IR 05000266/1983011

IE Insp Repts 50-266/83-11 & 50-301/83-19 on 830923-1120. Noncompliance Noted:Failure to Provide Specific Written exclusive-use Instructions to Drivers of exclusive-use Shipments

ML20083E331
Person / Time
Site:	Point Beach
Issue date:	11/30/1983
From:	Greger L, Lovendale P, Paul R NRC Office of Inspection & Enforcement (IE Region III)
To:
Shared Package
ML20083E312	List: IR 05000266/1983011
References
NRC-2020-000157 50-266-83-11, 50-301-83-19, NUDOCS 8312290149
Download: ML20083E331 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-266/83-11(DRMSP); 50-301/83-19(DRMSP)

Docket Nos. 50-266; 50-301 Licenses No. DPR-24; DPR-27 Licensee: Wisconsin Electric Power Company 231 West Michigan Milwaukee, WI 53201 Facility Name: Point Beach Nuclear Power Plant, Units 1 and 2 Inspection At: Point Beach Site, Two Creeks, WI Inspection Conducted: September 23 through November 20, 1983 Inspectors:

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S'S P. C. .fevendale M .

Date R. A. Paul M/ '

O Date Approved By:

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L. R.-Greger, Chief u/so Facilities Radiation Protection Date Section Inspection Summary Inspection on September 23 through November 20, 1983 (Reports No. 50-266/83-11(DRMSP); 50-301/83-19(DRMSP))

Areas Inspected: Routine, unannounced inspection of radiation protection activities during the Unit I steam generator replacement outage. Also, twenty-seven shipments of spent fuel were inspected, two containment evacua-tions.were reviewed, and licensee preparations for implementing 10 CFR 61 were reviewed. The inspection involved 113 inspector-hours onsite by two NRC inspector Results: Of the eleven areas inspected, no items of noncompliance or devia-tions were identified in eight areas; one item of noncompliance was identified in each of two areas (failure to provide exclusive use instructions - Section 11, and failure to follow procedures - Section 12); one deviation was identified in one area (failure to approve contractor procedures as committed - Section 6).

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DETAILS , Persons Contacted R. S. Bredvad, Plant Health Physicist

• F. ' A. Flentje, Supervisor, Office Services

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'*T. L. Fredrichs, Radiochemist

• D. F. Johnson, Health Physicist, Special Projects

• R. E. Link, Superintendent, Engineering, Quality, and Regulatory Services J. Marshall, Site Supervisor - Numanco J. Massey, Health Physics Director - Westinghouse C. Rapp, Onsite Manager - Westinghouse

• A. L. Reimer, Site Supervisor, Special Projects R. Shortridge, Health Physics Manager - Morrison Knudsen

• P. Skramstad, Superintendent, Chemistry and Health Physics

• J. J. Zach,-Plant Manager

• R. L. Hague, NRC Senior Resident Inspector

• Fitzpatrick, NRC Resident Inspector The inspector also contacted other licensee and contractor employees including radiation control operators, Numanco technicians, and Westinghouse and Morrison-Knudsen engineer * Denotes those present at the exit meeting.

i General The onsite portion of this inspection, which began at 8:00 a.m. on October 24, 1983, was conducted to examine radiation protection activi-ties related to the Unit I steam generator replacement outage. Also, previous inspection findings, the licensee preparations for implementa-

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tion of 10 CFR 61, and a containment hi bh airborne radioactivity incident were reviewe Other inspector effort included the review of nineteen spent fuel ship-ments from G. E. Morris Operation and eight shipments of spent fuel from West Valley Nuclear Services which occurred between September 23 and November 20, 198 During this period, independent radiation contamination surveys were con-ducted using NRC instruments. Measurements made were in close agreement with licensee survey data. During plant tours, posting, labeling, and housekeeping appeared good.

