IR 05000220/1981006
| ML17053C810 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/12/1981 |
| From: | Knapp P, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17053C809 | List: |
| References | |
| 50-220-81-06, 50-220-81-6, NUDOCS 8108280045 | |
| Download: ML17053C810 (30) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-220/81-"06 Docket No. 50-220 Inspection conducte
Inspectors:
rch, 9
.
R. White, Radiation Specialist License No.
DPR-63 Priority Licensee:
Nia ara Mohawk Power'Cor oration 300 Erie Bou evard West S racuse,'ew York 13202 Facility Name:
Nine Mile Point, Unit 1 Inspection at:
Nine Mile Point, Unit
Scriba, New York Category A.
y'
da sag ed Approved by:
P. J.
Knapp, C ief Facilities Radiation Protection Section esgn Ins ection Summar
Ins ection on March 2-5, 1981'(Re orat'No.
50-220 81-06)
reas Ins ecte
Spec>a
, unannounced inspect>on to review written a
egations concerning the performance of the Radiation Protection Program.
The inspection involved several personnel interviews, examination of records and surveys, review of procedures and physical inspection of facilities and areas.,
The inspection consisted of 26 inspector-hours on-site by one NRC inspector.
Results:
No items of noncompliance were identified.
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DETAILS 1.
Persons Contacted
"Mr. T.
"Mr. T.
"Mr. E.
- Mr. J.
"Mr. M.
Roman, Plant Superintendent Lempges, Vice President, Nuclear Generation Leach, Superintendent, Chemistry and Radiation Protection Duell, Supervisor, Chemistry and Radiation Protection Si lliman, Acting Site Superintendent In addition, several other personnel from the radiation protection staff (including contractor personnel)
were interviewed in the course of this appraisal.
- denotes persons present at the exit interview on March 5, 1981.
2.
References (1) Health Physics Appraisal Report Number 80-11, dated March 2,
1981 (2) Letter to the Vice President Nuclear Generation (Niagara Mohawk Power Corporation)
from Director, NRC Region I (Philadelphia)
dated October 10, 1980 (IAL-80-38)
(3) Letter to Director, NRC Region I (Philadelphia)
from Vice President Nuclear Generation, dated November 20, 1980 (Radiation Protection Action Plan)
3.
Notification The following chronology of events depicts the actions leading to this special inspection.
Date Event January 15, 1981 The NRC Resident Inspector (RI) at Nine Mile Point (NMP) was approached by personnel having general concerns pertaining to the implementation of certain radiation protection activities at the facilit ~ ~
January 16, 1981 Preliminary Notification (PN 81-07)
"Allegations of Inadequate Radiological Controls" was issued for information.
January 20, 1981 NRC Region I (Philadelphia)
contacted certain of the individuals who had approached the RI-NMP.
A meeting was arranged at the individuals,',request to discuss the specifics of their concerns.
January 21-22, 1981 Two NRC investigators arrived in Scriba, New York and contacted the subject personnel.
At this time, all of the individuals declined any interviews with the investigators; and indicated that their concerns had been alleviated to their satisfaction by the actions of NMP management, and that they believed they had "over-reacted" to certain problems they had perceived.
At this time, the investigators concluded that no grounds for formal allegations existed based on the conversation with these individuals.
January 23, 1981 An NRC inspector performed review of the plant facilities and areas, and reviewed the licensee's actions to date with regard to the commitments documented in Reference (2).
No improper or inadequate radiologi-cal controls were identified at this time.
February 5,
1981 Certain of the same individuals contacted NRC Region I by telephone and indicated that contrary to their initial perception, NMP management was not adequately implementing the radiation protection program.
General concerns similar to those of January 15, 1981 were discussed, and they indicated that NMP management was not responsive to their concern February 26, 1981 NRC Region I directed the individuals, that if they believed their concerns to be valid, to provide their allegations in writing to the regional office.
The individuals stated they would do so.
Written allegations were received<'from the subject individuals.
March 2 - 5, 1981 A special inspection was performed to determine the validity of the written allegations.
