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{{#Wiki_filter:A                                                       UNITED STATES
{{#Wiki_filter:A
9              C0
9
                                              NUCLEAR REGULATORY COMMISSION
C
    -.
-.
                                                                            Region III
0
                                                                    LISLE, ILLINOIS 60532
UNITED STATES
  MEMORANDUM TO:                                     Patrick Louden, Chief                                             (U         /C
NUCLEAR REGULATORY COMMISSION
                                                    Projects Branch 7
Region III
                                                      Division of Reactor Projects
LISLE, ILLINOIS 60532
  FROM:                                              Kenneth Riemer, Chief
MEMORANDUM TO:
                                                    Plant Support Branch                             i
FROM:
                                                    Division of Reactor Safety
SUBJECT:
  SUBJECT:                                          POINT BEACH NUCLEAR PLANT, UNITS 1 & 2
Patrick Louden, Chief  
                                                    DRS INPUT TO INTEGRATED REPORT 50-266/04-03;
(U  
                                                    50-301/04-03
/C
              Attached is the report input for Point Beach Nuclear Plant, Units 1 and 2, Inspection
Projects Branch 7
  Report 50-266/04-03; 50-301/04-03. Specifically, this report focused on occupational radiation
Division of Reactor Projects
  safety during the recent U1R28 refueling outage as related to the licensee's radiological access
Kenneth Riemer, Chief
  control and ALARA programs. I have reviewed this input and have determined it is ready for
Plant Support Branch  
  distribution to the licensee and dissemination to the public.
i
  Attachment:               Input to Inspection Report 50-266/04-03;
Division of Reactor Safety
                              50-301/04-03
POINT BEACH NUCLEAR PLANT, UNITS 1 & 2
  CONTACT:                  Ryan D. Alexander, DRS
DRS INPUT TO INTEGRATED REPORT 50-266/04-03;
                            (630) 829-9853
50-301/04-03
  DOCUMENT NAME: G:DRS\Point Beach Input to Report 04-03 RDA.wpd
Attached is the report input for Point Beach Nuclear Plant, Units 1 and 2, Inspection
  To receive a copy of this document, Indicate in the box: C * Copy without attachmentlenclosure E = Copy with attachment/enclosure N * No copy
Report 50-266/04-03; 50-301/04-03. Specifically, this report focused on occupational radiation
  lOFFICE lR111                                     W] R~ll                                                     L
safety during the recent U1R28 refueling outage as related to the licensee's radiological access
                                                                                                                I8}i
control and ALARA programs. I have reviewed this input and have determined it is ready for
    NAME               RAlexander:sd ?gn KRiemer 1,4
distribution to the licensee and dissemination to the public.
    DATE             05/1S104                             05P /04
Attachment:
                                                            OFFICIAL RECORD COPY
CONTACT:
                                                                                                                                            0-9
Input to Inspection Report 50-266/04-03;
50-301/04-03
Ryan D. Alexander, DRS
(630) 829-9853
DOCUMENT NAME: G:DRS\\Point Beach Input to Report 04-03 RDA.wpd
To receive a copy of this document, Indicate in the box:  
C * Copy without attachmentlenclosure  
E = Copy with attachment/enclosure  
N * No copy
lOFFICE  
lR111  
W] R~ll  
I8}i  
L
NAME  
RAlexander:sd ?gn KRiemer 1,4
DATE  
05/1S104  
05P /04
OFFICIAL RECORD COPY
0-9


                                            Cover Letter
Cover Letter
  /   No input, no significant findings.
/  
      Input below, no color or green findings were identified.
No input, no significant findings.
                                            Title Page
Input below, no color or green findings were identified.
Inspector:     R. D. Alexander, Radiation Specialist
Title Page
                                    SUMMARY OF FINDINGS
Inspector:  
R. D. Alexander, Radiation Specialist
SUMMARY OF FINDINGS
ADAMS boilerplate - Inspectable area: Radiation Protection
ADAMS boilerplate - Inspectable area: Radiation Protection
Modify second paragraph as follows:
Modify second paragraph as follows:
      The baseline inspection was conducted by a regional radiation specialist inspector.
The baseline inspection was conducted by a regional radiation specialist inspector.
A.     Insnector-ldentified and Self-Revealed Findings
A.  
      Cornerstones: Occupational and Public Radiation Safety (OS)
Insnector-ldentified and Self-Revealed Findings
      None
Cornerstones: Occupational and Public Radiation Safety (OS)
B.     Licensee-Identified Violations
None
        None
B.  
                                        REPORT DETAILS
Licensee-Identified Violations
2.     RADIATION SAFETY
None
      Cornerstone: Occupational Radiation Safety (OS)
REPORT DETAILS
2.  
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety (OS)
20S1 Access Control to Radiologically Significant Areas (71121.01)
20S1 Access Control to Radiologically Significant Areas (71121.01)
.1     Plant Walkdowns and Radiation Work Permit Reviews
.1  
  a.   Inspection Scone
Plant Walkdowns and Radiation Work Permit Reviews
      The inspectors reviewed licensee controls and surveys for selected radiation areas, high
a.  
        radiation areas and airborne radioactivity areas, as available, in the following
Inspection Scone
        radiologically significant work areas within the plant and reviewed work packages which
The inspectors reviewed licensee controls and surveys for selected radiation areas, high
        included associated licensee controls and surveys for these areas to determine if
radiation areas and airborne radioactivity areas, as available, in the following
        radiological controls (including postings and barricades) were acceptable:
radiologically significant work areas within the plant and reviewed work packages which
        *       Primary Auxiliary Building; and
included associated licensee controls and surveys for these areas to determine if
        *       Unit 1 Containment (all levels).
radiological controls (including postings and barricades) were acceptable:
        The inspectors reviewed the radiation work permits (RWP) and work packages used to
*  
        control work in these areas and other high radiation work areas to identify the work
Primary Auxiliary Building; and
        control instructions and control barriers that had been specified. Electronic dosimeter
*  
Unit 1 Containment (all levels).
The inspectors reviewed the radiation work permits (RWP) and work packages used to
control work in these areas and other high radiation work areas to identify the work
control instructions and control barriers that had been specified. Electronic dosimeter


