IR 05000266/1998004

Insp Repts 50-266/98-04 & 50-301/98-04 on 980202-06.No Violations Noted.Major Areas Inspected:Review of Health Physics Dept Preparations for Unit 1 Refueling Outage, Including ALARA Planning & Work Planning

ML20203K988
Person / Time
Site:	Point Beach
Issue date:	02/27/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203K966	List: IR 05000266/1998004 ML20203K962
References
50-266-98-04, 50-266-98-4, 50-301-98-04, 50-301-98-4, NUDOCS 9803050296
Download: ML20203K988 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION 111

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l Docket Nos: 50 266, 50-301

_ License Nos: DPR 24; DPR 27

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Report Nos: 50 266/98004(DRS); 50-301/98004(DRS)

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Licensee: Wismnsin Electric Power company Facility: Point Beach Nuclear plant, Units 1 and 2

i Location: 6610 Nuc! ear Road Two Rivers, WI 54241

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Dates

February 2-6,1998

j Inspector: K. Lambert, Radiation Specialist J

Approved by: G Shear, Chief, Plant Support Bran ,n 2 Division of Reactor Safety j

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ADOCK 05000266 PDR

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EXECUTIVE SUMMARY Point Beach Nuclear Plant, Units 1 & 2 '

NRC Inspection Reports 50-266/98004; 50-301/98004 This routine inspection included i review of the health physics department's preparations for the Unit i refueling outage. Th.s , luded a review of as low as reasonably achievable (ALARA) planning, work planning, tr . radiation work permit process, and the contractor health physics technologist qualifications and training program. In addition, several open items from previous inspections were reviewe .

The planning for the U1R24 refueling outage appropriately considered heauh physics requirements and radiologicalimpediments asociated with the outage. A weakness was identified where ALARA reviews did not always document how dose estimates were derived (Section R1.1).

. Radiological postings and labels in the auxiliay building were in accordance with procedures and housekeeping was generally good. Health physics staff response to the inspector identified overflowing bucket, labeled " Caution Radioactive Material," was considered good (Section R1.2).

. The health @ysics manager's qualifications indicated that he exceeded the position requirements in Technical Specification 15.6.3.2 (Section RS.1).

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The training program for contractor health physics technologists and radiation workers was sufMently detailed and effectively implemented. The trainers conducted formal discussions, practical demonstationa, and task performance evaluations to ensure an acceptable level of proficiency (Section R5.2).

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Corrective actions for a failure to survey a tool before removing it from a contaminated area included t. discussion of the event and the need to follow procedures with the health physics staff (Section R8.1).

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Weaknesses in the protective clothing program were adecessed by requiring that protective clothing be removed at contaminated area step off pads, and that personal clothing / modesty garments worn under protective clothing not be removed or covered up before using the contamination monitors (Section R8.2).

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Corrective actions for the failure to calibrate emergency plan dosimeters were implemented except for issuing the administrative procedura outlining expectations that surveillances be performed and documented in a timely manner (Section R8.3).

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Report Details IV. Plant Support R1- Radiological Protection and Chemistry (RPE) Controls R1,1 Unit 1 Rafnatha Outmaa (U1R24) Planning and Pranaration insoection Scone (IP 8372M The inspector reviewod radiation protection's advance planning and preparation for the U1R24 refueling outage including work pionning, as low as reasonably achievable (ALARA) reviews, radiation work permit (RWP) process, and dose estimates for several activitie _ Observation and Findings A station health physics (HP) supervisor had been assigned to the outage planning committee. The HP_ supervisor reviewed the work packages and provided information to the work planners on HP's involvement, including decontamination, required radiological surveys, and shielding requirements. The supervisor also provided to the planners, the i time requirements for HP activities and placement of shielding in an effort to include enough time in the outage schedule for those activities. The supervisor, as part of the work package review, F,erformed an initial ALARA review and assisted the work planners in properly completing the RWP request RWP requeu which indicated that an individual could receive a whole body dose i greater than 1 rem or a total projected dose greater than 2 rem, required that a formal

. ALARA review be performed. Work packages requiring a formal ALARA review were forwarded to the ALARA group. The ALARA group performed a detailed review of the project, including a review of historical files and ALARA suggesticns from previous evolutions. The ALARA greup had completed 10 of 14 ALARA reviews planned for the outage. The remaining reviews wera in progress and were scheduled to be completed before the work starte The inspector reviewed several ALARA reviews completed for the outage, which appeared comprehensive and used historical files and ALARA suggestions to develop

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comments. Comments included shielding requirements, radiological surveys, removing components to be worked on to lower dose areas when possible, respiratory protection requirement, and the use of mockup training. The inspector identified a weakness in that on at least one ALARA review the previous dose history was not indicated, but a dose estimate had been assigned for the work. When questioned, the ALARA technologist Indicated that he had contacted other stations where the evolution had been performed and the contractor, for dose informatien which he considered in the dose estimat '3

