IR 05000293/1987040

Insp Rept 50-293/87-40 on 870914-18.Violations Noted.Major Areas Inspected:Licensee Action on Previous Findings, Organization & Staffing,Alara & Radiological Controls for Drywell Work During Fuel Movement

ML20236H532
Person / Time
Site:	Pilgrim
Issue date:	10/26/1987
From:	Dragoun T, Nimitz R, Shanbacky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236H513	List: IR 05000293/1987040 ML20236H510 ML20236H515
References
50-293-87-40, NUDOCS 8711040184
Download: ML20236H532 (15)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-203/87-40 Dock'et' No'. 50-293 License No. DPR-63 Priority -

Category C Licensee: Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection Conductedi September 14-18, 19,8_7_

Inspectors: R L N/M R. L. Nimitz, Senior Radiation iel2.L/O date Specialist bl.BJ w ( 4 T. Dragoun, Senior RadiationV i c ltc l 4)

date Specialist Approved by: d .b% O d L7, l@

M. Shanbaky, Chief Q- date Facilities Radiation Protection Section Inspection Summary: Inspection on September 14-18, 1987 (Report N /87-40)

Areas Inspected: Routine, announced radiological controls inspectio Areas reviewed were: licensee action on previous findings; organization and staffing; ALARAjand radiological controls for drywell work during fuel movement. The inspection was perfornied by two region based inspector Results: One violation for failure to post a Notice of Violation involving radiological working conditions was identified (Details paragraph 3.13).

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DETAILS Persons Contacted 1.1 Boston Edison Company

• K. Roberts, Nuclear Operations Manager

• N. Bosse, Chief Maintenance Engineer

• J. Jens, Radiation Protection Manager

• S. Hudson, Operations Section Manager

• N. Gannon, Chief Radiological Engineer

• P. Hamilton, Acting Compliance Group Leader 3

• L. Whittenberger, Acting Technical Support Group Leader ;

1.2 NRC i J. Lyash, Resident Inspector

• T. Kim, Resident Inspector

• denotes attendance at the September 18, 1987 exit meetin The inspector also contacted other personne . Purpose-of Inspection

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The purpose of the inspection was to review the following matters:

Licensee action on previous findings Radiological Controls Organization and Staffing

ALARA Drywell Radiological Controls During Fuel Movement 3.0 Licensee Action on Previous Findings ,

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3.1 (Closed) Inspector Follow-Item (50-293/85-07-01) i Licensee to review procedure for performing inspections of heating l and ventilation duct work to determine the need to provide !

documentation of the date of the inspection and provide for review l of inspection results. The licensee established procedure 3M. 4-70, !

Resin Inspection of H & V Ductwork. The procedure addresses the !

above matters and replaces temporary procedure TP-83-58 3.2 (Closed) Inspector Follow-Item (50-293/85-13-10) l l

Licensee to upgrade housekeeping and appearance of health physics i facilities. The licensee has moved the instrument calibration l laboratory to an area in the machine shop. The previous area (Retube Building) was subjected to moisture problems. The licensee has also modified his access control point to provide for better j traffic flow and equipment flow into and out of the radiological j j

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control area. This has improved housekeeping in this area. Some areas for improvement were brought to the attention of licensee personne "

The instrument calibration and repair facility is crowde Little work space is available in the facilit The respirator cleaning facility is crowded. Respirators are frisked in close proximity to the area where dirty respirators are brought into the room for cleanin The licensee indicated these areas would be reviewe .3 (Closed) Inspector Follow-Item (50-293/85-13-11)

Licensee to tag out of service inoperable area radiation monitors in the area of the Traveling Incore Probes and waste segregated area and assign responsibility of units. The licensee tagged out the inoperable instruments and assigned responsibilit .4 (Closed) Inspector Follow-Item (50~293/85-22-05)

This item involved 5 remaining items to be resolve Item b (closed)

Licensee to evaluate potential contamination of pavement associated with unmonitored release from Hot Machine Sho Findings No contamination was identified at or near point of release from the ventilation syste *

Item c (closed)

The licensee to close out the Failure and Malfunction Report and Radiological Occurrence Report associated with unmonitored release.

