IR 05000266/1987019

Insp Repts 50-266/87-19 & 50-301/87-19 on 870921-1013.No Violations or Deviations Noted.Major Areas Inspected: Radiation Protection & Radwaste Programs,Including Organization & Mgt Controls & Audits & Appraisals

ML20236G994
Person / Time
Site:	Point Beach
Issue date:	10/28/1987
From:	Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236G970	List: IR 05000266/1987019 ML20236G966
References
50-266-87-19, 50-301-87-19, IEB-79-19, IEIN-86-107, IEIN-87-032, IEIN-87-32, NUDOCS 8711030381
Download: ML20236G994 (11)

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U. S. NUCLEAR REGULATORY' COMMISSION

REGION III

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l Reports No. 50-266/87019(DRSS);-50-301/87019(DRSS)

Docket-Nos. 50-266: 50-301 Licenses No. DPR-24; No. DPR-27 j Licensee: Wisconsin Elactric Power Company -

231 West Michigan

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Milwaukee, WI 53201 Facility Name: Point Beach Nuclear Plant (PBNP) -j i

Inspection At: PBNP; Units 1 and 2, Two Rivers, Wisconsin l Inspection Conducted: September 21 through October 13, 1987 Inspector: b8 'btElbfu R. A. Paul /O-R 9'# 7 q Date  ;

h. $ bYb ?N f .

Approved By: L. R. Greger, Chief /o -xc r7 '

Facilities Radiation Protection .0 ate Section Inspection Summary Inspection on September 21 through October 13, 1987 (Reports q No. 50-266/87019(DRSS); No. 50-301/87019(DRSS)) j Areas Inspected: Routine unannounced inspection of radiation protection and radwaste programs, including: organization and management controls, audits-and appraisals, solid radwaste, and transportation activities. .Also, certain Radiological Event Reports, open items, and two hot particle incidents involving personal exposure were reviewe i Results: No violations or deviations were identifie j l

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i DETAILS  !

'1. -Persons Contacted

• R. Bredvad, Plant Health Physicist

• D. Johnson, Superintendent., Health Physics ,

J. Knorr, Regulatory Engineer, Nuclear Plant Engineering  !

• J. Reisenbuechler, Superintendent,.EQR J. Zach, Plant Manager 1

• R. Greger, NRC, Chief, Facilities Radiation Protection 'j

• R. Hague, NRC, Senior Resident Inspector

• R. Leemon, NRC, Resident Inspector The inspector also contacted other plant staff during this inspectio * Denotes those present at the exit meeting held on September 25, 198 . General I This inspection, which began at approximately 8:00 a.m. on September 21,. l 1987, was conducted to review the operational. radiation protection and i radwaste programs, including organization and management controls, audits I and appraisals, solid radwaste, and transportation activities. Als reviewed were open items' corrective actions taken as a result of-

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previously identified' violations, and personal exposures from hot particle Several tours of radiologically controlled. areas were made; area postings, access controls, and housekeeping appear. goo . Licensee Actions on Previous Inspection Findings i i

(Closed) Violation (266/87011-02: 301/87010-02): Failure to instruct !

workers in proper use of shielding containers. The licensee has developed a step-by-step plan for recovery of' the temporary radwaste storage area and implemented procedures which provide instructions for the proper handling, packaging, transport, and temporary storage of radioactive wast (Closed) Violation (266/87011-01; 301/87010-01): Failure to instruct workers in proper use of a shielding container housing a radioactive source. The licensee has placed additional labeling on all containers housing sources to better identify and distinguish components and to provide handling instructions, installed tamper seals and locks to prevent inadvertent removal of sources, developed and implemented a new radiation source procedure, and provided training to: health physics supervisors'and technicians concerning the proper use of sources. A specific RWP'is required for use of portable source (Closed) Open Item (266/85007-01; 301/85007-01): Turnover rate of RCO staff and its effect on staff stabilit See Section 4;for th licensee's corrective action l

