IR 05000266/1988022

Insp Repts 50-266/88-22 & 50-301/88-20 on 880926-30. Violation & Weaknesses Noted.Major Areas Inspected:Liquid, Gaseous,Solid Radwaste Mgt & Transportation Programs. Programs for Controlling Radwastes Appear Effective

ML20195B366
Person / Time
Site:	Point Beach
Issue date:	10/21/1988
From:	Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20195B356	List: IR 05000266/1988022 ML20195B350 ML20195B359
References
50-266-88-22, 50-301-88-20, NUDOCS 8811010540
Download: ML20195B366 (10)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-266/88022(DRSS); 50-301/88020(ORSS)

Docket Nos. 50-266; 50-301 Licenses No. DPR-24; DPR-27 Licensee: Wisconsin Electic Power Company 231 West Michigan Milwaukee, WI 53201 Facility Name: Point Beach Nuclear Plant (PBNP)

Inspection At: PBNF; Units 1 and 2, Two Rivers, Wisconsin Inspection Conducted: Se tember 26-30, 1988 Inspector: . Pa /d [

Date /

Approved By: o re Chief /8 -J /-6d'

Facilities Radiation Protection Date Section Inspection Summary Inspection on September 26-30, 1988 (Reports No. 50-266/88022(DRSS);

No. 50-301/88020(DRSS))

Areas Inspected: Routine, unannounced inspection of the licensee's liquid, gaseous, solid radwaste management and transportation programs, including gasecus radwaste (IP 64724 and IP 84750), liquid radwaste (IP 84723 and IP 84750), solid radwaste (IP 84722 and IP 84750) and transportation (IP 86721 and IP 83750). Also reviewed were peevious open items, an allegation, and a hot particle even Results: The licensee's programs for controlling liquid, gaseous, solid radwaste and transportation activities appear effective. One violation was identified during review of an allegation concerning the general employee triining program. Also identified were weaknesses in the radwaste audit and filter replacement programs. The licensee is taking actions to correct the identified problem PDR ADOCK 05000'662 O PDC

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DETAILS Persons Contacted

• R. Bredvad, Health Physicist

• R. Bruno, Superintendent, Training C. Gates, Radwaste Supervisor E. Henshaw, Nuclear Plant Specialist, Chemistry

• D. Johnson, Superintendent, Health Physics

• J. Knorr, Regulatory Engineer -

• T. Koehler, General Superintendent M. Moseman, Specialist, Nuclear

• J. Zach, Plant Manager

• R. Leemon, NRC Resident Inspector The inspector also contacted other licensee employee * Denotes those present at the exit meetin . General The inspection, which began on September 26, 1988, was conducted to examine the licensee's gaseous, liquid, solid radwaste, and transportation management programs. Selected records of radioactive liquid and gaseous releases were reviewed, as were the licensee's semiannual effluent reports. The inspection included visual inspection of selected gaseous, particulate, and iodine sampling stations and monitor locations. A visit was made to the control room to observe monitor printout readings and alarm / trip setpoints. Calibration data for the gaseous and liquid effluent monitors were reviewe . l.icensee Actions on Previous Inspection Findings (IP 92701)

(Closed) Open Item 50-266/88003-04: 50-301/88003-0_4: Need to strengthen licensee followup of problems identified in Radiological Event Reports

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(RERs). The licensee initiated an administrative procedure (NE 4.9)

i that requires corporate personnel to perform a root cause evaluation of all RERs. In addition, a dedicated specialist onsite will perform Independent evaluations to ensure followup of each RER.