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Findings The licensee closed out the Failure and Malfunction Repor The ROR will be closed out upon final review of smoke test dat Item d (Closed)

Licensee to perform a safety evaluation to support continued operation of the Hot Shop Exhaust Ventilation System.

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Findings The licensee reconfigure the Hot Shop Ventilation System to exhaust to the Radwaste System Ventilation. A safety evaluation was performed for the reconfiguratio Iteme(closed)

Licensee to evaluate source of contamination of duct work in control room corridor and Health Physics Count Roo Findings The licensee attributed the source of low level contamination in the intake ducts to be buildup with time. No source other than this was identifie j Item 9 (closed)

Licensee to update Final Safety Analyses Report (FSAR) to reflect. actual ventilation flow paths of the " Hot Shop."

Findings As discussed above, the licensee reconfigure the ventilation flow paths from the " Hot Shop."

The licensee's Plant Design change methodology provides for updating of the FSAR. The licensee will update the FSAR upon final review and sign off of the PDC (85-82) per 10 CFR 50.71 .5 (Closed)InspectorFollow-Item (85-26-06)

Licensee to revise Radiological Occurrence Report (R0R) Program to provide for timely review and resolution of finding Procedure

1. 6 1-209, " Radiological Occurrence Reports," was revised in June, 1987. Changes include additional controls to ensure timely review and formal closecut of all RORs. The ROR coordinator targets completion of action for 2 to 3 weeks after the occurrenc Late replies are reported to upper management.

i 3.6 (Closed) Inspector Follow-Item (50-293/85-32-21)

Licensee to review adequacy of performing analysis of clean area smears when the frisker background is 300 counts per minute. The licensee reviewed the value of maximum allowable background for analysis of smears and determined it to be acceptable.

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V 3.7.-(Closed)InspectorFollow-Item-(50-293/86-02-01).

E Licensee Outage Management-Instruction did not provide clear guidance regarding holding of inter-group meetings to j discuss / resolve outage concerns. The licensee revised Outage '

i Management Instruction 11 to provide guidance regarding personnel

.. responsibilities for holding meetings and criteria for. holding such ;

meeting !

l 3.8 (Closed) Inspector. Follow-Item (50-293/86-02-05)- l Licensee to review the need to use continuous air monitors (CAMS)and establish. appropriate procedures if necessary. Licensee review indicated a need to utilize continuous air monitors. The licensee ,

has established and implemented procedures for calibration, ;

operation,.and checking of continuous air monitor i

The. licensee is currently replacing the older AMS-2 and AMS-3 CAMS !

with new type CAMS. Procedures have been established and i implemented for the new equipment, j However, procedures for both types of units do not provide optimum l oalarm set po_ints.for personal protection purposes. The licensee l

'will review this matte !

,' 3.9 (Closed) Inspector Follow-Item (50-293/86-02-10)

Licensee to resolve procedure inconsistencies. The inconsistencies '

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.in radiation protection procedures, identified during a licensee audit and a contractor ' audit, were corrected through pmcedure

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version .10 (Closed) Inspector Follow-Item (50-293/86-02-12)  !

Licensee to verify that there are sufficient procedures in place to implement the Radiation Protection Program described in the Radiation Protection Plan. The licensee ~has established implementing procedure.s for the Radiation Protection Plan. The

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licensee is currently reviewing his Nuclear Operating Policies to determine the need to revise or establish additional policies. The licensee's current program is functiona ;

3.11.(0 pen)InspectorFollow-Item (50-293/86-06-09)

Licensee to: establish ALARA Program Procedures; incorporate ALARA 3 planning earlier into the work planning process; and evaluate ,

acceptability)of ALARA Permits (RWPs . The control licensee has for ' A' priority established and Radiation Work implemented sixteen ALARA procedures. The procedures provide guidance for i

