IR 05000245/1987015
| ML20238B745 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/12/1987 |
| From: | Lequia D, Markley M, Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20238B741 | List: |
| References | |
| 50-245-87-15, 50-336-87-17, 50-423-87-14, NUDOCS 8708210434 | |
| Download: ML20238B745 (18) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-245/87-15 50-336/87-17 50-423/87-14 Docket Nos.
50-245 50-336 50-423
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i License Nos. DPR-21 Category C
DPR-65 NPF-49 Licensee:
Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut Facility Name: Millstone Nuclear Generating Station, Units 1, 2 and 3 Inspection At:
Niantic, Connecticut Inspection Conducted: July 6 - 10, 1987 Inspectors:
h. (/N4 L
7 fID {S7 A. Weadock, Radiation Specialist date j
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><wb 8'll-87 m
D. LeQuid/yiattin~ Specialist date N
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7/iih?
M. Markley, Radi n Specialist dat'e Approv by: /
c:th l_
h 8/LN7 M. Shanba% fhi e f,/ ~
date
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Facilitie Wadiation Protection Section Inspection Summary:
Inspection on July 6-10, 1987 (Combined Inspection Report Nos. 50-245/87-15, 50-336/87-17, and 50-423/87-14).
Areas Inspected:
Routine, unannounced inspection to review i) Radiation Protection activities associated with the Unit 1 outage, and ii) status of the Station Audit and Hot Particle Programs. Areas reviewed included Internal and External Exposure Controls, ALARA, and Posting and Labeling.
8708210434 070819 PDR ADOCK 05000245 G
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Results: Within the areas inspected, two apparent violations were identified:
failure to adequately 19 bel radioactive material (section 4.0), and failure to follow the station Radiation Work Permit procedure (section 5,0).
Significant weakness were also identified relating to the licensee's posting of High Radiation Areas.
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Details f
1.0 Persons Contacted
- M.
Bigiarelli Unit 1 Asst. Engineering Supervisor l
- M.
Brennan Unit 1 Radiation Protection Supervisor
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- C.
Clement Unit 3 Superintendent
- W. Collins Assoc. Scientist-Radiation Protection, NUSCo
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- R. Doherty Unit 1 ALARA Coordinator
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- B. Duffy Unit 2 Asst. Engineering Supervisor
- B. Granados, Jr.
Health Physics Supervisor
- H.
Haynes Station Services Superintendent
- J. Kangley Radiological Services Supervisor
- J.
Leason Unit 1 ISI Coordinator
- C. Libby Supervisor, Assessment Services, NUSCo M. Niswander Health Physicist
- H.
Siegrist Supervisor Radiological Protection, NUSCo
- G. Smith Unit 1 Asst. Radiation Protection Supervisor
- J. Stetz Unit 1 Superintendent
- R. West Unit 1 ISI Coordinator, NUSCo
- Denotes those individuals attending the exit interview on July 10, 1987.
Other licensee employees were also contacted or interviewed during the course of this inspection.
2.0 Purpose The purpose of this routine, unannounced inspection was to review i)
Radiation Protection activities associated with the Unit 1 outage, and ii) status of the stations Health Physics Audit and Hot Particle Programs.
The following areas were included in this review:
organization and management controls,
posting and labeling,
external exposure controls,
internal exposure controls,
audits,
hot particles program,
- 3.0 Organization and Management Controls The licensee's organization, staffing and motivation to effectively control radiation and radioactive materials was evaluated against the following criteria:
Technical Specifications, Section 6, " Administrative Controls";
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Regulatory Guide 1.8 " Personnel Selection and Training";
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l NUREG/CR-1280, " Power Plant Staffing"; and
j ANSI-N18.1-1971, " Selection and Training of Nuclear Power Plant
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Licensee performance relative to these criteria was determined by:
Discussions with cognizant personnel;
Review of contractor Health Physics (HP) technician staffing to support
the on going outage; Review of standard and outage organization charts; and
l Observation of the implementation of management controls to support
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l the Unit I refueling outage.
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Within the scope of the above review, no violations were identified.
