ML20214Q329

Safety Insp Rept 50-293/87-19 on 870427-0501.Violation noted:hi-hi Radiation Key Kept in Desk of Watch Engineer Rather than in Special Key Cabinet as Required

ML20214Q329
Person / Time
Site:	Pilgrim
Issue date:	05/20/1987
From:	Lequia D, Loesch R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214Q296	List: ML20214Q293 ML20214Q315 ML20214Q329
References
50-293-87-19, NUDOCS 8706040344
Download: ML20214Q329 (9)

See also: IR 05000293/1987019

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-293/87-19

Docket No. 50-293

License No. DPR-35 Priority - - Category C

Licensee: Boston Edison Company M/C Nuclear

800 Boylston street

Boston, Massachusetts

Facility Name: Pilgr_im Nuclear Power Station

Inspection At: P3 mouth, Massachusetts

Inspection Conducted: April 27 - May 1, 1987

Inspectors: /~ /gt aM

D. LeQu1a,' Radiation pecialist

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k. Loesch, Radiation Specialist

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Approved by:

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Radiation Protection Section

Inspection Summary:

Ar_eas Inspecteji: Routine, unannounced safety inspection of the licensee's

implementation of the Radiation Protection Program during an outage, including:

status of previously identified items; organization and management control;

external exposure control; and control of radioactive materials and contami-

nation, surveys and monitoring.

Results: One violation relative to High Radiation Area key control was

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Identified,

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DETAILS

1.0 Persons Contacted

During the course of this inspection, the following personnel were

contacted or interviewed:

1.1 Licensee Personnel

• R. Bird, Senior Vice President - Nuclear

K. Roberts, Nuclear Operations Manager

• T. Sowden, Radiological Section Manager

• S. Hudson, Operations Section Manager

• C Gannon, Chief Radiological Engineer

• S. Bibo, Quality Assurance Group Leader

• F. Famulart , Quality Control Group Leader

• J. Matta, Quality Assurance Surveillance Group Leader ~

W. Olson, Watch Engineer

• P. Hamilton, Compliance Group Leader (Acting)

• T. Ferris, Licensing Engineer

W. Mauro, Radiation Protection Supervisor

Other licensee or contractor personnel were also interviewed.

1.2 NRC Personnel

• T. Kim, Resident Inspector

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Note: * Denotes attendance at the Exit Meeting held on May 1, 1987.

2.0 Purpose ,

The purpose of this routine inspection was to review implementation of

the licensee's Radiological Control Program relative to the current

outage. Areas inspected included the following:

• Status of Previously Identified Items;

• Organization and Management Controls;

• External Exposure Control; and

• Control of Radioactive Materials and Contamination, Surveys and

Monitoring.

3.0 Status of Previously Identified Items

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3.1 (Closed)InspectorFollowItem(50-293/86-35-02): Licensee to

submit all missing data from last two semi-annual effluent reports

by December 31, 1986. Inspector review of Licensee letters (No.

2.86.190 and 2.86.191) submitted to the NRC, and review of the

semi-annual

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effluent reports for January 1 through June 30, 1986, and July 1

through December 31, 1986, verified that the licensee has submitted

all previously missing data by the,date required. This item is

closed.

3.2 (Closed) Non-compliance (50-293/86-44-01): Licensee to improve

controls for radiological release of vehicles / materials to offsite.

Inspector review of Security Procedure " Station Access Control,"

dated December 3, 1986, and two office memorandums dated March 2,

1987, and March 5, 1987, relative to " vehicle escorts," verified that

the licensee has taken additional actions to prevent the release of

vehicles without first obtaining required radiological surveys. In

addition, data compiled by the licensee demonstrated that 918

vehicles entered and left the PNPS Protected Area in January and

February of 1987, without a breakdown in the new controls. Based on

inspector review of this area, this item is closed.

