IR 05000220/1985011
| ML18038A042 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, 07002948  |
| Issue date: | 07/31/1985 |
| From: | Cioffi M, Myers L, Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18038A041 | List: |
| References | |
| 50-220-85-11, 50-410-85-20, 70-2948-85-01, 70-2948-85-1, NUDOCS 8508080540 | |
| Download: ML18038A042 (30) | |
Text
~ ~.S., NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-220/85-11, 50-410/85-20, and 70-2948/85-01 Docket Nos.
50-220, 50-410, and 70-2948 License No.
DRP-63 CPPR-112 SNM-1895 Pri ority Category C
B Licensee:
Niagara Mohawk Power Corporation 300 Erie Boulevard West Syracuse, New York 13202 Facility Name:
Nine Mile Point, Units 1 and
Inspection At:
Oswego, New York Inspection Conducted:
June 24-28, 1985 Inspectors:
R.
L. Nimitz, Senior Rad.'ation Specialist date M. J. Cioffi, Radiation S eci list date ( ~( ]o~
Approved by:
L.
E. Myers, Radiation Special st Cu~c~g date C
7si b>
W. J.
P BWR Ra i ciak, Chief tion Protection Section date Ins ection Summar
Ins ection on June 24-28 1985 Combined Re ort Nos.
50-220/85"11'0-410/85-20'0-2948/85-01 A~i*
.
i, d
di i
i i
f Unit 1 and preoperational radiological controls inspection of Unit 2.
The inspection of Unit 1 covered:
radioactive and contaminated material control; radioactive waste shipping; high radiation area access control; and radio-logical controls personnel training.
The inspection of Unit 2 covered:
preoperational testing of the solid, liquid and gaseous waste processing systems; safety related ventilation systems; radioactive material control and IE Bulletin 80-10 'he inspection involved 60 inspector hours onsite by three region-based inspectors.
Results:
No violations were identified'508080540 850805 PDR ADOCK 05000220 G
4'
DETAILS 1.0= Individuals Contacted I.
~tli N
- T. Roman, Station Superintendent, Unit
- R. B. Abbot, Station Superintendent, Unit 2
- B. R. Morrison, Manager of QA
"W. Ray, Manager Special Projects
- W. Hansen, Start-Up QA
- G. K. Afflerbach, Start-up Manager
"J.
R. Orland, Start-Up QA Supervisor
- P. Volza, Supervisor Radiological Support
"R. Gerbig, Unit 1, Radiation Protection Supervisor
- D. Barcomb, Unit 2, Radiation Protection 1.2 Nuclear Re ulator Commission
'S.
Hudson, Senior Resident Inspector, Unit
- R. Gramm, Senior Resident Inspector, Unit 2
"denotes those individuals attending the exit meeting on June 28, 1985.
The inspector also contacted other individuals during the course of the inspection.
2.0
~Pur ose The purpose of this inspection was to review the following program elements:
Unit
~ Radioactive and Contaminated Material Control
~ Radioactive Waste Shipping
~ High Radiation Area Access Control
~ Radiological Controls Personnel Training Unit 2 The inspection of Unit 2 was a preoperational inspection and was performed to determine if the licensee's radiological controls program adequately provides the radiation protection organization, staff, training, procedures, facilities, and equipment to comply with regulatory require-ments and commitments made in the Final Safety Analyses Report (FSAR).
In addition, the&nit 2 inspection was performed to verify that the licensee has conducted tests of waste systems to verify their operability and that the process and effluent monitoring program is adequate and conforms with the FSAR description.
A review of radioactive material control and IE Bulletine 80-10 was also performed.
3.0 Trans ortation of Radioactive Materials Unit
The licensee's program for the transportation of radioactive material was reviewed against the criteria in:
~ 10 CFR 71, "Packaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions"
"Surveys" CARPI-6,
"Radioactive Waste Shipment Requirements" AS-RP-3,
"Performance of Radiological Surveys"
~ RP-6,
"The Packaging and Transportation of Radioactive Material"
~ NRC Certificate of Compliance No. 9176, Revision
~ Niagara Mohawk Internal Correspondence,
"Externally Contaminated Concentrated Waste Shipment, Casii ¹215-5, 5/4/85", dated May 14, 1985 The following aspects of the licensee's program were reviewed:
inadequacy and implementation of established procedural program to ship radioactive waste; inadequacy and involvement of gA personnel in radioactive waste shipping activities; and inadequacy of radioactive waste organization.
