IR 05000220/1990025
| ML17056B157 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/26/1990 |
| From: | Dragoun T, Joseph Furia, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056B156 | List: |
| References | |
| 50-220-90-25, 50-410-90-24, NUDOCS 9012100292 | |
| Download: ML17056B157 (12) | |
Text
U. S. NUCLEARREGUL'ATORY COMMISSION
REGION I
50-220/90-25 Rp R
. ~cl-Pg 50-220 Docket Nos.
$~41 DPR-63 License Nos.
N~PF-4 Licensee:
ia ara M hawk P wer Erie ul vr W cu e New York 1 2 2 i n Facility Name:
Nin Mile P in ni
n
Inspection At: L c min New Y rk Inspection Conducted:
v m r 1-1
Inspectors:
J. Furia, Senior Radi
'on Specialist, Facilities Radiological Protection Section (FRPS), Facilities Radiological Safety and Safeguards Branch (FRSSB),
Division of Radiation Safety and Safeguards (DRSS)
~r~yz date T. Dragoun, Project Sc'tist, Effluents on Pro tion Section (ERPS), FRSSB, DRSS
~u date Approved by:
W. Pasciak, Chief, FRPS, FRSSB, DRSS li 2C da e
Inspection Summary:
Ins i n n N v m r 1-1
-22-2
-41-24 m in In i nRe R ',
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including:
management organization and controls, ALARA,plant outage operations and implementation of the above programs.
~Rail: Within the areas inspected, no violations or deviations were noted.
90i 2i 00292 902127 PDR ADOCK 05000220 G
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DETAILS 1.
Personnel Contacted 1.1 Licensee Personnel
'. Aiken, ALARASupervisor, Unit 2
- D. Barcomb, Health Physics Operations Supervisor, Unit 2 R. Cohen, Site Services Manager J. Conway, Technical Support Manager, Unit 2
- J. Firlit, Vice President - Nuclear Generation
- J. Gray, Acting 'Manager, Health Physics, Unit 1 T. Hogan, ALARASupervisor, Unit 1
- J. McAlpin, ALARASpecialist, Unit 1
- J. Pavel, Site Licensing A. Pinter, Site Licensing
- K. Rowe, ALARASpecialist, Unit 1
- P. Swafford, Manager, Health Physics, Unit 2
- W Thomson, Manager, Radiation Protection 1.2 NRC Personnel
- R. Laura, Resident Inspector R. Temps, Resident Inspector
- Denotes those present at the exit interview on November 16, 1990.
2.
Puruose The purpose of this routine inspection was to review the licensee's programs concerning ALARA,radiation protection during an outage, Radiation Work Permit development and implementation, and to review the licensee's significant changes in radiation protection management structure.
3.
Radiation Protection Pro ram 3.1 Mana ement Chan es Effective October 1, 1990, the licensee implemented a major company-wide reorganization that also changed the radiation protection program management structure.
Each unit now has a Manager, Health Physics, who directly reports to their respective Plant Manager.
Under each Health Physics Manager were supervisors for Health Physics Operations, Health Physics Support Services and ALARA. The Health Physics Support Services included programs for the calibration of both health
physics and plant effluent monitois.
Within the Site Support Services organization, there was now a Manager, Radiation Protection.
Under this position were supervisors for Radioactive Material Shipping, External Dosimetry, Respiratory Protection and Health Physics Services.
At the time of this inspection, the position of Manager, Health Physics at Unit 1 was Qlled by the Unit 1 Health Physics Operations Supervisor.
The licensee was actively recruiting to Qll this position. At Unit 2, many contractor personnel were being used in support of the refueling outage, however, all key positions were Qlled by licensee employees.
At the time of this inspection, the licensee had not revised its Administrative or Radiation Protection Procedures to reQect these management changes.
During this inspection, several discussions were held with various licensee personnel, including management, to decide whether the Manager, Health Physics for each unit or the Manager, Radiation Protection, under the Site Services Department, would be the Radiation Protection Manager for purposes of responsibility as outlined in the units'echnical SpeciQcatidns.
Based upon conversations with the licensee's Vice President - Nuclear Generation, it was determined that the Manager, Health Physics for each unit would assume the responsibilities of Radiation Protection Manager.
The inspectors had no further questions in this area.
3.2 ALARAPro ram Previously there was a site ~M group that serviced both plants.
The reorganization established separate ALARAgroups in each plant's Health Physics Department, At Unit 2, the position of ALARASupervisor was temporarily Qlled by the~~ Specialist.
In addition, the licensee was using the services of six contractor ALARASpecialists and two ALARA technicians to support the refueling outage.
The designated Unit 2 ALARASupervisor was temporarily tasked over to the Unit 2 Health Physics Operations Section to support outage activities as a Health Physics Chief.
In August, 1989, the licensee developed an ~6M goal for the refueling outage of 150 Man-rem.
As of this inspection, the licensee's outage dose was 300 Man-rem, with approximately two more months to go in the outage.
Projections made by the licensee indicated that the Qnal dose for the outage would be approximately 360 Man-rem.
The licensee indicated that the principle causes for significantly exceeding the projected dose were higher than anticipated 'effective'ose rates in the drywell, and work beyond the originally anticipated scope.
The licensee's August, 1989 dose projections were based on a drywell 'effective'ose rate of approximately 2.6 millirem per hour.