3.3 (0 pen) Inspector Follow-up item (50-293/85-13-11): Review status of

TIP and Radwaste Area Radiation Monitors. The licensee determined

an area monitor is not needed in the Radwaste Segregation

area. Relative to the TIP Monitor, a review by the Radiological

Oversight Committee for the proposed relocation of the TIP area

monitor was not yet available. Furthermore, the proposed Engineering

Request for this monitor was rejected by the NOD-RAD Section. Since

final resolution for these monitors has not been achieved, this item

will remain open and will be reviewed in a future inspection.

3.4 (Closed) Inspector follow-up item (50-293/85-17-04): Failure to

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i specify surveillance frequencies on RWPs for High Radiation Areas.

A review of Procedure 6.1-022, Rev. 20, " Issue, Use, and Termination

of Radiation Work Permits (RWPs)," and the revised RWP form

(6.1-022A-1) indicated that specific surveillance frequencies are

procedurally addressed. Inspector review of several active RWPs

verified that surveillance frequency are being specified on RWPs.

This item is considered closed.

4.0 Organization and Management Controls

The licensee's organization, and staffing to effectively control radiation

and radioactive materials was evaluated against the following criteria:

• Technical Specifications, Section 6, " Administrative Controls";

• Regulatory Guide 1.8 " Personnel Selection and Training";

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• NUREG/CR-1280, " Power Plant Staffing"; and

• ANSI-N18.1-1971, " Selection and Training of Nuclear Power Plant

Personnel"

Licensee performance relative to these criteria was determined by:

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• Review of Organizational Charts;

• Discussions with cognizant personnel;

• Inspector tours of radiologically controlled areas;

• Review of Radiological Occurance Reports (RORs); and

• Review of Exposure Evaluation Reports (EERs).

The licensee has taken action to increase HP technician and supervisory

staffing to support ongoing outage activities. In addition, the position

of Chief Radiological Engineer was recently filled with a certified

Health Physicist. This position had been vacant for approximately one

year.

Inspector review of RORs and EERs determined that these corrective action

documents effectively captured the details of events. However, they

frequently failed to identify root causes. Failure to determine a root

cause appeared to inhibit effective corrective action development and

implementation to prevent recurrence. Additional weaknesses relative to

RORs/EERs, as well as other weaknesses in management controls, are iden-

tified in the following section.

Within the scope of this inspection, the followirig additional weaknesses

were identified:

- While the licensee has increased the number of HP technicians and

first-line supervisory staff, inspector tours of the Reactor Building

noted an apparant lack of supervisory oversight. Specifically, supervisors

were not routinely ob:erved in the plant and unessential personnel were

observed to gather at control points.

- The newly proposed reorganizatica for the Health Physics (HP) Group

did not provide the position of Radiation Protection Manager (RPM) with

sufficient responsibility or authority.

- Management / Supervisory personnel voluntarily downgrading to HP technician

level may leave key positions vacant, with a potential impact on the

implementation of the Radiation Protection Program.

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- Contractors, in key positions in the ALARA Group, will take valuable

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experience with them when they leave. Station personnel were not being

groomed to fill these positions.

- Relative to RORs and EERs:

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- they frequently failed to identify root causes, as mentioned earlier.

l - follow-up action is often missing or not effective to prevent

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l - are not always closed out in a timely manner.

- frequently lack management support from groups outside of

Health Physics.

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The inspector discussed these weaknesses with the licensee, who stated

that they would evaluate these issues and take action as necessary to

improve management control in this area.