    alarm set points for both integrated dose and dose rate were evaluated for conformity
alarm set points for both integrated dose and dose rate were evaluated for conformity
    with survey indications and plant policy. Workers were interviewed to assess their
with survey indications and plant policy. Workers were interviewed to assess their
    knowledge of the actions required when their electronic dosimeters noticeably
knowledge of the actions required when their electronic dosimeters noticeably
    malfunctioned or alarmed.
malfunctioned or alarmed.
    The inspectors walked down these areas to verify that the prescribed RWPs,
The inspectors walked down these areas to verify that the prescribed RWPs,
    procedures, and engineering controls were in place, that licensee surveys and postings
procedures, and engineering controls were in place, that licensee surveys and postings
    were complete and accurate, and that air samplers (if necessary) were properly located.
were complete and accurate, and that air samplers (if necessary) were properly located.
    The inspectors reviewed the RWPs and surveys for the steam generator nozzle dam
The inspectors reviewed the RWPs and surveys for the steam generator nozzle dam
    installation and eddy current testing activities which had the potential for creating an
installation and eddy current testing activities which had the potential for creating an
    airborne radioactivity area. The inspectors reviewed the RWPs to verify barrier integrity
airborne radioactivity area. The inspectors reviewed the RWPs to verify barrier integrity
    and engineering control contingency plans were in place and to determine if there was a
and engineering control contingency plans were in place and to determine if there was a
    potential for individual worker internal exposures of greater than 50 millirem committed
potential for individual worker internal exposures of greater than 50 millirem committed
    effective dose equivalent. This and other work activities/areas having a history of, or the
effective dose equivalent. This and other work activities/areas having a history of, or the
    potential for, airborne transuranic isotopes were evaluated to verify that the licensee had
potential for, airborne transuranic isotopes were evaluated to verify that the licensee had
    considered the potential for transuranic isotopes and provided appropriate worker
considered the potential for transuranic isotopes and provided appropriate worker
    protection.
protection.
    The inspectors assessed the adequacy of the licensee's internal dose assessment
The inspectors assessed the adequacy of the licensee's internal dose assessment
    process by reviewing personnel contamination event logs (and associated dose
process by reviewing personnel contamination event logs (and associated dose
    assessments) for the refueling outage. As of April 21, 2004, no personnel
assessments) for the refueling outage. As of April 21, 2004, no personnel
    contamination events had resulted in dose assignments of greater than 10 millirem
contamination events had resulted in dose assignments of greater than 10 millirem
    committed effective dose equivalent.
committed effective dose equivalent.
    These reviews represented four inspection samples.
These reviews represented four inspection samples.
  b. Findings
b.  
    No findings of significance were identified.
Findings
.2   Job-In-Progress Reviews
No findings of significance were identified.
  a. Inspection Scope
.2  
    The inspectors observed the following four activities that were being performed in
Job-In-Progress Reviews
    radiation areas, airborne radioactivity areas, or high radiation areas for observation of
a.  
    work activities that presented the greatest radiological risk to workers:
Inspection Scope
    *       1B Reactor Coolant Pump Motor Lift;
The inspectors observed the following four activities that were being performed in
    *       Steam Generator Eddy Current Testing;
radiation areas, airborne radioactivity areas, or high radiation areas for observation of
    *       Reactor Vessel Head Lift; and
work activities that presented the greatest radiological risk to workers:
    *       Cono-Seal Bullet Replacement.
*  
    The inspectors reviewed radiological job requirements for these four activities, including
1 B Reactor Coolant Pump Motor Lift;
    RWP and work procedure requirements, and attended ALARA pre-job briefings.
*  
    Job performance was observed with respect to these requirements to verify that
Steam Generator Eddy Current Testing;
    radiological conditions in the work areas were adequately communicated to workers
*  
    through pre-job briefings and postings. The inspectors also verified the adequacy of
Reactor Vessel Head Lift; and
    radiological controls (including required radiation, contamination, and airborne surveys);
*  
    radiation protection job coverage (including audio/visual surveillance for remote job
Cono-Seal Bullet Replacement.
    coverage); and contamination controls.
The inspectors reviewed radiological job requirements for these four activities, including
RWP and work procedure requirements, and attended ALARA pre-job briefings.
Job performance was observed with respect to these requirements to verify that
radiological conditions in the work areas were adequately communicated to workers
through pre-job briefings and postings. The inspectors also verified the adequacy of
radiological controls (including required radiation, contamination, and airborne surveys);
radiation protection job coverage (including audio/visual surveillance for remote job
coverage); and contamination controls.


