IR 05000266/1997008: Difference between revisions

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{{Adams
{{Adams
| number = ML20148L445
| number = ML20151K461
| issue date = 06/09/1997
| issue date = 07/28/1997
| title = 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
| title = Ack Receipt of 970708 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-266/97-08 & 50-301/97-08
| author name =  
| author name = Grobe J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name =  
| addressee name = Patulski S
| addressee affiliation =  
| addressee affiliation = WISCONSIN ELECTRIC POWER CO.
| docket = 05000266, 05000301
| docket = 05000266, 05000301
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-266-97-08, 50-266-97-8, 50-301-97-08, 50-301-97-8, NUDOCS 9706190249
| document report number = 50-266-97-08, 50-266-97-8, 50-301-97-08, 50-301-97-8, NUDOCS 9708060086
| package number = ML20148L382
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 10
}}
}}


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July 28, 1997 l
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Mr. S. A. Patulski      I G!to Vice President Point Beach Nuclear Plant Wisconsin Electric Power Company 6610 Nuclear Road Two Rivers, WI 54241 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-206/97008(DRS;
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50-301/97008(DRS))
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==Dear Mr. Patuiski:==
l This will acknowledge receipt of your letter dated July 8,1997, in response to our
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letter dated June 9,1997, transmitting a Notice of Violation associated with: (1)
unauthorized entry by a painter into several areas which were posted as high radiation areas; and (2) the failure to provide training for contract health physics hazardous material workers in accordance with Department of Transportation requirements. We have
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, reviewed your corrective actions and have no further questions at this time. These  !
corrective actions may be examined during future inspections. I s
Sincerely, Original Signed by John A. Grobe  !
John A. Grobe, Acting Director Division of Reactor Safety Docket Nos. 50-266; 50-301 Licenses No. DPR-24; DPR-27 Enclosure: Ltr dtd 7/0/97 S. \g Point Beach to USNRC
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See Attached Distribution    gg O\
DOCUMENT NAME: G:DRS\ pol 071!7.DRS    M To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE Rill g Rlll E Rlli d ,Rlli ggl NAME Klambert:jpkSf,,- GShear $43& JMcCormick-B g 11GrobeL/QJ
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DATE 07/yg/97 ~
07//&/97 07/>f/97 07//6/5}7 OFF5 L RECOND COPY PDR ADOCK 05000266    11lkklk!!,!
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l      July 28, 1997  ;
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cc w/o encl: R. R. Grigg, President and    !
Chief Operating Officer, WEPCo
,    A. J. Cayia, Plant Manager    '
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U.S. NUCLEAR REGULATORY COMMISSION REGION lli
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l  Uc w/ encl: Virgil Kanable, Chief, Boiler Section  ,
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i   Cheryl L. Parrino, Chairman,    '
l Docket Nos: 50-266; 50 301 Licenses No: DPR-24; DPR-27
l   Wisconsin Public Service Commission l    State Liaison Officer $
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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 i
Distribution:
Approved by: G. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety l
l  Docket File w/ encl  Rlli PRR w/ encl  Rill Enf. Coordinator w/enct PUBLIC IE-01 w/ encl  SRI, Pt. Beach w/enct TSS w/enci OC/LFDCB w/enci  LPM, NRR w/enct  CAA1 w/ encl DRP w/ encl  A. B. Beach, Rlll w/enci DOCDESK w/ encl DRS w/ encl J. L. Caldwell, R!li w/ encl t
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9706190249 970609 E gDR ADOCK 05000266 I ena g    .
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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
Wisconsin i Electnc POWER COMPANY Point Beoch Nuclear Plant 6610 Nuclear Rd.. Two Rivers. WI 54241 NPL 97-0404    10 CFR 2.201
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radwaste program, transportation of radwaste, and the radiation protection program. The l following specific observations were made:
July 8,1997 Document Control Desk      i U. S. NUCLEAR REGULATORY COMMISSION Mail Station PI-137 Washington, DC 20555
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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
Ladies / Gentlemen:
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accordance with Department of Transportation requirements (Section R8.1).
DOCKETS 50-266 AND 50-301 REPLY TO A NOTICE OF VIOLATION    ,
NRC INSPECTION REPORT NOS. 50-266/97008 AND 301/97008    l POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 la a letter from Mr. John A. Grobe dated June 9,1997, the Nuclear Regulatory Commission forwarded the results of an inspection conducted by Messrs. K. Lambert and R. Paul of your staff ,
at our Point Beach Nuclear Plant between May 5-9,1997. This inspection report included a l Notice of Violation which identified two violations of NRC requirements.