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licensee has established a separate, special outage organization to support the accelerated workload associated with the outage. Approxi-mately seventy-five (75) Senior Health Physics (HP) technicians and 22 Control Point Monitors were added to the staff to augment the station's permanent HP technician staffing level.
To integrate the efforts of the contractor and station HP technicians, the station technicians have been upgraded to lead technicians providing direct oversight of contractor technicians activities. This was considered to be a good practice by the inspector.
One weakness associated with the use of temporary personnel was identified by the inspector.
Specifically, the use of temporary personnel to support l
whole body counting and record keeping had a negative impact on record quality.
Compounding this issue was poor management oversight and review of these records (see details in Section 6.0).
While there appeared to be sufficient numbers of management and technical staff to support both routine anc outage activities, the number of viola-tions and weaknesses identified during this inspection indicated a licensee weakness relative to the recognition of radiological concerns by all levels of the radiation protection organization and station management.
The inspector discussed this issue with the licensee, who stated that they would strengthen their oversight of in plant implementation of the Radiation Protection Program.
4.0 Posting and Labeling The licensee's program for the survey, posting, and control of radioactive materials and radiological areas was reviewed against the following criteria:
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q 10 CFR 20.203, " Caution signs, labels, signals and controls",
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Technical Specification 6.12, "High Radiation Area",
licensee procedure SHP 4906, " Posting of Radiological Controlled i
Areas".
Licensee performance in this area was evaluated by the following methods:
discussion with supervisory and technician level personnel,
inspector tour and independent survey of various radiological work a
areas.
Within the scope of the above review one apparent violation, concerning a failure to adequately label radioactive material, was identified.
Signi-ficant weaknesses were also identified with the licensee's posting and control of High Radiation Areas (HRAs).
4.1 Labeling of Radioactive Material 10 CFR 20.203(f)(1) requires that each container of licensed material bear a durable, clearly visible label identifying the radioactive
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contents.
10 CFR 20.203(f)(2) requires that labels bear the radia-l tion caution symbol and the words " Caution" or " Danger, Radioactive Material".
On July 6,1987, while performing a Unit I tour the inspector noted an unlabeled shipping box stacked in the railway access area on i
the 14'6" elevation of the reactor building.
No marking or labeling in accordance with 10 CFR 20.203 or Department of Transportation regulations was present on the shipping box.
Survey measurements performed by the inspector identified contact dose rates ranging to 50 mR/hr on the box, indicating licensed material in excess of 10 CFR 20 App. C quantities were contained inside.
The box was un-attended and easily accessible to personnel in the area.
Failure to label the above shipping box with a clearly visible label
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identifying the radioactive contents constitutes an apparent viola-
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tion of 10 CFR 20.203(f)(1)(245/87-15-01).
During the above tour of the Unit 1 Reactor Building the inspector noted additional examples where containers of radioactive material
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were not adequately labeled.
Several 55 gallon drums, stationed to j
hold used protective clothing, were noted to be unlabeled or I
stencilled with the words " Contaminated Clothing" rather than i
featuring labels as required by 10 CFR 20.203(f)(2). The inspector I
also noted numerous examples of yellow-bagged or herculite-wrapped tools or ccmponents throughout the building that did not feature the l
required labeling.
These items were pointed out to the licensee for l
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correction; however they were not included in the above citation as
survey measurements did not indicate licensed material in activities above the App. C limits.
The-licensee took immediate actions to properly label the above items and the inspector noted improvement in this area during subsequent tours.
4.2 High Radiation Area Posting and Control 10 CFR 20.202 defines a High Radiation Area (HRA) as an accessible area in which any individual could receive a dose in any one hour in excess of 100 millirem.
Technical Specification (TS) Section 6.12 requires that each HRA with dose rates less than 1000 mrem / hour be posted and barricaded.
In addition, HRAs with dose rates greater than 1000 mrem / hour are required to be locked.
The inspector reviewed licensee compliance with the above require-ments by the performance of several tours of the Unit I reactor building during the week of the inspection. Although no specific violation was issued, significant weaknesses in the licensee's posting and control of HRAs were noted. Specific examples are given below.
A.