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,. . . Licensee Action on Previous Inspection Findings (Closed) Violation (266/83-08-03; 301/83-08-04): Failure to have SA-11 mein steam lire monitors operational as required by NRC Confirmatory Order dated March 14, 1983. The inspectors verified that corrective actions described in letters to NRC Region III dated August 5, June 29, and May 25, 1983, have been taken. No further problems were note (Closed) Open Item (266/82-06-02; 301/82-06-02): Installation of a Yankee type post accident sampling syste In a letter to NRR dated February 21, 1983, the licensee stated that since advantages of that system would be minimal, plans for the modification have been cancelle (Closed) Open Item (266/83-03-04): Communicetion of the steam generator replacement project health physics organization changes to NRR. In a letter to NRR dated September 28, 1983, the licensee informed NRR of the current organization. The inspectors discussed this matter with NRR representatives and confirmed that the stated organization was acceptabl No further problems were note (Closed) Open Item (266/83-08-01; 301/83-08-02): Availability of Westing-house shutdown chemistry recommendations. Through discussions with licensee representatives, the inspectors determined that the Westinghouse shutdown chemistry recommendations had not been formally transmitted to the licensee, and therefore were not implemerted, before the Unit 2 shut-down in March 1983. The inspectors verified that these recommendations have been- incorporated into the licensee's shutdown procedures. No further problems were note (Closed) Unresolved-Item (266/83-08-02; 301/83-08-03): Review of the reactor head venting procedure. The inspectors reviewed the licensee's revised procedures for reactor head removal and venting. No problems were noted. These revised procedures were used during the recent Unit I reactor head vent and removal;no significant increase in containment gaseous activity was noted during these operation (Closed) Violation (301/83-08-01): Failure to collect and evaluate air samples during reactor head lift operations. The inspectors verified through observation and procedure review that the corrective actions out-lined in a-letter to NRC Region III dated July 27, 1983, had been com-

.pleted. These actions included specific air sampling instructions for reactor head lift operations and the procurement of continuous air

' monitors for use in containment during refueling or major maintenance outages. No further problems were note . Steam Generator Replacement Project (SGRP) Health Physics Organization and Qualifications The inspectors reviewed the licensee's health physics and personnel quali-fications for the SGRP. The organization and supervisory qualifications remain as previously stated Inspection Reports No. 50-266/83-08(DRMSP); 50-266/83-17(DRMSP)

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According to licensee personnel. contracted senior health physics technicians were selected based on the three-year experience criterion of ANS 3.1-1978, " Selection and Training of Nuclear Power Plant Personnel."

This criterion exceeds the two-year experience criterion required by ANSI 18.1-1971, " Selection and Training of Nuclear Power Plant Personnel",

and Technical Specification 15.6.3. Review of. selected contracted senior health physics technician resumes revealed that those presently working onsite meet or exceed the criteria of ANS 3.1-1978. No problems were note No items of noncompliance or deviations were identifie . Radiation Protection Orientation Training The inspectors reviewed the implementation and content of the licensee's radiation protection orientation training. This training is presented to all. workers associated with the steam generator replacement project (SGRP).

The training is conducted by Westinghouse and their sub-contractor General orientation training consists of a three-hour video tape and instructor presentation of security, quality assurance, radiation protection, fire protection, and emergency preparedness requirement Participants must successfully complete a written exam. In addition, all~ workers receive a one-hour radiation protection orientation before being-allowed onsite. Successful completion of a written exam is required. Workers requiring access to the controlled areas of the plant (Unit I containment) are required to attend a four-hour radiation worker training course in lieu of the one-hour radiation protection orientation. This course includes practical factor requirements such as frisking, donning and removal'of anti-contamination clothing, and controlled area entry (step off pad) procedures. Successful completion

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of a written exam is require .The inspectors reviewed selected training records, lesson plans, and examinations. Also, the inspectors viewed a short segment of the general i orientation video tape program. It appears that the extent of this train-ing is commensurate with potential radiological health problems associated with the SGRP as required by 10 CFR 19.12. No problems were noted.