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I (Closed) Open Item (266/87011-03; 301/87010-03): Use of protective I clothing to prevent problems associated with personal contamination. The I licensee has begun to use new coveralls without side pockets as' secondary protective clothing (PC). The use of the new PCs should prevent personal clothing contaminations which the licensee. speculated were caused by the use of protective coveralls which had open side' pocket i l

(Closed) Open Item (266/86016-03; 301/86015-03): Improvement of radwaste worker trainin See Section 5 for the licensee's corrective actions, j i

(Closed) Open Item (266/86016-04; 301/86015-04): Improve steam generator )

exhaust ventilation system to prevent radioactive releases into the i containment building. A modification was made by installing an interlock I on the vent systems that prohibits the steam generator vent unit from i operating when the containment purge vent is not operatin . Organization, Management Controls, and Staffing )

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for radiation protection, including changes in the organizational i structure and staffing, effectiveness of procedures and other management I techniques used to implement the program, and experience concerning j self-identification and correction of program implementation weaknesse A corporate staff health physicist has assumed the Superintendent-Health l Physics (S-HP) position and reports to the General Superintendent with a I direct reporting path to the Plant Manager as necessary for radiological matters. The Plant Health Physicist and the Radwaste Supervisor report to the S-HP. An additional staff professional HP position has been create i During two previous inspections (Inspection Repor's No. 266/85007; 301/85007 and No. 266/86004; 301/86004), it was noted that the turnover rate of the technician staff (RCOs and RCOTs) was significantly higher I than other Region III plants, and that it affected the qualification and l

experience level of the RC0 staff and appeared to diminish the stability i and effectiveness of the radiation protection organizatio Since then, there has been a significant reduction of staff turnover as demonstrated by the loss of only two RC0/RCOTs during 1987 to date. In addition, the l RC0/RCOT staff has increased from 12 to 16 since the previous inspection (Inspection Reports No. 266/87011; 301/87010), and four additional RCO positions have been authorized; these positions are scheduled to be filled by January 1988. The licensee has also initiated a review of the health physics organization to evaluate staffing levels, organizational structure, salary, and recommend program efficiency improvements and appropriate management control systems. This evaluation is scheduled for completion by January 1, 1988. These steps and the additional staff increases should enable the licensee to fulfill a previous commitment to provide 24-hour health physics coverage, and to significantly increase staff experience and availability by reducing staff turnove No violations or deviations were identified.

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1 5. Training and Qualifications I The inspector reviewed the training and qualifications aspects of the ,

licensee's radiation protection, radwaste, and transportation programs, including: changes in responsibilities, policies, goals, programs, and methods; qualifications of radiation protection personnel; and provisions for appropriate radiation protection training for station personne Also reviewed were management techniques used to implement these programs (

and experience concarning self-identification and correction program )

implementation weaknesse The Radiation Control Operator (RCO) training program was accredited by i the Institute of Nuclear Operations (INPO) in Argust 193 This program j appears to be effective in developing and strargthening RCO skill .)

The current training program for solid radwaste workers (contract i l

l employees) who work unsupervised consists of OJT, formal training, and j l

annual retraining as described in I.E. Bulletin 79-1 The training is done in accordance with training procedure TRCR 2 The radwaste workers j must be trained and task qualified in waste processing and receipt and I

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shipping of radioactive material The current training program for

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I radwaste workers appears to be more comprehensive than the one described in Inspection Reports No. 50-266/86016; 50-301/8601 !

No violations or deviations were identifie ]

6. External Exposure Control and Personal Dosimetry The inspector reviewed the licensee's thermoluminescent dosimeter (TLD)

quality control program. The quality control program consists of routinely (monthly) exposing TLDs to known exposures from cesium-137 sources and sending other TLDs to the National Bureau of Standards (NBS)

for similar purposes. Both sets of exposed TLDs are sent to the licensee's dosimetry vendor for processing and evaluation of their analysis capabilit The difference between the known and the vendor i reported exposure is calculated for each TLD in the tes The sum of the !