On July 8,1987, at approximately 1930, the inspector observed that the normally-locked gate to the Unit 1 Traversing Incore l
Probe (TIP) Machine room had been left open and unguarded. An inner, open gate inside the TIP Machine room provided free l
access to the TIP room, an area with known potential for extremely high dose rates during TIP movement. Access to both
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rooms were posted as HRAs; the floor area immediately outside the TIP Machine room gate was roped-off and posted as a contaminated area.
The licensee indicated that the TIP machine room was routinely treated and controlled as a lockable HRA.
Subsequent investigation into circumstances surrounding the open gate identified that the TIP Machine room gate had been blocked open by a work party as they exited the area at approximately 1600 that day.
The door was blocked open to facilitate equipment removal and was inadvertently lef t oper, after the workers lef t the area.
The open condition of the gate had then gone unnoticed until approximately 1930, when it was observed by the inspector.
During this interval a shift change occurred; however, the gate's condition was not noted by the licensee's HP staff as they moved past the gate on the way ty the building exi.
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The inspector performed a survey of the area and determined that a HRA did exist in the TIP room; measured general area dose rates ranged up to 500 mR/hr.
Despite the obvious loss of control over the area, however, the inspector determined that a violation of TS section 6.12 did not occur.
The required posting and barricade for the area was present; a HRA sign was on the gate to the TIP room and the contaminated area barrier
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rope, although not intended for that purpose, did act as a barricade to the area. General area dose rates were not significant enough (i.e., greater than 1000 mR/hr) to require the area be maintained locked. Additionally, the licensee did
~i have some positive controls over the area to insure the TIPS were not moved and area dose rates did not go up.
The RWP authorizing access to the work party (#4758) required the Control Room to be notified prior to entry to the area.
Additionally, the TIP drives were red-tagged out, ensuring the drives would not be operated without appropriate authorization and verification the area was empty.
i The inspector also noted two additional concerns with the posting and control of the TIP Machine Room:
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Inconsistent posting:
both a " Radiation Area" and an
" Airborne Activity Area" sign were posted inside the room.
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I A Health Physics (HP) technician left the outer gate open
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and unattended while performing a verification survey I
inside the TIP Room.
Lit ennee immediate corrective actions consisted of locking the l
c, I gate, panerating a radiological deficiency report, per-
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fo' ming an investigation, and counseling the work party.
The I
r licensee also indicated that the technician's practice of l
leaving the TIP Machine Room access unguarded to survey the I
inner cubicle was not considered to be a problem, as he was inside the area and could prevent someone from entering the actual HRA.
The inspector responded that the actual point of licensee control for the HRA was ostensibly at the outer gate, and that to try and maintain control over the gate without visual line of sight was a poor practice.
The licensee has had recurring problems with HRA gate control and has been previously cited for failure to maintain a HRA gate locked.
Review of Deficiency Trend Reports for 1987 identified several recent instances where similar problems had occurred.
The inspector indicated that the licensee's previous corrective actions, which focused on the installation of self-locking doors, might not be comprehensive enough and that additional measures such as strengthening procedural controls, might be required.
The inspector noted, for example, that although no problems with HRA key accountability were noted during the
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current inspection, that licensee procedure ACP 7.04A, Station Lock and Key Control, provides little in the way of formal controls over the maintenance, accountability and issue of HRA l
keys.
The licensee indicated that additional measures to ensure HRA gate integrity would be evaluated; and specifically committed to formalizing additional HRA key controls in a l
revised procedure.
Development and implementation of revised l
HRA key control procedure will be reviewed during a subsequent inspection (245/87-15-02, 336/87-17-01, 423/87-14-01).
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On July 8, 1987, at approximately 2030, the inspector noted l
that the HRA sign and barrier rope formerly present at the j
equipment hatch access to the Unit I drywell had fallen down l
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barricade.
Licensee surveys demonstrated that the drywell was a HRA; contact dose rates up to 4000 mR/hr and general area dose
rates up to 300 mR/hr were specified on the drywell status i
boards.
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drywell access was not cited as an apparent violation of TS l
Section 6.12, as the drywell HP technician was in the immediate area for the entire period while the inspectors were in the area and had direct visual control over the access. Additional HP personnel in the area included the personnel at the drywell control point, which was located outside but immediately ad,iacent to the drywell hatch laydown area.