    Radiological work in high radiation work areas having significant dose rate gradients
Radiological work in high radiation work areas having significant dose rate gradients
    was reviewed to evaluate the application of dosimetry to effectively monitor exposure to
was reviewed to evaluate the application of dosimetry to effectively monitor exposure to
    personnel and to verify that licensee controls were adequate. In particular, the steam
personnel and to verify that licensee controls were adequate. In particular, the steam
    generator eddy current activities and cono-seal bullet replacement involved evolutions
generator eddy current activities and cono-seal bullet replacement involved evolutions
    where the dose rate gradients were severe which increased the necessity of providing
where the dose rate gradients were severe which increased the necessity of providing
    multiple or repositioned dosimetry and/or enhanced job controls.
multiple or repositioned dosimetry and/or enhanced job controls.
    These reviews represented three inspection samples.
These reviews represented three inspection samples.
  b. Findings
b.  
    No findings of significance were identified.
Findings
.4   Radiation Worker Performance
No findings of significance were identified.
  a. Inspection Scope
.4  
    During job performance observations, the inspectors evaluated radiation worker
Radiation Worker Performance
    performance with respect to stated radiation protection work requirements and
a.  
    evaluated whether workers were aware of the significant radiological conditions in their
Inspection Scope
    workplace, the RWP controls and limits in place, and that their performance accounted
During job performance observations, the inspectors evaluated radiation worker
    for the level of radiological hazards present.
performance with respect to stated radiation protection work requirements and
    These reviews represented one inspection sample.
evaluated whether workers were aware of the significant radiological conditions in their
  b. Findings
workplace, the RWP controls and limits in place, and that their performance accounted
    No findings of significance were identified.
for the level of radiological hazards present.
.5   Radiation Protection Technician Proficiency
These reviews represented one inspection sample.
  a. Inspection Scope
b.  
    During job performance observations, the inspectors evaluated radiation protection (RP)
Findings
    technician performance with respect to radiation protection work requirements and
No findings of significance were identified.
    evaluated whether they were aware of the radiological conditions in their workplace, the
.5  
    RWP controls and limits in place, and if their oversight of radiological activities was
Radiation Protection Technician Proficiency
    consistent with their training and qualifications with respect to the radiological hazards
a.  
    and work activities.
Inspection Scope
    These reviews represented one inspection sample.
During job performance observations, the inspectors evaluated radiation protection (RP)
  b. Findings
technician performance with respect to radiation protection work requirements and
    No findings of significance were identified.
evaluated whether they were aware of the radiological conditions in their workplace, the
RWP controls and limits in place, and if their oversight of radiological activities was
consistent with their training and qualifications with respect to the radiological hazards
and work activities.
These reviews represented one inspection sample.
b.  
Findings
No findings of significance were identified.
20S2 As Low As Is Reasonably Achievable Planning And Controls (ALARA) (71121.02)
20S2 As Low As Is Reasonably Achievable Planning And Controls (ALARA) (71121.02)
.1   Inspection Planning
.1  
  a. Inspection Scone
Inspection Planning
    The inspectors reviewed the U1 R28 refueling outage work scheduled during the
a.  
    inspection period and associated work activity exposure estimates for the following four
Inspection Scone
    work activities which were likely to result in the highest personnel collective exposures:
The inspectors reviewed the U1 R28 refueling outage work scheduled during the
inspection period and associated work activity exposure estimates for the following four
work activities which were likely to result in the highest personnel collective exposures:


    *       U1R28 RP Coverage [RWP No. 04-104];
*  
    *       Bottom Mounted Instrumentation Inspection [RWP No. 04-133];
U1R28 RP Coverage [RWP No. 04-104];
    *       Nozzle Dam Installation/Removal [RWP No. 04-141]; and
*  
    *       Steam Generator Eddy Current Testing [RWP No. 04-142].
Bottom Mounted Instrumentation Inspection [RWP No. 04-133];
    These reviews represented one inspection sample.
*  
  b. Findings
Nozzle Dam Installation/Removal [RWP No. 04-141]; and
    No findings of significance were identified.
*  
.2   Radiological Work Planning
Steam Generator Eddy Current Testing [RWP No. 04-142].
  a. Inspection Scope
These reviews represented one inspection sample.
    For those activities identified in Section 20S2.1, the inspectors reviewed the ALARA
b.  
    evaluations, exposure estimates, and exposure mitigation requirements in order to verify
Findings
    that the licensee had established procedures, and engineering and work controls that
No findings of significance were identified.
    were based on sound radiation protection principles in order to achieve occupational
.2  
    exposures that were ALARA.
Radiological Work Planning
    The interfaces between radiation protection, operations, maintenance, planning,
a.  
    scheduling, and engineering groups were evaluated by the inspectors to identify
Inspection Scope
    interface problems or missing program elements. The inspectors evaluated if work
For those activities identified in Section 20S2.1, the inspectors reviewed the ALARA
    activity planning included consideration of the benefits of dose rate reduction activities
evaluations, exposure estimates, and exposure mitigation requirements in order to verify
    such as shielding provided by water filled components/piping, job scheduling, and
that the licensee had established procedures, and engineering and work controls that
    shielding and scaffolding installation/removal activities. Finally, the inspectors evaluated
were based on sound radiation protection principles in order to achieve occupational
    the integration of radiological job planning activities (pre-job ALARA reviews) into work
exposures that were ALARA.
    procedure and RWP documents.
The interfaces between radiation protection, operations, maintenance, planning,
    These reviews represented three inspection samples.
scheduling, and engineering groups were evaluated by the inspectors to identify
  b. Findings
interface problems or missing program elements. The inspectors evaluated if work
    No findings of significance were identified.
activity planning included consideration of the benefits of dose rate reduction activities
.3   Verification of Dose Estimates and Exposure Tracking Systems
such as shielding provided by water filled components/piping, job scheduling, and
  a. Inspection Scope
shielding and scaffolding installation/removal activities. Finally, the inspectors evaluated
    The inspectors reviewed the licensee's process for adjusting exposure estimates or
the integration of radiological job planning activities (pre-job ALARA reviews) into work
    re-planning work, when unexpected changes in scope, emergent work or higher than
procedure and RWP documents.
    anticipated radiation levels were encountered. This review included a determination if
These reviews represented three inspection samples.
    adjustments to estimated exposures (intended dose) were based on sound radiation
b.  
    protection and ALARA principles, rather than adjustments to account for failures to
Findings
    adequately control the work. The frequency of these adjustments was reviewed to
No findings of significance were identified.
    evaluate the adequacy of the original ALARA planning process. In particular, the
.3  
    inspectors reviewed and discussed with the RP staff the In-Progress ALARA reviews
Verification of Dose Estimates and Exposure Tracking Systems
    conducted for the bottom mounted instrumentation inspection and steam generator
a.  
    nozzle dam installation/removal RWPs.
Inspection Scope
    These reviews represented one inspection sample.
The inspectors reviewed the licensee's process for adjusting exposure estimates or
re-planning work, when unexpected changes in scope, emergent work or higher than
anticipated radiation levels were encountered. This review included a determination if
adjustments to estimated exposures (intended dose) were based on sound radiation
protection and ALARA principles, rather than adjustments to account for failures to
adequately control the work. The frequency of these adjustments was reviewed to
evaluate the adequacy of the original ALARA planning process. In particular, the
inspectors reviewed and discussed with the RP staff the In-Progress ALARA reviews
conducted for the bottom mounted instrumentation inspection and steam generator
nozzle dam installation/removal RWPs.
These reviews represented one inspection sample.


  b. Findings
b.  
    No findings of significance were identified.
Findings
.4   Job Site Inspections and ALARA Control
No findings of significance were identified.
  a. Inspection Scope
.4  
    The inspectors observed the four activities identified in Section 20S1.2 that were being
Job Site Inspections and ALARA Control
    performed in radiation areas, airborne radioactivity areas, or high radiation areas for
a.  
    observation of work activities that presented the greatest radiological risk to workers.
Inspection Scope
    The licensee's use of engineering controls to achieve dose reductions was evaluated to
The inspectors observed the four activities identified in Section 20S1.2 that were being
    verify that procedures and controls were consistent with the licensee's ALARA reviews,
performed in radiation areas, airborne radioactivity areas, or high radiation areas for
    that sufficient shielding of radiation sources was provided for and that the dose
observation of work activities that presented the greatest radiological risk to workers.
    expended to install/remove the shielding did not exceed the dose reduction benefits
The licensee's use of engineering controls to achieve dose reductions was evaluated to
    afforded by the shielding.
verify that procedures and controls were consistent with the licensee's ALARA reviews,
    These reviews represented one inspection sample.
that sufficient shielding of radiation sources was provided for and that the dose
  b. Findings
expended to install/remove the shielding did not exceed the dose reduction benefits
    No findings of significance were identified.
afforded by the shielding.
.5   Radiation Worker Performance
These reviews represented one inspection sample.
  a. Inspection Scope
b.  
    Radiation worker and RP technician performance was observed during work activities
Findings
    performed in radiological areas that presented the greatest radiological risk to workers.
No findings of significance were identified.
    The inspectors evaluated whether workers demonstrated the ALARA philosophy in
.5  
    practice by being familiar with the work activity scope and tools to be used, by utilizing
Radiation Worker Performance
    ALARA low dose waiting areas, and that work activity controls were being complied with.
a.  
    Also, radiation worker performance was observed to determine whether individual
Inspection Scope
    training/skill level was sufficient with respect to the radiological hazards and the work
Radiation worker and RP technician performance was observed during work activities
    involved.
performed in radiological areas that presented the greatest radiological risk to workers.
    These reviews represented one inspection sample.
The inspectors evaluated whether workers demonstrated the ALARA philosophy in
  b. Findings
practice by being familiar with the work activity scope and tools to be used, by utilizing
      No findings of significance were identified.
ALARA low dose waiting areas, and that work activity controls were being complied with.
4.   OTHER ACTIVITIES (OA)
Also, radiation worker performance was observed to determine whether individual
training/skill level was sufficient with respect to the radiological hazards and the work
involved.
These reviews represented one inspection sample.
b.  
Findings
No findings of significance were identified.
4.  
OTHER ACTIVITIES (OA)
40A6 Meetings
40A6 Meetings
.2   Interim Exit Meetings
.2  
      Interim exit meeting was conducted for:
Interim Exit Meetings
      *       Occupational Radiation Safety ALARA and access control programs inspection
Interim exit meeting was conducted for:
              with Mr. G. VanMiddlesworth on April 23, 2004.
*  
Occupational Radiation Safety ALARA and access control programs inspection
with Mr. G. VanMiddlesworth on April 23, 2004.