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No items of noncompliance or deviations were identifie . Radiation Protection Procedures ]Theinspect'rsreviewedselectedradiationprotectionproceduresrelated o

l to SGRP health physics activities. In a letter to NRR dated February 22,

1983, the licensee committed to review all Westinghouse deviations from j plant health physics procedures and all health physics procedures developed by Westinghouse for use during the SGRP. The described review process requires that, as a minimum, all deviations from existing plant

! procedures or new procedures developed by Westinghouse be reviewed by the

Wisconsin Electric Special Project staff and then the Superintendent of L ' Engineering, Quality and Regulatory Services (EQ&R). The Superintendent, I-i l-l

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-EQ&R, must determine if plant staff review is required. The inspectors

' observed that most procedural- deviations and new procedures developed by Westinghouse received the required review. However, it appears that one group of Westinghouse procedures titled Health Physics Operating Instruc-tions (HPOIs), did not receive the required revie It appears that the HPOIs fall within the technical specification definition of minor

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< procedures. Although the Special Projects Health Physics Coordinator reviewed the HPOIs, they were not. forwarded to the Superintendent, EQ&R, for further review and approval. This is considered a deviation from the commitment made to NRR. This matter was discussed during the exit meeting. -(266/83-11-01). The inspectors reviewed the'following Westinghouse HPOIs .to determine if they are consistent with regulatory requirements and good health physics practices. No problems were note HPOI 1.1- Revision O' Processing and Handling of Access Control Codes

HPOI Revision 0 Processing and Handling of Special Manitoring Dosimetry

'HPOI Revision 0 TLD Issuing / Handling Instructions HPOI Revision O Damaged or Lost Dosimetry Instructions HPOI Revision 0 Dosimetry Records Instructions HPOI Revision 0 Employee Termination Instructions HPOI Revision O Orientation and Training Responsi-bilities HPOI 1 ,

Revision 0 REMS System Operation Instructions HPOI 1 Revision 0 REMS Set-Up Instructions HPOI 1 Revision 0 REMS Set-Up Input Instructions HPOI 1 Revision 0 Employee Maintenance Instructions HPOI-1 Revision 0 REMS Dosimetry Input Instructions The following HPIPs were also reviewed:

HPIP Revision O Calculation of MPC-Hours and Allowable MPC Exposure Time HPIP 1.5 . Revision 0 Extremity Dose Monitoring HPIP 1.57 Revision 0 Lioassay HPIP 1.57 Revision 0 Bioassay - Appendix A - Operating Procedure for Helgeson Whole Body Counter

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HPIP 1.57 Revision 0 Bioassay - Appendix B - Flagging and Evaluation of Whole Body Count Results

.HPIP 1.57 Revision 0 Bioassay - Appendix C - Whole Body Counter Weekly QA Discrepancies'noted in Procedure HPIP 1.57, Appendix B, are discussed in Section 7. No other problems were noted during this revie The inspectors noted that the number of Health Physics Standing Orders (HPS0s) had. increased significantly over the last several years. Based on a review of selected HPS0s, it appears that many may fall within the technical specification definition of a minor procedure, and should tnerefore receive additional staff review. This matter was discussed during the exit meeting and will be reviewed further during a future quality assurance inspectio (266/83-11-02; 301/83-19-01). Exposure Control - Internal

. The program to control internal exposures during the SGRP includes engineering controls, air sampling and contamination surveillance, limiting exposure times to airborne concentrations, approved respiratory equipment, and protective clothing. Whole body counting is used to -

