IR 05000245/1978036
| ML19305A072 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/21/1978 |
| From: | Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19305A068 | List: |
| References | |
| 50-245-78-36, 50-336-78--33, NUDOCS 7901020514 | |
| Download: ML19305A072 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT Region I 50-245/78-36 rieport No.
50-336/78-33 50-245 Docket No.
50-336 DPR-21 C
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License No. DPR-65 Priority
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Category C
Licensee:
Northeast Nuclear Energy Company P.O. Fox 270 Hartford, Connecticut Facility Name:
Millstone Units 1 and 2 Inspection at:
Waterford, Connecticut Inspection conducted:
November 6-9, 1978 Inspectors:
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// -70 -7Y G. P.
date signed Oo e(Ydhas, Radiation Specialist fus&.;c
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/ J. A. Serabian, Intern Radiation Specialist date signed f
date signed Approved by:
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M jf/2//7 9 H. W. CrockerT Acting Chief, Radiation
' dat'e signed Support Section, FF&MS Branch Inspection Summary:
Inspection on November 6-9, 1978 (Report Nos. 50-245/78-36 and 50-336/78-33)
A_r:as Inspected: Routine, unannounced inspection by regional based inspectors of the radiation protection program during operations including: qualiffration of personnel; training; radiation protection procedures; posting, labeli-and control; followup on previcus inspection findings; followup on licensee ev:nt report and followup on IE Bulletins. Upon arrival at 3:00 PM on November 6, 1978, areas where work was being conducted were examined to re-vicw radiation safety practices and procedures.
This inspection involved 26 inspector-hours onsite for each unit by two NRC regional based inspectors.
R sults: Of the seven areas inspected, no items of noncompliance were found.
77WAof/1 Region I Form 12 (Rev. April 77)
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DETAILS'
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Persons Contacted
- E. J. Mroczka, Station Services Superintendent R. Herbert, Unit 1 Superintendent.
- A. G. Cheatham, Health Physics Supervisor R. Lent, Unit 1 Health Physics Foreman L. Vanderhorst, Unit 2 Health Physics Foreman
- denotes those present at the exit interview on Novemoer 9,1978.
The inspector also talked with and interviewed several other licensee employees, including members of the Health Physics staff.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (50-245/77-30-01): Failure to post a radia-tion area.
The inspector toured the facility making iniependent measurements to verify adequate posting of radiation areas. The licensee has instituted a weekly check sheet to insure proper posting is maintained.
(Closed) Unresolved Item (50-245/78-01-01; 50-336/78-01-01): Failure to complete the training program specified in Administrative Control Procedure (ACP) 8.14, " Health Physics Department Training Program".
The inspector reviewed training records of all Health Physics Technicians and found that the licensee has complied with the require-ments of ACP 8.14.
This matter is further discussed in Paragraph 6.
(Closed)
Inspector Followup Item (50-245/78-24-02; 78-GY-02; 50-336/
78-21-02): Failure to submit reports of exposure pursuant to 10 CFR 20.408 and 20.409 within 90 days of an individual's termination.
This matter is discussed in Paragraph 3.
(Closed)
Inspector Followup Item (50-245/78-01-04): Review qualif-ications of the Health Physics Supervisor.
As a result of record reviews and discussion with the individual, the inspector determined that the new Health Physics Supervisor meets the requirements spec-ified in Section 6.3 of Unit 1 Technical Specifications.
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(Closed)
Inspector Followup Item (50-245/78-24-01; 50-336/78-21-01):
Review Health Physics Department organization changes and qualifica-tions of additional staff members. This matter is discussed in Para-graph 5.
(Closed):
Inspector Followup Item (50-336/77-11-02): Review and investigate licensee beta dosimetry capability.
In August, 1978, the licensee changed dosimetry vendors.
The inspector reviewed records maintained pursuant to HPP 941/2941, " Performance Audits for Personnel Monitoring Equipment", for the period August thru October,1978. These records indicate the present film dosimeters used by the licensee responded within +30% of the known beta dose when exposed to a depleted uranium source.
3.
Review of Nonroutine Events Reported by the Licensee The inspector reviewed licensee actions with respect to the follow-ing listed nonroutine events reports to verify that the events were reviewed and evaluated by the licensee as required by Technical Spec-ifications, that corrective action was taken by the licensee, and that limiting safety system settings, and limiting conditions for operation were not exceeded. The inspector examined selected licen-see investigation reports, logs and records, and inspected equip-ment and interviewed selected personnel.