standard deviation of these percentage differences and the absolute value of the mean of the percentage differences is then compared to the tolerance level of 0.50 as noted in ANSI N13.11, 1983. If the sum is less or equal to the tolerance level, the processing results are considered acceptabl A recent QA audit noted that the vendor reported TLD readings for 1986 l

were consistently lower than the calculated values by 20 to 25 percen As a result, the licensee initiated a review to determine the cause of the lower values and possible effect on personnel exposure data. The results of this review indicated that the negative bias was the result of the vendor's processing and that an audit of the vendor would be required; l however, the observed negative bias was within applicable standards and it was not necessary to adjust personnel exposure data. In addition, the licensee has suggested the following measures to improve the TLD QA program: Expand the TLD QC program; record the TLD quality control results on graphs and tables; audit the vendor's processing

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l facilities sooner than scheduled; discontinue use of the Shepard Mark IV TLD irradiator; and choose tha dose equivalent I exposure levels randomly within the test irradiation rang These matters were discussed with the licensee and will be reviewed during a' future inspectio (0 pen Item 266/87019-01; 301/87109-01)

No violations or deviations were identifie . Internal Exposure Control - Respiratory Protection Program The inspector reviewed the licensee's internal exposure control and assessment programs, including changes to procedures affecting internal exposure controls and determination whether engineering controls and respirawry equipment meet regulatory requirement A review of the respiratory protection program was conducted to ensure compliance with regulatory requirements, use of good practices and guidance provided in Regulatory Guide 8.15 and NUREG-0041. This review included; applicable procedures (HPIP 4.51, " Maintenance, Inspection, Testing, Repair and Storage of Respiratory Protection Equipment,"

HPIP 4.53, " Cleaning, Disinfection and Decontamination of Respiratory Equipment," HPIP 4.54, " Operation and Maintenance of Dynatech Frontier Corporation Model 260 Respirator Fit Testing System"); interviews with HP personnel concerning personnel testing, use, and control of the respirators; record inspection of selected workers approved to wear respiratory equipment; and inspection of respirators available for us Based on this review it appears the licensee is conducting the respiratory protection program in compliance with applicable regulations and procedure No violations or deviations were identifie . Dry Radioactive Waste Volume Reduction Program The licensee does not segregate or survey controlled zone waste to reduce radioactive waste volume; however, waste volume reduction is accomplished i by reducing the material and equipment allowed into the controlled zone i and by using a vendor super compactor with increased compaction efficienc ]

l No violations or deviations were identifie . Solid Radioactive Waste The inspector reviewed the licensee's solid radioactive waste management program, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59, 10 CFR 61.55 and 61.50, and 10 CFR 20.311; adequacy of implementing procedures to properly j classify and characterize waste, prepare manifests, .wd mark packages; j overall performance of the process control and quality assurance i programs; adequacy of required records, reports, and notifications; and j experience concerning identification and correction of programmatic l weaknesse I

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i Solid radioactive waste consists almost solely of spent resins and i evaporator concentrates which are solidified using the Chem-Nuclear !

portable cement solidification syste DAW is placed into 55 gallon l steel drums and transported to a vendor operated super compactor for j final shipment to a burial sit )

The Chem-Nuclear system is vendor controlled and operated in accordance 1 with a NRR approved Process Control Program (PCP). Some of the provisions )

of the PCP require that procedures provide assurance that the solidification process is conducted within established process parameters and that the final waste product meets appropriate waste characteristic requirements for solidified waste To meet these requirements the ;

licensee uses vendor Procedure 50-0P-00 j No violations or deviations were identifie . Audits and Appraisals The inspector reviewed a quarterly audit of the PCP conducted by the i licensee in April,198 The audit reviewed activities concerning i radwaste shipping containers and documentation of radwaste shipment d The audit consisted mainly of procedures, reports, and records pertaining 1 to the pre. essing of radioactive waste to ensure compliance with the PC Nc significant problems were noted; however, one audit finding in the -

area of solidification waste volume percentage was noted. Adequate {

corrective actions were taken by the radwaste department for this l findin No violations or deviations were identifie . Transportation of Radioactive Materials I