supplement the monitoring program to ensure its effectivenes Urinalyses can be used if necessar A commercial whole body counter is used for workers associated with the SGRP. _A weekly spectrum check is performed on the system using low level cobalt-60 and cesium-137 mixed with water in a test phanto In addition, an americium-241 check source is mounted on the frame near the detecto The method of using phantoms of mixed nuclide sources for system performance checks appears to meet ANSI N343-1978 "American National Standard for Internal-Dosimetry for. Mixed Fission and Activation Products" criteri All persons associated with the SGRP who work in controlled areas receive a base line (incoming) whole body count (WBC), and a termination WB .0ther WBCs may be required at the discretion of the health physics staf The inspectors selectively reviewed the results of base line and termination WBCs through October 27, 1983; no results exceeding the 40 MPC-hour control measure were noted. The records also indicate that no persons were authorized to enter radiologically controlled areas without a base'line WB The inspectors also reviewed the whole body counting procedures and their method of relating whole body counting data to regulatory requirement .. It was noted that the procedures do not correctly relate whole body counting data-to MPC-hours for iodine-131. For instance, the procedure indicates that 99 nanocuries (nci) of iodine-131 is equivalent to 40 MPC-hours. This value is correct when the thyroid is used as the organ of reference. However, when the whole body is used as the organ of

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HPIP 1.57 Revision 0 Bioassay - Appendix B - Flagging and Evaluation of Whole Body Count Results

'HPIP 1.57' Revision Bioassay - Appendix C - Whole Body Counter Weekly QA Discrepancies'noted in Procedure HPIP 1.57, Appendix B, are discussed in

.Section 7. No other problems were noted during this revie The inspectors noted that the number of Health Physics Standing Orders (HPS0s) had' increased significantly over the last several years. Based on a review of relected HPS0s, it-appears that many may fall within the technical specification definition of a minor procedure, and should therefore receive additional staff revie This matter was discussed during the exit meeting and will be -reviewed further during a future quality assurance inspectio (266/83-11-02; 301/83-19-01). Exposure Control - Internal The program to control internal exposures during the SGRP includes engineering controls, air sampling and contamination surveillance, limiting exposure times to airborne concentrations, approved respiratory equipment, and protective clothing. Whole body counting is used to supplement the monitoring program to ensure its effectivenes Urinalyses can be used if necessar A commercial whole body counter is used for workers associated with the SGRP. A weekly spectrum check is performed on the system using low level cobalt-60 and cesium-137 mixed with water in a test phantom. In addition, an americium-241 check source is mounted on the frame near the detecto The method of.using phantoms of mixed nuclide sources for system performance checks appears to meet ANSI N343-1978 "American National Standard fer Internal Dosimetry for Mixed Fission and Activation Products" criteri All persons associated with the SGRP who work in controlled areas receive a base line (incoming) whole body count (WBC), and a termination WB Other WBCs may be required at the discretion of the health physics staf The inspectors selectively reviewed the results of base line and termination WBCs through October 27, 1983; no results exceeding the 40 MPC-hour control measure were noted. The records also indicate that no persons were authorized to enter radiclogically controlled areas without a base line WB The inspectors also reviewed the whole body counting procedures and their method of relating whole body counting data to regulatory requirement It was noted that the procedures do not correctly relate whole body counting data to MPC-hours for iodine-131. For instance, the procedure indicates that 99 nanocuries (nCi) of iodine-131 is equivalent to 40 MPC-hours. This value is correct when the thyroid is used as the organ i I

of reference. However, when the whole body is used as the organ of

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reference (which is the case using the whole body counting system) then 324 nCi should be used as the 40 MPC-hour equivalent. Although the proceduralized method results in computing conservative MPC-hour equiva-lents, this discrepancy should be correcte In addition, some discrep-ancies in the quantities of radioactivity constituting maximum permissible whole body burdens were also noted. These matters were discussed with the licensee who stated the current procedures used for computing MPC-hour equivalents from whole body intakes was in the process of revision. This matter will be reviewed during a future inspectio (266/83-11-03; 301/83-19-02).

8. Eyposure Control - External The external exposure measurement and control program for the SGRP con-sists of whole body and extremity monitoring using thermoluminescent dccimeters (TLDs), self-reading dosimeters (SRDs), direct surveys radiation work permits, administrative dose limits, and the Radiation Exposure Monitoring System (REMS).