3.
Review of Written Alle ations The allegations as received were in the form of specific instances of observed deficiencies in the program.
While they were not sequentially numbered, they are reported here, paraphrased, by number for the purpose of clarity.
Alle ation No.
On several occasions workers at the plant completely bypass the portal radiation monitors at the guardhouse.
While management has been notified of these occasions, no action has been taken,to resolve the situation.
Ins ectors'indin s
Management personnel admit that in the past certain workers were observed to bypass the portal monitors, but that on those occasions the personnel were reprimanded for the violation of company policy.
Items of a similar nature was previously identified in Reference (1) and addressed by the licensee in Reference (3).
Facility modifications that had been previously initiated were in place on March 1, 1981, and preclude the possibility of the portal monitors being purposely bypassed by any individual.
This item is resolve p
Alle ation No.
Workers trying to conform to contamination control requirements are sometimes subject to verbal abuse by certain members of the radiation protection staff.
Ins ectors'indin s
Episodes of this type were not observed, but according to several individuals this has occurred primarily as a result of insufficient manpower to adequately perform all of the activities for which the radiation protection staff is responsible, resulting in frustration which may be demonstrated verbally.
While not conclusive, such reasoning appears to apply in this case.
Reference ( 1) addresses the lack of sufficient manpower in the area of radiation protection; and Reference (3) provides an action plan to deal with this problem.
Specific to the area of concern, the licensee has assigned additional personnel to assure that all radiological requirements and co'ncerns are attended adequately.
This item is resolved.
Alle ation No.
Radiological posting and labeling have not been sufficient to assure adequate controls, particularly on the 250'levation of the Turbine Building.
Ins ector's Findin s
Reference (1) addressed this area of concerns In response, radiation protection personnel were directed by the licensee to amend and update posting and labelling of radioactive material, particularly on the 250'levation of the Turbine Building.
The observation was valid, but not indicative of a continuing lapse of radiological control since the situation was being corrected.
On Harch 4, 1981, the inspector reviewed this area and found that posting and labelling of radioactive material was in accord with the require-ments of 10 CFR 20.203,
"Caution signs, labels, signals, and controls."
This item is resolved.
Alle ation No.4 A radiation protection technician was observed to exit the restricted area with an equipment cart, without surveying the equipment or himself for radioactive contamination'ns ector's Findin s
This allegation could not be substantiated, but appears to be a
case of an individual's failure to adhere to specific radiological control procedures and conspicuously posted instructions, which were in effect at the time of the observation.
In such case, the observation is not indicative of a generic deficiency in the program, but rather a specific instance of failure to follow procedures.
During the course of this inspection several meetings were held between the licensee management and th'e plant staff, at which the licensee reaffirmed that procedures, Radiological Work Permit requirements and instructions from radiation protection personnel were expected to be adhered to unless otherwise amended by proper recourse.
This item is resolved.
Alle ation No.
Plant personnel were observed working in an area for which specific protective clothing and respiratory protection equipment was required, without the proper clothing or equipment.
The personnel ignored the instructions of the contractor radiation protection technician in the area.
Ins ector's Findin s
This particular allegation could not be directly substantiated.
The management policy as expressed in several meetings with plant personnel (See Inspector's Findings, Allegation No. 4), did address problems of this typ This item is resolved.
Alle ation No.
This allegation is similar in nature to Allegation No. 2, i.e.,
workers attempting to comply with contamination control require-ments are subjected to verbal abuse by a certain member of the radiation protection staff.
In this case, the radiological status of some scaffolding components was contested, in which case it is implied that the scaffolding was removed from the controlled area without an adequate survey.
Ins ector's Findin s
This allegation could not be substantiated.
Reportedly, a verification survey following this alleged occurrence revealed that the scaffolding was within the licensee's procedural limit for removing material from the controlled area.
As reported in Inspector's Findings, Allegation No. 2, the assignment of additional personnel to assure that all radiological requirements and concerns are attended adequately appears to address the major aspect of this particular allegation.
This item is resolved.
