IR 05000220/1990014
| ML17056A779 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/16/1990 |
| From: | Dragoun T, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056A778 | List: |
| References | |
| 50-220-90-14, 50-410-90-15, NUDOCS 9004250199 | |
| Download: ML17056A779 (14) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-220 90-14 and 50-410 90-15 Docket Nos.
50-220 and 50-410 License Nos.
Nia ara Mohawk Power Cor oration 300 Erie Boulevard West S racuse New York 13202 Category C
Facility Name: Nine Mile Points Units 1 and
Inspection At: Oswe o
New York Inspection Conducted:
March 19-23 1990 Inspector:
T. Dr o
, Senior Radiation Specialist ate o Approved by:
W. Pasciak, Chief, Facilities Radiation Protection Section
~//I/qy date Ins ection Summar
- Ins ection conducted on March 19-23 1990 Combined Ins ection Re ort Nos.
50-220 90-14 and 50-410-90-15 Areas Ins ected:
Routine unannounced inspection of radiological controls programs including audits, radiological event reporting, ALARA, RP Technician continuing training, control of locked high radiation areas, and elements of the respiratory protection program.
Results:
No violations were identifie DETAILS 1.0 Persons Contacted 1.1 Licensee Personnel R. Abbott, Station Superintendent, Unit 2 P. Volza, Radiation Protec'tion Manager E. Gordon, Supervisor, Radiological Support R. Randall, Operations Supervisor, Unit 1 B. Weaver, Assistant Superintendent-Training J. Gray, Unit 1 RP Supervisor D. Barcomb, Unit 2 RP Supervisor R. Carlson, Rad Support D. Stein, Regulatory Compliance Department W. Connolly, QA R. Byrnes, Employee Relations W. Allen, MATS 1.2 NRC Personnel W. Cook, Senior Resident Inspector
'2.0 Puruose The purpose of this routine radiation safety inspection was to review the following program elements:
Auditing and Radiological Event Reporting ALARA Radiation Protection (RP) Technician Continuing Training Control of Locked High Radiation Areas Respiratory Protection 3.0 Auditin and Radiolo ical Event Re ortin The licensee's program for auditing and event reporting by RP Technicians and first line supervisors was reviewed with respect to the criteria contained in:
10 CFR 50 Appendix B - Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plant CFR 2 Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions.
10 CFR 20 - Standards for Protection Against Radiation.
ANSI-N18.7-1972, "Administrative Controls for Nuclear Power Plants".
Unit 1 Technical Specification 6.8.1 - Procedures.
NUREG-0761, "Radiation Protection Plans for Nuclear Power Reactor Licensees" (Draft),
Station Procedures S-RPIP-9.1 through 9.5.
Performance was determined from a review of selected records and interviews with selected personnel.
Within the scope of this review no violations were identified.
The current program, consisting of scheduled plant tours by line supervisors along with a structured Radiological Occurrence Reporting (ROR) system, was implemented in mid-December 1989.
Records indicate that the tours were conducted as scheduled and appropriate findings recorded.
The sources of most RORs are the RP Technicians who provide verbal input to the Unit Supervisors who generate the RORs.
For the first 3 months of this year there were only 15 RORs recorded on Unit 1 and 6 on Unit 2. Of these, many were determined to be invalid. This is attributed to the newness of the system.
Analysis of plant tour findings and ROR reports is done by technical assistants using the root cause and human factors analysis techniques that are in widespread use by all site departments.
This approach is the currently accepted method to identify programmatic weaknesses.
The inspector concluded that the scope of the line supervisor audits and the analysis of findings constitutes a
licensee strength.
However, the system is still new and untried and may be emphasizing the need for documentation at the expense of corrective action effort. This matter will be reviewed in a future inspectio.0 As Low As Reasonabl Achievable ALARA The licensee's ALARAprogram was reviewed with respect to criteria in Regulatory Guides 8.8 and 8.10 and 10 CFR 20.1(c) - Purpose.
Performance was determined from interviews with selected personnel, a review of selected documents, and a tour of Unit 2. Within the scope of this review no violations were observed.
The inspector discussed the preparations for the first Unit 2 refueling outage with the site ALAI'upervisor. The poor layout of the equipment likely'to become increasingly contaminated such as the Hydraulic Control Unit (HCU),
Residual Heat Removal (RHR), High Pressure Coolant Injection (HPCI), and Low Pressure Coolant Injection (LPCI) systems will present challenges during outage work. The licensee has identified the potential trouble spots and is developing mitigation plans to deal with the radiological conditions.
In addition, during the January 1990 short Feedwater Outage, ALARApersonnel toured the Unit 2 drywell, identified hot spots in the vicinity of upcoming outage work, and initiated shielding packages to obtain engineering preapproval of equipment stresses to be caused by temporary lead shielding installed during the outage.
All outage jobs identified to date have been placed on a planning spreadsheet to track completion of preparations.
This preplanning constitutes a licensee strength.