                                  KEY POINTS OF CONTACT
KEY POINTS OF CONTACT
Licensee
Licensee
G. VanMiddlesworth, Site Vice President
G. VanMiddlesworth, Site Vice President
S. Thomas, Radiation Protection Manager
S. Thomas, Radiation Protection Manager
B. Carberry, Radiation Protection - ALARA
B. Carberry, Radiation Protection - ALARA
                    LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened. Closed, and Discussed
Opened. Closed, and Discussed
None
None
                              LIST OF DOCUMENTS REVIEWED
LIST OF DOCUMENTS REVIEWED
20S1 Access Control to Radiologically Significant Areas
20S1 Access Control to Radiologically Significant Areas
      CAP 055366; Worker Received Electronic Dosimeter Dose Alarm; dated April 5, 2004
CAP 055366; Worker Received Electronic Dosimeter Dose Alarm; dated April 5, 2004
      CAP 055587; SIG Nozzle Dam Installation Dose Exceeded Estimate; dated April 11,
CAP 055587; SIG Nozzle Dam Installation Dose Exceeded Estimate; dated April 11,
      2004
2004
      CAP 055951; Incore Thermocouple Guide ("Bullet Nose") Inadvertently Lifted with
CAP 055951; Incore Thermocouple Guide ("Bullet Nose") Inadvertently Lifted with
      Reactor Head; dated April 22, 2004
Reactor Head; dated April 22, 2004
      CAP 055986; Evaluate Use of RP Greeter at Containment Hatches During Outage
CAP 055986; Evaluate Use of RP Greeter at Containment Hatches During Outage
      Periods; dated April 23, 2004 [NRC-Identified Issue]
Periods; dated April 23, 2004 [NRC-Identified Issue]
      HP 3.2; Radiological Labeling, Posting, and Barricading Requirements; Revision 39
HP 3.2; Radiological Labeling, Posting, and Barricading Requirements; Revision 39
      (January 23, 2004)
(January 23, 2004)
      HPIP 3.52; Airborne Radioactivity Surveys; Revision 30 (June 20, 2003)
HPIP 3.52; Airborne Radioactivity Surveys; Revision 30 (June 20, 2003)
      PCE No. 04-02-018; Personnel Contamination Event (PCE) Report; dated April 8, 2004
PCE No. 04-02-018; Personnel Contamination Event (PCE) Report; dated April 8, 2004
      PCE No. 04-02-019; Personnel Contamination Event (PCE) Report; dated April 9, 2004
PCE No. 04-02-019; Personnel Contamination Event (PCE) Report; dated April 9, 2004
      PCE No. 04-02-020; Personnel Contamination Event (PCE) Report; dated April 8, 2004
PCE No. 04-02-020; Personnel Contamination Event (PCE) Report; dated April 8, 2004
      RWP No. 04-104; RP Coverage; Revision 0
RWP No. 04-104; RP Coverage; Revision 0
      RWP No. 04-113; Reactor Head Lift; Revision 0
RWP No. 04-113; Reactor Head Lift; Revision 0
      RWP No. 04-122; Reactor Coolant Pump Maintenance; Revision 0
RWP No. 04-122; Reactor Coolant Pump Maintenance; Revision 0
      RWP No. 04-133; BMI Inspection; Revision 0
RWP No. 04-133; BMI Inspection; Revision 0
      RWP No. 04-141; Nozzle Dam Install/Remove; Revision 0
RWP No. 04-141; Nozzle Dam Install/Remove; Revision 0
      RWP No. 04-142; Steam Generator Eddy Current Testing; Revision 1
RWP No. 04-142; Steam Generator Eddy Current Testing; Revision 1