* 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).
l We have reviewed the Notice of Violation and, pursuant to the provisions of 10 CFR 2.201, have I
prepared a written response to Violation 2, which is included as an attachment to this letter.


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Your letter indicates that we are not required to respond to Violation 1 unless the description does not accurately reflect our corrective actions or our position. Violation 1 is appropriately and accurately characterized. Therefore, we do not have any clarification or further information to provide regarding Violation 1.
* 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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We believe that the attached reply is responsive to the Notice of Violation and fulfills the requirements identified in your Jun: 9,1997, letter.
* 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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If you have any questions or require additional information regarding this response, please contact me.
* 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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Sincerely,
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ott Site Vice President Attachment l
cc: NRC Regional Administrator l
l  NRC Resident inspector WL M N
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Report Details i
R1 Radiological Protection and Chemistry (RP&C) Controls  I R1.1 Hiah Radiation Area Boundarv incident    l
      ' Inanection Scone (83750)
l 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 authorizatio 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 RW 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 area 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 period 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 3    l l
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j 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  )
Attachment to NPL 97-0404      i
, reconfigure the RCA access point so that individuals have to pass by a Health
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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  !
DOCKETS 50-266 AND 50-301 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT 50-266/97008 AND 50-301/97008 POINT BEACH NiiCLEAR PLANT UNITS 1 AND 2 During an inspection conducted between May 5-9,1997, two violations of NRC requirements were identified. Inspection Report 50-266/97008 and 50-301/97008 and the Notice of Violation (Notice)
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transmitted to Wisconsin Electric on June 9,1997, provide details regarding the violations.
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.
 
; 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 analysi I
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;  R1.2 External Dose Control and ALARA Imolementation
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j 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, i
hot particle evaluations, and hot spot reduction programs.


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The NRC inspection report indicated that unless Violation I does not accurately reflect Wisconsin Electric's corrective actions or ourposition, we are not required to reply to this Notice of Violation since the information previously provided in our letter of May 2,1997, in response to Inspection Reports 50-266/97004 and 50-301/97-004 adequately addresses this violation.
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. Findinas l
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 recentl 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.
Violation 1 is appropriately and accurately characterized. Therefore, we do not have any c!arification or further information to provide regarding Violation 1.


Violation 2 10 CFR 71.5(a) requires that a licensee who transports licensed material outside of the site of usage, as
; specified in the NRC license, or where transport is on public highways, or who delivers licensed
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Protective measures such as shielding or flushing of hot spots were performed to reduce dose rates when there could be an impact on worker dose Conclusions
material to a canier for transport. comply with the applicable requirements of the regulations appropriate l to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 through 189.
!  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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49 CFR 172.702 requires that each hazmat employer ensure that each hazmat employee is trained and l tested, and that no hazmat employee performs any function subject to the requirements of ( 49 CFR parts 171-177 unless trained, in accordance with Subpart H of 49 CFR 172, or works under the l direct supervision of a properly trained hazmat employee. The terms Hazmat Employer and Hazmat Employee are defined in 49 CFR 171.8.
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49 CFR 172.704(c)(2) requires that a hazmat employee receive the training required by Subpart H of 49 CFR Part 172 at least once every three years.
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j  performed. The licensee has good procedures in place to evaluate exposures from j  hot particles.