Failure of the spent fuel storage ventilation gaseous radia-
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tion monitor (MP-2-1017).
Alarm setpoint on spent fuel storage particulate air monitor
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(MP-2-952).
Late reports required by 10 CFR 20.408, 20.409 (MP-S-1015).
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The inspector noted that the licensee had completed the investigation and correct've action associated with the onsite manual thermolum-inescent desimeter (TLD) readers used during the 1977-1978 refueling outage.
This investigation involved the review of approximately 825 individual's exposure results.
Exposure adjustments were made re-sulting in an increase of about 5 to 15% of the previously reported dose for approximately 300 individuals who had been involved with the primary side steam generator maintenance.
There were no reported cases where connecting the exposure resulted in any individual ex-ceeding the limits specified in 10 CFR 20.101. This investigation was partly responsible for the delayed 20.408 and 20.409 reports noted abov. *
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No items of noncompliance were identified in this area.
4.
Licensee Response to IE Bulletins a.
IE Bulletin No. 78-07, " Protection Afforded by Air-Line Respira-tors and Supplied-Air Hoods" The licensee responded to the action requested in this Bulletin in a letter to Region I, dated August 14, 1978. The inspector noted from a review of records and discussions with licensee representatives that the licensee does not apply protection factors for the use of any respiratory protective equipment.
Respiratory protective equipment is used only to maintain ex-posures As Low As Is Reasorably Achievable (ALARA). Air-line supplied air respirators operated in the demand mode are not used.
Supplied air hoods are used and changes have been made to HPP 910/2910, " Respiratory Protection," to incorporate the information in this Bulletin.
b.
IE Bulletin No. 78-08, " Radiation Levels from Fuel Element Transfer Tubes" The licensee responded to the actions requested in this Bulletin in a letter to Region I, dated July 1G,1978.
Surveys performed with a fuel bundle in the transfer tube during the December 1977 outage did not locate any radiation streaming problems. A re-view of the shielding design by the licensee indicates the need for additional surveys during the next refueling outage. As a
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precaution, the licensee will establish positive control over potential high radiation areas until this confirmatory survey i
l is complete. This survey and evaluation will be reviewed in a subsequent inspection.
(50-336/78-33-01)
5.
Qualification of Personnel The inspector reviewed the qualifications of the Health Physics Super-visor to determine compliance with Technical Specifications 6.3,
" Facility Staff Qualifications", and USNRC Regulatory Guide 1.8.
The Health Physics Supervisor has six years of professional experience in
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applied radiation protection at similiar nuclear facilities and the equivalent of a bachelor's degree.
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The inspector noted that the licensee while operating in accordance with Technical Snecification 6.2, " Organization", has tegun to in-crease the health physics staff as previously describec in NRC Inspection Report 50-245/78-24,50-336/78-21. The inspector re-viewed the qualifications of six additional health physics techni-cians and three contractor supplied health physics technicians to determine compliance with the work experience requirement stated in ANSI N18.1-1971. All nine individuals have at least two years of working experience in health physics at a nuclear facility.
The licensee now provides onsite round-the-clock health physics coverage.
No items of noncompliance were identified in this area.
t 6.
_ Training a.
The inspector reviewed the general employee tr'ining to deter-a mine compliance with the requirements of 10 CFR 19.12, "In-structions to Workers" and ACP-8.03, " Health Physics Training and Retraining for Company and Contractor Personnel".
This review consisted of participation in the four hour class, taking the quiz, and a review of records selected at random from those individuals who have been issued personnel dosimetry.
The inspector also reviewed training records for five female workers to verify that they had been provided the information presented in the Appendix to Regulatory Guide 8.13, " Instruction Concerning Prenatal Radiation Exposure".
b.
ACP-8.14, " Health Physics Department Training Program" requires the following training for station health physics technicians.
(1)
Scientific principles associated with health physics and appropriate regulations initially and at least every five years.
(2) An annual review of all station Health Physics Procedures.
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Practical factor and plant system training initially and at least every two year *
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(4) Vendor instrumentation schools as required for individuals that perform as QA Level 1 inspectors.
In addition, each individual must pass a written examination administered by the Health Physics Supervisor on an annual basis.
The inspector reviewed the training records of all health physics technicians. With exception of the six recent staff additions, all individuals have completed the required training or retrain-ing for 1978.
The six individuals have completed the annual examination, several have not completed the practical factor and plant systems training.
c.