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performing pre-job ALARA reviews. The licensee has placed senior i

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Radiological Engineering personnel in the maintenance group to '

improve ALARA planning for work. The licensee has provided procedure guidance for ALARA planning for "A" priority Radiation Work' permits. However, Inspector review indicated little training was provided to technicians regarding job coverage for RWPs  ;

including 'A' priorit l 3.12 (0 pen) Inspector Follow-Item (50-293/86-19-01) i Licensee to address the following five weaknesses: The inspector f review of this item and licensee corrective actions was preliminar '

Additional review will be performed during a subsequent inspectio ;

Item 1 Open Improve communications and working relationships between the '

Radiation Protection Section and other station section !

Findings Department managers on site have stressed the need for cooperation  !

and support of the radiation protection program with their i

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department personnel. The effectiveness of this action will be reviewed during a subsequent inspectio l

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Item 2 (0 pen)

Improve the station ALARA and radiation protection section goals progra !

Findings  !

.l Accountability towards ALARA performance is now included in salaried  :

employee evaluation reports, j The station goals and objectives are prominently posted on various bulletin boards throughout the sit The adequacy of these actions will be reviewed during a subsequent inspectio Item 3 (0 pen)

Reduce the number of recurrent Radiological Occurrence Reports (R0Rs).

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Findings Management action to reduce recurring ROR includes identification of repeat offenders and a monthly review of ROR trend A review of the adequacy of this action will be performed during a subsequent inspectio Item 4 (0 pen)

Licensee to ensure necessary procedures to implement the Radiation Protection and Radioactive Material Control Plan are in plac Findings Necessary procedures have been established. See section 3.9 and 3.10 of this report for the Radiation Protection Pla Establishment of necessary procedures for implementing the Radioactive Material Control Plan will be reviewed during a subsequent inspectio Item 5 (0 pen)

Licensee to review and resolve findings of a Radiological Oversight Committee Audit and an independent contractor audit of the Radiological Controls Progra Findings This matter was not fully reviewed by the NR It will be reviewed during a subsequent inspectio .13 (Closed) Inspector Follow-Item (50-293/86-19-03)

Licensee to: conspicuously place bulletin boards for posting of material required by 10 CFR 19.11; correct discrepancies regarding individual qualifications in the training manual; and clarify experience requirements for selection of radiation protection technicians. The licensee has conspicuously placed the bulletin boards for 10 CFR 19.11 posting; corrected discrepancies in the training manual for individual qualification and clarified the experience requirements for selecting radiation protected technician During review of the item, one apparent violation was identified:

10 CFR 19.11 (a) requires in part that each licensee is to post current copies of any Notice of Violation involving radiological working conditions. 10 CFR 19.11 (c) requires that the copies be posted within 2 working days after receipt of the document .

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The-inspector found that as of September 17.-1987, a Notice of Violation,-involving radiological working conditions, dated q August 24, 1987 and received by the licensee on September 3,.1987 J" was.not posted. (50-293/87-40-01)

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Inspector review indicated that the licensee had assumed that their was not a need to post the Notice of Violation. The licensee incorrectly believed that a note placed on employee bulletin boards specifying where Notice-of Violations involving radiological working i conditions could be reviewed was acceptable. Such guidelines had been incorporated into licensee Compliance Group Instruction ;

The inspector informed the licensee-that 10 CFR 19.11 (a) requires posting of each Notice of Violatio The licensee took immediate corrective actions to correct this matter and prevent recurrence. The licensee posted the Notice of Violation and revised applicable procedures to require posting of- .

other such Notices of Violation received in the futur {

3.14 (Closed) Inspector Follow-Item (50-293/86-19-05)

Licensee to. upgrade the high radiation area controls to address: 4 recurring problem with identification of unlocked high radiation j areas; training of operations ' personnel in key control 1 requirements; and resolution of inconsistencies with high radiation area controls presented in procedures. The implementation of'high radiation area control and training of operations personnel was reviewed during inspection 50-293/87-29. Licensee corrective actions were reviewed and considered acceptable. The licensee _has

- revised procedures to remove the inconsistencie .15 (Closed) Inspector Follow-Item (50-293/86-19-06) l i

Licensee to address five areas for improvement in the area of {

personnel dosimetry:  !