The inspector questioned the HP staff as to their method of ensuring positive control over entry to the drywell.
The licensee indicted that positive control over the drywell access was provided by two means:
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.1 the drywell technician, when not required to actually be l
in the drywell, the HP technician at the control point desk, for
those periods when the drywell technician was not providing control.
The inspector questioned the adequacy of control exercised by HP personnel at the control point, however, based on the following observations:
The drywell access was not visible from the control point
desk; herculite drapes had been placed between the two and totally obscured visual line of sight; HP control point personnel questioned by the inspector were
unaware whether or not the drywell access was routinely posted and controlled as a HR _ _ _ _ - _ _ _.
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l Licensee immediate corrective actions included reposting the HRA sign and barrier at the drywell access.
The licensee also immeo'iately repo;,itioned the control point desk to obtain unobstructed sight of the drywell access.
HP personnel at the control point also indicated that although
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vision at the original desk location was obscured, control point
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personnel were constantly up and roving around the drywell control point area, maintaining access control.
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i inspector noted that for the approximate one-half to j
l three quarter hours while the inspector was in the area,
l control point personnel remained at the desk.
The inspector
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also noted that despite the two apparent levels of control over l
the access, the downed HRA sign and barrier was not roted or j
corrected until pointed out by the inspector.
The inspector also noted additional instances of poor or
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inadequate HRA barricading and posting. On July 6, 1987, the
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inspector noted that the HRA sign and barrier rope at the j
access to the Unit 1 torus had fallen down and was no longer conspicuous.
This specific example is not included in the HRA citation discussed above, however, as the inspector determined through discussion with the licensee that the interior HRAs located inside the torus and torus room were individually posted.
Upon identification, the sign and barrier rope were replaced by the licensee.
On July 6,1987, the inspector also noted that the upper level of scaffolding located in the southwest corner room on the 8'
elevation of the Unit I reactor building was inadequately
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I posted as a HRA. A pipe, accessible from the scaffolding, was
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reading 120 mR/hr on contact; consequently, the licensee was
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l posting part of the scaffold as a HRA.
The inspector noted,
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however, that the HRA posting for the upper level of scaffolding had fallen down and was no longer conspicuous.
The inspector also noted that a ladder, providing access to the upper level of staging, was not posted with a HRA sign.
Consequently, an individual could gain access to the upper level of scaffolding without confronting a HRA sign. This
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example is also not included in the HRA citation discussed above, because general area radiation dose rates emanating from the pipe did not equal or exceed 100 mR/hr.
Upon identification, posting in the area was corrected by the licensee.
While performing various tours of the Unit I reactor building, the inspector noted that area housekeeping was poor.
In addition to the posting and labeling problems noted above, the following examples of poor housekeeping were noted:
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large number of protective clothing garments (PCs) had
been thrown on the benches and floor of the 14'6" elevation general dress-out area; i
j PCs were noted to be tossed on the floor at the undressing
i area inside several posted contaminated areas; PCs were observed to be stuffed inside one overhead PA
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several loose respirators and respirator sorbent
canisters were noted to be unattended and apparently available for unauthorized use.
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The inspector inferred from the prevalence of easily observable deficiencies noted in the areas of HRA posting, labeling, and housekeeping, that the licensee's HP staff were not actively and aggressively scrutinizing work area radiological conditions.
5.0 External Exposure Controls The licensee's program for the control of external occupational exposure was reviewed against the following criteria:
j Technical Specification 6.12, "High Radiation Area",
Licensee procedure SHP 4912, " Radiation Work Permit Completion and l
Flow Control",
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Licensee procedure ACP 7.04A, " Station Lock and Key Control".
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The licensee's performance in this area was evaluat.ed by the following methods:
l discussion with supervisory and technician-level personnel, I
tour of radiological areas and observation of work activities,
inspection of the Unit 1 HP HRA key locker,
review of training and dosimetry records for selected individuals a
signing in on Radiation Work Permits (RWPs),
review of selected RWPs, including the following:
a-RWP 4616, Grind-sand and scrape torus liner,
-RWP 4631, Wire brush welds and hangars,
-RWP 4613, Erect / dismantle staging, temporary power in torus,
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-RWP 4348, Decontaminate respirators,
-RWP4716, Replace Yoke and MOV,
-RWP 4076, Install drywell temperature modifications,
-RWP 4088, JPI A and B nozzies; machine nozzles and cut tubes, and-RWP 4786, Install hangers and conduct in drywell.