vX - *
vX  
            RWP No. 04-171; NRC Walkdowns for U1R28; Revision 0
-
            RWP No. 04-182; Replace Cono-Seal Bullet; Revision 0
*
      20S2 As Low As Is Reasonably Achievable Planninq And Controls (ALARA)
RWP No. 04-171; NRC Walkdowns for U1R28; Revision 0
            ALARA Review No. 2004-0012; Level 3 Pre-Job ALARA Review for BMI Inspection
RWP No. 04-182; Replace Cono-Seal Bullet; Revision 0
            (RWP No. 04-133); dated April 6, 2004
20S2 As Low As Is Reasonably Achievable Planninq And Controls (ALARA)
            ALARA Review No. 2004-0017; Level 3 Pre-Job and In-Progress ALARA Reviews for
ALARA Review No. 2004-0012; Level 3 Pre-Job ALARA Review for BMI Inspection
            Nozzle Dam Install/Remove (RWP No. 04-141); dated April 2 and 11, 2004
(RWP No. 04-133); dated April 6, 2004
            ALARA Review No. 2004-0018; Level 3 Pre-Job ALARA Reviews (Revisions 0 and 1)
ALARA Review No. 2004-0017; Level 3 Pre-Job and In-Progress ALARA Reviews for
            for Steam Generator Eddy Current Testing (RWP No. 04-142); dated March 16 and
Nozzle Dam Install/Remove (RWP No. 04-141); dated April 2 and 11, 2004
            April 12, 2004
ALARA Review No. 2004-0018; Level 3 Pre-Job ALARA Reviews (Revisions 0 and 1)
            ALARA Review No. 2004-0027; Level 3 Pre-Job ALARA Review for Replace Cono-Seal
for Steam Generator Eddy Current Testing (RWP No. 04-142); dated March 16 and
            Bullet (RWP No. 04-182); dated April 22, 2004
April 12, 2004
            JIT Briefing Activity MM-8480D3; Just In Time Briefing for Reactor Vessel Head Lift;
ALARA Review No. 2004-0027; Level 3 Pre-Job ALARA Review for Replace Cono-Seal
            dated April 21, 2004
Bullet (RWP No. 04-182); dated April 22, 2004
            HPIP 4.40; TEDE ALARA Evaluation; Revision 0 (February 6, 2002)
JIT Briefing Activity MM-8480D3; Just In Time Briefing for Reactor Vessel Head Lift;
            NP 4.2.1; ALARA Program; Revision 11 (November 19, 2003)
dated April 21, 2004
            Point Beach Nuclear Plant U1R28 Estimated RWP Dose Spreadsheet; dated April 6,
HPIP 4.40; TEDE ALARA Evaluation; Revision 0 (February 6, 2002)
            2004
NP 4.2.1; ALARA Program; Revision 11 (November 19, 2003)
            TEDE ALARA Evaluation for RWP 04-141; dated April 3, 2004
Point Beach Nuclear Plant U1R28 Estimated RWP Dose Spreadsheet; dated April 6,
            TEDE ALARA Evaluation for RWP 04-182; dated April 22, 2004
2004
                                        LIST OF ACRONYMS USED
TEDE ALARA Evaluation for RWP 04-141; dated April 3, 2004
      ALARA         As Low As Is Reasonably Achievable
TEDE ALARA Evaluation for RWP 04-182; dated April 22, 2004
      U1R28         Point Beach Unit 1's 28th Refueling Outage
LIST OF ACRONYMS USED
      RP           Radiation Protection
ALARA  
      RWP           Radiation Work Permit
As Low As Is Reasonably Achievable
U1R28  
Point Beach Unit 1's 28th Refueling Outage
RP  
Radiation Protection
RWP  
Radiation Work Permit
}}
}}

Latest revision as of 18:30, 15 January 2025

Previous Revision of Inspection Input to Point Beach Integrated Report 50-266-04-003 & 50-301-04-003
ML051520247
Person / Time
Site: Point Beach  
Issue date: 05/24/2005
From: Kenneth Riemer
Division of Reactor Safety III
To: Louden P
NRC/RGN-III/DRP/RPB7
References
FOIA/PA-2004-0282 IR-04-003
Download: ML051520247 (8)
v • d • e


See also: IR 05000266/2004003

Text

A

9

C

-.

0

UNITED STATES

NUCLEAR REGULATORY COMMISSION

Region III

LISLE, ILLINOIS 60532

MEMORANDUM TO:

FROM:

SUBJECT:

Patrick Louden, Chief

(U

/C

Projects Branch 7

Division of Reactor Projects

Kenneth Riemer, Chief

Plant Support Branch

i

Division of Reactor Safety

POINT BEACH NUCLEAR PLANT, UNITS 1 & 2

DRS INPUT TO INTEGRATED REPORT 50-266/04-03;

50-301/04-03

Attached is the report input for Point Beach Nuclear Plant, Units 1 and 2, Inspection

Report 50-266/04-03; 50-301/04-03. Specifically, this report focused on occupational radiation

safety during the recent U1R28 refueling outage as related to the licensee's radiological access

control and ALARA programs. I have reviewed this input and have determined it is ready for

distribution to the licensee and dissemination to the public.

Attachment:

CONTACT:

Input to Inspection Report 50-266/04-03;

50-301/04-03

Ryan D. Alexander, DRS

(630) 829-9853

DOCUMENT NAME: G:DRS\\Point Beach Input to Report 04-03 RDA.wpd

To receive a copy of this document, Indicate in the box:

C * Copy without attachmentlenclosure

E = Copy with attachment/enclosure

N * No copy

lOFFICE

lR111

W] R~ll

I8}i

L

NAME

RAlexander:sd ?gn KRiemer 1,4

DATE

05/1S104

05P /04

OFFICIAL RECORD COPY

0-9

Cover Letter

/

No input, no significant findings.

Input below, no color or green findings were identified.

Title Page

Inspector:

R. D. Alexander, Radiation Specialist

SUMMARY OF FINDINGS

ADAMS boilerplate - Inspectable area: Radiation Protection

Modify second paragraph as follows:

The baseline inspection was conducted by a regional radiation specialist inspector.

A.

Insnector-ldentified and Self-Revealed Findings

Cornerstones: Occupational and Public Radiation Safety (OS)

None

B.

Licensee-Identified Violations

None

REPORT DETAILS

2.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety (OS)

20S1 Access Control to Radiologically Significant Areas (71121.01)

.1

Plant Walkdowns and Radiation Work Permit Reviews

a.

Inspection Scone

The inspectors reviewed licensee controls and surveys for selected radiation areas, high

radiation areas and airborne radioactivity areas, as available, in the following

radiologically significant work areas within the plant and reviewed work packages which

included associated licensee controls and surveys for these areas to determine if

radiological controls (including postings and barricades) were acceptable:

Primary Auxiliary Building; and

Unit 1 Containment (all levels).

