IR 05000245/1980023
| ML20005B353 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/12/1981 |
| From: | Knapp P, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20005B351 | List: |
| References | |
| 50-245-80-23, NUDOCS 8107070526 | |
| Download: ML20005B353 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-245/80-23 Docki::t No.
50-245 C
License.Nc, DPR-21 Priority Category
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_ ortheast Nuclear Energy Company Licensee:
N P. O. Box 270
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Hartford, Connecticut 06101 l
Facility Name:
Millstone Unit 1 l
Inspection at:
Waterford, Connecticut Inspection conducted: November 5-7 and 12-14, 1980 N
W M d-Inspectors:
'K.' E. Plumlee, Radiation Specialist date signed
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date signed
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date signed.
Approved by: -
,0 S-7.,-[)
P. J. Knapp, Chief,'Radiatioy date signed Support Section, FF&MS Branch l
Inspection Summary:
Inspection on November 5-7 and 12-14, 1980 (Report No. 50-245/80-23)
Areas Inspected:
Routine, unannounced inspection by a regional bssed inspector of radiation protection during refueling, including:
procedures, advanced pl,anning and preparations, training, exposure control, posting, radioactive and This contaminated material control, surveys, and-independent measurements.
inspection involved 51 inspector-hours on site by one NRC regional based inspector.
Results:
Of the eight areas inspected, no items of noncompliance were identified in seven areas. Two items of noncompliance were identified in one area: one failure to wear the assigned personal dosimeter devices, paragraph 3b; and one
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failure to restore the Radiation Area and Radioactive Materials Area signs at an entrance to the area after admitting a vehicle, paragraph 3c.
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Region I Form 12 (Rev. April 77)
8107070526 810224 P
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DETAILS 1.
Persons Contacted a.
Northeast Nuclear Energy Company Personnel
- A. Cheatham, Radiological Services Supervisor
- E. Farrell, Station Services Superintendent J. Gibson, Health Physics Foreman (Support)
J. Laine, Health Physicist R. Lent, Radiation Protection Supervisor
- E. Mroczka, Station Superintendent
- E. Spruill, Health Physics Supervisor L. Vande horst, Corporate Technical Advisor to the Health Physics Supervisor b.
NRC Personnel, Present During the Exit Interview
- K. Plumlee, Radiation Specialist
- J. Shediosky, Senior Resident Inspector
- Denotes presence at the exit-interview, 3 P.M., November 14, 1980.
2.
Licensee Action on previously Identified Items (Closed) Inspector Follow Item (79-11-01):
Review the supply of radiation survey instruments. Observation during this inspection dld not identify any significant delays attributable to a shortage of instruments. Servicing and calibration appeared to be timely. Beta dose rate survey instruments were readily available.
(Closed) IE Bulletin 78-07:
Re Inspection Report No. 50-336/80-12, paragraph 12.
(Closed) IE Bulletin 78-08:
(Ibid).
(Closed) IE Bulletin 80-10:
(Ibid).
3.
Adherence to Procedural Requirements Part of the inspection effort was to tour the facility and observe and review practices and procedures in use during the outage. A member of the licensee's Health Physics staff generally accompanied these tours.
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T.S. 6.8, " Procedures", requires the licensee to establish written procedures.
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T.S. 6.11, " Radiation Protection Program", states, " Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations, involving personnel radiation exposure."
a.
Adherence to RWP Instructions In order to implement requirements of 10 CFR 20.101 " Exposure of individuals to radiation in restricted areas", and other sections of 10 CFR 20, Station Procedure HP 4912, " Radiation Work Permit Completion and Flow Control", Revision 0, effective date July 1,1980, states,
" Workers are responsible for...rcading, understanding, initialling and following RWP instructions... Individuals read and initial the RWP indicating understanding of work conditions, radiation and contamina-tion controls."
Station Procedure HP 4908, " Protective Clothing", Revision 0, effective date August 1, 1980, states, "...Each individual is responsible for donning and removing protective clothing properly and for using the protective clothing required by the RWP...All physical work in contam-inated areas with contamination levels greater than or equal to 1,,000
2 dpm/100 cm beta gamma or 100 dpm/100 cm alpha should require full protective clothing. Health Physics Supervision may specify alternate protective clothing as appropriate... Definitions:... Full protective clothing - Consists of hood, cloth coveralls, cottom liners, rubber gloves, plastic shoe covers and rubber shoe covers or rubber boots... Donning of Protective Clothing...All personnel effects (watches, rings, etc.) and uter clothing should be removed."