The monthly TLD results are normally maintained as the official record of personal exposure data. The SRD results are used for daily updating of personal exposures and can be entered into the official exposure records only when other TLD results are not available, or if the TLD results are determined to be invalid. The highest personal exposure received on the SGRP through October 26, 1983, was 1.425 rems. This expo-sure was based on SRD result REMS is a computerized radiation protection information management system used by Westinghouse which allows the entry and retrieval of radiation protection information. Data retrieved from the system can be shown on the computer display screen or on a reproduced hard copy. The system is used for occupational radiation exposure control and dore tracking by job category and job task. Information entered into the system includes:

personal exposure history, medical approvals, daily SRD results, RWP information, types of respiratory equipment authorized for each individual, training status, and whole body count dat REMS has a system description manual and operating procedures which are used to control the operation of the system. These documents include the current programs, a description of system capabilities, and operating instruction During the inspection, personnel files of several employees were reviewed to verify that each file contained a completed Employee Check-In Sheet, a completed NRC Form 4 report of the individuals' previously accumulated exposure, results of respiratory fit test analyses, medical approval, ac-cess control cards, and special monitoring issues. The inspectors veri-fied that certain of this information for selected individuals had been entered into the computer system. No significant problems were note No items of noncompliance or deviations were identifie k

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. ALARA A formal ALARA program was implemented for the SGRP. This program in-cludes: use of instructions'and procedures applicable to the replacement-activities; use of detailed work packages which contain all the informa-tion required.to implement a specific task; review of each work package by health physics and the ALARA coordinator; establishing personal radia-

. tion exposure dose estimates and tracking of personal radiation exposures; health physics training; use of full size mockups; installation of shielding; and methods to identify locations, operation:, and conditions that have the potential for significant radiation exposur In addition, the- ALARA coordinator tours the SGRP job, audits the ALARA program, and tracks radiation exposure for each job / work packag The1 occupational external dose for the SGRP was estimated to be 1165

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, person-rems. Through the first four weeks of the SGRP, the estimated occupational exposure was 140 person-rems which is approximately 15

. percent lower than the projected personal exposures for the job functions accomplished for this period. There should be a further decrease because the accumulated exposures are based on self-reading dosimeters, which are generally higher than the TLD No items of noncompliance or deviations were identifie . Audits There is no formal onsite audit program which revicss the SGRP health physics program. The licensee (WEPCo) intends to initiate a corporate Quality Assurance. audit of this program in the near futur Although.no formal program exists, the Special Projects health physics

, personnel (WEPCo) perform daily' audit surveillance activities and docu-ment their results in log books. Each day the $pecial Projects HP selectively reviews postings, RWPs, log books, air sample results, rad-waste reports, incident reports, personal contamination reports, general housekeeping, and' access control cards. Discrepancies are noted in the log books. The Special Projects HP informs Westinghouse personnel of these discrepancies and recommends corrective actions be taken where necessary. According to WEPCo personnel, the recommended corrective actions have been.taken by Westinghouse. However, during a review of WEPCo's log books, it was noted there is little documented verification that. recommended corrective actions had been taken. This matter was discussed at the exit meetin ^ No items of noncompliance or deviations were identifie . Spent Fuel' Shipping Activities During this period, twenty-seven spent reactor fuel shipments were inspec-

.te Twenty of the spent fuel shipments originated at General Electric's Morris Operation and were inspected before departure by NRC Region III inspectors, Illinois Department of Nuclear Safety inspectors, and Illinois

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State Police motor carrier inspectors. The remaining eight spent fuel shipments originated at West Valley Nuclear Services (DOE contractor) and were inspected before departure by NRC Region I inspectors, New York Energy Research and Development Authority inspectors, New York Department of Transportation inspectors, U.S. Department of Transportation inspectors, and a U.S. "epartment of Energy contracted vehicle inspecto Inspection of the shipments upon arrival at Point Beach Nuclear plant included: in-dependent radiation and contamination surveys, review of licensee survey results, discussions with shipment escorts and drivers related to safe-guards measures and procedures, and periodic monitoring of licensee cask handling operations. Also, licensee surveys of outgoing empty casks were

. selectively reviewed. Except as noted below, no significant problems

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were noted or reported to the NRC.