Alle ation No.
This allegation is similar in nature to Allegation No.
2 and Allegation No. 6, and involves a disagreement between an alleger and supervising personnel.
Ins ector's Findin s
The observation does not appear to be an allegation of improper radiological controls but rather a difference in opinion among the individuals involved.
The actions previously identified in Inspector's Findings, Allegation No. 2, appear to address situations of this type.
This item is resolve Alle ation No.
A RMP requirement that workers involved in a welding and grinding operation wear respirators was waived without sufficient reason.
Surface contamination in the area was 5000 dpm/100 cm2.
Ins ector's Findin s
This allegation is not substantiated.
In discussing this item with an alleger it was agreed that 5000 dpm/100 cm2 did not constitute significant contamination, and would not result in airborne activity in excess of a regulatory limit even when disturbed by a welding or grinding operation.
Furthermore, an examination of the survey records that pertained to this work revealed that the airborne activity at the time of the grinding and welding operation was only 1.4% of the maximum permissible concentration stated in 10 CFR 20.
Based upon this data, it appears that there was apparently sufficient reason to delete a respiratory protection requirement for the case mentioned.
This item is resolved.
Alle ation No.
An operation involving the removal of a valve measuring as high as 45,000 mR/hr on the 298'levation of the Reactor Building involved personnel exposure to airborne radioactivity.
Air samples taken of general areas of the 298'levation during the job revealed 10.9 MPC-hr/hr* airborne radioactivity.
Several workers were present on this elevation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> without the benefit of respiratory protection.
Additionally, workers directly involved in the valve removal operation ignored instructions from the radiation protection technician regarding the placement of dosimetry devices; and exited the work area without removing their protective clothing resulting in spreading contamination as high as 10,000 dpm/100 cm2 in other areas of the plant.
"MPC-hr/hr is a unit used by the licensee.
1 MPH-hr/hr = The applicable value of 10 CFR 20, Appendix B, Table 1, Column Ins ector'
Findin s
This allegation is not totally substantiated.
From a review of the RMP and radiological surveys pertaining to this operation and personnel interviews it is evident that there was only one air sample taken that resembles the information in the allegation.
The air sample was taken in the specific work area of the valve removal (as opposed to the general area of the 298'levation);
and was reported as
"109% MPC", or 1.09 MPC-hr/hr (as opposed to 10.9 MPC-hr/hr.)
This results in a significant reduction of radiological hazard as compared to the information supplied in the allegation.
(NOTE:
"109% MPC" as reported here is due primarily to a concentration of 9.485 E-9 uCi/ml, Co-60, as compared to the Appendix B,
CFR 20, value of 9E-9 uCi/ml.)
The RMP indicates that workers directly involved in this activity were required to wear air-supplied bubble suits which provided adequate respiratory protection in this circumstance.
Since the air sample was taken in the specific area of the valve removal, it was not representative of the general airborne activity on the 298'levation.
A 1.09 MPC-hr/hr airborne level at the work area would not present a radiological problem to other personnel working on the 'same elevation.
Therefore, there is no evidence of personnel exposure to airborne radioactivity as indicated by the allegation.
The corrective actions identified in Inspector's Findings, Allegations No.
4 and 5,appear to address the concern that some personnel ignore instruction and procedures relating to the implementation of radiological controls.
This item is resolved.
Alle ation No.
The count rate meters used for personnel and equipment monitoring (frisking) are not sufficiently sensitive to detect the licensee's contamination limits.
Ins ector's Findin s
The allegation is substantiated, however, this item was previously identified in Reference ( 1) and is addressed by the licensee in Reference (3).
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The licensee has several HP-210 PPA2 and PPB2 detectors on order.
These are more sensitive and reliable as devices for personnel and equipment monitoring.
As a result of this inspection, on March 5, 1981, the licensee initiated action to install all available HP-210 detectors as monitoring devices.
This item is resolved.
Alle ation No.
A worker in the Large Equipment Decon Room ignored instructions from a radiation control technician regarding adherence to procedures and RWP requirements.
