IR 05000220/1986025
| ML18038A235 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/24/1986 |
| From: | Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18038A234 | List: |
| References | |
| 50-220-86-25, 50-410-86-63, IEB-80-10, IEC-76-03, IEC-76-3, IEC-77-14, IEC-80-14, IEC-80-18, IEC-81-07, IEC-81-7, IEIN-81-26, IEIN-82-43, IEIN-83-14, NUDOCS 8701070393 | |
| Download: ML18038A235 (22) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-220/86-25 50-410/86-63 Docket Nos.
50-220 50-410 License Nos.
DPR-63 CPPR-112 Pri ority Category C
B Licensee:
Nia ara Mohawk Power Cor oration 300 Erie Boulevard West S racuse New York 13202 Facility Name:
Nine Mile Point Unit 152 Inspection At:
Oswe o
New York Inspection Conducted:
November 17-21 1986 Inspectors:
L.
" l.
R.L. Nimitz, Senior Ra iation Specialist Approved by:
M.M. Shanbaky, Chief Facilities Radiation Protection Section date date Ins ection Summar:
Inspection on November 17-21, 1986.
(Combined Inspection Report Nos. 50-220/86-25; 50-410/86-63).
R~ld:
R l, d
controls including:
action on previous findings at Unit 1 and Unit 2; action on bulletins and circulars and preoprerational testing at Unit 2; and imple-mentation of corrective action for an off-scale dosimeter incident at Unit 1.
Results:
No violations were identified 8701070393 861229 PDR
- DOCK 05000220
DETAILS 1.
Persons Contacted l.l
~tli
- T. Perkins, General Superintendent
"T. Roman, Station Superintendent, Unit
"R. Abbott, Station Superintendent, Unit P
"E. Leach, Superintendent, Chemistry/Radiation Protection Manager
"J. Duell, Supervisor, Chemistry and Radiation Protection
"P. Volza, Supervisor, Radiological Suffert 1.2 USNRC
"C. Marschall, Resident Inspector
- Iti. Cook, Senior Resident Inspection
'" Denotes those individual who attended the exit meeting on November 21, 1986.
The inspector also contacted other licensee personnel.
2. 0
~Pur o ee The purpose of the routine inspection was to review the following matters.
Unit
Licensee Action on Previous Findings Establishment and implementation of corrective action for an April 29, 1986 off-scale dosimeter event
'rganization and.staffing Unit 2
'icensee Action on previous findings
'icensee action on bulletins, circulars and information notices
'reoperational testing 3.
Licensee Action on Previous Findin s
3. 1 (Closed)
Follow-up Item (50-220/84-03-03)
Licensee to provide training records of personnel involved with fuel rack installation activities.
The inspector reviewed the records during inspection No. 50-220/84-05.
No unacceptable conditions were identified.
This matter is close.2 (Cl osed)
Fol low-up Item (50-220/83-27-02)
Licensee to establish appropriate management controls to ensure only those technicians who meet qualification requirements of Technical Specification 6.3 act in responsible positions.
The licensee estab-lished procedure No. CI-3/RPI-4, Management Control for ANSI qual-ification of Technicians.
This matter is closed.
3.3 3.4 (Closed)
Follow-up Item (50-220/83-27-03)~
Licensee to establish administrative controls for Radwaste Operator Training.
The licensee established procedure NTP-13, Training and Continuing Training for Radwaste Operators.
This matter is closed.
(Closed)
Follow-up Item (50-220/85-11-01)
Licensee to establish methodology to ensure radiation protection personnel understand radioactive waste handling responsibilities.
The licensee established specific qualification methodology to ensure personnel are aware of their responsibilities.
This matter is closed.
3.5 (Closed)
Unresolved Item (50-220/83-27-06)
3.6 Licensee to implement corrective action for operations personnel violation of radiation work permits associated with Control Rod Blade handling work.
The licensee issued a Radiological Occurrence Report for the event, disciplined the involved individuals and notified all operations personnel of the need to adhere to radiation work permit requirements.
This. matter is closed.
(Closed)
Follow-up Item (50-220/86-04-01)
Licensee to complete the review of the adequacy of the new whole body badge of record, evaluate the acceptability of taping over the whole body badge when working in contaminated areas, and evaluate the adequacy of dosimetry placement for workers replacing condenser tubes.
The licensee evaluated the new badge and determined it was unacceptable for use at Nine Mile Station.
The licensee has selected another whole body badge vendor.
The licensee considers the new vendor's TLD badge acce'ptable for use.
The licensee evaluated the acceptability of taping over badges and subsequently placed restrictions on use of tape for this purpose in appropriate procedures.
The licensee evaluated the-dosimetry placement of workers removing condenser tubes, and determined it to be acceptable.
This matter is closed.
3.7 (Closed)
Follow-up Item (50-220/86-04-02)
Licensee to:
establish methodology for collection of airborne radioactivity samples in dusty environments, modify alpha airborne
radioactivity analysis procedures to ensure detection of activity above a specified Lower Limit of Detection (LLO) and incorporate dead-time correction factors into procedures for use of GM tubes to count samples.
