IR 05000220/1982020
| ML20028B554 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/16/1982 |
| From: | Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20028B548 | List: |
| References | |
| 50-220-82-20, NUDOCS 8212030023 | |
| Download: ML20028B554 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION Region I Report No. 50-220/82-20 Docket No. 50-220 License No. DPR-53 Priority
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Category C
Licensee:
Niagara Mohawk Power Corporation 300 Erie Boulevard West Syracuse, New York 13202 Facility Name:
Nine Mile Point, Unit 1 (NMP-1)
Inspection At:
Nine Mile Point, Unit 1, Oswego, New York Inspection Conducted:
October 26-29, 1982 Inspectors:
b /S, II-R.L.Nimitf,*SeniorRadiationSpecialist date signed date signed
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Approved By:
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M. M. Shanbaky, ' Chief, Facifities Radiation date signed Protection Section Inspection Summary:
Inspection on October 26-29, 1982 (Inspection Report No.
50-220/82-20)
Areas Inspected:
Routine, unannounced inspection of the implementation of corrective actions for Health Physics Appraisal Significant Appraisal Findings, licensee action on previous routine inspection findings, IE Circular 79-09, and radiological controls for recirculation safe-end work. The inspection involved 30 inspector-hours onsite by one region-based inspector.
Results: No violations were identified.
8212030023 00220 PDR ADOCK 0 PDR G
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DETAILS 1.
Persons Contacted NMP-1 R. Carlson, Respiratory Protection Coordinator
- J. Duell, Supervisor Chemistry and Radiation Protection
- C. Gerber, Radioactive Waste Operation Supervisor
- R. Gerbig, Assistant Supervisor Chemistry and Radiation Protection D. Helms, Dosimetry and ALARA Coordinator
- E. Leach, Superintendent, Chemistry and Radiation Protection
- T. Perkins, General Superintendent Nuclear Generation T. Roman, Station Superintendent USNRC
- S. Hudson, Senior Resident Inspector
- denotes those individuals present at the exit interview on October 29, 1982.
The inspector also contacted other licensee personnel during the in-spection.
2.
Licensee Action on Previous Inspection Findings 2.1 (Closed) Inspector Follow-up Item (50-220/79-07-01) Review licensee evaluation of a beta monitoring capability. The licensee performed a test in March 1979 to verify the ability of personnel monitoring devices to monitor beta radiation with tape covering the beta window. The review of licensee test results, dated July 23, 1979, indicated the badges provided acceptable beta dose values when covered with the tape used to secure the badges'to protective clothing.
2.2 (Closed) Inspector Follow-up Item (50-220/79-07-02) Review instal-lation of Go-No-Go Testers for Scott Regulators.
The licensee deleted the test requirement from Procedure No. S-RTP-62, " Resp-iratory Equipment - Assembly, Test and Inspection, Storage." The licensee performs monthly checks of Scott Air Pacs, including regulators in accordance with a factory authorized check list contained in Procedure No. S-RTP-62, Revision 2.
The units are also sent out every five years for complete maintenance and testing.
2.3 (Closed) Noncompliance (50-220/79-22-03) Leadman failed to adhere to Radiation Work Permit procedure.
The review of this item in-dicated the corrective actions described in Niagara Mohawk letter NMP-1153, dated October 19, 1979 were implemente ___________
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Licensee Action on IE Circulars The inspector reviewed licensee action on IE Circular 79-09, " Occurrences of Split or Punctured Regulator Diaphrams in Certain Self-Contained Breathing Apparatus," dated June 22, 1979.
The circular transmitted a National Institute of Occupational Safety and Health (NIOSH) mailgram which described the occurrences and requested that licensees establish a program, or incorporate into their existing program, provisions for inspection of the apparatus.
The licensee obtained modification kits from the manufacturers of the affected apparatus in order to correct the cause of the diaphram degrada-tion (modifications completed July 1980). A factory authorized test procedure was in place when the circular was issued which met the testing requirements of the circular. The licensee currently inspects the regulators monthly in accordance with this station approved test proce-dure.
4.
Health Physics Appraisal Corrective Action Review 4.1 References NRC81 NRC Region I Health Physics Appraisal Report No.
50-220/80-11, dated March 12, 1981.
NMPC81 Letter from Thomas E. Lempges, Vice President, Nuclear Generation (Niagara Mohawk Power Corporation), to Boyce H.