Ins ector's Findin s
The allegation could not be directly substant,iated.
However, the licensee's actions in this area as reported in Inspector's Findings, Allegation No. 4, appear to address the area of concern.
This item is resolved.
Alle ation No.
A worker involved in an operation on the 229'levation ignored instructions from a radiation protection technician pertaining to the implementation of radiological controls.
Additionally, it is alleged that the licensee's management has informed the contractor radiation protection service group that they do not have the authority to "remove RWPs", i.e.,
stop a job in progress, due to noncompliance with the RWP requirements.
Ins ector's Findin s
The corrective actions as specified in Inspector's Findings, Allegation No. 4, appear to address the area of concerns Interviews with members of the licensee's management, and members of the contractor radiation protection service group (.including technicians and supervisors)
refutes the allegation that the contractor radiation protection service group does not have the authority to stop work in progress (remove RWP's)
due to noncompliance with the requirements.
Representatives from both organizations
affirmed that such authority was vested in all qualified radiation protection technicians, but that the technicians were cautioned to advise the supervisor prior to initiating such action.
Licensee management indicated that this point was reaffirmed in meetings with all technicians as a result of this inspection.
This item is resolved.
Alle ation No.
Water measuring 50 mR/hr is leaking from the ventilation duct from the Spent Fuel Pool Surge Tank Vent.
(East Aisle of the Reactor Building 318'levation).
The posted signs which indicate that an RWP is required to enter the area, and that 'the Radiation Protection Department must be contacted prior to entering, are frequently removed.
Ins ector's Findin s This allegation could not be totally substantiated.
The inspector verified that water does sometimes leak from the ventilation duct identified.in.the allegation.
Measurement of the radioactivity indicated that the concentration is approximately
E-4 uCi/ml, Cs-137.
Such concentration will produce radiation levels of approximately
5 mR/hr, depending on detector geometry.
The aisle was found to be posted in accordance with 10 CFR ZO.Z03 at the time of'he inspection, however the nearly constant leakage did produce areas in which fixed contamination as high ~s 150 mR/hr, and loose surface activity was 70,000 dpm/100 cm, was measured in some spots.
According to the licensee representative the leakage problem has been recurrent over several years, but no efforts have been undertaken to resolve the condition.
While the posting. and controls noted by the inspector do effect some degree of radiological control over the area, the inspector noted that it appeared that a modest effort by the licensee could control the leakage problem and thereby eliminate further contamination of the area and the need for control.
Licensee representatives indicated that the leakage problem would be reviewed in an effort to resolve the condition and that an engineering evaluation 'had been initiate ~'
J"
The licensee's actions in this area will be reviewed during a subsequent inspection.
(220/81-06-01)
Alle ation No.
Some valid radiological signs and labels have been removed due to the inconvenience that may be caused if an RMP is required.
Specific areas of concern were:
a.
Sentry Panel, Turbine Building, 261'levation b.
Reactor Building 298'levation (under a radiation source measuring as high as 20,000 mR/hr at 1")
Ins ector's Findin s
The allegation is not totally substantiated, however from a review of records and interviews with several persons it was apparent that in the case of the Sentry Panel some radiation protection technicians did contest the need for such radiological posting and requirements based on their assumption that they knew the radiological status and were the only persons that would work in the area.
They indicated that their own surveys, while undocumented, did not reveal the need for such radiological controls.
Subsequently, such posting and requirements were removed.
A review of the Reactor Building 298'levation on Narch 4, 1981, indicated that radiological posting control conformed to
CFR 20.203.
The area under the 20,000 mr/hr radiation source was effectively barricaded and posted.
However according to the personnel interviewed, such controls were only recently implemented.
During the course of this inspection, the inspector did not identify any areas that were not properly posted and controlled, however Reference ( 1) did identify such conditions.
The inspector noted that some technicians stated reasons for contesting the posting requirement for certain radiological areas which were not in accord with the requirements of 10 CFR 20.203.
