IR 05000220/1993024

Insp Repts 50-220/93-24 & 50-410/93-23 on 931018-22.No Violations Noted.Major Areas Inspected:Exams of Procedures, Representative Records,Interviews W/Personnel & Observations by Inspectors

ML20059F780
Person / Time
Site:	Nine Mile Point
Issue date:	10/27/1993
From:	Bores R, Joseph Furia NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20059F767	List: IR 05000220/1993024 ML20059F765
References
50-220-93-24, 50-410-93-23, NUDOCS 9311050079
Download: ML20059F780 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-220/93-24 Report No /93-23

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50-220 Docket No DPR-63 License No NPF-54 Licensee: Niagara Mohawk Power Corporation j 300 Eric Boulevard West '

Syracuse. New York 13202 Facility Name: Nine Mile Point Units 1 and 2 -

Inspection At: Lycoming. New York Inspection Conducted: October 18-22. 1993 Inspectors: ?Y /4/2M/3 J. Fu'ria, Senior Radiation Specialist, ' date Facilities Radiation Protection Section (FRPS),

Facilities Radiological Safety and Safeguards Branch (FRSSB), Division of Radiation Safety and Safeguards (DRSS)

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Approved by: R L h3LM lo]27\ct3 R. Bores, Chief, FRPS" FRSSB, DRSS date Areas Inspected: Areas inspected include your programs for radiation protection of workers during refueling operations. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspecto l Results: The results of the inspection indicate that the control of work during the Unit 2 refueling outage was generally good, occupational exposure of personnel was maintained As Low As Reasonably Achievable (ALARA), and oversight of radiological work activities by radiation protection supervisors was very goo .

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9311050079 931029-PDR ADOCK 05000220 G PDR s

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DETAILS Personnel Contacted Licensee Personnel

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• K. Ball, Radiation Protection Technician, Unit 1

• D. Barcomb, Radiological Operations Supervisor, Unit 2

• C. Beckham, Manager, Quality Assurance

• R. Cole, General Supervisor - Radwaste, Unit 2

• K. Dahlberg, Plant Manager, Unit 1

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• P. Dunn, Radiation Protection Supervisor, Unit 2 T. Hogan, Supervisor - ALARA and Radiological Engineering, Unit 1

• M. McCormick, General Manager, Safety Assessment, Licensing & Training

• J. Mueller, Plant Manager, Unit 2

• J. Pavel, Site Licensing

• K. Rowe, ALARA Supervisor, Unit 2

• P. Smalley, Radiation Protection Manager, Unit 1

• N. Spagnoletti, Executive Vice President's Assistant

• B. Sylvia, Executive Vice President J. Torbitt, General Supervisor - Radwaste, Unit 1

• A Zallnick, Supervisor Site Licensing

, NRC Personnel

• W. Mattingly, Resident Inspector '

B. Norris, Senior Resident Inspector R. Plasse, Resident Inspector -

• Denotes those present at the exit interview on October 22,199 .0 Previously Identified items >

(Closed) Violation (50-220/92-05-01; 50-410/92-05-01) Improper High Radiation Area entries. All long term corrective actions, including procedure changes and training have been completed. No further examples of this type of problem have subsequently occurred. This item is close (Closed) Unresolved (50-220/92-08-01; 50-410/92-09-01) Dosimetry records. The licensee has completed reviews of approximately 53% of the active records, with no discrepancies identified with an issue of safety significance. The licensee will continue to report on its review progress every three month ;

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(Closed) Violation (50-410/92-19-01) Failure to follow RWP. The licensee's long-term corrective actions, including the establishment of a new radiation protection access point on the refueling floor have been completed. This item is close .0 Unit 2 - Refueline Outage <

Since the last inspection in this area, the licensee's Unit-2 Radiation Protection Manager, left the position to become Maintenance Manager. The licensee named M '

David Barcomb to serve as Radiation Protection Manager. An analysis of the qualifications of this individual to serve as Radiation Protection Manager was undertaken by the licensee, and the results of that analysis were reviewed by the ,

inspector. The individual selected by the licensee was required to meet or exceed the

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qualification criteria specified in NRC Regulatory Guide 1.8 (September 1975) and American National Standards Institute (ANSI) standard N18.1-1975, in accordance with Plant Technical Specifications. The individual selected by the licensee was determined to meet or exceed all requirements for the positio .1 Access Control

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Approximately two months prior to the start of the third refueling outage (RF03), the licensee opened an Access Control Building. The new access point provides a single point of access to the Radiologically Controlled Area and houses all of the Radiation Protection staff. This single story structure is located adjacent to the southeast corner of the Reactor Building, and includes a large area for signing in on Radiation Work Permits, conference rooms for conducting briefings, office space for the Radiation Protection staff, and the portal monitors and decontamination facilities needed for appropriate access control. Two drawbacks with this facility included ru direct covered access to the Turbine Building and the need to go through six airlock doors (3 sets) in order to access the Reactor Buildin ,

, ALABA Prior to the Mart af RF03, the licensee established a goal of not more than 285

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person-rem , ccupational exposure dese for the outage. This compares favorably u M, which was completed with a total exposure of 275 person-rem. d c ansiderably lower than RF01, which had a total dose of 449 person-rem. 1; critical item necessary for meeting this goal, according to the licensee, s.as keeping the outage on schedule for 60 days or les After the first seven days of the outage, the exposure goal was reduced to 270 person-rem, due to the removal of some 12 person-rem of contingency dose built in to the original goal, but determined to be unnecessary, and the highly successful defueling operation, which was completed for approximately 4 l

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person-rem less than the cage goal. The contingency dose was in-place in anticipation of major work in the drywell that upon entry was determined not 1 to be needed. The reactor disassembly was carried out by a contractor l (General Electric). The contractor had financial incentives built into its l

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contract involving exposure, contamination occurrences and NRC violation This same contractor, according to the licensee, will also be responsible for I reactor reassembly later in the outag .