Grier, Director, Region I (NRC), dated May 7, 1981.
4.2 Corrective Action Review The inspector reviewed actions taken with respect to selected Health Physics Appraisal Significant Appraisal Findings. The findings reviewed were as follows:
4.2.1 The organizational structure as currently implemented is not in agreement with the description provided in the licensee's Technical Specification 6.2.2.
As of October 9, 1980, the licensee had not initiated any action to amend the existing technical specification.
In addition, supporting administrative procedures such as APN-2 and APN-2A were not subject to any revision necessary to reflect the reorganization; and personnel job descriptions were not revised to recognize new or added responsibil-ities or authorities as a result of the reorganization.
Although an organization exists, it has not been formally established within the licensee's own administrative system nor in accordance with the normal regulatory process.
(Appraisal Finding A.1, 50-220/80-11-01)
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Findings The licensee's response (NMPC81) stated that a Technical Specification change would be submitted by June 1, 1981 to update the organizational structure, Administrative Procedures APN-2 and APN-2A were revised to reflect the current organizational structure, Position Analysis Questionnaires / Job Descriptions will be generated in June 1981 for new positions, and that existing Supervisory Job Descriptions would be revised January 1982.
The review indicated that as of October 25, 1982, a Technical Specification change to address the appraisal finding was not issued.
Review of Procedure No. APN-2, Revision 5, " Composition and Responsibilities of Site Organization," dated August 18, 1982, indicated the current Radiation Protection Orga-nizational structure is depicted therein.
Radiation Protection Organization Job Descriptions are discussed in Appraisal Finding A.5 follow-up (Section 4.2.2).
Licensee representatives stated a Technical Specification change was to be submitted after November 10, 1982.
Pending review of this submittal, this finding remains open.
4.2.2 Licensee management has not developed Job Descriptions for individuals associated with the area of radiation pro-tection that specify authority commensurate with respon-sibilities, particularly in the position of Superinten-dent, Radiochemistry and Radiation Protection, supervi-sors, technical coordinators and technicians.
(Appraisal Finding A.5, 50-220/80-11-05)
Findings The licensee is in the process of revising and reviewing Job Descriptions for all Radiation Protection personnel and has established draft Job Descriptions.
The licensee is including advancement criteria (i.e.
training and experience) (Appraisal Finding B.1, 80-11-06)
and duties (Appraisal Finding B.2, 80-11-07) into the job descriptions.
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This finding remains open pending review of approved job descriptions.
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i 4.2.3 Radiation Protection training:and experience is not addressed in the criteria fpr'adYancement of Health Physics Personnel. (Appra.isal Finding B.1, 50-220/80-11-06) ~
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Findings ThismatterisbeingreviewedinconjunctionwithRa-f(,
diation-Protection Personnel Job Descriptions (Appraisal
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Finding A.5, 50-220/80-11-05) and is closed for adminf s-
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trative purposes.
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4.2.4 Health Physics duties are'not,specified in formalized Job
Descriptions for techniciansf (Apprais'al Finding B.2, I
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50-220/80-11-07)
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diation Protection Persorinel Jcb Descriptions (Appraisall{
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Findinp A.5, 50-220/80-11-05) 'an'd ;is closed for adminis'-
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trative purposes.
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4.2.5 No independent verification by the licensee of the-
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calibration of the whole body counter wasJerfSrmed.. \\ i '
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for counting personnel are not followed. ?(Appraisal /l Q
- N Finding' C.2.a, 50-220/80-11-11)
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Findings'
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i The licensee established Procedure No. N1-RTP-45, Revision
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3, "Whole Body Counter System Operation and Calibration,"s.d i
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data indicated the procedure was implemented.
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independent verification of the counter._ The re'iew of'"
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The implementation of existing procedures for-counting i
personnel at an established frequency was reviewed during j
Inspection No. 50-220/82-06 and was found acceptable.'
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This finding is closed.
i 4.2.6 The evaluation of internal exposure data is insufficient
to determine whether the protection provided by protective
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i clothing and equipment is adequate.-
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Findings
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Documents Reviewed
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S-RTP-10, Revision 0, " Calculation of Internal Ra-diation EFposure," dated July 15, 1981
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N1-RTP-45, (Revision 3, "Whole Body Counter System
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Operation and, Calibration," dated June 30, 1982
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A N1-RTP-45A, Revision 0, " Indirect Bioassay Sampling,"
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x dated July 22, 1982
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The review of the abov:. procedures indicated guidance-m
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detailing specified evaluations to be performed with
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respect to protection provided by protective clothing and
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equipment was not addressed.
