IR 05000220/1986004
| ML18038A157 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/23/1986 |
| From: | Nimitz R, Shanbaky M, Tuccinardi T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18038A156 | List: |
| References | |
| 50-220-86-04, 50-410-86-12, IEB-77-14, IEB-79-19, IEB-79-20, IEC-76-03, IEC-78-03, IEC-80-18, IEC-81-07, IEC-81-09, IEIN-79-07, IEIN-79-21, IEIN-80-24, IEIN-80-32, IEIN-83-05, IEIN-83-09, IEIN-83-14, NUDOCS 8605020175 | |
| Download: ML18038A157 (30) | |
Text
. N.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-220/86-04 50-410/86-12 Docket Nos.
50-220 50-440 License Nos.
DPR-63 CPPR-112 Priori ty Cate or
.
C Licensee:
Nia ara Mohawk Power Cor oration 300 Erie Boulevard West S racuse New York 13202 Facility Name:
Nine Mile Point Inspection At:
Oswe o
New York Inspection Conducted:
March 23-28 1986 Inspectors:
R.
L. Nimitz, S
ior Radiation Specialist date T
. Tuccinardi, Radiation Specialist Approved by:
M.
M. Shanbaky, Chief acilities Radiation Protection Section, date date Ins ection Summar
Inspection conducted on March 23-28, 1986 (Combined Inspection Report No. 50-220/86-04; 50-410/86-12).
A~Ad:
R <<,
df l
flf Rdf Controls during the current Unit 1 outage including:
outstanding items, train-ing and qualification; external exposure control; internal exposure control; radioactive and contaminated material control; and ALARA.
Outstanding items; training and qualification; bulletin, circular, and information notices; and preoperation testing was reviewed at Unit 2.
Results:
No violations were identified.
Sb05020175 Sb0423 PDR ADOCK 05000220
DETAILS 1.
Persons Contacted
1
~tli h
k
~I. Weakley, Special Projects K.
F. Zollitsch, Superintendent, Nuclear Training
- H. J.
Flanagan, Environmental Protection Coordinator
~P. Volya, Supervisor, Radiological Support
- R. T. Seifried, Assistant Superintendent, Nuclear Training
"T. Perkins, General Superintendent
- T. W.
Roman, Station Superintendent, NMP-1
- E. W. Leach, Superintendent, Chemistry/Radiation Management
- R. Gerbig, Radiation Protection Supervisor, NMP-1
- T. Irving, ALARA Coordinator
"D. C.
Helms, Dosimetry Coordinator
"R. Carlson, Respiratory Protection Coordinator
- M. Goldych, Assistant Supervisor, Training
"M. Dooley, Training Supervisor-Nuclear
- R. Abbott, Station Superintendent, NMP-2 1.2 NRC
"S
~ Hudson, Senior Resident Inspector C. Marschall, Resident Inspector
"denotes those individuals who attended the Exit Interview on March 28, 1986.
The inspector also contacted other licensee employees during the inspector.
2.
~Pur ose Unit
The purpose of this inspection was to review the adequacy, effectiveness and implementation of radiological controls during the refueling outage.
The following elements were reviewed:.
outstanding items, training and qualification, external exposure control, internal exposure control, radioactive and contaminated material control, and ALARA;
Unit 2.=
outstanding items, training and qualification, preoperational testing (Area Radiator Monitors),
and Bulletins, Circulars, and Information Notices.
~
Licensee Action on Previous Findin s
3.1 3.2 (closed)
Follow-up Item (50-410/85-32-03)
Licensee to address Unit 2 Radiological Controls deficiencies for fuel receipt discussed in inspection 50-410/85-32.
The licensee's action on the NRC iden-tified deficiencies was reviewed during inspection 50-410/85-47 and this inspection (50-410/86-12).
The licensee addressed the concerns identified.
This item is closed.
(closed)
Follow-up Item (50-220/84-22-02)
Licensee to establish and implement a revised ALARA Program.
The licensee revised and imple-mented his ALARA Program.
This matter is discussed in Section 5 of the report.
This item is closed.
3.3 (open)
Follow-up Ivem (50-410/85-32-04)
Licensee to complete pre-operational tests of area radiation monitoring (ARM) system.
The licensee has not commenced preoperational testing of the ARMs.