In response, licensee management indicated that action would be taken to assure that technicians were aware that all areas must be adequately posted and identified to conform to the requirements of
10 CFR 20.203 and station procedures, regardless of personal assumptions concerning the area.
This item is resolved.
Alle ation No.
Respirators are issued for use with no operability checks to verify proper operation.
Ins ector's Findin s
Reference ( 1) had previously identified several deficiencies in the licensee's respiratory protection program including items of a similar nature.
Reference (3) identified the licensee's corrective actions in this area to be implemented by March 31, 1981.
The licensee'
corrective actions in this area will be reviewed during a subsequent inspection.
(220/81-06-02)
Alle ation No.
The air sampling program is deficient in its breathing zone air sampling capability and equipment available to take air samples.
Ins ector's Findin s
This item was previously identified in Reference (1).
Reference (3) identified the licensee.'s corrective actions in this area to be implemented by March 31, 1981.
The licensee'
corrective actions in the area will be reviewed during a subsequent inspection.
(220/81-06-03)
~Summa r Most of the allegations reviewed appear to be the result of poor communication between the licensee management and some station staff regarding the licensee's action plan and commitments for upgrading the radiation protection program.
For example, Allegations 1, 2, 3,
10, 14, 15, and 16 are similar to previous matters brought to the licensee's attention and documented in Reference (1), which required corrective action.
In some cases certain actions were already in progress as a result of the licensee's action plan, Reference (3).
Several meetings between licensee management and the station staff, were conducted previous to and during this inspection (to inform them of the action plan and management policy in the area of radiation protection) to alleviate this problem.
Some allegations (such as 2, 4, 5, 6, 7, 9, ll, 12, 14 and 16)
appear also to be the result, of differences of opinion and personality conflicts stimulated by observations of personnel fai ling to follow station procedures.
The licensee's effort to communicate management's policy. in the area of radiation protection, as well as increased personnel resources dedicated to the implementation of the radiation protection program, appear to have assuaged these areas of concern.
Portions of Allegations 8, 9, and 13 state, respectively, (a) Valid RWP requirements were changed without adequate reason or basis; (b)
Personnel were subject to exposure to airborne radioactivity without adequate controls; and, (c) Water measured as having significantly high levels of radiation (50 mR/hr) is leaking from a ventilation duct.
Allegations of this type indicate a rather severe lack of radiological controls.
However, in these cases it was found that the concerns were based on data and reasoning that was exaggerated or incorrect, which significantly reduced the import of these allegations.
Certain aspects of the allegations are valid and do require the licensee to initiate action to resolve particular matters, such as:
a.
Assuring that radiation protection personnel vigorously implement and attend the radiation protection program and the assocated procedures; b.
Assuring that radiation protection personnel identify radio-active material and radiological areas in accordance with the requirements of 10 CFR 20.203, regardless of personal preference or assumptio ~'v
C.
Assuring that the recurrent leakage noted on the Reactor Building 318'levation (east aisle) i s-evaluated and corrective action taken to resolve the condition; and, d.
Assuring the use of more sensitive devices such as HP-210 detectors for personnel and equipment monitoring.
Additionally, the licensee's corrective actions, as stated in Inspector's Findings regarding Allegations Nos.
13, 15, and 16, will be reviewed in a subsequent inspection to assure that the items are effectively resolved.
Exit Interview The inspector met with the licensee representatives (denoted in Section 1) at the conclusion of the inspection on March 5, 1981.
The inspector summarized the purpose, scope and findings of the inspection.
Licensee representatives made the following statements in regard to these findings.
(1)
More sensitive monitoring equipment (personnel friskers)
will be installed using all available equipment from the emergency kits or other sources until previously ordered instruments become available.
(2)
Actions will be taken to assure that all radiation protection personnel are cognizant of the posting and labelling requirements of 10 CFR 20.203 and station procedures, and comply with such requirements regardless of personal preference or judgment.
Additionally, in a telephone conversation on March 20, 1981, the Acting Site Superintendent stated that actions would be initiated to resolve the leakage problem associated with the ventilation duct on the 318'levation of the Reactor Building (east aisle).
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