Within the scope of the above review, one apparent violation, consisting of several examples of a failure to follow the station RWP procedure was identified and is described below.
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l Licensee TS Section 6.11 states that procedures for personnel radiation
protection shall be approved, maintained and adhered to for all operations
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l involving personnel radiation exposure. Specific requirements in the licensee's RWP procedure (SHP 4912) include the following:
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t Workers are responsible for reading, understanding, initialing and I
following RWP instructions (4.5.1),
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I No work shall be performed under an RWP once it is terminated or a
expired..(8.1.10).
During the course of the inspection, the inspector identified two instances in which stated RWP requirements were not followed by the workers signed in on the RWP. One instance was also identified in which workers had signed in on an expired RWP. These multiple instances are collectively considered as an apparent violation of TS 6.11 (245/87-15-03). Specific details are given below.
A.
RWP No. 4348, controlling the decontamination of respiratory protection equipment, was noted to include a requirement that workers
" Review Latest Health Physics Survey" to obtain current radiological
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conditions in the work area.
This weekly blanket RWP, posted in the Mask Decon room and dated July 3, 1987, had been signed and entered on by various individuals throughout the week of-the inspection.
The inspector noted that no radiological survey of the Mask Decon room was attached to the RWP, posted in the work area, or posted in the hallway outside the HP office.
Subsequent investigation revealed that surveys of the Mask Decon room were performed weekly as part of the HP routine survey program, and that completed surveys were placed in a file in the HP office, essentially unavailable for worker review.
The inspector questioned the Mask Decon room job supervisor who acknowledged that surveys for the room were not reviewed by decontamination workers, who instead relied on area posting to
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l inform them as to radiological conditions.
Failure of the decontamination workers working in the Mask Decon room to review area surveys as required by the RWP constitutes an apparent violation of SHP 4912 Section 4.5.1.
Subsequent to identification of the above concern, the licensee indicated that the current HP survey for the Mask Decon room would be made available to workers by posting the survey in the room.
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On July 7,1987, the inspector observed a worker sign-in and prepare to enter the Unit I drywell on RWP No. 4631.
This RWP contained a requirement for a full face respirator; no exceptions or exemptions
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to this respiratory protection requirement were listed on the RWP.
The inspector noticed the worker signing in on the RWP did not have a respirator.
Failure of the worker to comply with the respiratory protection requirements of RWP No. 4631 constitutes an apparent violation of SHP 4912, Section 4.5.1.
The inspector pointed out the above discrepancy to the control point HP technician, who indicated the worker would visually inspect the work area only and would not be performing work which would generate airborne activity.
The control point HP also stated that a specific exemption had been included on the previous day's RWP for the same work activity and the lack of such an exemptionon the current RWP had gone unnoticed.
The control point technician subsequently made an amendment to RWP No. 4631 which irdicated respirators were required i
only for certain airborne generating activities.
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On July 8,1987, at approximately 2100, the inspector noted that RWP No. 4786 was being maintained as active at the Unit 1 drywell control point.
The RWP expiration date and time given on the RWP, however, indicated the RWP expired on July 8,1987, at 0630.
Issue and use of the ostensibly expired RWP had gone unnoted through two levels of RWP review; the inspector also determined that six individuals had signed in on RWP No. 4786 on July 8 at times subsequent to the stated expiration time of 0630.
Worker sign-in and entry under an expired RWP constitutes an apparent violation of SHP 4912 Section 8.1.10.
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Upon identification of the above discrepancy, the control point HP technician contacted the RWP office and determined that an incorrect
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expiration date had been given on RWP No. 4786, and that the
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expiration date/ time should actually read July 9,1987, at 0630.
A change was subsequently inade to RWP No. 4786 to reflect this.
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Summary r
The several instances of worker failure to comply v,ith the station RWP procedure as listed above constitute, in the aggregate, one apparent violation of TS Section 6.11.