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Contrary to the above, since 1991, the licensee has not provided training for its contract health physics technician hazmat employees as required by Subpart H to 49 CFR Part 172, and the licensee otherwise meets the definition of hazmat employer in 49 CFR 171.8.


R1.3 Imalementation of the Solid Radioactive Waste Prooram l Insoection Scone (86750)
This is a Severity Level IV violation (Supplement 1).
!  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 Observations and Findinas j
I j Reason for Violatiort2
j  The licensee's radwaste included Dry Active Waste (DAW), evaporator a
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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
The violation occurred as a result of management failure to as ertain that the contract health physics technologists had received hazmat training prior to being assigned radwaste duties. This situation
]  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
continued until recently identified because contract health physics technologist recurrent training needs i
!  unexpected high alarm sounded and the transfer was automatically shutdown when
had not been included on the continuing training schedule.
;  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.


i 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 i
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 j-  integrity, l
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Corrective Actions Takern
 
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All radwaste transportation-related activities being performed by contract health physics i technologists were curtailed until they were under the direct supervision o'f personnel who had received the proper training within the required periodicity.


. 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.
2. A condition report (CR 97-1540) was issued to document the event.


R2 Status of RP&C Facilities and Equipment R2.1 General Tours of Primarv Auxiliarv Buildina (83750)
3. A review by the licensee radwaste supervisor determined there were no concerns associated with
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 dosimetr 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 insoection Scone (83750)
the adequacy of previous radioactive materials shipments associated with packaging, loading, i bracing, or overall transportation safety.
The inspectors reviewed training programs for licensee technicians and contract technicians. This included a review of training records, and discussions with technician 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-of .
. 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 implemente R7 Quality Assurance in RP&C activities R7.1 Health Physics Denartment Audit 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 report 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 progra R8 Miscellaneous RP&C lasues


R8.1 Imolementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71  l Insoection Scone (Tl 2515/133)
4. This violation was discussed during a meeting held between health physics management and the contract health physics site coordinator.
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 material 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 regulation .
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)). 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
5. The two current contract health physics technologists who are assigned to radwaste duties !
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received training on the requirements of 49 CFR 172 Subpart H on May 24,1997. Following l
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.
completion of the training, an examination was administered and both of the tested individuals l passed the examination. Training records are maintained in accordance with established records retention requirements.


The licensee did not identify any information discussed as being proprietar . - . _ . . - - - . - . ~ . - - . . . . . . - ~ . - . - ~  - . . . _ - - . - _ _ - - - . - ..
l 6. Subsequent to the above training, the materials used in the training were formalized into a
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training lesson plan. LP 2598, " DOT Hazmat," Revision 0, issued on July 7,1997.
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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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Contract health physics technologists have been included in the health physics continuing
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training program. This will ensure that contract health physics technologists receive the same continuing training as the licensee-employed health physics technologists.


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LIST OF DOCUMENTS REVIEWED Condition Report No. 97-1132 Condition Report No. 97-1525 Condition Report No. 97-1540
 
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The continuing training schedule has been revised to address long-term training and qualification needs of contract health physics technologists.
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" 10
9. The continuing training schedule is being maintained as a living document. This will ensure that training requirements having an established periodicity will be appropriately addressed in the future.
 
Corrective Actions to be Taken:
l There are no additional conective actions planned at this time.
 
Dale Full Compliance Willbe Achieved:
Full complianc e was achieved on May 24,1997, upon satisfactory completion of training for the
; contract health physics technologist assigned to radwaste duties.
 