RWP No. 807079, on which the following individual signed at about 11:37 A.M., November 5, 1980, gave instructions to wear a protective hood, coveralls, cotton liners, gloves and double shoe covers. The RWP also contained a note "or as determined by HP on job".
At about 12:05 P.M., November 5, 1980, the inspector pointed out to the Radiological Services Supervisor, during a tour of the Reactor Building, that an individual was seated inside a roped and posted
" Contaminated Area", "RWP Required Area", and the individur.1 was wearing a lab coat over his personal outer clothing instead of the protective coveralls and no personal outer clothing indicated on the RWP. He was wearing the hood, gloves ar.d shoe covers indicated on the RWP.
The HP Technician on this level of the Rr=-tor Building stated that he had given consent and allowed the indivic m.
to enter the area, attired as he was, within the authorization given on the above RWP.
He stated that he was not aware of any written licensee procedures or guidance other than the above on the specification of alternate protective
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clothing.
He stated that he had surveyed the specific job location where the worker was stationed and it was non-contaminated.
The inspector observed that the worker had to enter the posted con-taminated area surrounding this job location in going to and from the job, and no stepoff pad was provided to maintain this non-contaminated area. The RWP job and location descriptions did not identify the above and did not state any controls on work without full protective clothing.
The survey record for the roped and posted contaminated
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work area indicated that >20,000 dpm/100 cm beta gamma contamination
was present and the general level was 1,000 dpm/100 cm beta gamma contamination which necessitated full protective clothing in order to
properly protect the workers under the job conditions described on the RWP.
The job did not appear to have urgency requiring verbal authorization i
vo enter the area, without waiting to suit up.
The inspector stated a concern that, as written, the RWP was inadequate to assure that the worker would not contaminate his personal outer clothing by undertaking aJditional work within the RWP job and location description.
The licensee representative instructed this individual to comply with the RWP written clothing instructions, which he did. The individual frisked on leaving the contaminated area in preparation for removal of his personal outer clothing and donning coveralls, and no contamination was found on his clothing and body.
The licensee informed all personnel working on site that verbatim adherence is required to RWP conditions.
Subsequently, as documented in IAL No. 81-02, the lfcensee agreed to revise HP 4912 by February l
15, 1981, to prohibit work not fully described on the RWP.
b.
Adherence to Instructions to Wear the Assigned Personal Dosimeters In order to implement the requirements of 10 CFR 20.232, " Personnel monitoring", Station Procedure SHP 4902, " External Radiation Control and Dosimetry Issue", Revision 1, September 19, 1980, requires each worker shall wear the assigned dosimetry devices when ent.ering any radiological controlled area (RCA).
l The licensee informed all personnel of the above requirement daring l
training before assigning dosimetry devices. The licensee also main-tained manned control points at RCA entrances to verify that personnel l
had the dosimetry devices on their persons when entering.
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At about 1 P.M. on November 5, 1980, the inspector observed a worker without his assigned dosimetry devices on his person, in the Reactor Building Equipment Access Lock, which is part of an RCA. The inspector measured the radiation dose rate at 1 to 2 mrem / hour (variable) in the immediate area where the worker was working.
The worker stated that he had inadvertently removed the dosimetry devices with an article of clothing, and he pointed out their location, which was about 25 feet distance.
The inspector stated that the failure to wear the dosimetry devices constituted noncompliance with the above requirements.
(80-23-01)
The licensee representative assigned an estimated whole body dose to the individual pursuant to procedure HP 907 " Personnel Exposure Evalua-tion and Investigation".
The licensee notified all of the plant personnel of the above and
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reemphasized the requirement to wear dosimeters on entering any RCA.
The inspector verified, through subsequent contacts with workers, that plant personnel were informed of the above.
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c.
Posting of Areas In order to implement the requirements of 10 CFR 20.202, " Personnel monitoring", and 10 CFR 20.203 " Caution signs, labels, signals and controls", Station Procedure SHP 4906, " Posting of Radiological Controlled Areas", states:
"All entrances to the RCAs should be conspicuously posted with signs bearing the radiation caution symbol...and the words Caution / Radiation Area / Radioactive Materials Area / Personnel Monitoring Required For Entry."
Tours of the facility verified that the licensee carried out the above procedure however while walking from the Unit 1 Administration Offices toward the NRC Resident office, at 8:30 A.M. on November 7, 1980, the inspector observed that the entrance to an outdoor RCA was not posted.