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RWPs for the outage have not been written. According to the RWP procedure, work requests are submitted at least 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> before work begins to allow processing of the request. The health physics department's expectation was that requests were to be submitted within 24 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> before the start of work; therefore allowing the RWP to be prepared using the latest survey data and radiological conditions. The inspecto'

reviewed RWPs with ALARA reviews from previous work. The RWPs were complete and included specialinstructions such as health physics hold points, air sampling requirements and survey requirements during opening of systems. The inspector noted that while the ALARA review was attached to the RWP, the ALARA comments were not referenced in the RW ConcluslQna The planning for the U1R24 refueling outage eppropnately considered health physics requirements and alologicalimpediments associated with the outage. A weakness was identified where ALARA reviews did not always document how dose estimates were derive R1.2 General Tours of the Auxiliary Buildina ' Insoection Scone (IP 83750)

Severalinspections of the auxiliary building were performed to review housekeeping practices, and posting and labeling, Observation and Findinas Radiological costings were well maintained. The Inspector determined, through independent measurements, that radiation areas and high radiation areas were appropriately posted in accordance with station procedures and regulatory requirements. Housekeeping was (,coerally good. The inspector ic%nfied a few minor housekeeping inconsistencies, which once reported to health physics, were appropriately corrected. Labeling of containers was in accordance with station procedures. The inspectors noted that the health physics staff was revising the posting and labeling procedure to more accurately identify those containers holding radioactive material. Containers were being surveyed, with labels removed from those containers were radioactive material was not identifie During a tour of the facade, the inspector identified water running onto the lowest level of the facade. Upon further review the inspector noted that a valve was leaking into and overflowing from a bucket labeled " Caution Raolcactive Material." Once the health physics staff was informed, a technician was sent to address the issue. The technician surveyed the water and collected a sample for analysis. The survey data and analysis result Indicated that there was no detectable radioactivity in the liquid. The heahh physics staff indicated that the bucket would be replaced with a drip basin and funneled to a drain. The health physics staff also indicated that the plant staff would be reminded to notify health physics of any leaks and ensure that the proper containers be u::e ,

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. Conclusions Radiological postings and labels were in accordance with procedures and housekeeping was generally good. Health physics staff response to the inspector identified overflowing bucket, labeled radioactive material; was considered goo R5 Staff Training and Qualification in RP&C R tiealth Physics Manager Qualifications The qualifications of the new radiation protection manager, who was scheduled to start on February 9,1998, were reviewed for conformance with Technical Specification Technical Specification 15.6.3.2 required that the manager meet the following requirements: Possess a bachelors degree in science or engineering; have at least five years of experisnce in applied radiation protect!on work with at least three years at a nuclerr facility with similar radiological problems as nuclear power plants. The individual's resume was reviewed, which indicated that he had atisined a masters degree in Health Physics, was a certified health physicist, and had g,reaer than five years of experience in applied radiation picaction at a nuclear power facility The individual's qualifications indicated that he exceeded the requirements of Technical Specification 15.6. RS.2 Train!ng and Qualifications of Contrattor Personnel Insoection Scoce (IP 83729)

The inspectors reviewed the training programs for contracter health physics technologists (CHPTs), and newly hired employees and contractor outage worker This included a review of procedures, and discussions with the radiation protection staf Observations and Findings Radiation protection management indicated that approximately 30 CHPTs were needed besides the 15 contractor technologists already onsite. These additional individuals would fill health physics technologist and laundry-decon position The licensee maintained a task list for which health physics technologists (HPTs),

including CHPTs, must receive training on prior to being qualified to independently perform a task. The training included written exams, on-tne-job training and task performance evaluations. CHPT's qualifications were reviewed by the radiation protection trainer. Technologists new to the station or who have no; worked at the station within the last 18 months, were provided training before independently performing tasks in radiation protection. The training was being performed in accordance with the qualification manual for contract health physics technologist .