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i4.2.7 Procedural guidance and action levels which specify when
nssay samples are to be taken have not been excr o deve (Apertisal Finding C.2.c, 50-220/80-11-13)
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The licensee established Procedure No. S-RTP-45A, Revision
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0, "Ind1 rect Bioass'ay," on July 22, 1982. The procedure
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provides ade~quate guidance and action levels for col-
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lection of indirect bio' assay samples including excreta
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This finding is closed.
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4.2.C There are no procedures for collecting, handling,
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analyzing and avaluating bioassay samples.
(Appraisal s
Finding C.2.d, 50-220/80-11-14)
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i Findings The licensee established Procedure No.' S-RTP-45A, "Ind-irect Bioassay Sampling," on July 22, 1982. The procedure
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provides adequate guidance for collecting and handling bioassay samples.
-Regarding Analysis and evaluation of bioassay samples,
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' procedure 5-RTP-45A requires that the Respiratory Pro-
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'MPCihours,' skin doses, if significant, from external con-
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tamination using the methods described in '3-RTP-10, l;
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available.
Procedare No. S-RTP-10, Revision 0, "Calcu-lation of Inter:.al Radiation Exposure," dated July 15,
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1981, provides guidance for evaluating direct bioassay sam'pl e s.
However, no guidance is contained in the procedure for evaluation of indirect bioassay samples. In
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addition, the section of the procedure for organ dose
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evaluation references a procedure step which does not
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exist. Also, the procch re does not define "significant
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,j skiri Coses" for purposes of evaluation.
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This f.nding remains open.
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4.2.9 In suppo,t of the respiratory protection program: ' medical examinatit.ns were not performed annually; breathing air
was not tested to Grade D specifications or bdtter;
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regulators and valves were not tested as required by
procedures; quantitative test equipment was found-inopera-ble; and the training / retraining program did'not include
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field training or examinations.
(Appraisal Findin7'C.3.a.
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The licensee established procedure RP-10, Revision 1, "Use
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of Respirators," on September 20, 1982.
The procedura si requires personnel to receive a physical exam prior to use of equipment and requires annual re-exams.
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On December 20, 1979, the licensee completed pre-operational testing of the service air system.
The system uses a breathing air compressor which was tested and found to provide Grade D air. A test of the High Pressure Breathing Air Compressor for the Scott Air Pac, completed January 21, 1981, indicated this compressor also produced Grade D air.
The licensee modified the breathing air system subsequent to the performance of the air quality tests.
Licensee representatives stated that the breathing air system will be reviewed with respect to IE Information Notice 79-08,
" Interconnection of Contaminated Systems with Service Air Systems Used as the Source of Breathing Air," dated March
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The testing of regulators and valves is discussed in Section 2.2 of this report.
The licensee has placed in operation a sodium chloride quantitative fit test booth. A second quantitative booth, which uses corn oil, is being tested prior to placing it
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in service. The inspector was fit tested on October 27, 1982. The testing was performed by knowledgeable person-nel in accordance with approved procedures.
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The training and retraining of respirator users is de-scribed in Procedure RP-10, Revision 1, "Use of Respiratory Equipment," dated September 20, 1982. The procedure requires that personnel pass a written exam to qualify to use respirators. Discussions with licensee personnel indicated no hands-on respirator training was provided, e.g., donni ng, removal, negative pressure testing and
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emergency drills. The only use of the respirator prior to actual field use was when an individual was quantitatively
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fit tested.
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respiratory protection field training.
4.2.10 The quantitative fit test equipment and respirator assembly areas were not adequately located.
(Appraisal Finding C.3.b, 50-220/80-11-16)
Findings The licensee is placing into service a quantitative fit test booth within the protected area but oJtside the restricted area. The in-service booth, located within the Turbine Building (T.B.) on the 261' elevation, will be used for leak testing respirator face pieces and may be used for fit testing during high demand. The licensee plans to maintain the respirator assembly area at the same location (T.B. 261' elevation)
This finding is closed.