3.4 (open)
Follow-up Item (50-410/85-20-07)
Licensee to train and qualify Unit 2 Radiation Protection and Radwaste Operation personnel.
The licensee is currently training and qualifying these personnel.
The minimum training and qualification requirements are not yet estab-lished (Details, paragraph 4.0).
4.
Selection ualification and Trainin General The inspector reviewed the selection, qualification and training of selected radiation protection and radwaste operations personnel.
The review was with respect to criteria contained in the following:
CFR 19. 12 " Instruction to Workers;"
CFR 20. 103 "Exposure of Individuals to Concent'rations of Radioactive Materials in Air in Restricted Areas;"
Technical Specification 6.4, "Training;"
NTP-l, "Training and Continued Training of Chemistry and Radio-chemistry Technicians;"
NTP-14, "Training and Continued Training of Radiation Protection Technicians;"
and
~
Respiratorg+rotection Training gualification and Requalification Program and Review Sheet.
The licensee's performance in this area was based on:
~
review of selected radiation protection personnel records including those of personnel performing radiation protection coverage;
~
review of radiation protection personnel performance;
~
discussions with cognizant licensee personnel;
~
review of training records of workers identified performing in field radiological work including those wearing respirators.
The following matters were reviewed:
Unit
Adequacy and implementation of General Employee Training Program for radiation workers; Adequacy and implementation of the Respiratory Protection Training Program; Training and gualification of Instructors; Selection, qualification and training of radiation protection technicians performing responsible work; Training facilities'nit
Selection, qualification and training of radiation protection technicians.
Training and qualification of radwaste operations personnel.
~Findin n
Unit
Within the scope of this review, the following was noted:
The licensee was implementing an adequate General Employee Training Program.
The licensee was implementing an adequate Respiratory Protection Training Program.
Instructors were adequately trained and qualifie ~
Radiation.p~ection technicians were provided adequate initial training.
~
Training facilities were above average.
Unit 2 Within the scope of this review, the following matter needing licensee attention was identified:
(50-410/85-20-07)
~
The licensee has not clearly described the minimum training and qualification of radiation protection personnel based on their task assignments.
The licensee should define the minimum training and qualifications required by these personnel based on the tasks required to be performed and ensure the individuals are trained and qualified commensurate with their task assignments and plant milestones (e.g.
fuel load, initial criticality, etc.).
5.
A~LAII I
The inspector reviewed the adequacy, effectiveness and implementation of the licensee's ALARA Program with respect to criteria contained in the following:
CFR 20.1,
"Purpose" Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupa-tional Radiation Exposures at Nuclear Power Stations will be As Low As Is Reasonably Achievable (ALARA)," Revision 3; Regulatory Guide 8. 10, "Operating Philosophy for Maintaining Occupa-tional Radiation Exposures As Low As Is Reasonably Achievable,
"Revision 1-R; NUREG/CR-3254,
"Licensee Programs for Maintaining Occupational Exposure to Radiation As Low As Is Reasonably Achievable."
Licensee Procedures:
AP-3.2. 1, "Administrative Procedure for Maintaining Occupational Exposure to Radiation and Radioactive Materials As Low As Reasonably Achievable," Revision 1;
S-RR-1,
"Access and Radiological Control," Revision 5;
S-RTP-92, "Establishing and Evaluating Exposure Goals,"
Revision 0; S-RTP-93,
"Establishing and Evaluating ALARA Goals,"
Revision 0; S-ARI-1,
"ALARA Records Instruction," Revision 0;
e
S-ARI-Q "Instruction for Tracking Site Exposure,"
Revision 0;
\\
S-ARI-4, "Instruction for Daily Exposure Monitoring,"
Revision 0; S-RP-7,
"Incorporating ALARA Requirements Into Work Planning and Initiation," Revision 1;
ALARA Design Manual, dated June 1985; S-RP-S,
"Post Task/Job ALARA Evaluation," Revision 1;
HP-03, "Establishment of Annual Exposure Goals," Revision 3; HP-04, "Evaluation of Exposure Goals Program,"
Revision 1;
HP-06,
"Performance Monitoring of the Radiation Protection and Radioactive Waste Management Programs,"
Revision 0; HP-07,
"ALARA Cost-Benefit Analysis Guide," Revision 0; and HP-OS,
"ALARA Final Design Checklist," Revision 0.