Apparently the rope and the attached signs between a power transmission line tower and a light standard had been laid aside in order to admit a forklift vehicle to an RCA, the radwaste laydown area, earlier in the day and had not been replaced.
The inspector noticed that the forklift vehicle remained unattended in the RCA and no one was visible in or near the RCA.
ihe inspector returned at 8:45 A.M. and found no one present in or near the RCA at that time, and the rope and signs remained as described above. A licensee representative later measured the distance at 22 feet between the above line tower and lighting standard.
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The inspector notified a licensee representative and the rope and signs were then restored.
The inspector identified the above as an item of noncompliance with Procedure HP 4906.
(80-23-02)
A licensee representative objected to the citation, on the basis that several signs were posted.
The inspector stated that, as found, a pedestrian or a vehicle operator could enter the RCA without facing any caution sign or barrier before he reached a point where he was exposed to several mrem /hr.
Specifically if one walked west or northwest through this entrance he would reach containers that were labeled " Radio-active Material" and possibly a posted rope barrier delineating a High Radiation Area >100 mr/hr, enclosing containers of radioactive materials.
The inspector also ' stated that this RCA entrance was accessible to personnel who had no assigned dosimeters.
Oosimeters are required for entry into any RCA.
See paragraph 3.b.
4.
Radiation Protection Procedures a.
Review and Evaluation of Licensee Procedures The inspector reviewed the following procedures during the course of the inspection, including the completion of forms and/or checkoff sheets where applicable.
Procedure Revision No.
Date Title HP 901/2901-A
7/1/80 Radiation Exposure l
Cards
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HP 906/2906
1/26/79 Radiation Incidents -
I Reporting Requirements i
HP 906/2907
7/1/80 Personnel Exposure (
Evaluation and Investi-gation
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HP 911/2911
3/14/80 Health Physics Depart-ment Training Program HP 920
7/27/79 Containment Entrance Unit I HP 4905
8/11/80 Radiological Surveys l
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Procedure Revision No.
Date Title SHP 4906
9/19/80 Posting of Radiological Controlled Areas
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HP 4907
8/1/80
, Bioassays HP 4903
8/1/80 Protective Clothing HP 4912
7/1/80 Radiation Work P'ermit Completion and Flow Control The inspector did not identify any inadequacies in the above pro-cedures even though specific examples of failures to adhere to procedures were identified as described in paragrap'h 3.
b.
Implementation of Respiratory Protection Program The inspector verified the licensee's implementation of the following procedures but did not evaluate the procedures, which were previously reviewed on Inspection No. 245/80-12. The licensee submitted a written notice dated July 23, 1980, of intention to make allowance for the use of respiratory protection equipment commencing on or about September 1, 1980, which included the following:
ACP-6.05, Revision 4, 8/1/80, " Basic Policy Regarding Use of j
Respirators" HP 4931, Revision 0, 8/1/80, " Selection and Use of Respiratory Protection Equipment" HP 4932, Revision 0, 8/1/80, " Maintenance and Quality Assurance Program for Respiratory Protection Equipment" HP 4933, Revision 0, 8/1/80, " Breathing Air Supply and Utilization" HP 4934, Revision 0, 8/1/80, " Medical Screening Program for Respirator Users" HP 4935, Revision 0, 8/1/80,'" Respiratory Man-Fit Using the Sodium Chloride Aerosol Test System" The inspector did not identify any omissions in the implementation of the above procedures.
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c.
Other Procedures (1) Licensee Adoption of 5 Rems / Year Dose Limit A licensee representative stated that the procedures incor-porated as company policy a 5 rems / year limit on occupational whole body dose, which was consistent with the proposed change to 10 CFR 20.101, published February 20, 1979 in the Federal Register (44 FR 10388).
This resulted in examples of individuals who could be authorized under current NRC Regulations to receive as much as 3 rems during the current calendar quarter or 12 rems during the current calendar year being denied employment by the licensee in order to avoid exceeding the 5 rems / calendar year policy.
No examples were identified of exceeding the 5 rems / year licensee control level.
(2) Procedures for use of installed plant monitors during the outage.
The inspector observed that the licensee's preparations for the outage did not include procedural provisions to readjust the trip settings on the installed Area Radiation Monitors, as examples, as the radiation levels changed during the outage (paragraph 5.c.)