Liquids and Liquid Radioactive Wastes (IP 84723, 84750)

The licensee's reactor liquids and liquid radwaste management programs l were reviewed, including: determination whether changes to equipment and i procedures were in accordance with 10 CFR 50.59; determination whether liquid radioactive waste effluents were in accordance with regulatory

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requirements; adequacy of required records, reports, and notifications;

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determination whether process and effluent monitors are maintained, calibrated, and operated as required; and experience concerning identification and correction of programmatic weaknesse All liquid releases, both batch and continuous, are discharged by one of three monitored pathways to the circul:tir; . ster which discharges to the lake. The three monitored pathways are the retention pond effluent (including sewage treatment plant effluent and turbine building floor drains), the Unit I service water return, and the Unit 2 service water return (including their respective steam generator blowdown). The four CVCS monitor tanks, and the two waste distillate tanks discharge into the service water returns. Releases via the service water are also typically monitored upstream before dilution with the service wate Quantification of liquid release is based on analyses of samples collected from each batch before release and samples collected twice weekly from continuous release path The inspector reviewed selected records of and procedures for radioactive liquid effluent sampling and analysis for 1988, and semiannual effluent reports for 1987 and 1988 through June. The pathways sampled and the analyses performed appear to comply with technical specifications. In

1987, about 0.75 Ci of gross beta gamma activity (excluding tritium) and 700 Ci of tritium were released in liquid effluent f om both units

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combined; for the first six months of 1988, the gross beta gamma and tritium release were 0.5 and 152 C1, respectively. Activity (excludi tritium) in liquids has continued to decline from about 1.9 Ci in 1985 to 0.85 Ci in 1986 to 0.75 Ci in 1987. This indicates good use of liquid waste processing systems. Tritium (which c&a not be removed by processing)

releases seen to have stabilized at about 700 Ci total per year for the last two years. Activity in liquid effluents were less than one percent of applicable annual RETS limit No violations or deviations were identifie . Gaseous Radioactive Waste (Ip 84524, 84750)

The licensee's gaseous radwaste management program was reviewed including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether gaseous radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; determination whether process and effluent monitors are maintained, calibrated, and operated as required; and experience concerning identification and correction of programmatic weaknesse The inspector reviewed selected records of radioactive gaseous effluent records and semiannual effluent reports for 1987 and 1988 to date. The pathways sampled and analyses performed appear to comply with technical specification requirements. All radioactive gaseous effluents are

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exhausted by one of four vents. These are the auxiliary building vents (including waste gas decay tank (WGDT) effluent and air ejector effluent), the drumming area vent (including spent fuel pool surface exhaust system), Unit I containment purge vent, and Unit 2 containment purge vent (including gas stripper building ventilation). The licensee's gaseous effluent sampling and monitoring program includes continuous monitoring of the auxiliary building vent, Units 1 and 2 containment purge vents, and the drumming area vent. In addition, weekly grab samples are collected from the auxiliary building vent, Units 1 and 2 gas stripper building ventilation, and the drumming area vent; the samples are isotoically analyzed. Grab samples from the Units 1 and 2 containment purge vents are collected when the system is ventin The containment noble gas monitors initiate containment ventilation isolation upon detection of high activity. The auxiliary building vent stack noble gas monitor high alarm shuts the vent gas release valve and initiates exhaust vent filtration through a filter bank. The control room noble gas monitor high alarm shifts control room ventilation to 100% recirculation. All process monitoring systems provide indication on the control room computer terminal. All gaseous releases are quantified using effluent monitors. No discrepancies from the technical specification surveillance requirements were identifie The inspector selectively reviewed the licensee's calculations and records of gaseous releases for 1988 to date. No releases exceeding technical specification release limits were identifie Gaseous releases for this period average less than one percent of the technical specification limi No violations or deviations were identifie . Radioactive Iodine and particulate Releases The licensee's calculations and records of iodine and particulate (with half-lives longer than eight days) releases for 1988 to date were selectively reviewed. According to licensee statements, and licensee records reviewed by the inspector, there were no releases greater than technical specification limits. Releases are quantified from the analysis of isokinetically collected iodine and particulate samples collected weekly from the auxiliary building and drumming area vent Units 1 and 2 containment purge system releases are based on low volume air samples collected when venting the containment. Releases for this period averaged less than one percent of the technical specification limi No violations or deviations were identifie . Effluent Control Instrumentation Selected gaseous and liquid effluent / process monitor surveillance records for calendar year 1987 and 1988 to date were reviewed for compliance with technical specification and procedural re.luirements for operability, trip setpoint, calibrations, and functional testing. Some of the following monitors were examined and were found to have met the above noted requirement , - - - - _ _ _ . - - - - - - - - - - - - - - -

