ML20212E902
| ML20212E902 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/05/1986 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Hind J, James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CON-NRC-86-119 VPNPD-86-497, NUDOCS 8701050525 | |
| Download: ML20212E902 (5) | |
Text
-
1 Wisconsin Electnc m coum 231 W. MICHIGAN, P.o. BOX 2046, MILWAUKEE,WI S3201 (414)277-2345 VPNPD-86-497 NRC-86-119 December 5, 1986 Mr. James R. Keppler, Regional Administrator Office of Inspection & Enforcement Region III U.S. NUCLEAR REGULATORY COMMISSION 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention:
Jack A. Hind, Director Division of Radiation Safety and Safeguards
Dear Mr. Hind:
DOCKETS 50-266 AND 50-301 RESPONSE TO INSPECTION REPORT 50-266/86016 (DRSS) AND 50-301/86015 (DRSS)
POINT BEACH NUCLEAR PLANT This is in response to your letter dated November 5,
- 1986, regarding inspections conducted by Mr. R. A. Paul of your office 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 some perceived programmatic weaknesses in the Point Beach Nuclear Plant radiation protection program.
The violations identified in the Inspection Report resulted from circumstances associated with an internal uptake of radionuclides by a PBNP auxiliary operator.
In response to the event, PBNP conducted a detailed investigation of the event to determine the probable cause and consequences.
The detailed investigation identified appropriate corrective actions.
Response to Violation No. 1 The first violation concerned a deviation from 10 CFR 20.201(b) which requires that surveys be performed which are reasonable under the circumstances to evaluate the extent of radiation hazards.
The Inspection Report specifies that, contrary to this
- (
8701050525 861205 73(430 PDR ADOCK 05000266 g g 1986 Q
]
=
Mr. James R. Keppler December 5, 1986 Page 2 requirement, adequate surveys were not performed to determine radiological conditions to support a July 19, 1986 changeout of a PBNP waste evaporator feed filter.
The frequency and nature of radiation and contamination surveys conducted in the blowdown waste evaporator feed filter cubicle was determined based upon j
a review of cubicle work activities and historical survey data.
The established survey frequency was determined reasonable to evaluate the hazards present in the waste evaporator filter cubicle and to provide adequate protection to health physics qualified personnel.
Entry into this filter cubicle could not be accomplished by non-health physics qualified personnel without a specific RWP survey.
This survey schedule had permitted effective filter removal for several years without
-incident or radiological hazard to PBNP personnel.
In response to.the July 19, 1986 ircident, in which activities l
performed in the blowdown evaporator feed filter cubicle were suspected as probable cause. for an internal radionuclide uptake by an auxiliary operator, the frequency of radiation and contamination surveys conducted in the waste evaporator feed filter cubicle was increased.
The need to perform more thorough surveys of this area and other areas subject to changing radiological conditions was discussed with health physics personnel.
Additional protective clothing requirements a
including plastic suit top, hood, respirator, and rubber gloves are now required of operations personnel involved with routine shift blowdown evaporator filter changes.
With the increased I
frequency and adequacy of surveys conducted in the feed filter cubicle and enhanced protective _ clothing requirements, PBNP has completed its corrective action in response to NRC concerns regarding compliance with the applicable regulation.
I In addition to these actions, PBNP has established an evaluation
[
program to determine the actual need for the utilization of blow-down evaporator bottoms loop and feed filters.
PBNP has operated for approximately two months without these filters installed and j
has therefore eliminated the need for filter changeouts.
Our preliminary assessme.at indicates that these filters can be perma-4 nently eliminated from the waste evaporator process system.
PBNP is in the process of revising Health Physics Procedure HP 2.5 " Radiation Work Permits."
The revision will include a redefinition and restriction of activities which may be per-formed without utilization of an RWP.
It is anticipated that activities such as blowdown evaporator filter changeouts will be required by the revised procedure to be done in accordance with a standing RWP or specific RWP.
Implementation of revised procedure HP 2.5 is expected to be accomplished not later than March 31, 1987.
RWP requirements for work activities of the nature of blowdown filter changeouts will ensure timely and adequate determination of radiological hazards.
l c,.
A Mr.-James R. Keppler December 5,.1986 Page 3 Response-to Violation No. 2 The second violation involved the failure to follow Health Physics Procedure HP 1.11 which requires certain actions to be taken in response to a portal contamination monitor alarm.