The licensee introduced a Nuclear Division ALARAgoal for the first time in 1990. At'506 man-rem total, the goal is realistic considering the outage planned for Unit 2.
By issuing a Division goal, the corporate management commitment to ALARAis visible and support by corporate groups such as engineering is facilitated.
The ALARAgroup issued a post outage report that "analyzed ALARA performance during the Unit 2 Feedwater Outage.
Specific recommendations were provided to management based on the lessons learned.
The ALARA supervisor stated that an analysis will be done after each future outage.
The inspector noted that this was an excellent initiative.
Based on a,comparison with previous performance, the inspector concluded that the licensee's ALARAprogram is improving.
5.0 RP Tech Continuin Trainin The licensee's program that provides continuing training to RP Technicians was reviewed with respect to criteria in Technical Specification 6.4, ANSI 18.1-1971
and ANSI 3.1-1978, Performance was determined from:
Discussions with the Assistant Superintendent of Training, Chemistry/RP Training Supervisor (Acting), a senior instructor, Manager of Radiation Protection, and the Supervisor Radiological Support.
A tour of training facilities.
A review of selected Job Performance Measures (JPM) and Job Task Analyses (JTA) used to develop training material including the schedule for completion of these efforts.
Observation of a technician training class conducted by a Subject Matter Expert (SME).
Within the scope of this review no violations were observed.
Licensee strengths and weaknesses were noted as follows:
There is close cooperation between the site RP supervisors and the Training Department in assuring a high quality Continuing Training program.
Subject matter is selected by joint efforts.
The site provides SME personnel as instructors to provide detailed presentations in their area of expertise to support continuing training.
The SME session observed by the inspector was found to be excellent.
All 'routine'esson plans are being rewritten to incorporate the latest JTA and JPM approaches used in the nuclear industry.
Feedback from the JTA and JPM is also used to improve the site's radiation protection procedures.
Completion of this rewrite is scheduled for year-end 1990.
These elements of the licensee's program constitute a notable programmatic strength.
The inspector noted that there is currently only one permanent RP instructor and one vacancy with the Supervisor unavailable due to extended illness.
There are approximately 6 contracted instructors providing the bulk of the training.
The inspector stated that the small size of the permanent staff may lead to program weaknesses.
The licensee acknowledged this Qnding.
6.0 Control of Locked Hi h Radiation Areas The licensee was issued a Notice of Violation during Specialist Inspection 50-220/89-03 for failure to properly lock a high radiation area.
The licensee's corrective action was described in a reply dated March 6, 1989 (NMPIL @0366).
A second Notice of Violation was issued in Resident Inspector Report 50-220/89-06 for multiple reoccurrences of unlocked areas in February through June 198 The licensee responded on September 18, 1989.
The inspector reviewed the licensee's corrective actions by interviewing selected personnel and by a tour of selected locked areas.
Control of locked areas now relies primarily on double veriQcation in accordance with OfQce Instruction 412. A sign-out sheet is maintained at each door. After an entry, two personnel must certify that the door has been relocked.
Since this system was implemented there have been no reported problems.
Additional measures include increased surveillance by RP technicians and installation of door alarms.
Approximately 50% of Unit 2 high radiation area doors have been alarmed.
The licensee indicated that additional installation of alarms will depend on the effectiveness of the administrative controls.
The inspector concluded that the licensee's corrective action in this matter is satisfactory.
7.0 Res irato Protection Pro rams Selected aspects of the licensee's respiratory protection programs were reviewed with respect to requirements in 10 CFR 20.103 - Exposure of individuals to concentrations of radioactive materials in air in restricted areas.
Areas reviewed included worker training, medical evaluation prior to respirator use, and Whole Body Counting procedures.
Performance was determined from observation of a training class, personnel interviews, and a tour of medical facilities. Within the scope of this review, no violations were observed.
Weaknesses were noted as follows:
The lesson plan for training the workers was exceptionally long and cumbersome.
In addition, not all instructors had completed a commercial respirator training class.
The training supervisor stated that the lesson plan was already identiQed as one to be streamlined and that all instructors will receive the commercial training.
Physical evaluation of most respirator users on site, including the entire permanent RP staff, is done by contractors.
The site is notified of the results but all records are maintained elsewhere.
This creates a problem in that reports of contraindication for respirator use cannot be followed up by the site. Similarly, there is no mechanism to handle transient medical conditions such as a cold or flu that make respirator use temporarily inadvisable.
The inspector noted that there is a well equipped inQrmary located at Unit 2 which provides medical evaluations for reactor operators and QreQghters only but could be used to serve the sites needs.
The inspector also noted that medical records maintained for various reasons, such as fitness-for-duty, could be consolidated.
The licensee stated that these matters would be reviewe.0 Exit Interview The inspector met with the personnel denoted in section 1 at the conclusion of this inspection on March 23,1990.
The scope and Gndings of the inspection were presented at that time.