The licensee:
established a methodology for collection of airborne radioactivity samples in dusty environments, modified appropriate p> ocedures to ensure meeting a specified LLD when counting air samples for airborne radioactivity, and modified appropriate procedures to incorporate dead-time correction factors when using GM tubes for sample counting.
This item is closed.
3.8 (Closed)
Follow-up Item (50-220/80-11-29)
Licensee to upgrade controls to ensure personnel perform adequate personnel monitoring prior to leaving the restricted areas.
This matter was reviewed during Inspection 50-220/86-06.
Licensee corrective action was considered acceptable.
This matter is closed.
4.
Or anization and Staffin The inspector reviewed the Radiological Controls organization and staff-ing with respect to the criteria contained in Unit 1 and Unit 2 Technical Specifications.
Within the scope of this review, the following was identified:
The Radiological Controls Organization depicted in the Technical Specifications is not consistent with the in-place organization.
The current Unit 1 Technical Specifications do not require that the Radiation Protection Manager (or equivalent title) be Regulatory Guide 1.8 qualified.
Unit 2 Technical Specifications do require such qualifications.
Licensee personnel indicated the above matters would be reviewed and appropriate action taken to update the Technical Specifications.
5.
Bulletins Circulars and Information Notices Un'it 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 this area was based on discussions with personnel, review of licensee close-out packages, and review of applicable procedures.
5. 1 Bulletins IE Bulletin 80-10,
"Contamination of Nonradioactive System and Resulting Potential for Unmonitered, Uncontrolled Release of Radio-activity to the Environment"
The licensee has revised and drafted several procedures to address the bulletin requirements.
Procedures are in draft.
This bulletin remains open.
5.2 Circulars 5.2.1 IE Circular 77-14, "Separation of Contaminated Water Systems from Noncontaminated Pl~ant Systems" The licensee reviewed and evaluated the information con-tained in this circular.
The following matters needing licensee atten'tion were identified:
Review all applicable plant operating procedures which would cause or result in system cross-contamination.
The licensee only reviewed liquid radwaste system operating procedures.
Review adequacy of administrative controls for temp-orary hook-up of hoses.
~Findin s
The licensee reviewed plant operating procedures for other liquid systems identified as having the potential to become cross contaminated through use of less than adequate procedures.
Procedures were found acceptable.
The licensee included, in appropriate procedures, controls for temporary hook-ups using hoses.
Procedures require safety evaluations for temporary hook ups.
This circular is closed.
5.2.2 I.E. Circular 80-18,
"10 CFR 50.59 Safety Evaluations for Changes to Radioactive Waste Systems" The licensee reviewed and evaluated the information con-tained in the circular.
The following matters needing licensee attention were identified:
Procedures for review of modifications do not provide sufficient guidance to ensure-the criteria contained in this circular are addressed.
~Findin s
Licensee procedure PG-201,
"Safety Evaluation NMP2 Mod-ifications", references IE Circular 80-18 as review cri-teria.
Station AP 6. 1, "Procedure for Modification and Additions Unit 2," requires safety evaluations for all
modifications to be performed per NT 1008, "Preparation and Control of Safety Evaluations".
The NT also references IE Circular 80-18 as review criteria.
This Circular is closed.
5.2.3 I.E. Circular 76-03, "Radiation Exposures In Reactor Cavities" The licensee reviewed and evaluated the information con-tained 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.
Findin<is The licensee revised procedure S-RP-1,
"Access and Radio-logical Control", to provide guidance for control of access to upper levels of the drywell during irradiated fuel movement.
Procedure N2-FHP-12,
"Fuel Handling," requires operations personnel to notify radiation protection personnel prior to irradiated component movement.
Procedures are in-place to control access to other transient and unusually high radiation areas.
Entry into such areas is to be made only with Radiation Protection Supervision approval when dose rates are in excess of 2500 mrem/hour.
Supervisory rev'iew of personnel entries into transient areas with dose rates less than 2500 mrem/hr but'hich have the potential to be much higher is not adequately described.
5.2.4 This circular remains open.
I.E. Circular 81-07, "Control of Radioactively Contaminated Material" The licensee reviewed and evaluated the information con-tained 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 necessar ~Findin The licensee revised Procedures S-RP-3,
"Performance of Radiological Surveys",
to include precaution statements regarding surveys of inaccessible areas.
Appropriate personnel wei.e trained in the procedure revision.
The following matter is considered open:
5.2.5 guidance for determination of fixed alpha contamin-ation is not contained in applicable procedures.
IE Circular No. 80-14, "Radioactive Contamination of Plant Demineralized Water System and Resultant Internal Contamination of Personnel",
dated June 24, 1980.
This circular described problems associated with personnel use of demineralized water as a potable water source.
~Findin s
The licensee established and implemented procedure N2-0P-16,
"Make-up Water Storage and Transfer".