Security personnel responsible for responding to portal monitor alarms were counseled on the need to comply with procedures.
HP 1.11 has'been revised to better define specific responsi-bilities regarding response to portal monitor alarms.
The revised procedure limits security personnel involvement in i
decision-making regarding personnel contamination and specifi-cally assigns the responsibility to health physics supervision or the Duty Shift Superintendent.
Training Needs Analysis j
Number 86-0989 has been initiated by the Training Group to address the need for training of security personnel in the initial response to a portal contamination monitor alarm as
' identified in revised HP 1.11.
Although formal training has j
not yet been provided, security personnel are currently imple-menting the revised procedure.
This training will be accom-plished by March 1, 1987.
Health Physics Procedure HP 2.1.2 i
has also been revised to clarify employee responsibilities for flisking, notification of appropriate personnel when personal i
i contamination is encountered, and documentation requirements.
With the completion of the formal training, PBNP will have completed its corrective action in response to NRC concerns i
regarding compliance with procedures.
Beyond these corrective actions, other changes to plant facili-ties and equipment will further improve. contamination control at PBNP.
The arrangement of the portal contamination monitors at the gatehouse has been improved.
An area at the entrance to the monitors has been identified to prevent a person from entering the monitor area while another person is in the i
monitor.
The purpose of this action is to allow the security personnel responsible for observing the portal monitors more effective control when large numbers of personnel are exiting through the gatehouse.
This action also decreases the poten-i tial for erroneous monitor readings caused by ambient background radiation in the area of the monitors.
A Modification Request has been submitted and approved to evaluate the installation of a portal monitor alarm light panel to be positioned clearly i
i visible to security personnel.
Improvement of the portal l
monitors by modifying the current monitors to include head contamination detectors is also in progress.
An evaluation is currently being conducted of whole body contamination frisker booths as replacements for the handheld frisker probes currently used at the exit from the PBNP radio-1 logical controlled zone.
It is anticipated that these units will be procured and installed in 1987.
The use of whole body l
frisker booths in lieu of handheld friskers is expected to l
I
~.
1 Mr. James R. Keppler December 5, 1986 Page 4 improve personnel contamination control at the exit from the radiological controlled zone.
These described corrective actions and facility improvements are expected to ensure that PBNP personnel are prohibited from exiting the site with measurable quantities of contamination.
Additional Information In addition to the above described corrective actions, a management letter dated September 16, 1986 was issued to the auxiliary operator involved in the incident which expressed concern regarding radiological control practices and habits which may have contributed to the internal radionuclide uptake and expressed concerns regarding his conduct and judgement upon
-exiting PBNP after having alarmed the portal monitors.
The employee has been instructed as to his responsibility to follow health physics procedures and practices.
The Inspection Report contains apparent minor inaccuracies in the description of events associated with the radionuclide intake incident.
The first paragraph on page 6 and the last paragraph on page 8 contain sentences which indicate the involved auxiliary operator placed his personal clothing inside his controlled side locker.
PENP procedures prohibits the placement or storage of personal clothing in controlled side lockers, and from our investigation we have no reason to believe this procedure was violated by the auxiliary operator.
The second full paragraph on page 3 states that small quantities of radioactive material were detected in the employee's house, personal clothing, and automobile.
The surveys were taken as stated, but no detectable radiation was identified in the employee's automobile.
The Inspection Report identified a number of perceived program-matic weaknesses including the reuse of protective clothing, lack of full-time health physics coverage during off-shift hours, and health physics qualified auxiliary operator activ-l ities conducted exempt from RWP requirements.
l 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 r
recommendations in those areas of apparent weakness.
Addition-ally, a newly hired but experienced corporate health physicist, who could provide an independent assessment, conducted a specific review and audit of health physics activities and practices accomplished by PBNP auxiliary operators.
The i
recommendations of these reviewers will be implemented as appropriate in a time frame commensurate with the identified needs and available resources.
1
)
A Mr. James R. Keppler December 5, 1986 Page 5 Our response to the programmatic weaknesses identified in the Inspection Report will be formulated pending management review of recommendations offered by the radiation protection program reviewers.
A response will be submitted within 60 days of this letter.
If you have any questions regarding our response to these items, please contact us.
Very truly yours, w'j
,e bbU 1 /
C. W.
Fay Vice President Nuclear Power bjm Copy to NRC Resident Inspector i
l I
l t
i