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v Containment Noble Gas Monitor (RE-212)

Auxiliary Building Vent Stack Noble Gas Monitor (RE-214)

Waste Disposal System Discharge Liquid Process Monitor (RE-218)

Steam Generator Blowdown Liquid Process Monitor (RE-219)

Steam Generator Blowdown Tank Outlet Liquid Process Monitor (RE-222)

Drumming Area Vent (RE-221)

Units 1 and 2 Condenser Air Ejectori (RE-215)

Units 1 and 2 Service Water Monitors (RE-229)

Auxiliary Building Vent (SPING 21 & 22)

Units 1 and 2 Containment Purge Vents (SPING 21 & 22)

Liquid and gaseous monitors (some of which are used to quantify releases)

which rerform indication, alarm, and control functions were found to be calibrated in accordance with procedural requirements. Calibration constants are established to relate detector readout values to activit Calibrations were performed at technical specification required frequencies. Calibrations and alert and alarm setpoint methodologies are as described in tha 00CM. Alert setpoints are normally set to alarm at E

two times established steady-state readings and are intended to identify changing plant conditions which may need corrective action. The alarm setpoints ',7 noble gas and liquid effluent monitors are set to alarm at or below the point where calculated concentrations at the nearest unrestricted area reach 10 CFR 20, Appendix B, Table II limit No violations or deviations were identifie . Reactor and Secondary Coolant Radiochemistry The inspector selectively reviewed the licensee's reactor coolant and secondary coolant radiochemistry results for 1988 to date to determine compliance with technical specification requirements for coolant activities and surveillance. Reactor coolant activities were less than technical specification limits for Units 1 and No discrepancies from the radioactivity technical specification surveillance requirements were identifie No violations or deviations were identifie . Solid Radioactive Waste (IP 84722 and 84750)

The inspector reviewed the licensee's solid radwaste program for compliance with waste generator requirements in 10 CFR 20.311 and 61.5 Included in this review was an examination of waste manifests, scaling factor and curies-content determinations, and management oversigh Solid radioactive waste consists almost solely of spent resins and evaporator concentrates which are solidified using the Chem-Nuclear portable cement solidification system. Curie content determinations are based on samples removed from waste streams. DAW is placed into 52 gallon steel drums (strong tight containers) and transported

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to a vendor operated super compactor before final shipment to a burial site. A selective review of manifests for burial site shipments made in 1987 and 1988 to date indicated they contained all information required by 10 CFR 20.311(b) and (c).

The Chem-Nuclear system is vendor controlled and operated in accordance with an approved Process Control Pr:g = (PCP). The purpose of the PCP is to established processing conditions assuruq safe and effective solidification of radioactive materials. The provisions of the PCP require that proce h res provide assurance that the solidification process is conducted within established process parameters and the final waste product meets appropriate waste characteristic requirements for solidified wastes. To meet these requirements, the vendor uses Procedure SD-OP-003-307, PCP for CNSI Cement Solidification at Point Beach. This procedure and others concerning the use of the solidification system were reviewed during the inspection; no problems were note The licensee has shipped Class A, B and C waste. The waste is shipped either as unstable waste or stable waste in high integrity containers; procedures require verification of dewatering and solidificatio The inspector identified no problems with the licensee'. waste characterization and stabilization pregram No violations or deviations were identifie . Dry Radioactive Waste Volume Reduction Program The licensee does not segregate or survey controlled zone waste to reduce radioactive waste volume; however, waste volume reduction is accomplished by reducing the material and equipment allowed into the controlled zone and by using a vendor super compactor with increased compaction efficienc No violations or deviations were identifie . Transportation of Radioactive Materials (IP 86721 and IP 83750)