This procedure provides specific control for temporary hose connections.
The licensee also verified that the deminer-alized water supplies are protected from interacting with normally radioactive water sources by check valves.
The General Employee Training Program and station posting instruct workers against eating, drinking, or smoking in permanent station structures.
This circular is closed.
5.3 Information Notice 5.3.1 Information Notice 83-14,
"Dewatered Spent Ion Exchange Resin Susceptibility to Exothermic Chemical Reactions" The licensee reviewed and evaluated the information con-tained 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).
~Findkn s
The licensee revised procedures AP 7. 1, "Control of Organic Materials," to provide for control of oxidizing agents.
This Information Notice is closed.
Information Notice No. 82-43, "Deficiencies in LWR Air Filtration Ventilation Systems,f'ated November 10, 1982.
This information notice describes
.some unplanned releases resulting from inadequate maintenance and surveillance of non-safety related ventilation systems.
~Findin s
The licensee established a procedure for maintenance of safety and'non-safety related ventilation systems.
The procedure describes the surveillance program for all safety and non-safety related ventilation systems.
This notice is closed.
This notice contains 5 parts including revisions.
The five parts are discussed below:
Part 1:
Use of Recirculatory Mode (Closed-Circuit) Self-contained Breathing Apparatus (Rebreathers)
~Findin s
The licensee is aware of this part.
The licensee does not possess the device and is not contemplating its use.
This part is closed.
Part 2:
Use of the Chemical
"DOP"
~Findin s
The licensee is aware of this part.
DOP is not used for respirator fit testing.
It is used for checking the respirator fit on a mannequin and filter testing under controlled conditions.
This part is closed.
Part 3:
Placement of Personnel Monitory Devices for External Exposure
~Findin s:
The licensee is aware of this part.
Applicable procedures are provided for placement of dosimetry for unusual exposure situations.
This part closed.
Part 3:
Supplement
This supplement provided further guidance for placement of dosimetry and discussed meaning of "whole body" and "skin of whole body".
The licensee is aware of the supplement.
Procedures implement guidance in the supplement.
This part closed.
Part 4:
Personnel Entry into Inerted Containment
~Findin s
The. licensee established and,implemented a special procedure for Initial Drywell Entry.
The procedure addresses the concerns raised in this part.
This part is closed'art 5:
Evaluation of Instrument Characteristics When Using Portable Radiation Survey Instruments
~Findin s
The licensee included in procedures precautions regarding potential portable survey instrument concerns (e.g.
geotropism).
This item is closed.
6.
Audits and Assessments The inspector reviewed the adequacy, implementation and effectiveness of selected audits, surveillances, and assessments of the Radiological Controls Program.
Audits, surveillances and assessments for the period 1984 and 1985 by the following groups were reviewed:
Safety Review and Audit Board (SRAB) Audits Corporate Health Physics Group Assessments Corporate equality Assurance Group Audits On-site guality Assurance Group Survei llances
The review was with respect to criteria contained in:
Technical Specifications 6', "Review and Audit" Corporate Procedure HP-05, "External Inspection and Corporate Audit Tracking System" Corporate Health Physics Group Charter, dated April 22, 1985
~Findin n
I Within the scope of the review, no violations were identified'owever, the following items for improvement were identified.
The audits of the implementationof radiological controls for on-going work were considered minimally acceptable.
No significant review of the implementation of these controls for on-going work was performed.
Licensee QA personnel indicated more aggressive reviews of the implementation of radiological controls for on-going work would be performed.
The assessments of site radiological controls activities by the Corporate Health Physics group were considered of limited effective-ness.
No apparent reviews of on going work activities in contamin-ated areas was performed.
Licensee Corporate Health Physics personnel indicated this matter would be reviewed.
The inspector indicated the effectiveness of audits and assessments would be review during subsequent inspections.
7.
Review of Correction Action for Off-scale Dosimetr Incident The inspector reviewed the licensee evaluation and correction actions associated with an off-scale dosimetry incident which was discussed in Combined Inspection Report Nos. 50-220/80-16; 50-410/86-46.
Within the scope of the review, the following matters were brought to the licensee's attention as needing additional review and/or clarification.
The licensee has inplace a procedure which provides guidance for review of minor and major radiological concerns/incident.
However, the procedure does not clearly distinguish between a "minor" and
"major" radiological concern/incident.
-Consequently major concerns may be and have been previously classified as a "minor" concern and did not receive adequate management review.
The licensee initiated action to provide clear guidance to distinguish a major radiological concern/incident from a minor concer An effective program to trend radiological concerns/incidents as a
performance indicator and to provide data to assistin root cause analysis was not inplace.
The licensee indicated this matter would be reviewed.
Procedures do not provide guidance to ensure personnel are questioned when requesting additional dosimetry to ensure the requests are valid.
The licensee indicatpd this matter would be reviewed.
8.
Exit Interview The inspectors met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on November 21, 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 inspectors.