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5.
Review of Advanced Planning and Preparation for the Outage
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a.
Increased Health Physics Staff
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A licensee representative stated that about 90 contract senior health physics technicians and 70 contract personnel serving as clerks, junior technicians and control point monitors were on site during the inspection.
The inspector reviewed the personnel files of contract senior technicians.
Their resumes and onsite qualification records indicated that each was qualified in accordance with ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel" (
and also in accordance with licensee procedure.
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Equipment The licensee representative stated that hydrolaser equipment was used to decontaminate pipes and nozzles in order to minimize personnel exposures during inservice inspection.
l Remote inspection, cutting, machining and welding equipment was l
used,.to minimize the time that any individual was present in high radiation areas. Temporary shielding was applied as needed, to reduce personnel exposures.
l Crews of workers trained on the equipment were supplied by the l
equipment vendors.
l No items of noncompliance were identified in this area of the l
inspection.
c.
Installed Plant Monitoring Equipment Inspection of remote readouts in the control room such as the Area Radiation Monitors (ARMS) indicated that the HP personnel did not routinely review the information available on these
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instruments. Typically two or three of these instruments were observed to remain tripped and although control room personnel appeared knowledgeable of the cause, the HP personnel were not informed unless a known occupied area was involved.
The inspector noted that the trip points of some of the instruments were specified by the Technical Specifications. As an example the refueling floor ARMS are required to trip at 100 mr/hr (T.S.
3.2.E.2.b), and these were observed to be operating.
The inspector observed that although there was a heavy workload in the drywell, as of November 12 the drywell atmospheric monitor (a continuous air monitor) had been turned off on October 8, 1980, as entered on the recorder chart. The inspector stated that he had not identified any licensee review of the potential value of such equipment during the outage.
This item was reviewed during the exit interview.
Licensee
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followup on this item will be reviewed on a subsequent inspection.
L (80-23-03)
d.
Supplies The licensee representative stated that a protective clothing i
laundry was being maintained on site during the outage, and in j
addition commitments had been obtained for backup by an offsite l
laundry as needed.
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Observation of work activities did not identify any shortage of protective clothing, respirators, survey instruments, air samplers or shielding. No delays were identified involving supplies.
6.
Exposure Control The inspector reviewed several personnel files for accuracy and complete-ness of records.
The inspector identified four Form NRC-4s which contained errors in the total occupational doses however none of these errors would have resulted in an exposure on site that would not be permitted had the Form NRC-4 been properly executed.
One of the four individuals had been authorized to receive up to 1.5 rems during the calendar quarter based on the erroneous Form NRC-4 calculation.
None of these individuals had actually exceedad 1.25 rems during the calendar quarter.
The licensee corrected these records and stated that a double check is always made of the Form NRC-4 before the individual actually exceeds 1.25 rem during the quarter.
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Review of Form NRC-5s, and of recent termination letters, did not
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identify any problems.
Review of dosimetry practices did not identify any omissions of extremity monitoring that would be necessary for compliance with 10 CFR 20.101.
7.
Respiratory Protection The inspector noted that enclosures, ventilation and air cleaning systems, decontamination, and access controls were used to minimize the need for respirators.
Observation of adherence to procedures did not identify any problems involving respiratory protection (paragraph 4.b).
Observation of air sampling and respirator usage did not identify any errors in mpc-hour estimates.
8.
Radioactive and Contaminated Material Control Observation of container labels and area access controls was described in paragraph 3.c.
The inspector observed the collection and dispostion of contaminated tools, trash and radioactive waste.
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The inspector observed one vehicle being loaded with radioactive materials.
No items of noncompliance were identified.
9.
Training The licensee representative stated that typically 1,500 contract workers were on the job in Unit I during the inspection.
The inspector observed the radiation worker training, respirator training, and respiratory fitting provided to a group of arriving workers.
- The inspector contacted several workers on the job and also reviewed their qualification records. No examples were identified of omissions of required training for these job assignments.
The inspector had no further questions on this item.
10.
Exit Interview The inspector met with the individuals denoted in paragraph 1 at the conclusion of the inspection. The following items were reviewed.
Inspection findings (paragraphs 2 and 3).
a.
b.
Other posted information.
c.
RWP concerns (paragraph 3.1).
d.
Records and correspondence necessary for Form NRC-4 preparation (paragraph 6).
Use of Area Radiation Monitors during the outage (paragraph 5.c).
e.
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