The evaluation of the licensee's performance in the area was based on the following:
discussions with cognizant personnel review of applicable documentation specific reviews of ALARA planning and implementation for the following:
Control Rod Drive Removal and Rebuilding Induction Heating Stress Improvement ( IHSI)
Main Condenser Retubing review of on-going work.
The following matters were reviewed:
management system for program implementation, maintenance and evaluation organizational effectiveness staffing ALARA optimization process program implementation
Within the scope~f the review, the following was noted:
General
~
The licensee has established a defined ALARA Program.
The Program provides for work pre-planning, on-going job review and post-job evaluation.
Guidance for establishing ALARA Goals and performing reviews of design changes is in place.
~
Personnel responsibilities and authorities are defined.
~
The ALARA organization and staffing is acceptable.
~
Appropriate cost-benefit analyses are performed were applicable.
~Seci fic
~
The licensee is using shielding to effectively reduce exposure
~
The licensee is using television cameras where appropriate to minimize entry into radioactive areas
~
Mock-ups are used for training and work planning (e.g.
CRD under vessel mock-up, IHSI mock-up, CRD support housing mock-up
)
Within the scope of the review the following items needing licensee attention were identified:
Post-job ALARA reviews were not performed for some tasks in accordance with procedure guidance.
Some ALARA post-job. evaluations were lost or misplaced.
On-going job reviews are not being performed in accordance with procedure guidance due to problems with computer software.
The 'soft-ware was generated to perform the specified reviews.
Limited reviews are performed manually.
The licensee should:
improve maintenance of documentation; perform post-job reviews in accordance with procedure guidance, and revise procedures or correct software to perform on-going job reviews in accordance with proce-dure guidanc.
External Ex osurauControl (Unit 1)
General The inspector r'eviewed the licensee's control of external exposure of personnel with respect to the following:
~
CFR 20, "Standards for Protection Against Radiation";
~
Technical Specifications;
~
S-RP-2,
"Radiation Work Permit Procedure".
The inspector reviewed the following aspects of the licensee's external exposure control program:
performance, documentation, and maintenance of radiation surveys; issuance, adherence to, and adequacy of Radiation Work Permits;
~
use of proper ly calibrated survey instrumentation;
~
=issuance of proper personnel monitoring devices;
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generation and maintenance of external exposure records and/or exposure reports;
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posting and/or access control to radiation and high radiation areas; use of, and evaluation of, the Siemens film badges currently in use.
The evaluation of the licensee's performance in this area was based on:
review of in-field radiological work; discussion with personnel; independent surveys performed by the inspector; review of documentation.
~Findin s
Within the scope of this review, no violations were identified.
The licensee was implementing a generally adequate external exposure control progra Within..the scopeWf this review, the following matters needing licensee attention were identified:
(50-220/86-04-01)
~
complete the review and evaluate the adequacy of the new badge of record being used (Siemens)
~
The evaluation is scheduled to be complete on or before April 14, 1986.
The badge should be evaluated for its response to the radiation environment at Nine Mile Point Station.
~
evaluate the acceptability of taping over personnel monitoring badges.
Badges are taped over in some cases with exposed skin surfaces present.
The taping over may result in improper assessment of exposure to the exposed skin surfaces.
~
evaluate the adequacy of dosimetry placement for condenser tube workers.
The workers are carrying the tubes next to their face, but the personnel monitoring badge is worn on the chest.
7.
Internal Ex osure Control Unit
General The inspector reviewed the licensee's control of internal exposure with respect to criteria contained in the following:
~
CFR 20 "Standards for Protection Against Radiation";
~
Technical Specifications;
~
S-RP-2,
"Radiation Work Permit Procedure".
The following elements of the internal exposure control program were reviewed:
airborne radioactivity surveys; implementation of applicable administrative controls (e.g., radiation work permit survey requirements);
respiratory protection equipment selection and use; maintenance of records, exposure reporting and notification; use of engineering controls in-lieu of use of respiratory protection equipment; and adequacy of airborne radioactivity sampling and analysis methodolog The evaluation.oCuthe licensee's performance in the area was based on:
~
review of in-field airborne radioactivity sampling practices;
~
review of surveys;
~
review of procedures;
~
discussions with personnel; and
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review of on-going work
~Findin s
Within the scope of this review, the following was noted:
~
The licensee is making extensive use of engineering controls to minimize airborne radioactivity and use of respiratory protection equipment.