Also reviewed was the circumstances and licensee corrective actions taken as a result of the identification of a shipment of licensee radioactive waste which arrived at the Barnwell, South Carolina burial site on May 4, 1985, with excess levels of removable contamination.
The licensee's performance relative to the above was based on:
~discussions with cognizant personnel, reexamination of the documentation associate with three radioactive waste shipments made since January 1985, and
preview of the. 14gensee's investigation of the excess contamination event.
Within the scope of this review, the following was noted:
~manifests for the radioactive waste shipments reviewed contained the applicable information required by 10 CFR 61.55,
CFR 61.56, and
CFR 20.311;
~ notifications, if appropriate, were made for applicable shipments,
~ procedures are well defined for:
~ handling waste shipments,
~ acceptance of shipping casks on site.
Regarding the May 4, 1985, incident involving excess contamination on a
shipping cask, the following was noted:
~ the licensee performed an acceptable investigation of the incident,
~ the licensee identified the causal factors of the incident,
~ the licensee initiated appropriate, timely corrective actions to preclude recurrence.
These corrective actions included revisions of procedures to clearly define radioactive waste shipment contamination surveys.
Also, involved individuals were counseled.
No violations were identified.
4.0 Radioactive Waste Shi in Personnel Trainin and Qualification Unit
The inspector reviewed selected elements of the licensee training and qualification program for radioactive waste shipping personnel.
The following elements were reviewed:
~ an initial training and qualification program for all applicable personnel was established,
~ the program was properly implemented,
~ an retraining and requalification program for all applicable personnel was established.
The review was with respect to criteria contained in the following:
~ Technical Specification 6.4, "Training";
~ ANSI N18. 1-1971 "Selection and Training of Nuclear Plant Personnel";
~ IE Bulletin No.&9-19 "Packaging of Low Level Radioactive Waste For Transport and Burial", August 10, 1979;
~ Letter, T.
E.
Lempges (Niagara Mohawk) to B.
H. Bier (NRC-RI) dated September 21, 1979;
~ Procedure RPI-6 "Radioactive Waste Shipment Survey Requirements",
Revision 0, dated May 24, 1985;
~ Procedure S-RP-3,
"Performance of Radioactive Surveys",
Revision 3, dated April 1, 1985;
~ Procedure RP-6,
"The Packaging and Transportation of Radioactive Material" Revision 1, dated January 16, 1984.
The following positive attributes were noted:
~ the licensee provided training to appl,icable personnel in a timely manner in the instruction, RPI-6, generated to preclude recurrence of contaminated shipments being sent from the site (see Section 3);
~ contents of lesson plans and lectures meet the requirements of IE Bulletin 79-19; and straining of applicable personnel in changes in transportation regulations was performed.
Within the scope of this review the following matters requiring licensee attention were identified:
(50-220/85-11-01)
~ the applicable procedures an individual was to be qualified in to be certified to perform radioactive waste shipping activities was not clearly defined;
~the retraining frequency and scope of material an individual was to be retrained in was not clearly defined; and
~although the licensee provided retraining of personnel in changes to transportation regulations, the licensee had not established qualification criteria (e.g.
oral or written exam) to ensure appropriate personnel were cognizant of all appropriate material presented.
The licensee should establish some methodology to demonstrate the effectiveness of the retraining.
No violations were identified.
5.0 Radioactive and Contaminated Material Control Unit
The inspector reviewed selected elements of the licensee's radioactive
and contaminated~aterial control program.
The following elements of the program were reviewed:
inadequacy of surveys and monitoring of radioactive and contaminated material; decontrol of radioactive and contaminated material;
~ posting and labeling of. radioactive and contaminated material; and
~maintenance of survey and monitoring records.
The review was with respect to criteria contained in the following:
"Surveys";
"Caution Signs, Labels, Signals and Controls";
and
"Records of Surveys, Radiation Monitoring, and Disposal".
The evaluation of the licensee's performance in this area was based on:
~periodic tours through out the facility on normal and backshifts,
~discussions with cognizant licensee personnel,
~ performance of independent surveys by the inspector.
Within the scope of this review, no violations were identified, The licensee was implementing an acceptable program in this area.
6.0 Hi h Radiation Area Access Control Unit
The inspector reviewed selected aspects of the licensee's High Radiation Area Access Control Program.
The review was with respect to requirements contained in Technical Specification 6. 13, "High Radiation Area".
The evaluation of the licensee's performance in this area was based on independent radiation surveys performed by the inspector, observations during plant tours, and discussions with cognizant personnel.
Within the scope of this review, no violation were identified.