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The inspector reviewed the licensee's radioactive materials transportation l program, including: determination whether written implementing procedures l are adequate, maintained current, properly approved, and acceptably l implemented; determination whether shipments are in compliance with NRC ]

and DOT regulations and the licensee's quality assurance program; j determination if there were any transportation incidents involving (

licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification l and cori ection of programmatic weaknesse ;

Contaminated solid trash (DAW) is packaged in 55 gallon steel drums and

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l l compacte DOT Specification 17-H drums are used which meet the DOT 7-A !

performance criteri Most DAW is stored in onsite sea vans outside the l l radwaste building until shipment. During this inspection, shipments of l DAW were sent to the vendor for compaction; no problems were noted by the l inspector. Liquid wastes consisting primarily of resins and evaporator l l bottoms are solidified using a vendor syste j t

Records of radioactive waste shipments were selectively reviewed for '

! compliance with 10 CFR 172-173 and 10 CFR 7 From September 1986 l l through August 1987, the licensee shipped approximately 354 cubic feet of l l

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l evaporator bottoms and 384 cubic feet of primary plant resin Total Dry Active Waste (DAW) shipped during 1987 to date was 1322 cubic fee There were no transportation incidents-during this perio No violations or deviations were identifie H

1 IE Information' Notice Followup '

l The inspector reviewed the licensee's internal actions to selected IE Information Notices. The licensee's evaluations, conclusions and i

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corrective actions are presented below:

Notice No. 87-32: " Deficiencies in the Testing of Nuclear-Grade Activated Charcoal." This notice alerts licensees to deficiencies found- ,

in the testing of nuclear grade activated charcoal used for accident I mitigation in nuclear facilitie i Testing of charcoal filters is performed for the licensee by a vendor which reportedly performed satisfactorily during the NRC/ Idaho National Engineering interlaboratory comparison study. The licensee. anticipates retaining the services of their vendor and does not plan to take any actions as a result of this notic Notice No. 86-107: IE Information Notices 86-44 and No.86-107 address potential radiological hazards associated with entry into TIP rooms and cavities beneath reactor vessels. The station has two areas for each l unit similar to those described in the Information. Notices, the seal j table and incore reactor cavity area Both areas are potentially very

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l high radiation areas (> 1R/hr), depending on operational mode and '

location of incore detectors and thimble Refueling Procedure No. RP-1A, " Preparation for Refueling," requires tha health physics secure the keyway (reactor cavity) entrance with a lock and post "no entry" while thimbles are withdrawn. f The procedure'also has a caution addressing steps to be taken before sending personnel into a keyway and a requirement that health physics' coverage be provided during entr Instrument Control Procedure No. ICP 10.29, " Routine Maintenance Procedure, Seal Table Operations for Refueling," requires that health physics be contacted to ensure personnel are clear of the keyway before

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withdrawing thimbles, and contains cautions ensuring that detectors are

in their storage locations and that none of the thimbles are retracted before sending personnel into the keyway. In addition, Health Physics Standing Order-36 (HPS0-36), " Keyway-Entrance During Refueling," imposes further radiological controls to prevent radiological overexposur The licensee does not have a specific ongoing training program which addresses the hazards associated with entry into the reactor vessel sump room while retractable incore detector (RID) thimbles are withdraw However, in response to an INPO Notice related to this matter, the licensee presented a training course to all plant. radiation workers in December 1985, and January 1986, covering the hazards with cavity entr In addition, HPs, RCOs, RCOTs, and ads receive training in proper survey methods for high radiation area entry which includes cavity entrie .

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No violations or deviations were identifie !

j 13. Facilities and Equipment  !