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Revision as of 06:46, 25 October 2020

Ack Receipt of 970708 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-266/97-08 & 50-301/97-08
ML20151K461
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 07/28/1997
From: Grobe J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Patulski S
WISCONSIN ELECTRIC POWER CO.
References
50-266-97-08, 50-266-97-8, 50-301-97-08, 50-301-97-8, NUDOCS 9708060086
Download: ML20151K461 (2)
v • d • e


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July 28, 1997 l

Mr. S. A. Patulski I G!to Vice President Point Beach Nuclear Plant Wisconsin Electric Power Company 6610 Nuclear Road Two Rivers, WI 54241 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-206/97008(DRS;

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50-301/97008(DRS))

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Dear Mr. Patuiski:

l This will acknowledge receipt of your letter dated July 8,1997, in response to our

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letter dated June 9,1997, transmitting a Notice of Violation associated with: (1)

unauthorized entry by a painter into several areas which were posted as high radiation areas; and (2) the failure to provide training for contract health physics hazardous material workers in accordance with Department of Transportation requirements. We have

, reviewed your corrective actions and have no further questions at this time. These  !

corrective actions may be examined during future inspections. I s

Sincerely, Original Signed by John A. Grobe  !

John A. Grobe, Acting Director Division of Reactor Safety Docket Nos. 50-266; 50-301 Licenses No. DPR-24; DPR-27 Enclosure: Ltr dtd 7/0/97 S. \g Point Beach to USNRC

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See Attached Distribution gg O\

DOCUMENT NAME: G:DRS\ pol 071!7.DRS M To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE Rill g Rlll E Rlli d ,Rlli ggl NAME Klambert:jpkSf,,- GShear $43& JMcCormick-B g 11GrobeL/QJ

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DATE 07/yg/97 ~

07//&/97 07/>f/97 07//6/5}7 OFF5 L RECOND COPY PDR ADOCK 05000266 11lkklk!!,!

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l July 28, 1997  ;

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cc w/o encl: R. R. Grigg, President and  !

Chief Operating Officer, WEPCo

, A. J. Cayia, Plant Manager '

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l Uc w/ encl: Virgil Kanable, Chief, Boiler Section ,

i Cheryl L. Parrino, Chairman, '

l Wisconsin Public Service Commission l State Liaison Officer $

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Distribution:

l Docket File w/ encl Rlli PRR w/ encl Rill Enf. Coordinator w/enct PUBLIC IE-01 w/ encl SRI, Pt. Beach w/enct TSS w/enci OC/LFDCB w/enci LPM, NRR w/enct CAA1 w/ encl DRP w/ encl A. B. Beach, Rlll w/enci DOCDESK w/ encl DRS w/ encl J. L. Caldwell, R!li w/ encl t

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Wisconsin i Electnc POWER COMPANY Point Beoch Nuclear Plant 6610 Nuclear Rd.. Two Rivers. WI 54241 NPL 97-0404 10 CFR 2.201

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July 8,1997 Document Control Desk i U. S. NUCLEAR REGULATORY COMMISSION Mail Station PI-137 Washington, DC 20555

Ladies / Gentlemen:

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DOCKETS 50-266 AND 50-301 REPLY TO A NOTICE OF VIOLATION ,

NRC INSPECTION REPORT NOS. 50-266/97008 AND 301/97008 l POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 la a letter from Mr. John A. Grobe dated June 9,1997, the Nuclear Regulatory Commission forwarded the results of an inspection conducted by Messrs. K. Lambert and R. Paul of your staff ,

at our Point Beach Nuclear Plant between May 5-9,1997. This inspection report included a l Notice of Violation which identified two violations of NRC requirements.

l We have reviewed the Notice of Violation and, pursuant to the provisions of 10 CFR 2.201, have I

prepared a written response to Violation 2, which is included as an attachment to this letter.

Your letter indicates that we are not required to respond to Violation 1 unless the description does not accurately reflect our corrective actions or our position. Violation 1 is appropriately and accurately characterized. Therefore, we do not have any clarification or further information to provide regarding Violation 1.

We believe that the attached reply is responsive to the Notice of Violation and fulfills the requirements identified in your Jun: 9,1997, letter.

If you have any questions or require additional information regarding this response, please contact me.