The inspector reviewed the licensee's radioactive materials transportation program to determine whether shipments are prepared and made in compliance with NRC and DOT requirements and with the licensee's administrative and implementing procedure Most of the radioactive material shipped from the station, by volume and by activity, is low specific activity (LSA) DAW and solidified wast In 1987, approximately 19 shipments of radwaste (totaling approximately 1400 C1) were made, with most of the radwaste sent to the burial site in Barnwell, NC. Through June 1988, nine shipments had been mad _

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The inspector selectively reviewed portions of the solid radwaste shipment records for 1987 and 1988 to date, and the 1987 and 1988 semiannual waste reports. The information on the shipping papers appears to satisfy NRC, DOT, and burial site requirements. According to the licensee, there have been no transportation incidents involving these shipment No violations or deviations were identifie . Audits and Appraisals The Quality Assurance Department does not conduct audits to ensure performance of required surveillance tests and calibrations on the liquid and gaseous effluent monitoring systems. Although a yearly corporate audit is performed of radiation safety activiti:ts, no audits have been conducted of liquid and gaseous radwaste activities, and the last audit conducted by the licensee of solid radwaste and transportation activities was in April 1987. Although no significant weaknesses in the radwaste and transportation programs were identified, the inspector indicated that the lack of an audit program to perform periodic surveillance of these activities is a weakness. This matter was discussed at the exit meeting and will be further reviewed during a future inspection. (0 pen Item 266/88022-01; 301/88020-01)

No violattuns or deviations were identifie . Air Cleaning Systems (IP 84724, 84750)

Although technical specifications require only testing of control room filter systems, all systems are tested annually. The in place testing includes DOP testing of HEPA filters, freon in place testing of charcoal adsorbers and laboratory testing of charcoal adsorber samples for methyl iodide removal efficiency. The ventilation systems tested include containment purge (1F11A, 2F11A, IF11B, 2F118), control room emergency ventilation (F16), auxiliary building ventilation (F20, F21, F23, F25, F29), drumming area ventilation (F26), combined air ejector vent (F30),

and containment cleaning (1F32 and 2F32). The inspector noted that results of tests performed in April 1987 on two charcoal trains on the Unit 1 containment purge were below the procedural criteria of 80% removal efficiency. Procedure HPIP 11.50, "Filter Testing," requires that charcoal adsorbers be replaced when the efficiency is below 80%.

Although the licensee initiated a maintenance work request for the replacement of these filters, their installation had not been accomplished at the time of this inspectio This matter was discussed with the licensee representatives and at the exit meeting. (0 pen Item 266/77922-02; 301/88020-02)

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1 Radiation Protection Training Incident (Allegation No. RIII-88-A-126)

NRC Region III received an allegation that workers had cheated during a September 13, 1988 General Employee Training examination for incoming workers because the examination was not adequately proctored. The ;

allegction vc: forverdad to the licc:::ce by letter dated September 22, .

, 1988, for immediate review in order to expedite any needed corrective '

action During this inspcetion, the inspector reviewed the licensee's preliminary I findings concerning the allegation, and contacted station training personnel responsible for General Employee Training and an NRC employee (NRR) who participated in the specific training class referenced in the allegation. The inspector also reviewed personnel training and test i records, relevant training procedures, a prr,vious Nonconformance Report !

concerning a similar problem, and corrective actions taken to dat '

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The NRC employee who participated in the class and who took the i examination confirmed that the instructor was not always present in the l classroom during the examination; however, he could not confirm that !

cheating occurred because he was not seated near those who allegedly cheated on the test during the instructor's absence. In a similar ;

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incident, which occurred in March 1987, an instructor was not present during an examination and two students were found to have cheated. That i

, incident wrs documented in a Nonconformance Report; the licensee found !