ALARA initiatives to reduce occupational exposure during the outage -

included: temporary shielding installations; hot spot and system flushes;

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nozzle hydrowashes; and area decontaminations. The most significant challenge to the licensee, as has been the case during the first two refueling outages, has been the drywell design. Most areas of the drywell are very cramped, requiring workers to be extremely conscious of area and hot spot dose rates, and necessitating careful pre-job planning to minimize exposure.

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During this inspection, two important licensee initiatives in the drywell were evident, the limiting of the number of personnel entering the area, and the :

increased visibility of management in perf wing job oversight, as evidenced by the increased presence of Radiation Protection supervision and ALARA :

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personnel at the drywell entrance and inside the drywel A significant accomplishment during the early part of the outage was the removal of the Intermediate Range Monitors (IRMs) from undervessel. Based upon past industry experiences, the licensee had in place contingency plans in the event that any one IRM had dose rates higher than 50 Roentgen per hour (R/hr). Expectations were that the detectors and a few feet of each detector's cable might be several R/hr, but that in general dose rates would be relatively Icw as all detectors had been out of the core for greater than 300 day During the Ahdrawal of IRM "E", dose rates of 200 R/hr were detecte .

Due to the 1 Svel of advanced licensee planning, during the subsequent removal ant - m ent in a shielded container of the detector and cable, the total dose recei,u2 during this evolution was limited to 230 millire i Throughout the five days of this inspection, the inspector noted that all personnel questioned by the inspector were knowledgeable of dose rates in !

their work area and of ALARA controls to be utilized during their wor Extensive pre-entry briefm' gs were provided to all personnel entering the ,

drywell, both at the Access Control Building (ACB) check-in point, and at the drywell access point on the 261' elevation of the reactor building. Of particular licensee concern was work in the upper elevations of the drywell during Safety Relief Valve (SRV) removal while control rod blades were being removed from the reactor and placed in the spent fuel pool. No concerns with the activities were noted by the inspector. All pre-entry briefings observed at i the drywell access control point included several minutes of discussion on

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alarm response and evacuation mutes in the event of a control rod blade dro Postings were observed throughout the drywell identifying the exit routes and j alarm responses as wel .3 Radioloeical Work '

During various drywell entries, the inspector observed work being performed on the SRVs, on the in-board Main Steam Isolation Valves (MSIV), and in the undervessel area. Appropriate radiation protection job coverage, based on the

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requirements identified in the Radiation Work Permit (RWP) and the ALARA review, was observed. Only a few minor instances of improper radiological housekeeping, involving materials not properly controlled at High Contamination Area boundaries were observed, and these deficiencies were promptly addressed by the license i

In general, work conducted outside the drywell was also accomplished in a ,

similar manner. On the refueling floor (353' elevation of the Reactor Building) the licensee constructed a permanent structure for use as a :

secondary access control point. Included in this clean area structure were closed circuit video systems that allowed Radiation Protection personnel and others to observe work being performed in the cavity area without having to be ;

exposed to unnecessary radiation fields. This structure represented the final part of the long-term corrective actions taken by the licensee in response to a Notice of Violation issued for an event that occurred late in the last refueling outage involving cavity decontamination wor Again on the refueling floor, work control and supervisory oversight from Radiation Protection and from an ALARA standpoint were very good. Only

two weaknesses were observed during several entries to the floor by the inspector. One involved less than adequate control of materials at a High Contamination Area boundary. The second involved two workers failing to follow an RWP dress-out procedure, in that they failed to wear additional ,

rubber gloves when working with equipment that was in or in close proximity to the spent fuel pool. Radiation Protection personnel took immediate and thorough corrective action to this event, and no further action was warranted at this time for this isolated incident.

, Unit i Radiati- Protection As part of this inspection, a limited tour of the Unit I facilities was conducted. Of

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significant note was the removal of large amounts of equipment in storage from the upper elevations of the Reactor Building, especially the refueling floor (340'

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elevation). Of additional note was the near completion of the Old Radwaste Building clean-up project. Discussions with the Radwaste Operations Supervisor indicated that

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6- l this project, which was planned for several years, and finally commenced after the completion of the Unit I refueling outage in the early part of 1993, represented a i major decontamination and maintenance effort on the part of the licensee.-

' E_xit Interview The inspector met with the licensee representatives denoted in Section 1 at the .

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conclusion of the inspection on October 22,1993. The inspector summarized the purpose, scope and findings of the inspection. The licensee concurred in the findings of the inspectio i

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