Contractor supplied health physics technicians must review all appropriate Health Physics Procedures and complete a written i
examination prior to assuming responsibilities.
The three contractor health physics technicians have completed the above requirements.
No items of noncomr~iance e identified in this area.
7.
Procedures The inspector reviewed the following procedures to determine compli-ance with Technical Specifications 6.8, " Procedures", 6.11, "Radia-tion Protection Program" and Administrative Control Procedure, ACP-QA-3.02, " Station Procedures and Forms", Revision 6, dated October 16, 1978.
Procedure No.
Revision Title ACP-6.02
Maintenance of Occupational Radiation Exposures As Low As Is Reasonably
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Achievable ACP-8.03
Health Physics Training and Retraining l
For Company and Contractor Personnel ACP-8.14
Health Physics Department Training Program HPP 901/2901
Dosimetry and Exposure Control HPP 901/2901A
Radiation Exposure Cards i
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Procedure No.
Revision Title
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HPP 902/2902
Station Radiological Areas HPP 903/2903
Radiation Work Permits
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HPP 907/2907
Personnel Exposure Evaluation and Investigation HPP 908/2908A
Health Physics Count Rate Instrumentation HPP 908/2908D
Continuous Air Monitor Operation and Interpretation HPP 912
Area Radiation Monitor.alibration HPP 915/2915
Health Physics Surveys HPP 2920
Containment Entry HPP 931/2931
Monitoring for Personnel Contamination HPP 932/2932
Personnel Decontamination
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HPP 936/2936
Implementation / Documentation of "As Low As Is Reasonably Achievable" (ALARA)
Exposure HPP 941/2941
Performance Audit for Personnel Monitoring
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Equipment The inspector discussed with the Health Physics Supervisor the need to revise sections of the following procedures to insure compliance with applicable rules and regulations.
Procedure No.
Section HPP 902/2902 5.2.5 HPP 903/2903 5.9.2 HPP 906/2906 5.1.1.1.4, 5.2.1.2.4 and 5.3.1.2 HPP 907/2907 Exposure Comparison
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i This matter will be reviewed in a subsequent inspection (50-245/
78-36-01; 50-336/78-33-02),
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No items of noncompliance were identified in this area.
8.
Posting, Labeling and Control a.
During tours of the facility, the inspector verified that the documents specified in 10 CFR 19.11, " Posting of Notices to Workers", were properly displayed.
b.
The inspector toured the controlled areas making independent measurements to determine compliance with the following re-quirements.
Subjec_t_
Requirement Station Radiological Areas HPP 902/2902, Rev. 6 Radiation Areas 10CFR20.203(b)
The inspector noted that access to the roof of the Xenon Krypton Building was not conspicuously posted so as to inform a worker of the presence of up to 2 mrem /hr of whole body radiation.
This matter was brought to the attention of licensee representa-tives. A licensee representative stated that a comprehensive survey of the a"ea would be made and the need for additional posting evaluated.
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Technical Specification 6.13, "High Radiation Area", requires that these areas be posted, barricaded and locked if the inten-sity of radiation is greater than 1000 mrem /hr.
In addition, in order to enter the area, a Radiation Work Permit (RWP) and survey instrument is required.
Keys to locked high radiation areas are controlled according to Administrative Control Pro-cedure ACP-7.04, Revision 2.
The inspector toured both units checking locked high radiation area doors, taking measurements to determine adequacy of posting and barricading and observed several RWP's in progress involving high radiation area wor. _ _ _ _ _ _ - _ _ _ - _ _
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The inspector found a high radiation area access key (H.R. 22299)
unattended near the counter scaler located on the 108' elevation of Unit 1.
The key had been properly signed out in accordance with ACP-7.04. The licensee representative informed the in-spector that this key was left outside the locked gate so as to permit additional authorized personnel to enter the attended area. The inspector noted this practice would not preclude unauthorized use of the key.
The licensee representative agreed, and stated that administrative control of high radia-tion area keys would be re-evaluated and that ACP-7.04 would be refined by March 1,1979.
This matter will be reviewed in a subsequent _ inspection (50-245/
78-36-02; 50-336/78-33-03).
9.
Exit Interview The inspector met with the licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on November 9,1978.
The inspector summ.arized the scope and findings of the inspection as presented in this report.
The licensee representative stated that the procedure for adminis-trative control of high radiation area keys will be reviewed and refined by March 1,1979.
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