The inspectors reviewed the radiation work permits (RWP) and work packages used to

control work in these areas and other high radiation work areas to identify the work

control instructions and control barriers that had been specified. Electronic dosimeter

alarm set points for both integrated dose and dose rate were evaluated for conformity

with survey indications and plant policy. Workers were interviewed to assess their

knowledge of the actions required when their electronic dosimeters noticeably

malfunctioned or alarmed.

The inspectors walked down these areas to verify that the prescribed RWPs,

procedures, and engineering controls were in place, that licensee surveys and postings

were complete and accurate, and that air samplers (if necessary) were properly located.

The inspectors reviewed the RWPs and surveys for the steam generator nozzle dam

installation and eddy current testing activities which had the potential for creating an

airborne radioactivity area. The inspectors reviewed the RWPs to verify barrier integrity

and engineering control contingency plans were in place and to determine if there was a

potential for individual worker internal exposures of greater than 50 millirem committed

effective dose equivalent. This and other work activities/areas having a history of, or the

potential for, airborne transuranic isotopes were evaluated to verify that the licensee had

considered the potential for transuranic isotopes and provided appropriate worker

protection.

The inspectors assessed the adequacy of the licensee's internal dose assessment

process by reviewing personnel contamination event logs (and associated dose

assessments) for the refueling outage. As of April 21, 2004, no personnel

contamination events had resulted in dose assignments of greater than 10 millirem

committed effective dose equivalent.

These reviews represented four inspection samples.

b.

Findings

No findings of significance were identified.

.2

Job-In-Progress Reviews

a.

Inspection Scope

The inspectors observed the following four activities that were being performed in

radiation areas, airborne radioactivity areas, or high radiation areas for observation of

work activities that presented the greatest radiological risk to workers:

1 B Reactor Coolant Pump Motor Lift;

Steam Generator Eddy Current Testing;

Reactor Vessel Head Lift; and

Cono-Seal Bullet Replacement.

The inspectors reviewed radiological job requirements for these four activities, including

RWP and work procedure requirements, and attended ALARA pre-job briefings.

Job performance was observed with respect to these requirements to verify that

radiological conditions in the work areas were adequately communicated to workers

through pre-job briefings and postings. The inspectors also verified the adequacy of

radiological controls (including required radiation, contamination, and airborne surveys);

radiation protection job coverage (including audio/visual surveillance for remote job

coverage); and contamination controls.

Radiological work in high radiation work areas having significant dose rate gradients

was reviewed to evaluate the application of dosimetry to effectively monitor exposure to

personnel and to verify that licensee controls were adequate. In particular, the steam

generator eddy current activities and cono-seal bullet replacement involved evolutions

where the dose rate gradients were severe which increased the necessity of providing

multiple or repositioned dosimetry and/or enhanced job controls.

These reviews represented three inspection samples.

b.

Findings

No findings of significance were identified.

.4

Radiation Worker Performance

a.

Inspection Scope

During job performance observations, the inspectors evaluated radiation worker

performance with respect to stated radiation protection work requirements and

evaluated whether workers were aware of the significant radiological conditions in their

workplace, the RWP controls and limits in place, and that their performance accounted

for the level of radiological hazards present.

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

.5

Radiation Protection Technician Proficiency

a.

Inspection Scope

During job performance observations, the inspectors evaluated radiation protection (RP)

technician performance with respect to radiation protection work requirements and

evaluated whether they were aware of the radiological conditions in their workplace, the

RWP controls and limits in place, and if their oversight of radiological activities was

consistent with their training and qualifications with respect to the radiological hazards

and work activities.

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

20S2 As Low As Is Reasonably Achievable Planning And Controls (ALARA) (71121.02)

.1

Inspection Planning

a.

Inspection Scone

The inspectors reviewed the U1 R28 refueling outage work scheduled during the

inspection period and associated work activity exposure estimates for the following four

work activities which were likely to result in the highest personnel collective exposures:

U1R28 RP Coverage [RWP No. 04-104];

Bottom Mounted Instrumentation Inspection [RWP No. 04-133];

Nozzle Dam Installation/Removal [RWP No. 04-141]; and

Steam Generator Eddy Current Testing [RWP No. 04-142].

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

.2

Radiological Work Planning

a.

Inspection Scope

For those activities identified in Section 20S2.1, the inspectors reviewed the ALARA

evaluations, exposure estimates, and exposure mitigation requirements in order to verify

that the licensee had established procedures, and engineering and work controls that

were based on sound radiation protection principles in order to achieve occupational

exposures that were ALARA.

The interfaces between radiation protection, operations, maintenance, planning,

scheduling, and engineering groups were evaluated by the inspectors to identify

interface problems or missing program elements. The inspectors evaluated if work

activity planning included consideration of the benefits of dose rate reduction activities

such as shielding provided by water filled components/piping, job scheduling, and

shielding and scaffolding installation/removal activities. Finally, the inspectors evaluated

the integration of radiological job planning activities (pre-job ALARA reviews) into work

procedure and RWP documents.

These reviews represented three inspection samples.

b.

Findings

No findings of significance were identified.

.3

Verification of Dose Estimates and Exposure Tracking Systems

a.