I Item 1 (Closed)

Licensee to complete dosimetry procedure revision Findings The licensee established and implemented eleven dosimetry procedures.

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Licensee to complete training of personnel on newly established procedures.

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The licensee established lesson plans and provided training for the !

appropriate dosimetry staff for the newly issued procedure Item 3 (Closed)

Licensee to staff dosimetry assistant position Findings  !

The licensee upgraded an individual to temporarily fill the dosimetry assistant position. Additional contractor staff have been hired to supplement the clerical staff pending selection of an individual to permanently fill the dosimetry assistant positio i Item 4 (Closed)

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Licensee to resolve technical issues associated with personnel beta dosimetr Findings The licensee: reviewed the issues; performed a beta spectrum analysis; modified the algorithm for read-outs of TLD badges; and updated personnel dosimetry records, as app spriate, to address the ;

matte The licensee also corrected the whole body gamma exposure totals for several individuals whose total dose was found to be in erro .16 (0 pen) Inspector Follow-Item (50-293/86-19-11)

Licensee to review and evaluate the adequacy of his sources used for instrument calibration and his calibration facility to handle larger sources. The licensee reviewed his sources. The licensee evaluated the errors caused by scatter from the radiator and found it to be minima The licensee purchased a new calibrator capable of handling up to 400 curies of Co-6 This would produce usable .

calibration fields of about 6,000 R/h Procedures have not yet i been written for use of the calibrator. The calibration room can handle the larger sources. This item remains open pending establishment of a procedure for the new calibrato ___- _ _. _ _ -

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3.17 (0 pen) Inspector Follow-Item (50-293/86-19-12)

Licensee to review areas for improvement in the area of health physics counting equipment. The items for review and inspection findings are as follows:

Item 1 (0 pen)

Licensee to improve QA/QC practice for laboratory counting instrument Findings ,

The licensee established and implemented procedure SI-RP.400, Counting Room Instrumentation Statistical Evaluation, Revision 4 to provide additional control of QA/QC practices of laboratory counting equipment. The QA/QC practices include daily instrument checks, control chart data reviews, Chi Square tests, and Supervisory review of control chart test results. However, the procedures provide limited guidance for resolution of source check concerns ( source checks that fall outside of specifications).

Item 2 (Closed) i Licensee to improve supervisory review of counting laboratory data, particularly daily QA dat Findings As discussed in Item 1, the licensees' procedures provide for supervisory review of control chart data on a weekly basis. The licensee is reviewing the need to increase the frequency to dail Item 3 (Closed)

Licensee to review need for additional (back-up) counting equipmen Findings

NRC review during Inspection No. 50-293/86-19 found that there was an adequate number of instruments. The licensee performed a review to determine the need for additional equipment. Additional equipment will be ordered if needed for back-up purpose Item 4(Closed)

Licensee to develop a document to provide technical bases and methods for choice of quality control chart limits and method of calculating detection limits.

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Findings The licensee established procedure SI-RP-4000. Counting Room i Instrumentation Evaluation. This procedure addresses this matte .18 (Close'd) Unresolved Item (50-293/86-37-05)

Licensee to review odequacy of current methods for updating extended Radiation Work Permits (RWP) to reflect changes in radiological controls necessitated by issuance of a specific RWP for an area covered by an extended RWP. The licensee revised procedure 6.1-022 to include provisions for updating the extended RWP briefing sheet to reflect the presence of on-going work under a specific radiation work permi Extended RWP briefing sheets are to be reviewed and initialed daily by supervisors. The licensee aisc performs twice daily audits of the updating of extended RWPs. The inspector reviewed the updating of extended RWPs. The extended RWPs were updated according to procedure requirements. The licensee plans to revise his procedures to address:

Use of RWP status log book Updating extended RWPs when RWP revisions are made 3.19 (Closed) Inspector Follow-Item (50-293/87-17-01)

Licensee to upgrade personnel contamination control by: improving surveys of personnel anti-contamination clothiag; installation of improved personnel contamination monitors; and enhancement of the contamination surveillance program. The licensee's cleaning services vendor lowered the alarm set points on his contamination monitor to readily detect small point sources of activity. The licensee installed high sensitivity portal monitors in various locations within the radiological controlled area (RCA) and at exits from the RC The licensee also modified his surveillance program in order to provide for improved detection of point sources of contamination, a 3.20(Closed)InspectorFollow-Item (50-293/87-17-02)

i Licensee to upgrade oversight of his laundry monitoring and cnsite QA of processed laundry. The licensee upgraded oversight of his l

laundry vendor to improve vendor identification of point sources of

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contamination on processed laundry. The licensee also upgraded his onsite QA of processed laundry to improve identification of any l degradation of laundry monitoring performed by the vendo Instructions have been provided to appropriate personnel who check laundry.

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3.21(Closed)InspectorFollow-Item (50-293/87-17-03)

l Licensee to upgrade his review and evaluation of Radiological Occurrence Reports (RORs) associated with personnel contaminatio The licensee revised his radiological occurrence report procedure to provide ~for review of previous R0Rs to identify trends, repeat and degrading personnel performanc Review of selected RORs found contamination incidents / events to be reviewed and dispositioned with action taken to prevent recurrenc .22 (Closed) Inspector Follow-Item (50-293/87-17-05)

Licensee to upgrade exposure evaluation process and implement action to ensure timely review of exposure concerns. The licensee established and implemented procedure SI-RP-2400, Exposure Evaluation Reports. The procedure requires review and resolution of all exposure evaluations within 30 days after date of initiation unless authorized by the appropriate supervision. Inspector review indicated the licensee is generating a periodic status of exposure evaluation reports for review, evaluation and trending. All reports in excess of 30 days old were authorized. At the time of this inspection 20 authorized reports over 30 days old were awaiting processin .23(Closed)UnresolvedItem(50-293/87-17-06)

Licensee to review and revise 1986 Occupational Exposure Tabulation to assign at least 80% of the aggregate exposure to a specific work function. The licensee had only accounted-for 69% of the aggregate exposures. The licensee reviewed the initial data presented, revised it to include additional unaccounted for exposure, and included it in a resubmitted report. The licensee has implemented corrective actions to prevent recurrenc .24 (Closed) Inspector Follow-Item (50-293/87-18-02)

NRC to review licensee evaluation and corrective actions for a personnel contamination incident which occurred on September 3, 1987. The inspector reviewed the issued Radiological Occurrence Report, the worker's skin dose evaluation, and licensee corrective actions. Licensee review of the event was considered aggressive. A dose evaluation was performed and is undergoing review, a review of the source of the contamination was performed and a review of i laundry processing was performed. The licensee implemented the '

corrective action described in Inspection Report 50-293/87-18. The licensea will close out the R0R upon final review of the worker's dose and corrective action I

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. l 4.0 Organization and Staffing The requirements for the training and experience of the radiation j protection staff are specified in Technical Specification 6.3, " Facility >

Staff Qualification," and ANSI N18.1-1971, " Selection and Training of Personnel for Nuclear Power Plants." The qualification of the Radiation Protection Section Manager and selected members of his staff were f determined from interviews with these personnel. In addition, the inspector assessed the job responsibilities of each functional area within the_RP department and a proposed reorganization of the departmen Within the scope of this review, no violations were observed. The incumbent group leaders appear to be qualified for their positions and understand their responsibilitie ;