The licensee was implementing an acceptable High Radiation Area Access Control Program.
7.0 Preo erational Testin Unit 2 The inspector reviewed the licensee's preoperational testing of the following systems:
~ liquid radwaste system;
~ solid radwaste
~stem;
~ gaseous radwaste system;
~ safety related ventilation systems; and
~ area, process and effluent radiation monitoring systems.
The review was with respect to criteria contained in the following.
~ Final Safety Analyses Report (FSAR), Chapter 14, "Initial Tests Program;"
~ Regulatory Guide 1.68, November 1978, "Preoperational and Initial Start-up Test Program for Water Cooled Power Reactors";
~ Procedure N2-SAP-100, "Start-up and Test Program description and Organization";
~ Procedure N2-SAP-101,
"Preparation and Control of Start-up Administration Procedures";
~ Procedure N2-SAP-102, "Joint Test Group";
~ Procedure N2-SAP-106A, "Test Procedure Format";
~ Procedure N2-SAP-106B, "Test Procedure Review, Approval and Revision";
~ Procedure N2-SAP-107A,
"System Turnover".
The following matters were reviewed:
~ status of construction, release, and/or turnover of systems;
~ status of start-up test procedure establishment;
~ status of testing; inadequacy of test procedures;
~ extent and adequcy of gA involvement with procedure reviews;
~ extent and adequacy of gA involvement in system release and turnover to plant staff.
The evaluation of licensee performance in the above areas was based on:
~ independent inspector walk down (commensurate with degree of construction) of the above systems;
~ review of proc~res;
~discussions with cognizant licensee representatives.
7.1 Li uid Radioactive Waste S stems Documents Reviewed
~ Final Safety Analysis Report (FSAR), Section 11.2, "Liquid Waste Management Systems";
~ANSI/ANS-55.3, 1976, "Boiling Wastes Reactor Liquid Waste Processing Systems;"
~ Interim Operating Procedure N2-IOP-40, Revision 0, "Liquid Radwaste System",
dated June 11, 1985; and
~Applicable Stone and Webster, F-SK Piping and Instrumentation Drawings (P&IDs).
~Findin n
An independent walkdown of the liquid radioactive waste systems was conducted commensurate with construction completion.
Comparison of the as-built system with applicable P&IDs IDs and comparison between FSAR description and Pand IDs did not identify any significant deficiencies.
The as-built system matched the FSAR described system.
The system has been partially released for testing.
The licensee has established an interim operating procedure ( IOP-40)
for system operation.
Inspector review of selected aspects of the procedure did not identify any deficiencies.
The licensee has developed the major procedure for system testing (FSK-31-POT-40),
however, the procedure is currently being reviewed but it is not yet approved.
The licensee has written and approved procedures for testing floor drains and equipment drains.
The licensee's preoperational testing of the liquid radioactive waste system will be reviewed during a subsequent inspection (50-410/85-20-01).
7.2 Solid Radioactive Waste S stem Documents Reviewed
~ Final Safety Analysis Report (FSAR) Section 11.2, "Solid Waste Management";
~ANSI/ANS-.5~1, 1979, "Solid Radioactive Waste Processing System for Light Water Cooled Reactor Plants";
~Applicable Stone and Webster, F-SK Piping and Instrumentation Drawings (P&IOs).
~Findin n
An independent walkdown of the liquid radioactive waste systems was conducted'ommensurate with construction completion.
Comparison of the as-built system with applicable P&IOs and comparison between FSAR description and P&IDs did not identify any significant deficiencies.
The as-built system matched the FSAR described system.
The system has not been released for testing.
The licensee has established an interim operating procedure (IOP-41) for system operation.
The licensee is currently establishing applicable preoperational test procedures for the system.
The licensee is including appropriate solidification test criteria.
The licensee has not yet started testing of the major components of the system.
The preoperational testing of the solid radioactive waste system were be reviewed during a subsequent inspection (50-410/85-20-02).
7.3 Safet Related Ventilation S stems Control Room and Standb Gas Treatment Unit 2 Documents Reviewed
~ Final Safety Analysis Report, Section 6.4 "Habitability Systems",
~ Final Safety Analysis Report, Section 6.5, "Fission Product Removal and Control Systems",
~Applicable Stone and Webster, F-SK Piping and Instrumentation Drawings (P&IDs)
~Findin n
An independent walkdown of the Control Room and Standby Gas Treatment System was conducted commensurate with construction completion.
Comparison of the as-built system with applicable P&IDs and comparison between FSAR description and P&IOs did not identify any significant deficiencies.
