration, and technical i

specification requirements. This audit was performed by a team comprised of

licensee personnel from the station and its headquarters, and individuals from

outside the licensee's organization. The audit team identified several areas where

improvements in the program could be made and initiated several condition reports.

The HP department manager indicated that corrective actions to the condition

reports and other areas will be implemented. The inspectors noted that the audit

appeared comprehensive and that corrective actions in response to

recommendations and condition reports should strengthen the HP program.

R8 Miscellaneous RP&C lasues

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R8.1 Imolementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71 l

a. Insoection Scone (Tl 2515/133)

The inspectors reviewed the licensee's transportation program for the

implementation of the revised Department of Transportation (DOT) and NRC

trinsportation regulations for shipments of radioactive materials.

b. Observations and Findinas

The inspectors verified that station procedures correctly referenced the revised

Department of fransportation (DOT) requirements and, through interviews, that

workers responsible for shipping were cognizant of these requirements. Overall,

the .ecedures effectively incorporated the changes in the classification and

tra;.s . tation of LSA material and implemented the use of SI units as required in

49 CFR 172.203(d)(4). The inspectors reviewed selected 1996 and 1997

shipments and noted that documentation for several LSA material and SCO

shipments contained required information. The licensee used a vendor computer

program (RADMAN) to classify shipments and maintained current files of

certificates of compliance for high integrity containers (HICs), shipping cask

licenses, and burial site regulations.

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The licensee's training program was comprehensive in content and effectively

addressed the regulations; personnel interviewed by the inspectors had an

acceptable understanding of the requirements. However, the inspectors identified

that current contractor technicians who are assigned to radwaste, and are

considered hazmat employees, had not been provided periodic training as required

by 49 CFR Part 172. The regulation requires all DOT defined hazmat employees to

receive recurrent training every three years. The last time contractor technicians

were trained at the station to meet these requirements was in 1991. Failure to

provide this training is a violation of 49 CFR 172.704(c)(2). (VIO 52-266/97008-

02(DRS); 50-301/97008-02(DRS)).

c. Conclusions

With the exception of the violation of DOT training requirements, the licensee's

transportation program was effective in meeting the revised DOT and NRC

transportation regulations for shipments of radioactive materials.

X1 Exit Meeting Summary

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The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on May 9,1997. The licensee acknowledged the findings

presented.

The licensee did not identify any information discussed as being proprietary.

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

A. J. Cayia, Plant Manager

E. J. Epstein, Health Physics Specialist

F. A. Flentje, Regulatory Specialist

' S. P. Johnson, Training Specialist

E. J. Lange, Health Physics Supervisor

T. A. Smith, Health Physics Supervisor

S. J. Thomas, Health Physics Specialist

P.' B. Tindall, Manager, Chemistry and Health Physics

INSPECTION PROCEDURES USED

IP 83750 Occupational Radiation Exposure

IP 86750 Solid Radioactive Waste Management and

Transportation of Radioactive Materials

IP 92904 Followup-Plant Support

Tl 2515/133 Implementation of Revised 49 CFR Parts 100-179

and 10 CFR part 71

LIST OF ITEMS OPENED AND CLOSED

Opened

50-266(301)/97008-01 VIO The failure to follow a Health Physics procedure and the

Radiologically Controlled Area Entry Permit is a violation

of Technical Specification 15.6.11

50 266(301)/97008-02 VIO The failure to provide hazmat training to contractor

HPTs working in redwaste once every three years is a

violation of 49 CFR 172.704(c)(2).

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LIST OF DOCUMENTS REVIEWED

Condition Report No. 97-1132

Condition Report No. 97-1525

Condition Report No. 97-1540

Health Physics Implementing Procedure, HPIP 1.51, Revision 6, "SRD-TLD Comparison"

Health Physics implementing Procedure, HPIP 1.60, Revision 7, " Calculating Shallow and

Deep Dose Rates Due to Skin Contamination" l

Health Physics Implementing Procedure, HPIP 1.70, Revision 3, " Completion of Forms

NRC-4 and NRC-5"

Health Physics Manual, HP 2.15, Revision 3, " Control of Personnel Exposure to High Level

Contamination, Hot Particles, and Activated or Fission Product Debris"

Health Physics Manual, HP 2.15.1, Revision 3, " Implementation of Control Program for

High Level Contamination, Hot Particies, and Activated or Fission Product Debris" !

Health Physics Manual, HP 2.15.2, Revision 3, " Action Levels for Response to incidents

involving High Levels of Contamination, Hot Particles and Activated or Fission Product

Debris" l

Health Physics Manual, HP 2.5.6, Revision 3, " Radiologically Controlled Area Entry Permit" i

Health Physics Radiologically Controlled Area Orientation Checklist

Nuclear Procedures Manual, NP 4.2.19, Revision 1, " General Rules for Work in a

Radiologically Controlled Area"

Personnel Dosimetry Records

Process Control Program Manual

Radioactive Material Handling Manual, RDW 17.3, Revision 50, " Processing Bead Resin by

Dewatering"

Radioactive Material Handling Manual, RDW 18.1.1, Revision 1, "10 CFR 61 Sampling

Program"

Radioactive Material Handling Manual, RDW 18.2, Revision 1, "Radwaste Classification,

Shipment Type and Waste Stability Determination"

Radiologically Controlled Area Entry Permit, January 1 - December 31,1997

Technical Specification 15.6.11, " Radiation Protection Program"

Updated Safety Analysis Report, June 1992, Section 11, " Waste Disposal and Radiation

Protection System"

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ML20148L445

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