The RP Section Manager stated that a reorganization and staff expansion was planned to increase the effectiveness of the organization and to minimize the backlog of work in the RP department. Additional contractors would be hired until qualified permanent staff could be found. Priority attention will be directed towards improving radiological operations to reduce exposures and increase productivit The inspector concurred with the licensee assessment that these organization changes could correct some of the weaknesses previously identified in the RP progra The RP Section manager stated that the Radiation Protection Manager's function described in the Technical Specifications, was assigned to the Chief Radiological Engineer /Radcon Operations Supervisor. This licensee decision will be formally stated in a letter to the NR .0 ALARA t

The inspector reviewed the status of the ALARA program through discussions with the Senior ALARA Engineer. On September 17, 1987, the inspector attended a licensee management presentation that analyzed the exposure status for 1987 and projected the year-end total exposur The ALARA group on site consists of 19 personnel who report to the Senior ALARA engineer. The group falls within the RP department. Five ALARA engineers review radiation work permits end specify the ALARA precautions to be taken on each job. There are six ALARA technicians who review on-going work to ensure that the specified ALARA precautions are being followed. Several clerks are used to extract dosimeter readings from RWP reports and enter the data into computer files for analysis and reporting. There is an ALARA Committee chaired by the Station Superintendent (Nuclear Operations Manager) and consisting of the various site Department Managers (Chief Engineers). The committee provides oversight and sets policy for the ALARA Program. The inspector concluded that the major elements of an operational ALARA Program are available on site.

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!- The licensee estimates that the year end total exposure for 1987 will be 2060 person-rems. Of this 2060 person-rems, 1350 person-rems is attributed to extending the refueling outage past the originally scheduled March completion to December 1987. The licensee indicated that this additional exposure is attributed to licensee initiated modifications (63%), NRC mandated work (19%), poor planning or coordination (8%),. nonproductive rework (7%) and improper contamination control (3%). Licensee analysis shows that 969 person-rem were saved in 1987 due to ALARA efforts thus far. In addition, certain modifications performed during this outage are expected to reduce exposures in future outage Some exaTples are: 1 I

- Installation of hydrogen addition for the condensate system j

- Replacement of in-core detector terminals with high reliability design

- Use of live-loaded packings during valve rebuilds

- Replacement of asbestos insulation with pre-formed quick l removal insulatio I The inspector noted that the licensee's analysis was thorough and l detailed. The major causes of personnel exposure have been identifie The inspector expressed concern regarding the high person-rem total. The

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inspector indicated that aggressive effort is needed to reduce  ;

unnecessary / unplanned personnel exposur The licensee indicated this area will be reviewed for improvement. The inspector stated that licensee efforts in this area will be reviewed during a subsequent inspectio ]

6.0 Radiological Controls During Fuel Movement (Drywell)

The inspector reviewed the adequacy and effectiveness of licensee Radiological controls for Drywell work during fuel movemen Documents Reviewed Procedure No. 4.3, Fuel Handling; )

Procedure No. 6.1 - 012, Access to High Radiation Areas; i General Electric Operating Experience Report No. 78, Radiation Levels I and Shielding Recommendations for the Upper Drywell Area During Fuel I Transfer; j General Electric Service Infonnation Letter No. 354, Potential ;

Radiation Levels In Upper Drywell Areas During Fuel Movement I Activitie I

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Within the scope of the review, the following was identified:

The licensee performed a detailed radiation exposure dose rate profile of the Drywell for various fuel handling / accident situation The licensee utilized the exposure dose rate data to evaluate the adequacy and effectiveness of his current radiological controls for access to and work in the Drywell during fuel movemen As a result of the evaluation, the licensee revised his High Radiation Area Access Control Procedures and Fuel Movement procedures to enhance access controls and ensure shielding installation prior to fuel movemen .0 Exit Meeting The inspectors meet with licensee personnel (denoted in Section 1) at the conclusion of the inspection on September 18, 1987. The inspectors summarized the purpose, scope and findings of the inspectio No written material was provided to the license I

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