The as-built system matched the FSAR described system.
The system has not been released for testin The licens~has not fully established and approved preoperational test procedures for the systems.
The licensee's preoperational testing of safety related ventilation systems will be reviewed during a subsequent inspection (50-410/85-20-03).
7.4 Area Process and Effluent Radiation Monitorin S stems Unit 2 Documents Reviewed
~ Final Safety Analysis Report, Section 11.5,
"Radiation Monitoring Systems;"
~ANSI N42. 18-1980, "Specification and Performance of On-Site Instrumentation for Continuously Monitoring Radioactivity in Effluents
~ ANSI N13. 1-1969,
"Guide to Sampling Airborne Radioactive Materials in.Nuclear Facilities;"
~ANSI/ANS 6.8.2-1981,
"Location and Design Criteria'or Area Radiation Monitoring Systems for Light Water Nuclear Reactors."
~Findin s
With the exception of the Drywell atmospheres monitors, all process and effluent radiation monitoring systems have been delivered to the licensee.
None of the monitors have been installed.
Area radiation monitoring systems are currently being installed.
Preoperation test procedures for the systems have not yet been approved.
The following matters will be reviewed during a subsequent inspection:
~ preoperational testing and calibration of area, process and effluent moni tor (50-410/85-20-04),
~ the ability/verification of the effluent monitors to the collect representative samples (50-410/85-20-05).
8.0 Trainin and ualification of Start-u Test Personnel Unit 2 The inspector reviewed selected elements of the Start-up Test Personnel Training and Qualification Program.
The review was with respect to criteria contained in the following:
~ Final Safety Analysis Report Section 14, "Initial Tests Program;"
~ Procedures N2-SAP-109, "Qualification and Certification of Start-up and Test Personnel;"
~ Procedures N2-.S4P-109A, "Qualification and Certification of Site/Unit Personnel;"
~ Procedure N2-SAP-110, "Training of Start-up and Test Personnel;"
~ Stone and Webster Project Test Program Directive, PTPD-3. 1, Revision 2,
"Qualification of Test Personnel;"
~ANSI N45. 1.6, 1978, "Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants".
The review was performed to determine the following:
~ test postion experience and qualification criteria were clearly described;
~ the program was implemented; and
~ personnel performing testing of systems were properly trained and qualified.
The evaluation of the licensee's performance was based on:
~discussions with cognizant personnel, preview of training records, preview of resumes,
~discussions with testing personnel.
Within the scope of the review, no violations were identified.
The following unresolved item was identified and will be reviewed during a
subsequent inspection:
(S0-410/85-20-06).
~the licensee was qualifying personnel in accordance with N2-SAP-109A by accepting individuals qualified under Stone and Webster Procedure PTPD-3. 1.
Both procedures had been reviewed and approved by licensee management.
However, the inspector was unable to identify any formal review and documented approval of the contents (e.g. written exams or oral exams) of the programs used to qualify personnel per Stone and Webster Procedure PTPD-3
~ 1.
Licensee representatives indicate a Test Group Supervisor had reviewed
'the written exams and had found them acceptable.
Time limitations prevented the inspector from examining the extent of licensee review of the program or certification of personnel accepting individuals prior qualifications.
Licensee Quality Assurance personnel indicated that an audit of the training and qualification program of testing personnel was to be conducted in about two weeks.
9.0 Selection uglification and Trainin of Radiolo ical Controls and Radioactive Waste 0 erations Personnel Unit 2 The inspector reviewed selected aspects of the selection, qualification and training program for the following groups:
irradiation prot~ion personnel,
~ radiochemistry personnel, and
~ radwaste operations personnel.
The licensee's performance in the above area was based on:
~discussions with cognizant personnel, and preview of procedures.
Within the scope of the review, the following matters were identified:
~ The licensee has establish'ed a
new Radiation Protection and Chemistry Personnel Training Program.
The program consists of a number of modules with each module consisting of a number of specific task training segments (cog. selection of radiological monitoring instruments based on expected radiological hazard).
However, all modules have not been formally approved.
~ The licensee has not clearly identified what tasks an individual must be qualified in based on the individuals scope of responsibilities.
~ The licensee has not clearly identified the retraining/requalification frequency for radiation protection and chemistry personnel.
~ The licensee has not clearly identified the minimum material an individual should be retrained/requalified in following initial training and qualifications.
~ A Unit 2 initial training and qualification program has not been established for Radioactive Waste Operations personnel.
~ A Unit 2 retraining/requalification program has not been established for, Radioactive Waste Operations personnel.
