ML20210D161

Responds to NRC Re Violations Noted in Insp Repts 50-266/86-16 & 50-301/86-15 on 860807-08 & 1016-17. Corrective Actions:Staffing,Recruitment,Development,Mgt Commitment & Resources Re Health Physics Coverage Evaluated

ML20210D161
Person / Time
Site:	Point Beach
Issue date:	02/04/1987
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-87-011, CON-NRC-87-11 VPNPD-87-037, VPNPD-87-37, NUDOCS 8702100026
Download: ML20210D161 (4)

Text

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I%SCORSin Electnc eom couen 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 (414)221-2345 VPNPD-87-037 NRC-87-011 February 4, 1987 Document Control Desk U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C. 20555 r Gentlemen:

DOCKETS 50-266 AND 50-301 ADDITIONAL RESPONSE TO INSPECTION REPORT

. 50-266/86016(DRSS) AND 50-301/86015(DRSS)

} POINT BEACH NUCLEAR PLANT l

This is in response to your letter dated November 5, 1986 regarding inspections conducted on August 7-8 and October 16-17, 1986 of activities at Point Beach Nuclear Plant and the enforcement conference conducted at the NRC Region III office on September 17, 1986. The inspection report identified two violations and certain perceived programmatic weaknessds in the Point Beach Nuclear Plant radiation protection program.

Ou;r December 5, 1986 letter provided our response to the two violations reported in the inspection report. In addition to the response to violations, we committed to respond to the programmatic weaknesses identified in the inspection report within sixty days of our December 5, 1986 letter.

As we reported in our December 5 response to the two violations, a review committee was formed consisting of the plant health physicist, radiochemist, and corporate health physicist to evaluate the current radiation protection program and to make recommendations in those areas of apparent weakness. Additionally, the Nuclear Power Department has recently hired an additional experienced corporate health physicist, who was able to provide a fresh and independent 00 8702100026 870204 g:25 PDR ADCCK 05000266 #[0 G PDR

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f Document Control Desk-February 4, 1987 Page 2 j assessment of Point Beach Nuclear Plant activities. He

. conducted a review and audit of plant health physics activities, as well as the normal practices by Point Beach i

auxiliary operators. The recommendations of these reviewers will be implemented as appropriate in a time frame commensurate with the identified ne'ed and available resources.

j Response to Programmatic Weaknesses The inspection report identifies certain perceived programmatic weaknesses including (a) lack of full-time health physics

! coverage during off-shift hours, (b) certain activities conducted by health physics qualified auxiliary operators exempt from RWP requirements, and (c) the reuse of protective clothing. Specific actions have been initiated in response to NRC concerns and to Point Beach Nuclear Plant review committee l recommendations..

It is currently our objective to maintain the health physics  :

!' qualification status of auxiliary operators. A contributing r factor responsible for the success of the Point Beach Nuclear Plant radiation protection program has been our practice of qualifying auxiliary operators in' health physics-related areas. '

The continued success of the program will be dependent upon auxiliary operators' knowledge and understanding of appropriate

! health physics practices. We believe the reduction of auxiliary operator personnel qualifications is inappropriate at this time. Due to increased responsibilities and associated increased regulatory ~ requirements, it has become more difficult 3

and more time-consuming for operations = personnel to respond to unusual health physics-related tasks. Along with the increases in health physics requirements, a concurrent increase in operation proceduralization and documentation has occurred.

j. Due to this increased work load, operator attention to abnormal or non-routine health physics responsibilities may detract i from operating responsibilities or may cause health physics tasks to be performed in a non-optimal manner. To accommodate the current and anticipated increased operator work load and to enhance our radiation protection program to ensure continued n success, we intend to implement full-time health physics 4 coverage.

Accordingly, Point Beach is currently evaluating the staffing, i recruitment, development, management commitment, and resources which would be required to accommodate continuous on-site

health physics coverage. Following completion of this 1-l I

o Document Control Desk February 4, 1987 Page 3 evaluation, a determination will be made regarding the need and priority of events to be accomplished to achieve continuous health physics coverage. An initial assessment indicates that at least two years will be required to recruit and fully qualify additional health physics personnel necessary to implement continuous on-site health physics coverage.

Point Beach Nuclear Plant is in the process of evaluating Health Physics Procedure 2.5, " Radiation Work Permits". In accordance with Technical Specifications, the procedure permits the accomplishment of certain work activities by health physics qualified personnel without an RWP. HP 2.5 will be reviewed for purposes of redefining, restricting, or eliminating activities which may be performed by health physics qualified personnel without the use of a radiation work permit.

Activities currently RWP-exempt will be evaluated to determine whether these activities warrant a specific RWP or standing RWP. We anticipate the adoption and utilization of a standing RWP system to better control the routine activities of auxiliary operators and other health physics qualified personnel.

Standing RWP's for appropriate work activities will be issued and approved by the responsible group head and the health physicist. The standing RWP instructions will provide guidance to the employee directed toward preventing recurrence of events such as noted in the November 5, 1986 inspection report.

Limiting conditions will be identified in the standing RWP to prevent the performance of work activities that could involve or result in occurrences of radiological significance. An appropriate revision to HP 2.5 will be implemented by March 31, 1987.

Point Beach Nuclear Plant has implemented changes to the protective clothing reuse policy. A policy memorandum on the use of controlled zone protective clothing was issued on October 13, 1986 to all Point Beach personnel and contractor supervisors. The new policy was also discussed with plant personnel at a plant-wide safety meeting. The policy requires that each person frisk protective coveralls prior to being placed in controlled zone lockers. Friskers have been I installed in the exit hallway from the primary auxiliary building to facilitate this frisking requirement. Protective clothing contamination limits have been technically re-evaluated l

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Document Control Desk February 4, 1987 Page 4 and are posted at the frisker location. The policy also identified personnel in certain job classifications who are now required, as a minimum, to discard their protective coveralls These job classifications at the end of each work shift.

include employees that are likely to enter contaminated areas during their work shift. A revision.to Health Physics Procedure HP 2.7, " General Use of Protective Clothing", to incorporate appropriate policy requirements is in process.

If you have any questions or require additional information regarding our response to these items, please contact me.

Very truly ours,

[b C. W. Fy '

Vice P esident Nuclear Power Copies to Regional Administrator - Region III Att: Jack A. Hind, Director Division of Radiation Safety & Safeguards Resident Inspector