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On September 30 and October 21, 1983, West Valley Nuclear Services reported that incoming spent fuel shipping casks were received from Point Beach Nuclear Plant with removable contamination in excess of of 22,000 dpm/100cm 2 . West Valley's survey results of the September 30 shipment indicated that a small area of the cask was contaminated to a maximum of 29,000 dpm/100cm 2 . Of the forty-nine contamination smears performed, only two showed contamination levels in excess of 22,000 dpm/100cm2, West Valle;'s survey results of the October 21 shipment indicated three small areas of the cask were contaminated to a maximum of 56,000 dpm/

100cm 2 . Of the forty-nine contamination smears performed, only three showed contamination levels in excess of 22,000 dpm/100cm2 ,

Before departure on September 30 and October 21, 1983, the licensee per-formed detailed removable contamination surveys of the casks. The results of these surveys indicated recovable contamination levels below 2200. ,

dpm/100cm 2 . The apparent cause of the increased contamination levels upon arrival was excessive cask " weeping" of contamination from the metal surface of the cas DOT regulation 49 CFR 173.443 and NRC regulation 10 CFR 71.87 limit the removable contamination levels as measured by wiping (smearing) the package (cask) surface at the time of departure to 22 dpm/cm2 . Due to -

" weeping, removable contamination levels on the cask surface are allowed to rise by a factor of ten during transport. There are na DOT /NRC limits for fixed contamination levels other than direct radiation level Although tl.e September-30 and October 21 shipments apparently exceeded the 220 dpm/cm 2 limit upon arrival, clarification of regulatory requirements and enforcement criteria are needed before the appropriate enforcement actions can be imposed. The needed clarifications include:

(1)-determination of the legal responsibility for ensuring adherence-to the " arrival" contamination limits, (2) applicability of third party insnection data, (3) allowable use of contamination averaging, and (4) allowable use of measured smear efficiencies for determining contamination level For example, if the actual smear removal efficiency (greater than 90 percent) was assumed instead of the conservative 10 percent efficiency

assumed by DOT regulation and if averaging over 300cm was permitted

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(previously permitted by DOT), then the DOT limits would not have been exceeded for the September 30 or October 21 shipment This matter is coctidered an unresolved item pending evaluation by NRC .

Headquarters. Actions taken and planned by the licensee to prevent recurrence were discussed during the exit meeting. (266/83 .11-04; 301/

83-19-03).

Through a review of selected shipping records and discussions with the NRC resident inspectors, it was learned that the drivers of spent fuel ship-ments from West Valley to Point Beach on cwo occasions (WV2-2 and WV3-5)

were not provided with specific written instructions for maintenance of the exclusive use shipment controls as required by 49 CFR 173.444(c).

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This is considered an item of noncompliance. This matter was ' discussed ~ '

during the exit meeting. (266/83-11-05; 301/83-19-04).

12. Containment Evacuations

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The inspectors reviewed the circumstances surrounding Unit I containment evacuations occurring on November 1 and 3, 1983, and licensee corrective

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actions taken as a result of these event On November 1,1983, the licensee conducted a precautionary evacuation of the Unit I containment based on increasing airborne radioactive iodine level The maximum airbczne radioactivity level was about 50 percent of the maximum permissible concentration (MPC)'for iodine-131. Normal purge and exhaust ventilations were used to reduce the airborne levels. Workers'

, were allowed to return to containment in about three and one-half hour Although the exact cause of the increasing airbcrne iodine-131 levels could not be determined, it appears most likely to have been due to pri-mary system pipe cuts which were made shortly before the increasing lodine-131 levels were detecte On November 3, 1983, a second iodine release occurred inside the Unit 1