The licensee's actions on the above matters will be reviewed during a
subsequent inspection (50-410/85-20-07).
Control of Radioactive Material Unit 2 The inspector reviewed the adequacy of licensee control of radioactive material on the Unit 2 Refueling Floor.
The material was contained inside unirradiated incore neutron detectors.
The review was with respect to criteria contained in the following:
~ SNM License No.
1895, and Amendment 1, dated April 19, 1982, and May 8, 1985, respectively; f
~ Licensee letter (Wetterhahn, Niagara Mohawk Counsel, to J.
G. Oavis, NRC), dated April 17, 1985;
~ Licensee letter+Lyman, Attorney for Niagara Mohawk, to R.
G.
Page, NRC), dated March 23, 1982;
"Storage and Control of Licensed Materials In Unrestricted Areas";
~ 10 CFR Part 70,'Domestic Licensing of Special Nuclear Material."
~ 10CFR 73, "Physical Protection of Plants and Materials;"
l
~ Procedure IS.0094.001, Revision 1, "Inspection, Preassembly and Installation of Incore Detectors and Dry Tubes;"
~AP-3.6, Revision 0, "Special Nuclear Material Control Procedure;"
~ SWEC Project Guideline PG60, Revision 1, "Receiving and Handling Special Nuclear Material;"
RCMP 1.3-2.79,
"Material/Equipment Storage;"
RCMP 1.2-3.8,
"Receiving Materials and Equipment;"
and AS-RP-1, Revision 5, "Access and Radiological Controls."
The evaluation of the licensee's performance in this area was based on, review of documentation, discussion with cognizant personnel and review of in-field activities.
The licensee's posting, barricading, and control of the material was found to meet applicable requirements.
No violations were identified.
11.0 IE Bulletin No. 80-10 Unit 2 Documents Reviewed
"Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment," dated May 6, 1980.
General The bulletin requested that:
~ licensees review the design and operation of their facility to identify systems that are considered as nonradioactive but could possibly become radioactive as a result of interfaces with radioactive system 'J
~establish a routine sampling/analysis or monitoring program for these systems in order to promptly identify any contaminating event which could lead to unmonitored or uncontrolled releases.
~ licensees decontaminate systems that do become contaminated or perform an immediate safety evaluation in accordance with 10 CFR 50.59 if the effected system is to be operated as a contaminated system
~ licensees make provisions to assure compliance with applicable regulatory requirements for release of radioactive material and make changes to Technical Specifications.
The changes are to be, made prior to continued operation of the contaminated system if an unreviewed safety question exists or a Technical Specification change is required.
~Pnr nse The inspector review of this area was to determine if the licensee had appropriate administrative controls and/or sampling and analysis programs to preclude/identify any radioactive efflucent releases from Unit 2.
.
~Findin s
Within the scope of the review the following was noted:
~ no physical connections currently exist for radioactive liquid/gaseous streams between Units
and 2.
Three liquid waste lines are available for cross-connection.
However, they are currently blanked-off.
~ Unit 2 receives fire water from Unit
~
However, the supply is from a non-radioactive source.
~ A sampling and analysis program of appropriate Unit 2 systems was initiated.
The following matters will be reviewed during a subsequent inspection:
(50-410/85-20-08)
~ Establishment (as appropriate)
of administrative controls for connecting the three cross-connects between Unit 1 and 2.
~ Full establishment of an IE Bulletin 80-10 program for Unit 2.
12.0 Radiolo ical Controls Or anization and Staffin Unit 2 The inspector reviewed the current status of the licensee's development of an expanded Radiological Control Organization to support combined Unit 1 and 2 operation bl
Documents Reviewe
~ Procedure AP-1. 1, Revision 0, "Composition and Responsibility of Site Organization,"
~ Procedure AP-1.2, Revision 0, "Composition and Responsibility of Unit Organization,"
~ Procedure AP-1.3, (Draft), "Personnel Responsibilities and Authority."
Within the scope of this review, the following was identified:
~ The licensee currently has insufficient chemistry staff to support combined Unit 1 and Unit 2 operations.
The licensee is aware of this matter and is aggressively recruiting personnel to fill the six identified vacancies.
The staffing of the Radiological Controls Organization will be reviewed during a subsequent inspection.
(50-410/85-20-09)
13.0 Exit Interview The inspector met with licensee representatives at the conclusion of the inspection on June 28, 1985.
The inspector summarizes the purpose, scope and findings of the inspection.
No written material was provided to the licensee.