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Returning CHPTs who were previously qualified for a task were not required to rir cive formal training, but an informal refresher training was provided. However, tr.e returning CHPTs were required to attend a formal orientation, where procedure changes, recent events, and policy changes were discusse Contractor radiation protection technologists who have been onsite for greater than six months were included in the licensee's continuing training program for HPT The inspector attended part of the radworker training course for newly hired employees and contractor radiation workers. The instructor was knowledgeable in the subject matter and engaged the class with questions and answers. The training program included lectures, hand outs, and a practical exercise where trainees enter and exit a simulated RWP required contaminated area. This exercise included reviewing the RWP, donning and removing protective cle'51ng, and performing whole body contamination surveys using a portable survey instrumen Conclusions The training program for CHPTs and radiation workers was sufficiently detailed and effectively implemented. The trr!ners conducted formal discussions, practical demonstrations and task performance evaluations to ensure an acceptable level of proficienc R8 Miscellaneous RP&C lssues R (Closed) VIO 50-266/96004-02(DRSh 50-301/96004-02(DRS): The failure to perform a survey of a wrench prior to removing it from a contaminated area durhg dry cask loading operations. Corrective actions to prevent recurrence included a discussion of the event with the HPTs involved and at a health physics group mceting, and a review of the procedure to evaluate wh3ther changes could be made to improve contamination control practices. After reviewing the procedure, the licensee indicated that changes were not needed as the violation was due to worker performance. The inspector verified that HPT3 wore aware of the process to remove contaminated or potentially contaminated materias from a contaminated area. This violation is close R8.2 (Closed) IFl 50-266/96016-02(DRS): 50-301/96016-02(DRSh Weaknesses in the protective clothing program where individuals were allowed to leave a contaminated area without removing protective clothing and were allowed to put on clothing after removal of protective clothing and before using the contamination monitors. The licensee revised nuclear procedure 4.2.22 " Requirements for Use of Protective Clothing," to include the requirements to remove protective clothing at contaminated area ster r'ff pads and perform a whole body frisk immed:ately after exiting a contaminated area. The procedure was also revised to require that personal clothing / modesty garments wom under protective t,othing will not be removed or covered up before using the contamination monitors. This item is close _

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i R8.3 (Discussed) VIO 50-266/97018-01(DRSh 50-301/97018-01(DRSh Failure to cal.brated

. emergency plan self reading dosimeters in accordance with the procedure. The I

corrective actions, described in a letter dated November 3 -1997, were reviewed to I confirm their implementation. The licensee revised the calibration procedure HPCAL

1.28 to more clearly define when the calibrations were due. The licensee discussed with the health physics staff the importance of performing and documenting surveillances in a timely manner, in addition, the licensee discussed the need to promptly initiate a

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condition report when deficiencies in procodures were identified or surveillances were

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not completed in a timely manner. The November 3,1997, letter also indicated that an l administrative procedure outlining these expectations would be implemented by March 31,1998. This last corrective action had not yet been completed; thereforo, this

violation will remain open until the procedure has been issued.

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X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the l

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conclusion of the inspection on February 6,1998. The licensee acknowledged the findings presente The licensee did not identify any information discussed as proprietary, i

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O PARTIAL LIST OF PERSONS CONTACTED Licensee A. J. Cayla, Plant Manager E. J. Epstein, HP Supervisor F. A. Flentje, Regulatory Specialist D. J. LeClair, HP Supervisor M. D. Moseman, HP Specialist C. H. Onesti, Health Physic!st S. J. Thomas, HP Specialist P. B. Tindall, Manager, Health Physics R. E. Walesh, Quality Assurance NRC F. Brown, Senior Resident inspector INSPECTION PROCEDURES USED IP 83729: Occupational Exposure During Extended Outages IP 83750: Occupational Radiation Exposure IP 92904: Followup - Plant Support LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Closed 50-266/301-96004-02 VIO Failure to follow contamination control procedures 50-266/301-96016-02 IFl Weaknesses in the protective clothing program Discussed 50-266/301-97018-01 IFl Failure to calibrate emergency plan 0-200 roentgen self reading dosimeters in accordance with the procedure

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LIST OF DOCUMENTS REVIEWED AL. ARA Review Log for U1R24 Outage --

ALARA Review Number 98-0001, S/G Narrow Range Level Tap Replacement ALARA Review Number 98-0004, Conoseal Removal / Installation Exposure Reduction Committee Charter of Responsibilities

- Health Physics Calibration Procedure, HPCAL 1.28, Revision 12, Self-Reading Dosimeter Response and Drift Check (Calibration) Procedure Health Physics Manual, HP 3.2.2, Revision 13 RCA Contaminated Areas, Tools, Equipment and Materials Posting Requirements

- Procedures Manual, NP 4.2.1, Revision 0, ALARA Policy Procedures Manual, NP 4.2.2, Revision 0, Post-Job ALARA Evaluations Procedures Manual, NP 4.2.3, Revision 2 ALARA Review Procedure Procedures Manual,- NP 4.2.20, Radiation Work Permit i

Procedures Manual, NP 4.2.22, Revision 4, Requirements For Use of Protective Clothing Qualification Manual, CHPQC, Revision 1 (DRAFT), Contractor Health Physics Technologist Radiation Worker Tiaining Practical Exercise Radiation Work Permit 97-483

- Technical Specification 15.6.3, Facility Staff Qualifications 4 U1R24 Dose Estimate

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LIST OF ACRONYMS USED

, ALARA- As Low As Reasonably Achievable CHPT Contract Health Physics Technologist HP . Health Physics HPCAL Health Physics Calibration HPT Health Physics Technologist

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NRC Nuclear Regulatory Commission

, RWP Radiation Work Permit

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