Inspection Scope

The inspectors reviewed the licensee's process for adjusting exposure estimates or

re-planning work, when unexpected changes in scope, emergent work or higher than

anticipated radiation levels were encountered. This review included a determination if

adjustments to estimated exposures (intended dose) were based on sound radiation

protection and ALARA principles, rather than adjustments to account for failures to

adequately control the work. The frequency of these adjustments was reviewed to

evaluate the adequacy of the original ALARA planning process. In particular, the

inspectors reviewed and discussed with the RP staff the In-Progress ALARA reviews

conducted for the bottom mounted instrumentation inspection and steam generator

nozzle dam installation/removal RWPs.

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

.4

Job Site Inspections and ALARA Control

a.

Inspection Scope

The inspectors observed the four activities identified in Section 20S1.2 that were being

performed in radiation areas, airborne radioactivity areas, or high radiation areas for

observation of work activities that presented the greatest radiological risk to workers.

The licensee's use of engineering controls to achieve dose reductions was evaluated to

verify that procedures and controls were consistent with the licensee's ALARA reviews,

that sufficient shielding of radiation sources was provided for and that the dose

expended to install/remove the shielding did not exceed the dose reduction benefits

afforded by the shielding.

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

.5

Radiation Worker Performance

a.

Inspection Scope

Radiation worker and RP technician performance was observed during work activities

performed in radiological areas that presented the greatest radiological risk to workers.

The inspectors evaluated whether workers demonstrated the ALARA philosophy in

practice by being familiar with the work activity scope and tools to be used, by utilizing

ALARA low dose waiting areas, and that work activity controls were being complied with.

Also, radiation worker performance was observed to determine whether individual

training/skill level was sufficient with respect to the radiological hazards and the work

involved.

These reviews represented one inspection sample.

b.

Findings

No findings of significance were identified.

4.

OTHER ACTIVITIES (OA)

40A6 Meetings

.2

Interim Exit Meetings

Interim exit meeting was conducted for:

Occupational Radiation Safety ALARA and access control programs inspection

with Mr. G. VanMiddlesworth on April 23, 2004.

KEY POINTS OF CONTACT

Licensee

G. VanMiddlesworth, Site Vice President

S. Thomas, Radiation Protection Manager

B. Carberry, Radiation Protection - ALARA

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened. Closed, and Discussed

None

LIST OF DOCUMENTS REVIEWED

20S1 Access Control to Radiologically Significant Areas

CAP 055366; Worker Received Electronic Dosimeter Dose Alarm; dated April 5, 2004

CAP 055587; SIG Nozzle Dam Installation Dose Exceeded Estimate; dated April 11,

2004

CAP 055951; Incore Thermocouple Guide ("Bullet Nose") Inadvertently Lifted with

Reactor Head; dated April 22, 2004

CAP 055986; Evaluate Use of RP Greeter at Containment Hatches During Outage

Periods; dated April 23, 2004 [NRC-Identified Issue]

HP 3.2; Radiological Labeling, Posting, and Barricading Requirements; Revision 39

(January 23, 2004)

HPIP 3.52; Airborne Radioactivity Surveys; Revision 30 (June 20, 2003)

PCE No. 04-02-018; Personnel Contamination Event (PCE) Report; dated April 8, 2004

PCE No. 04-02-019; Personnel Contamination Event (PCE) Report; dated April 9, 2004

PCE No. 04-02-020; Personnel Contamination Event (PCE) Report; dated April 8, 2004

RWP No.04-104; RP Coverage; Revision 0

RWP No.04-113; Reactor Head Lift; Revision 0

RWP No.04-122; Reactor Coolant Pump Maintenance; Revision 0

RWP No.04-133; BMI Inspection; Revision 0

RWP No.04-141; Nozzle Dam Install/Remove; Revision 0

RWP No.04-142; Steam Generator Eddy Current Testing; Revision 1

vX

-

RWP No.04-171; NRC Walkdowns for U1R28; Revision 0

RWP No.04-182; Replace Cono-Seal Bullet; Revision 0

20S2 As Low As Is Reasonably Achievable Planninq And Controls (ALARA)

ALARA Review No. 2004-0012; Level 3 Pre-Job ALARA Review for BMI Inspection

(RWP No.04-133); dated April 6, 2004

ALARA Review No. 2004-0017; Level 3 Pre-Job and In-Progress ALARA Reviews for

Nozzle Dam Install/Remove (RWP No.04-141); dated April 2 and 11, 2004

ALARA Review No. 2004-0018; Level 3 Pre-Job ALARA Reviews (Revisions 0 and 1)

for Steam Generator Eddy Current Testing (RWP No.04-142); dated March 16 and

April 12, 2004

ALARA Review No. 2004-0027; Level 3 Pre-Job ALARA Review for Replace Cono-Seal

Bullet (RWP No.04-182); dated April 22, 2004

JIT Briefing Activity MM-8480D3; Just In Time Briefing for Reactor Vessel Head Lift;

dated April 21, 2004

HPIP 4.40; TEDE ALARA Evaluation; Revision 0 (February 6, 2002)

NP 4.2.1; ALARA Program; Revision 11 (November 19, 2003)

Point Beach Nuclear Plant U1R28 Estimated RWP Dose Spreadsheet; dated April 6,

2004

TEDE ALARA Evaluation for RWP 04-141; dated April 3, 2004

TEDE ALARA Evaluation for RWP 04-182; dated April 22, 2004

LIST OF ACRONYMS USED

ALARA

As Low As Is Reasonably Achievable

U1R28

Point Beach Unit 1's 28th Refueling Outage

RP

Radiation Protection

RWP

Radiation Work Permit

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