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containment. This release was significantly greater than the November 1 release and also coincided with cutting operations on the primary coolant piping. The maximum airborne radioactivity level was about 22 times MPC for iodine-131. Normal purge and exhaust ventilation was u. sed to reduce

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the airborne levels. Workers were allowed to return to containment in about twelve hours. In conducting the evacuation,- the contractors failed s to notify the control room as required by the Special Order PBNP S3-06, Westinghouse Steam Generator Replacement Project Emergency Plan and Implementing Procedures. As a result, the control room operators did not i learn of this evacuation until thirty to forty-five minutes after the event. Because of this, the evacuation alarm was not sounded. Also, the supply fan was not immediately secured and the personnel hatch (66-foot

elevation) was not closed. With the supply fan operating and the personnel hatch open, containment air flows out the hatch and subsequently to the environment. The release from the containment building was calculated to be 658 microcuries of iodine-131 at a release rate equal to about 10 percent of the technical specification release rate limit (15-minute average). Failnre to promptly notify the control room of the high

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airborne radioactivity levels in containment is considered noncompliance with Technical Specification 15.6.8, which requi res adherence to plant procedures. (266/83-11-07).

Whole body counts of all workers who were inside containment during the two events (about 45) indicate a maximum uptake of about 12 MPC-hrs. The worst case uptake based on air sample data and estimated stay times is calculated to be about 26 MPC-hrs. The inspectors reviewed records of the whole body count Based on that review and a review of licensee calcu-lations, it appears the 40 MPC-hr control measure was not exceede Both events occurred during or soon after plasma cutting of the steam generator hot leg The event on November 1 occurred soon after trimming the completed plasma cut of the "A" steam generator hot leg. No in-crease in containment airborne iodine levels were noted during or after initial plasma cutting of the "A" steam generator cold or hot legs. The November 3 event occurred while performing the plasma cut of the "B" steam generator hot leg. No increase in contaia=~nt airborne activity was noted during or after plasma cutting of the "B" steam generator cold le All plasma cuts of primary system piping were conducted within a contain-ment tent which was maintained at a negative pressure in relation to the outside atmosphere. Air flow direction into the containment tent was verified by smoke test before cutting began. The ventilation system used during the cuts consisted of four 1000 cfm blowers and two 2000 cfm blowers. All blowers contained HEPA filters but not charcoal filter The discharge of the blower (1000 cfm) taking suction from the steam generator channel head (assumed to be the blower which would remove the majority of radioactivity) was ducted to the suction of the plant's MSA blower (1000 cfm) located on the 75-foot level. The MSA blower discharges to the containment purge system which contains HEPA and charcoal filter The remaining blowers were arranged in various designs during the cutting; the designs appeared generally satisfactory unless airborne radioactive iodine became a problem. The licensee stated that charcoal filters were not installed in the portable blowers because isotopic analyses of smears taken inside the piping during a previous outage indicated that. only a small percentage of the available source term was iodin The results of air samples taken during and after these events indicated that the majority of the airborne iodine was being discharged onto or near the 66-foot elevation. The pipe cuts were made at about the 20-foot elevation. Based on this, it appears the source of the iodine was a leak in the ventilation ducting at or near the 66-foot elevation. The inspectors walked down portions of the ventilation system. Although no leaks were found, several areas of ducting appeared susceptible to leakage due to taped joints, ducting diameter changes (8-inch ducting to 16-inch ducting), and sharp bend _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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Based on data available from other plants making similar cuts, and smear analyses completed earlier, no significant radioactive release was expected. However, the licensee's subsequent evaluation, based on an air sample taken inside the channel head suction ventilation duct, revealed that an estimated 41,000 microcuries of radioactivity was released during the plasma cut. Based on air sample data within containment, it appears that 2,500 microcuries of radioactivity was released to containment during the November 3 event. Ninety-seven percent of this released activity was iodine. Approximately fifty percent of this iodine was gaseous and fifty percent was in particulate form. There appears to be no clear explanation as to why iodine was the only nuclide which became airborne in significant quantities during the plasma cuts nor why the large unanticipated quantities of iodine were available for releas Licensee corrective actions include, among others, installation of char-coal filtered portable blowers which vill bypass the MSA blowers, removal of nonessential workers.from containment during the cuts, improved place-