5.0 External Exposure Control

The licensee's program for external radiation exposure control was

reviewed against criteria contained in:

• 10 CFR 20.201, " Surveys";

10 CFR 20.203, " Caution signs, labels, signals and controls";

• 10 CFR 20.401, " Records of surveys, radiation monitoring, and

disposal";

Technical Specification 6.13, "High Radiation Area";

• Regulatory Guide 8.2 " Administrative Practices and Radiation

Monitoring";

• Regulatory Guide 8.4, " Direct Reading and Indirect Reading

Pocket Dosimeters";

• Regulatory Guide 8.7, " Occupational Radiation Exposure Record

Systems";

IE Information Notice No. 81-26, Part 2, " Placement of Personnel

Monitoring Devices for External Radiation Exposure", August 2, 1981 and

Supplement 1, July 19,1982;

• IE Information Notice No. 83-59, " Dose Assignment for Workers in

Non-Uniform Radiation Fields", September 15, 1983.

• Licensee procedures:

- 6.1-012, " Access to High Radiation. Areas";

- 6.1-022, " Issue, Use, and Termination of Radiation Work

Permits (RWPs)";

- 6.1-024, " Radiological Posting of Areas of the Station";

- 6.3-060, " Radiation Survey Techniques"; and

- 1.3.10, " Key Control."

Performance of the licensee relative to these criteria was

determined from:

• Discussions with cognizant personnel;

• Review of Radiation Work Permits (RWPs);

• Inspection of ALARA Reviews;

• Review of High Radiation Area Key Controls;

• Independent Surveys by the Inspector;

• Tours of the Reactor and Turbine Buildings;

• Review of Radiological Occurance Reports (RORs);

Review of Exposure Evaluation Reports (EERs); and

• Review of Radiological Surveys.

The licensee's radiological postings appeared adequate to prevent

inadvertent exposure of personnel and properly informed individuals

of potential radiological hazards. In addition, the inspector noted

that a recent RWP for the cutting of Dry Tubes appeared effective

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and used recent industry experience to improve radiological

controls. This RWP included a "Small Source" radiological hazard

briefing for all personnel prior to work initiation.

- Within the scope of this inspection, the following apparent

violation was identified:

Technical specification 6.8 requires, in part, that the procedures

recommended in Regulatory Guide 1.33 be implemented and adhered to.

Procedure No.1.3.10, Rev.16, " Key Control" authorizes one

high-high radiation key (which controls access to areas potentially

greater than 10,000 mrem /hr) to be kept in the Control Room in the

Special Key Cabinet. In addition, the key will be accounted for at

the beginning of each shift and an entry will be made in either the

NOS Log or Radwaste Log.

Contrary to the above, inspector audit of the key on April 28, 1987,

determined that the high-high radiation key was being kept in the

Watch Engineers desk rather than in the Special Key Cabinet as

, required.

Contrary to the above, inspector review of the NOS Log and the

Radwaste Log for the month of April identified three (3) instances

(4/6, 4/7 and 4/25/87) of failure to account for the high-high

radiation key on a shiftly basis as required.

The above items constitute an apparent violation. (50-293/87-19-01)

In addition to the Ibeve violation, the inspector identified some weakness

relative to control of high radiation area keys maintained by the Health

Physics Group. Specifically, the inspector observed that key number one

(1) had been simultaneously issued to two different individuals. Licensee

, investigation revealed that the key was in the custody of the last person

on the key issue list, but that the previous user of the key had failed to

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record that the key had been returned.

The inspector noted that the above incidents provide continuing evidence

of weaknesses in high radiation area key control. Two previous inspec-

tions this year (87-03 and 87-11) have identified similar issues associ-

ated with high radiation area key control.

The following weakness was also identified:

During inspector reviews of Reactor Building work, two workers, one

wearing a respirator and one without a respirator, were observed in the

same work area. When the inspector identified this situation to the

licensee, they promptly removed the individual without a respirator from

the area. Subsequent investigation by the inspector determined that

respiratory protection was not required for the job based upon RWP survey

results and the nature of the work. When the inspector discussed this

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event with the licensee, they stated that HP personnel wanted to revise

the RWP to delete the requirement for respiratory protection, but that

maintenance management wanted to start.the work immediately, without

waiting for an RWP revision. HP personnel succumbed to the pressures of

production and allowed the work to be done with respiratory protection.