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Sincerely,

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ott Site Vice President Attachment l

cc: NRC Regional Administrator l

l NRC Resident inspector WL M N

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Attachment to NPL 97-0404 i

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DOCKETS 50-266 AND 50-301 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT 50-266/97008 AND 50-301/97008 POINT BEACH NiiCLEAR PLANT UNITS 1 AND 2 During an inspection conducted between May 5-9,1997, two violations of NRC requirements were identified. Inspection Report 50-266/97008 and 50-301/97008 and the Notice of Violation (Notice)

transmitted to Wisconsin Electric on June 9,1997, provide details regarding the violations.

The NRC inspection report indicated that unless Violation I does not accurately reflect Wisconsin Electric's corrective actions or ourposition, we are not required to reply to this Notice of Violation since the information previously provided in our letter of May 2,1997, in response to Inspection Reports 50-266/97004 and 50-301/97-004 adequately addresses this violation.

Violation 1 is appropriately and accurately characterized. Therefore, we do not have any c!arification or further information to provide regarding Violation 1.

Violation 2 10 CFR 71.5(a) requires that a licensee who transports licensed material outside of the site of usage, as

specified in the NRC license, or where transport is on public highways, or who delivers licensed

material to a canier for transport. comply with the applicable requirements of the regulations appropriate l to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 through 189.

49 CFR 172.702 requires that each hazmat employer ensure that each hazmat employee is trained and l tested, and that no hazmat employee performs any function subject to the requirements of ( 49 CFR parts 171-177 unless trained, in accordance with Subpart H of 49 CFR 172, or works under the l direct supervision of a properly trained hazmat employee. The terms Hazmat Employer and Hazmat Employee are defined in 49 CFR 171.8.

49 CFR 172.704(c)(2) requires that a hazmat employee receive the training required by Subpart H of 49 CFR Part 172 at least once every three years.

Contrary to the above, since 1991, the licensee has not provided training for its contract health physics technician hazmat employees as required by Subpart H to 49 CFR Part 172, and the licensee otherwise meets the definition of hazmat employer in 49 CFR 171.8.

This is a Severity Level IV violation (Supplement 1).

I j Reason for Violatiort2

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The violation occurred as a result of management failure to as ertain that the contract health physics technologists had received hazmat training prior to being assigned radwaste duties. This situation

continued until recently identified because contract health physics technologist recurrent training needs i

had not been included on the continuing training schedule.

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'; Attachment to NPL 97-0404

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Corrective Actions Takern

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1.

All radwaste transportation-related activities being performed by contract health physics i technologists were curtailed until they were under the direct supervision o'f personnel who had received the proper training within the required periodicity.

2. A condition report (CR 97-1540) was issued to document the event.

3. A review by the licensee radwaste supervisor determined there were no concerns associated with

the adequacy of previous radioactive materials shipments associated with packaging, loading, i bracing, or overall transportation safety.

4. This violation was discussed during a meeting held between health physics management and the contract health physics site coordinator.

5. The two current contract health physics technologists who are assigned to radwaste duties !

received training on the requirements of 49 CFR 172 Subpart H on May 24,1997. Following l

completion of the training, an examination was administered and both of the tested individuals l passed the examination. Training records are maintained in accordance with established records retention requirements.

l 6. Subsequent to the above training, the materials used in the training were formalized into a

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training lesson plan. LP 2598, " DOT Hazmat," Revision 0, issued on July 7,1997.

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7.

Contract health physics technologists have been included in the health physics continuing

training program. This will ensure that contract health physics technologists receive the same continuing training as the licensee-employed health physics technologists.

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8.

The continuing training schedule has been revised to address long-term training and qualification needs of contract health physics technologists.

9. The continuing training schedule is being maintained as a living document. This will ensure that training requirements having an established periodicity will be appropriately addressed in the future.

Corrective Actions to be Taken:

l There are no additional conective actions planned at this time.

Dale Full Compliance Willbe Achieved:

Full complianc e was achieved on May 24,1997, upon satisfactory completion of training for the

contract health physics technologist assigned to radwaste duties.

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