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The inspector toured radiation protection facilities, observed radiation )

protection equipment in use, noted facility and equipment changes, and i discussed plans for future facility and equipment change Current and j future facility and equipment changes included: -(1) new bag type suits were purchased for outer protective clothing for entry in high contamination areas; (2) additional friskers have been installed in the hallway at the exit from the Auxiliary Buildings and in the drum compacting area; (3) additional portable constant air monitors have been placed within the Auxiliary Building; (4) temporary frisker stations are scheduled to be setup for the Unit 2 refueling; (5) eberline Model PCM-13 frisker l booths have been purchased to replace handheld friskers at the egress I from the controlled zone; and (6) painting and improving lighting facilities in the PAB continue It appears the licensee has sufficient supplies of PC's, respiratory equipment and survey instrumentation to accommodate routine and outage activitie In addition, it appears the facilities and equipment for radiation protection activities are adequate; however, improved laundry facilities including a laundry monitoring detection system, woul increase efficiency of contamination detection on laundered clothing and be less labor intensive than the current method of surveying clothing using a hand held friske No violations or deviations were identifie l 14. Radiological Event Report l The inspector reviewed several Radiological Event Reports (RERs) which l concerned the inoperability/ problem with the station's radiation monitoring syste One such report (RER No. 87-02-016), discussed the licensee's review and investigation of the circumstances which allowed the inoperability of one of the RMS system As a result of the inspector's review of this and other RERs, the licensee was requested to evaluate the adaquacy of the RMS surveillance progra The inspector will review the licensee's evaluation at a future inspection; this matter was discussed at the exit intervie (0 pen Item 266/87019-02; 301/87019-02).

No violations or deviations were identifie . Skin Exposures by " Hot Particles" The inspector reviewed the licensee's investigations of two incidents in which minute discrete radioactive particles were found; one on top of a contractor's tennis shoe and one on the bottom of a substation employee's soc In one incident the particle was found on the top of an individual's tennis shoe on October 3, 198 After removal, the particle was analyzed and found to contain 2.7 microcuries of cobalt-6 The licensee conducted an investigation of the individual's activities before and during October 3, 1987, his first day in the statio The licensee's investigation included interviews with the individual, review of his previous and current work activities, entries and exits from the controlled area, and the individual's frisking metho The results of their investigation is discussed belo On October 3, 1987, the contract worker was removing potentially contaminated refueling equipment wrapped in plastic bags from a container on the refueling floor (controlled zone). The equipment had recently been sent to the licensee from the San Onofre Nuclear Plant and was shipped in accordance with regulatory requirement The equipment was surveyed by the licensee upon receipt; no hot particles were foun The worker wore prescribed protective clothing (PC) which included plastic booties worn under toe rubbers. After the individual completed his work, he removed his toe rubbers before crossing the step-off pad (SOP) but did not frisk out at the local hand held friske The worker proceeded to the radiologically controlled side locker room, removed his protective coveralls and placed them into the PC barrel, then performed a whole body frisk at the control zone friske During this frisk the hot particle was found at the base of the tongue of his tennis shoe; no other hot particles were found during the surve The licensee confiscated his shoe, removed and analyzed the particl The licensee concurrently retrieved and surveyed the PC's the individual had worn; no hot particles were detecte During the investigation it was learned that the individual had worn his tennis shoes about two weeks earlier at the San Onofre station while working with the same refueling equipment. Before his departure from I

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that station on September 9, 1987, he reportedly proceeded through two beta sensitive whole body friskers and one gamma sensitive portal monitor while wearing his tennis shoes; he stated that no contamination was detected by these monitor According to the worker, the tennis shoes were not worn between September 9 and October 3, 198 During that period the tennis shoes were wrapped in a plastic bag and stored in his suitcas Because the licensee suspected the hot particle may have been on the worker's tennis shoe before working in their facility, surveys were made of his personal belongings, (including the plastic bag which had contained the shoes) and his motel room; no contamination was foun The licensee subsequently learned from San Onofre personnel (through tests performed on the San Onofre monitoring systems used by the worker departing that station) that a 2.7 microcurie cobalt-60 particle located on the top of a person's shoe should be detecte In an effort to find the source of the particle, extensive surveys were performed in all areas of the station, including the refueling equipment and the refueling floor; no other particles were foun The licensee eventually concluded that the particle most likely came from the