The inspector stated that the unnecessary wearing of respiratory

equipment, particularly in a posted high radiation area, results in

excessive man-rem expenditures for a given task due to increased time for

work completion.

The above matters were brought to the licensee's attention. The

licensee stated that they would review these issues and strengthen

training and controls in this area.

6.0 Control of Radioactive Materials and Contamination,

Surveys, and Monitoring

The licensee's program to ensure effective control of radioactive

material and contamination, as well as performing adequate surveys and

monitoring, was reviewed against criteria in:

• 10 CFR 20.201, " Surveys";

• 10 CFR 20.202, " Personnel Monitoring";

10 CFR 20.203, " Caution signs, labels, signals and controls";

• 10 CFR 20.207, " Storage and control of licensed materials in

unrestricted areas";

10 CFR 20.401, " Records of surveys, radiation monitoring, and

disposal"; and

Licensee Procedures;

• 6.1-207 " Control of Radioactive Material", Rev. 9.

• 6.1-024 " Radiological Posting of Areas of the Station", Rev. 14.

Licensee performance relative to these criteria was determined by:

Inspector tours of radiologically controlled areas;

Independent surveys;

Inspection of posting and barricades;

• Review of applicable procedures;

Discussions with cognizant personnel; and

• Review of survey records.

Within the scope of this inspection, no violations were observed. The

licensee has established an aggressive decontamination goal to allow

unrestricted accessibility to greater than 90% of the station. This will

enhance operability of the station and help to minimize radwaste genera-

tion.

Inspector tours of the station found contaminated areas to be well

defined by suitable barricades and floor markers. Step-off pads were

being used to control the spread of contamination. To support the

contamination control program, the licensee has implemented the use of

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sticky smears and rollers to optimize collection efficiency for hot

particle detection. Furthermore, additional automated whole body

friskers have been purchased to enhance personnel safety through

increased sensitivity and state-of-the-art frisking techniques.

Within the scope of this inspection, the following weaknesses were

identified:

- Several containers of radioactive material were not labelled " Caution-

Radioactive Material." However, independent surveys performed by the

inspector verified that 10 CFR 20, Appendix C quantities were not

present, therefore, no violation was issued. The licensee took prompt

precautionary measures to label the containers.

- Inspector review of procedure 6.1-207 " Control of Radioactive

Material," Rev. 9, determined that the procedure was weak with

reference to labelling requirements for containers of radioactive

material. The inspector discussed this issue with the licensee, who

stated that the procedure would be revised to improve procedure content

relative to container labelling.

- There appears to be an excessive number of surveys taken as a result of

poor work descriptions when the Radiation Work Permit (RWP) is submitted

for processing. In some instances, HP Technicians performed surveys

only to find later that they did not survey the exact work area. This

required another survey, with a resultant increase in exposure and

delaying of the job. The licensee stated that they were aware of this

problem and were in the process of developing an RWP Request form to

improve this area.

- Inspector questioning of HP Technicians relative to sticky smear (hot

particle) survey methodology, determined the following:

- Technicians did not know the approximate collection efficiency for

dry or sticky smears. One technician stated that sticky smears were

less efficient.

- Some sticky smears covered 100 cm 2

while others only covered the

area of the smear itself (approximately 20 cm2 ). However, HP

technicians stated that all sticky smears are being recorded as

activity per 100 cm 2.

- HP technicians were not always taking the number of sticky smears

required by their management. In addition, survey maps did not

always identify which were sticky versus dry smears.

The above observations relative to the hot particle identification

program, indicate a communication and training weakness within the Health

Physics Department. The inspector discussed this issue with HP

management, who stated that a lesson plan was being developed to

strengthen controls in this area.

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7.0 Exit Meeting

The inspector met with licensee management denoted in Section 1.0 on May

1, 1987, at the conclusion of the inspection. The scope and findings of

the inspection were discussed at the time.

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