, that the instructor had not followed procedures which require that an !

l instructor be present throughout the examination. Corrective actions ,

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resulting from the 1987 incident were apparently ineffective since it was '

determined by the licensee and confirmed by the NRR representative that :

the instructor was not present throughout the examination give on !

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September 13, 1988. This is a violation of Procedure TRNG 9.0-6.3

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(Violation 266/88022-01; 301/88020-01). This matter was discussed at the exit meeting and will be reviewed at a future inspectio i The licensee's immediate corrective actions for the latest incident included requiring that all class participants who took the examination !

l be retrained and retested. The inspector verified that none of the !

25 persons who participated in the class had entered the plant. At (

I the time of the inspection, the inspector also verified that eight j of the 25 class participants had been retrained and retested, the !

remainder had notes placed into their personal file prohibiting I

plant access until successful cumpletion of the retrainin [

l retesting program. These corrective actions are adequate to address !

immediate potential problems due to this inciden The licensee's i corrective actions to avoid future similar incidents will be reviewed i during a future inspection, t i This allegation remains open pending receipt and review cf the licensee's I

response to the September 22, 1988 lette l

"Hot" Particle Event

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The inspector reviewed the licensee's investigation of an incident in [

which a minute discrete radioactive particle was found on the Index l finger of a canvas work glove worn by an employee. After removal, the '

1 particle was analyzed and found to contain 39 microcuries of fuel

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frageent isotopes cesium-134 and 137, and ruthenium-106/ rhodium-10 I The licensee conducted an investigation of the individuals' activities involved in the incide.1t shortly after the incident occurred. The investigation included interviews with the individuals involved, and review of their work activities frisking habit On the evening of May 12, 1988, the Plant Manager (PM) and a Radiation Control Operater (RCO) conducted containment inspection work; the RCO was assigned to provide health physics coverage. The inspection required t entry into the steam generator and the reactor coolant pump and pressurizer f cubicles; entry and exi'. times were logged. While surveying a plastic bag containing used canva shoe covers which had been worn by the PM in l the "B" reactor coolant pump cubicle, the RCO found a t.igh radiation field ;

caused by contamination on the index finger of the RCO's glove. The RCO immediately removed the glove, wrapped it into a clean rubber glove, and transferred it to the HP station where the contamination was identified as t a hot particle; no other hot particles were found on either person's skin !

or protective clothing. The hot particle was quantified by acid i dissolution and gamma spectroscopic analysis, i

f As a result of their investigation, the licensee speculates that the hot [

particle was transferred to the RCO's glove while assisting in the removal of the PM's shoe covers after he exited the "B" reactor coolant pump cubicle. The licensee conservatively estimated that the RCO wore the :

contaminated glove with the hot particle for four minutes and that the t PM had the hot particle on his shoe for 12 minutes. The licensee

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i calculated the beta gamma dose to the RCO's finger and the RM's foot !

(averaged over one square centimeter and accounting for shielding

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a i thickness) to be 4.27 rems and 426 mrem, respectively. Extensive surveys i were performed in the "B" reactor coolant pump cubicle and on the 66 foot level of the containment after the incident; no other hot particles were foun .

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The inspector interviewed the radiation protection manager, discussed the licensee's investigation results and calculational methods, and performed i independent calculations. The skin doses calculated by the licensee were

! less than regulatory limits. No problems with the licensee's i investigation or calculations were note No violations or deviations were identifie . Exit Meeting

! The inspector met with licensee representatives (denoted in Section 1)

at the conclusion of the onsite inspection on September 30, 1988. The inspector summarized the scope and firidings of the inspection. The

. inspector also discussed the likely informational content of the

! inspection report with regard to docurents and processes reviewed by the inspector curing the inspection. The licensee did not identify an/ such documents or processes as proprietary. The following matters were discussed specifically by the inspector:

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, The violation concerning failure to follow a training procedural requirement (Section 14). The apparent need to develop an audit program for the radwaste and transportation programs (Section 12), The need to expedite replacement of filters found to have less than required removal efficiencies (Section 13).

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