4.2.11 The individual assigned responsibility for supervising l
the respiratory protection program was not adequately l
qualified. (Appraisal Finding C.3.c, 50-220/80-11-17)
Findings
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of Respiratory Protection Coordinator. This individual has limited experience and training in establishing and
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implementing a Respiratory Protection Program. The licensee representative acknowledged the above and indicated the individual was currently in training. Adequately experi-
l enced and trained personnel are overseeing this individu-als activities pending completion of his training.
This finding is closed.
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4.2.12 There was a lack of written procedures specific to the
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quality assurance program for respiratory devices.
(Appraisal Finding C.3.d, 50-220/80-11-18)
Findings The licensee is performing quality assurance on new and used respiratory protection equipment. However, no procedures have been established which specify the minimum quality assurance program.
Licensee representatives indicated the respiratory pro-tection program is being reviewed and approprl ie proce-dure revisions will be made by July 1983.
This finding remains open.
4.2.13 Management review of and policy for the respiratory protection program was not established, implemented and maintained.
(Appraisal Finding C.3.e, 50-220/80-11-19)
Findings The licensee established a new Nine Mile Point Policy Statement on May 6, 1981.
This statement is included as Appendix B to Procedure No. APN-12, Revision 3, "Admini-strative Procedure for Maintaining Occupational Exposure to Radiation and Radioactive Materials As Low As Rea-sonably Achievable," dated May 7, 1981. The statement was signed by appropriate management and specifies the tech-niques and measures that will be used to ensure the policy i; carried out and also identifies the responsible indi-vidual.
This finding is closed.
4.2.14 Procedures do not exist to describe the methods used to count air samples and there is no evidence to indicate that all <ignificant isotopes were identified for air samples.
(Appraisal Finding D.6, 50-220/80-11-25)
Findings The licensee established Procedure No. N1-CRP-1, Revision 0, " Air Sample Analysis," on July 30, 1982. The procedure provides adequate guidance for analysis of air samples.
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This finding is closed.
4.2.15 Procedures do not exist fcr the calibration, operation, or setting of alarm points for the count rate instruments normally used to monitor personnel and equipment leaving
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restricted areas.
(Appraisal Finding D.12, 50-220/80-11-31)
Findings The licensee uses Eberline Model RM-14 and RM-3C count rate meters with either HP-210 or HP-260 probes for monitoring personnel and equipment leaving the restricted areas.
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Procedure No. S-RTP-71, Revision 0, " Operation and Cali-bration of the Eberline Radiation Monitor Model RM-14 Count Rate Meter," and Procedure No. S-RTP-51, Revision 0,
" Operation and Calibration of the Count Rate Meter Model RM-3C," were reviewed. The procedures adequately address l
the finding.
This finding is closed.
4.2.16 Adequate accountability, control, labeling and leak tests do not exist for all radioactive test and calibration sources.
(Appraisal Finding D.13, 50-220/80-11-32)
Findings The licensee established Procedure Nos. S-RTP-35A, Re-vision 0, "* Sealed Source Leakage / Contamination Test,"
and S-RTP-35B, Revision 0, "* Accountability of Calibration and Check Sources," on June 30, 1982.
Review of procedure S-RTP-35A and contamination test data indicated the procedure was adequate and implemented.
Review of procedure S-RTP-358 and accountability data indicated quarterly inventories were performed. However, the procedure did not require updating the inventory if a source was placed in a new iccation prior to the perfor-mance of a new quarterly inventory nor did it specify regulatory reporting requirements for lost sources.
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Licensee representatives indicated procedure S-RTP-35B would be revised by July 1983.
This matter remains open.
4.2.17 The licensee does not exercise control over or provide source checks for all survey meters.
(Appraisal Finding D.14, 50-220/80-11-33)
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Findings i
The licensee has established sign out sheets for control of survey meters. The sign out sheets are reviewed by licensee senior technician level personnel.
The review of survey instrument source checks indicated the licensee has obtained a source check device for checking instruments. However, review of source checks for the Eberline Teletector Indicated no procedure guidance was provided in Procedure No. S-RTP-16, Revision 2,
" Operation and Calibration of the Teletector and Modified Stack High Range Teletector," for source checking the instrument.
In addition, the source check being used for this instrument only provided a check of the external (low range) probe and not the internal (high range) probe.