~
No intakes in excess of 40 mpc-hours were identified.
Within the scope nf this review, the following matters needing licensee attention were identified:
(50-220/86-04-02)
Establish and implement an effective airborne radioactivity sampling program for personnel performing sand blasting.
Although airborne radioactivity samples have been low and subsequent whole body counts of sand blasters has not identified any measurable intake of radio-active material, it is not apparent that the sampling is adequate due to filter plugging.
Effective sampling is needed to ensure compliance with the respira-tory protective equipment selection requirement of 10 CFR 20. 103 to ensure the MPC-factors encountered do not exceed the protection factor of the respirator used.
,Establish and implement an alpha airborne radioactivity sampling program which provides for collection of adequate sample volumes and analysis methodology to ensure compliance with 10 CFR 20.
The program should provide for meeting an appropriate alpha airborne radioactivity concentration lower limit of detection (LLD).
Incorporate appropriate dead-time correction factors for use when analyzing samples on the BC-4 and PC-5 gross beta/gamma counters.
Failure to correct for dead time will result in underestimation of total radioactivity presen e Additi.onal Item ~
The following licensee identified violation was reviewed with respect to the criteria contained in 10 CFR, Appendix C, "General Statement of Policy and Procedure for NRC Enforcement Actions."
At about 4:30 p.m.
on March 28, 1986, licensee radiation protection per-sonnel failed to perform adequate contamination surveys prior to lapping work on ¹15 recirculation discharge bypass valve (Drywell). As a result of this failure to survey, two workers lapping the valve generated airborne radioactivity of about 420 times the applicable concentration value speci-fied in 10 CFR 20 Appendix B.
This results in the protection factor (50)
of the full face particulate mask being exceeded.
This represents a
failure of the licensee to perform surveys required by
CFR 20.201 to comply with 10 CFR 20.103.
Inspector review indicated the licensee took appropriate action for non-issuance of a violation.
The following matter is unresolved (50-220/86-04-03):
~
verification of implementation of long term corrective actions.
These are:
establishment and implementation of criteria requiring decon-tamination and use of supplementary ventilation (fixed and removable contamination);
training of appropriate personnel in the long term corrective actions.
Note:
Inspector review of worker whole body count data indicated no measurable intake of radioactive material occurred.
8.
Radioactive and Contaminated Material Control General The control of radioactive and contaminated material was reviewed with respect to criteria contained in the following:
~
Technical Specifications;
~
CFR 20, "Standards for Protection Against Radiation";
~
RP-5, Radiation and Radioactive Contamination control".
The following matters were reviewed:
~
posting and labeling of radioactive and contaminated material;
~
surveys to 55 performed prior to removing items/material from the radiological controlled areas;
~
adequacy of instrumentation use to perform surveys of material removed from the radiological controlled area.
The evaluation of the licensee's performance in this area was based on:
~
observations by the inspector;
~
performance of independent radiation surveys by the inspector;
~
review of documentation; and
~
discussions with cognizant licensee personnel.
~Findin s
Within the scope of this review, no violations were identified.
However, the following matter needing licensee attention was identified:
(50-220/86-04-04).
~
Procedures provided insufficient guidance relative to performance of surveys of inaccessible surfaces of equipment to be removed from the radiological controlled area.
Training of personnel did not ensure this matter was appropriately addressed.
The licensee immediately issued a temporary instruction for surveys of inaccessible surfaces.
Appropriate personnel were trained in the instruction in a timely manner.
Licensee review and revision (as appropriate)
of applicable proce-dures will be reviewed during a subsequent inspection.
9.
Bulletins Circulars and Information Notices Unit 2 The Inspector reviewed the licensee's action (as appropriate)
and the status of a number of Bulletins and Circulars.
Information Notices were also discussed.
The evaluation of the licensee's performance in the area was based on discussions with personnel, review of licensee close-out packages, and review of applicable procedures'.1 Bulletins IE Bulletin 79-20,
"Packaging, Transport and Burial of Low-Level Radioactive Waste," August 10, 1979.
The information and guidance contained in the bulletin is provided in IE Bulletin 79-19.