' ment of air samplers, and installation of improved ventilation ductin These events, including corrective actions, were discussed during the exit meetin . Preparation for Implementation of 10 CFR 61 The inspectors reviewed the licensee's preparation for implementation of 10 CFR 61, which becomes effective December 27, 1983. According to licen-see representatives, they are aware of 10 CFR 61 requirements, and pro-cedures for waste classification and characterization are being prepared.

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No problems were note . Radiation Monitoring System CRT The inspectors briefly reviewed the radioactive effluent data acquisition capabilities available to the control room operators. It appears that one concern related to the centrol room's ability to obtain effluent data rapidly during an accident warrants further review. This matter will be reviewed further during a future inspectio (266/83-11-06; 301/83-19-05).

1 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncom-pliance, or deviations. An unresolved item disclosed during the inspec-tion is discussed in Section 1 . Exit Meeting The inspectors met vith licensee representatives (denoted in Section 1)

on October 28, 1983. Further discussions were conducted during a tele-phone conversation between the inspectors and licensee management on November 15, 1983. The inspectors summarized the scope and findings of the inspection. The inspectors stated that Unit I steam generator

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replacement project radiation protection activities appeared to be progressing smoothly. Except for those concerns related to the containment iodine release and the spent fuel cask contaminations, no significant problems were identified. In response to certain matters discussed by the inspectors, the licensee: Acknowledged the deviation and stated that Westinghouse's HPOIs would receive the required revie (Section 6) Acknowledged the inspectors' concerns related to the number and con-tent of the Health Physics Standing Orders, and stated that their couteat would be reviewe (Section 6) Acknowledged the inspectors' comments related to the whole body count procedure,'and stated the procedure would be revised as neede (Section 7) Stated that corrective actions taken to resolve audit findings would be documente (Section 10) Stated that the corporate health physics group was attempting to analyze the cask " weeping" proces (Section 11) Stated that tests would be conducted'over an extended period to deter-mine the most effective cask decontamination method. The tests are to include direct beta measurements of the cask surface to help deter-mine the total fixed activity buildup available for weepin (Section 11) Stated that methods for covering the cask before placement in the fuel pool are under consideration by the plant staff. (Section 11) Stated that the fuel pool demineralizer decontamination factors are low, but resin replacement would be difficult because of limited storage space for spent resin. Other methods of reducing the fuel pool radioactivity concentrations such as use of vendor supplied demineralizers are under consideratio (Section 11) Acknowledged the item of noncompliance regarding written instructions for maintenance of exclusive use shipping controls and stated that West Valley Nuclear Services would be supplied with a copy of the needed instructions for issuance to the drivers of all future ship-ment (Section 11) Acknowledged the unresolved item related to the two shipments which exceeded DOT /NRC removable contamination levels. (Section 11) Stated that portable ventilation blowers with installed charcoal and HEPA filters would be used during future primary system pipe cut (Section 12) Stated the ducting used for ventilation of the pipe cut area would be all one size with limited -bends and banded connection (Section 12)

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m. Stated that all nonessential workers would be removed from contain-ment during future primary system pipe cut (Section 12)

n. Stated that air samples will be_taken on both inlet and outlet sides of the portable ventilation units to help pinpoint any problem area (Section 12)

o. Stated that all ventilation system ducting would be visually inspec-ted and smoke tested before starting future pipe cuts. The results of these tests and inspections will be documented. (Section 12)

p. Acknowledged the item of noncompliance for failure to notify the control room of the high_ airborne radioactivity in containmen (Section 12)

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