This finding remains open.
4.2.18 The instruments used to monitor personnel and equipment for contamination could not detect the licensee's release limits and the detector types used did not meet the ANSI 323 recommendations.
(Appraisal Finding D.22, 50-220/80-11-41)
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The licensee no longer uses 30 mg/cm GM tubes to monitor personnel and equipment for contamination.
Thin window (2 mg/cm ) GM tubes now used (See Section 4.2.15 of this report) can detect the licensee's release limits and are acceptable.
This finding is closed.
4.2.19 The Radwaste Coordinator did not have adequatc personnel support or authority commensurate with his assigned responsibilities.
(Appraisal Finding E.1, 50-220/80-11-42)
Findings The licensee has established a dedicated Radioactive Waste Organization. The orcanization consists of a Radioactive Waste Supervisor (formerly the Radwaste Coordinator), an Assistant Radwaste Supervi~sor, and 15 auxiliary operator positions dedicated to radwaste operations.
Fourteen of the 15 positions were filled at the time of the inspection.
A contracted individual is also assisting in the develop-ment and coordination of the Radioactive Waste Program.
The review of Procedure No. APN-2, Revision 5, " Compos-ition and Responsibilities of Site Organization,"
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indicated the current Radwaste Organization was depicted in the procedure (Figure 1, dated July 1982). However, the procedure did not contain any description of the respon-sibilities and/or authority of the radwaste organization positions.
Procedure No. APN-2A, Revision 6, " Conduct of Operations and Composition and Responsibilities of Station or Unit Organization," provided a brief discussion of the Radwaste Operations Supervisofs responsibilities, but contained none for the assistent Radwaste Operations Supervisor.
Discussions with the current Radwaste Operation Supervisor indicated job position descriptions were being developed for Radwaste Organization personnel.
This finding remains open pending review of completed job descriptions.
4.2.20 Waste handling procedures were not adequately established, implemented or maintained.
(Appraisal Findings E.3, 50-220/80-11-44)
Findings The licensee has established waste handling procedures for packaging, handling and transporting of radioactive waste for all package types used.
Procedures for solidifica-tion, waste collection and compaction, and van loading are also in place.
A review of selected procedures indicated the procedures were adequate.
This finding is closed.
4.2.21 There is no assurance that all radioisotopes that may have significantly contributed to the radioactive content of Person-packages of rrdioactive material were evaluated.
nel did not evaluate peak indications that were not positively labeled by the counting system's computer.
(Appraisal Finding E.5, 50-220/80-11-46)
Findings Procedure V.A.7-N, Revision 0, " Operation nd Calibration of the GeLi-2 Multi-Channel Analyzer," dated January 30, 1981, was reviewed.
The review indicated the procedure does not provide adequate guidance for resolving unknown peaks. _
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Licensee representatives indicated additional guidance would be included in the procedure by December 30, 1982.
This finding remains open.
5.
Drywell Tour The inspector toured the Reactor Drywell on October 27, 1982 and observed ongoing work on the following:
No. 13 Recirculation Pump discharge weld preparation
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No. 13 Discharger Safe-end nozzle welding
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No. 15 Recirculation Pump discharge cutting
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Preparation for leak rate testing on shutdown cooling isolation valves The inspector determined that radiation and airborne radioactivity surveys had been performed in accordance with 10 CFR 20.201, " Surveys",
High Radiation Areas were being controlled in accordance with Technical Specification 6.13, "High Radiation Areas," and that personnel were following Radiation Work Permits.
Independent radiation surveys were also performed to verify the licensee's surveys.
No radiation exposure levels inconsistent with licensee results were identified.
In reviewing safe-end Radiation Work Permits, the inspector noted that contamination levels and job specific dose rates were not presented on the permits. The permits did contain dose rate ranges for the general areas to be entered.
Licensee representatives stated radiation pro-tection technicians covering each job were providing specific informa-tion. The licensee plans to provide survey maps for this purpose but is awaiting holders for the maps.
Radiation Work Permits for work other than recirculation safe-end work did contain specific information on the permits. This matter remains open (50-220/82-20-01).
No violations were identified.
6.
Exit Interview The inspector met with licensee representatives (denoted in Section 1 of l
this report) on October 29, 1982.
The inspector summarized the scope and findings of the inspection.