This Bulletin is closed for administrative purpose.13 9.2 Cir cul ars 9.2. 1 IE Circular 77-14,
"Separation of Contaminated Water Systems from Noncontaminated Plant Systems" The licensee reviewed and evaluated the information contained in this circular.
The following matters needing licensee attention were identified:
~
Review all applicable plant operating procedures which would cause/or result in system cr'oss-contamination.
The licensee only reviewed liquid radwaste system operating procedures.
~
Review adequacy of administration controls for temporary hook-ups using hoses.
This circular remains open.
9.2.2 I.E. Circular 80-18,
"10 CFR 50.59 Safety Evaluations for Changes to Radioactive Waste Systems" The licensee reviewed and evaluated the information contained in the circular.
The following matter needing licensee attention was identified:
~
Procedures for review of modification do not provide sufficient guidance to ensure the criteria contained in this circular are addressed.
This circular remains open.
9'.3 I.E. Circular 81-09,
"Containment Effluent Water that Bypasses Radiation Monitor" The licensee reviewed and evaluated the information contained in this circular.
The following matter needing licensee attention was identified:
~
Verification that plant or system design changes performed after initial review of the circular have not resulted in changes to initial conclusions presented in the circular evaluations.
This circular remains open.
9.2.4 I.E. Circular 76-03, "Radiation Exposures in Reactor Cavities"
The li~nsee reviewed and evaluated the information contained in the circular.
The following matter needing licensee attention was identified:
~
Verify adequate administrative controls are in place to control access to transient and unusually high radiation areas.
This circular remains open.
9.2.5 I.E. Circular 81-07, "Control of Radioactively Contaminated Material" The licensee reviewed and evaluated the information contained in this circular.
The following matter needing licensee attention was identified:
~
establish guidance to ensure inaccessible surfaces of items/components are free of radioactive contamination prior to removal from the radiological controlled area.
Provide training as necessary.
This circular remains open.
9.3 Information Notices 9.3. 1 Information Notice 79-07,
"Rupture of Radioactive Waste Tanks" The licensee reviewed and evaluated the information contained in this notice.
The licensee addressed the specific concerns discussed in the notice.
~ This notice is closed.
9.3.2 Information Notice 83-09, "Safety and Security of Irradiators" The licensee. reviewed and evaluated the information contained in this notice.
The licensee addressed the specific concerns discussed in this notice.
This notice is closed.
9.3.3 Information Notice 83-14,
"Oewatered Spent Ion Exchange Resin Susceptibility to Exothermic Chemical Reactions" The licensee reviewed and evaluated the information contained in this notice.
The following matter needing clarification was identified:
~
The information notice discussed control of oxidizing agents.
The inspector was unable to identify any specific evaluation or control of oxidizing agents (as appropriate).
This notice is ope.3.4 Inform+ion Notice 83-05, "Obtaining approval for Oisposing of Very-Low-Level Radioactive Waste
CFR 20.302" The licensee reviewed and evaluated the information contained in this notice.
The licensee is aware of the provisions of
CFR 20.302 and would implement them if the need arises.
This information notice is closed.
9.4 Others (Radwaste Shipping-Unit 2)
The following Circular s and Information Notices dealt with establishment and implementation of a program for shipping radioactive material.
The licensee is currently establishing the Unit 2 program for radwaste shipping.
The licensee's program associated with these documents will be reviewed during a subsequent inspection (50-410/86-12-01):
~
Circular 78-03,
"Packaging Greater than Type A Quantities of Low Specific Activity Radioactive Material for Transport;"
~
Information Notice 79-21, "Transportation and Commercial Burial of Radioactive Materials;"
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"Low Level Waste Burial Criteria;"
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Information Notice 80-32 (and Revision 1), "Clarification of Certain Requirements for Exclusive Use Shipments of Radio-active Materials;"
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Information Notice 83-10, "Clarification of Several Aspects Relating to Use of NRC-certified Transport Packages;"
and
~
Information Notice 84-14, "Highlights of Recent Transport Regulatory Revisions by DOT and NRC."
10.
Exit Interview The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on March 28, 1986.
The inspectors summarized the purpose, scope and findings of the inspection.
At no time during the inspection was written material provided to the licensee by the inspector ss s;l I.
t