This figure was based upon doses received during a mini-outage in early 1988. After the goal projection, in September,
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1989 the licensee had another mini-outage, in which the 'effective'ose rates in the drywell were found to have increased to approximately 9 millirem/hr. Some of this increase was attributed to a change in work to include 'hotter'quipment.
In April, 1990, the ALARASupervisor, in an internal memorandum, recalculated the expected dose projection at approximately 290 Man-rem.
Review of the licensee's ALARAprogram in preparation for the current outage at Unit-2 showed that there have been significant communications problems between the plant outage planning and system engineering groups with the ALARASection.
One notable exception was the Recirc Pump StufGng Box modiGcation that was very well planned and executed.
However, review of several Radiation Work Permits used during the outage showed that most had to be modiGed, in one case 12 times, to accommodate changes of work scope.
Additionally, it was determined that the ALARASection was not advised of some radiologically signiGcant outage work until informally notiGe'd by representatives of the corporate health physics department. The licensee's decision to initiate a complete reorganization of the company at the beginning of the outage also had a negative impact on coordination.
The inspectors concluded that the poor coordination and cooperation prior to the outage could be attributed to a lack of emphasis by upper management on ALARA. Although corporate policy NDMP-10 "ALARA Program" was issued in December 1989 and supervisors performance is evaluated in this area, there appears to be a lack of aggressiveness in achieving ALARA. Most personnel interviewed were unaware of the corporate policy. The Vice President - Nuclear Generation stated that this matter will be discussed with the executive staff and appropriate action willbe taken.
This matter will be reviewed in a future inspection (50-220/90-25-01 and 50-410/90-24-01).
The ALARAstaff at Unit 1,which was not as impacted by the reorganization,has shown excellent progress and initiative in planning for the March 1991 mini-outage.
Most surveillance work has been identiGed.
Work packages are assembled that include isometric drawing locations for the equipment, component identiGcation numbers, PAID diagrams, isolation tag out locations, expected radiological conditions and a summary of the equipment problem history.
The ALARAstaff is negotiating to modify the Planning Department's computer software to link work requests to speciGc RWPs.
The effectiveness of these efforts willhinge on the support and cooperation received from other departments as discussed abov '
Other initiatives at Unit 1 include the purchase of a Control Rod Drive handling system and a hot spot reduction program.
The ALARAgroup was among the first to join the ALARACenter for Exposure at Brookhaven National Laboratory to share exposure reduction techniques.
'ith other utilities worldwide. The group is attempting to assemble records for all high dose jobs performed during the many previous outages to determine the lessons learned.
The licensee was commended for fhese efforts.
3.3 Radiation Work Permits The licensee prepares and issues Radiation Work Permits (RWP),
generally on a daily basis, in accordance with plant Administrative Procedure 3.3.2, Rev 0, "Radiation Work Permit". As part of this
- inspection, 14 RWPs utilized at Unit-2 were reviewed.
As was noted in Paragraph 3.2 above, several of the RWPs associated with outage work had been modified on several occasions due to changing scope of work.
Some of these changes were requested only hours before the revised RWP was needed, giving the licensee's Health Physics staf'f little time for review.
RWPs can be modified due to changing plant conditions without issuing a new RWP.
Health Physics Chiefs assigned to certain plant areas can authorize these pen and ink changes, with the Health Physics Technicians tasked with advising the radiation workers of the changes.
During the inspection, the inspectors observed plant personnel entering contaminated areas and conducting work both in the drywell and refueling Qoor at Unit-2., All entries were made in accordance with properly written and approved RWPs, and plant personnel were observed wearing the appropriate protective clothing and dosimetry devices as set forth in the RWPs.
The inspectors had no further questions in this area.
3.4 Alle ation Fo]low-U On November 5, 1990, licensee management contacted the NRC to indicate that they understood that an allegation was being sent to the NRC concerning changing the 'deltas'or some contractor employees.
Deltas are a measure of the available occupational dose remaining within a calendar quarter for a given radiation worker. In accordance with plant Administrative Procedure 3.3, Rev 0, "Radiation Protection Program", the delta value for each radiation worker was normally set at 1000 millirem at the beginning of each calendar quarter.
On November 6, 1990, an allegation (0 RI-90-A-0203) was received by one of the Resident Inspectors on the subjects of changing deltas and physical examinations before being exposed to ionizing radiation.
The second concern, regarding physical examinations,.was apparently based on a New York State
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regulation, and thus was outside the scope of this review. With regard to the changing of radiation worker deltas, Administrative Procedure 3.3 contains procedures for administratively enlarging a worker's delta to 1500 millirem per calendar quarter.
Title 10, Code of Federal Regulations, Part 20.101(b) limits the exposure of radiation workers to 3000 millirem per calendar quarter provided that a completed NRC Form 4 has been completed for the worker.
Review of the records of five contractor employees whose deltas were extended to 1500 millirem per quarter demonstrated that the licensee'correctly followed its own procedure, that the requests for delta extension were signed by the effected employees, reviewed by licensee Health Physics supervisory personnel, and that a completed NRC Form 4 was on file for each effected employee.
The inspector had no f'urther questions in this area.
Exit Interview The inspectors met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on November 16, 1990.
The inspectors summarized the purpose, scope and findings of the inspectio ~
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