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refueling equipment being handled by the worker. As a result, the licensee has strengthened their surveillance program for incoming materials with the potential for hot particle Based on the individual's work activity, the location of the particle, and the maximum probable time the particle could have been on the individual's shoe while worn at the licensee's facility (two hours and thirty-two minutes), the. licensee calculated the beta gamma dose to the worker's foot (extremity), averaged over one square centimeter, was less than one rem, which agrees reasonably with the inspector's estimate of the dos In another incident on October 5, 1987, a particle was found on the heel i of the outside of an individual's sock upon his exit from the controlled

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zone. After removal, the particle was analyzed and found to contain 2.35 microcuries of cobalt-60. The individual had been working on a reactor coolant pump motor in containment, a job that was unrelated to and physically separated from the hot particle incident described abov After departing from containment, the worker removed his PC's and work shoes, placed them into his control side locker, put on paper bottom shoe covers and proceeded to the control side frisker station (the first location requiring a frisk) where he detected the particle. The licensee investigated this matter by conducting a review similar to that performed for the October 3, 1987 incident. Additional surveys of the worker's l PC's (brand new and never before worn), and the areas in which he worked were also performed; no other particles were foun As a result of the investigation the licensee speculates that the particle was most likely transferred from the floor of the controlled i side locker room to the bottom of the worker's sock and may have had the same origin as the October 3 hot particle. Based on the individual's work activities, the licensee estimated the exposure occurred for

' approximately one hour fifty minutes, and the dose to skin averaged .

over one square centimeter was less than one rem, which agrees reasonably I with the inspector's estimate of the exposur An apparent weakness associated with the former incident involved the following matter: The worker did not perform a personal survey after crossing the 50P using a hand held frisker located near by. According to the licensee, the frisker had just recently been situated in that area of the refueling floor for use during the current refueling outage. Although there were no specific instructions posted requiring the use of the frisker after crossing the SOP, it was the licensee's intent that the frisker be used for that purpose. However, because of poor communications between the worker, his escort, and station personnel, the licensee's {

intent for the use of the frisker was not adequately conveyed. The 1 l

licensee corrected this problem by posting specific instructions at the !

SOP, and by requiring use of the frisker in accordance with the RW The inspector interviewed one of the participants in the incidents, discussed the licensee's investigation results and calculational methods, and performed independent calculations. The licensee's calculated skin doses in both incidents were less than one rems. The licensee and NRC

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calculations are in reasonable agreement. No overexposure occurred as a j result of the incidents, and no items of noncompliance with regulator I requirements were identified. One weakness was noted. The licensee's'

investigation appeared timely and thorough. This matter was discussed with the licensee on several occasions between October 5 and 13, 198 . Surveillance; Independent Surveys; Plant Tours J Based on several tours of the plants, the inspector noted: (1) Posting, labelling and radiological controls for radiation and high radiation areas were in accordance with regulatory requirements; however, barrels containing what appeared to be new and unused protective clothing and equipment were observed to be inappropriately labelled with " Radioactive j Material" labels on the outside of the barrels. The licensee stated ,

that, although the barrels contained nonradioactive material, they were j in preparation for the Unit 2 refueling outage and were labelled as such because they would probably contain radioactive material during the outage; the licensee subsequently removed the labels. Also observed were what appeared to be excessive Radiation Area postings in the Auxiliary Building. The inspector informed the licensee that mislabelling and overposting are poor practices which can lead to worker confusion and -

inattention to postings. This matter was discussed at the exit interview; and (2) independent radiation surveys performed by the inspector indicated radiation postings corresponded to the actual radiation fields. The results of 35 smears of floor and horizontal surfaces indicated only two areas were slightly in excess of the licensee's limit for controlling contaminated areas (300 dpm/100cm2), l The areas were subsequently decontaminated / controlle These matters were discussed at the exit intervie . Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on September 25, 1987. The inspector summarized the scope and findings of the inspection. The inspectors also discussed the likely information content of the inspection report  !

with regard to documents or processes reviewed by tha inspector during the inspection. The licensee identified no such documents / processes as proprietary. In response to certain items discussed by the insoehtor, the licensee:

0 Acknowledged the inspector's comments concerning the adequacy of  !

the RMS surveillance program (Section 14). > Acknowledged the inspector's comments concerning mislabelling and overposting (Section 16). e i

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