An NRC inspection during the l
previous Unit 1 outage identified a similar violation involving a l
failure to comply with RWP requirements (see NRC Report No.
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245/85-28).
The inspector recognized and acknowledged to the licensee that in the instances cited above, the level of radiological safety was not the overriding issue.
Radiological conditions in the Mask Decon room, for example, were observed to be innocuous; the HP technician's decision t( allow the worker in to sight work areas in the drywell
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without a r.spirator was a sound one, based on anticipated activity, radiological ;onditions, and ALARA concerns.
NRC concern is raised, I
however, as tia above noted discrepancies indicate a weakness in the administrative ontrol of the RWP system.
This weakness appears to stem from a lack of attention to detail and adequate administrative oversight over th' system from the HP staff.
6.0 Internal Exposure Control and Assessment l
The licensee's program for control of internal exposure was reviewed against criteria contained in the following:
10 CFR 20.103, " Exposure of individuals to concentrations of
radioactive material in air in restricted areas";
NUREG-0041, " Manual of Respiratory Protection Against Airborne
Radioactive Materials";
"NIOSH Certified Equipment List";
Regulatory Guide 8.7, " Occupational Radiation Exposure Records
System"; and Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations, and
Assumptions for a Bioassay Program".
Evaluation of licensee performance in this area was based on the following:
Discussions with cognizant personnel;
Review of whole body counting (WBC) records;
Inspection of the WBC facility;
Observation of whole body counting activities;
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Observation of respirator issue and control;
Observation of respirator decontamination and survey;
Observation of respirator usage; j
I Review of air sample record sheets and isotope analysis records; and
Selected review of training, respirator fit test and pulmonary l
function test records.
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Within the. sccpe of this inspection, no violations were observed.
The licensee has ir.plemented an adequate Internal Exposure Control Program.
However, the following weaknesses were identified:
Poor reccrd keeping practices at the WBC facility indicate a lack
of management attention to detail.
Examples included:
(1) App-oximately 120 source check and background checks for the period of June 11, 1987, through July 9, 1987, had not been reviewed in a timely manner by the Health Physicist.
(2) Quality Control charts for the WBC equipment were inaccurately plotted with no recounting initiated or corrective action taken by c:anagement.
(3) Source and background checks were of ten improperly recorded
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varying by as many as three significant digits.
When the above items were brought to the licensee's attention, they took prompt action to review the records and correct the forms.
7.0 Audits The licensee's program for audits of the Radiological Control Program was
reviewed against criteria contained in:
Technical Specification 6.5.3.7 " Audits";
Regulatory Guide 1.146 " Qualifications of Quality Assurance Program
Audit Personnel for Nuclear Power Plants"; and The Quality Assurance Program Topical Report.
- The. licensee's performance in this area was determined by the following:
Discussions with cognizant personnel;
Review of " Audit and Training Unit" goal records:
Review of the 1986 and 1987 " Health Physics and Emergency Plant
Audit Schedules";
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l Review of the "Open Health Physics Audit Findings" list;
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l Review of Corporate ALARA Procedure No. 3, " Audits And Appraisals Of
The Stations' Health Physics Programs";
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Review and evaluation of the following audit records:
-Millstone Health Physics Audit of December 12 and 29, 1986 i
(NE-86-RA-004).
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-ALARA Program Appraisal (NE-86-RA-1229).
-Preoutage Health Physics Appraisal: Millstone Unit 1 (NE-87-RA-538).
-Quarterly Summary of Health Physics Audits for the Millstone Power j
Plant (NE-87-RA-348).
Review of "NUSCo Auditor Qualification Exam" for RAB auditors.
- Within the scope of this inspection, no violations were observed.
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l However, several weaknesses relative to auditing of the Health Physics Programs were noted and are detailed below.
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Under current procedures audits of the Health Physics Program, required by Technical Specifications (TS), are conducted by the Radiological Assessment Branch (RAB).
Remaining TS required audits are conducted by the Quality Services Division (QSD).
NRC review of audits conducted by RAB found that all TS required areas had been addressed.
However, the audits were shallow in depth and compliance oriented rather than programmatic in nature. Additionally, RAB auditor time spent onsite (approximately 4-8 hours per audit) appeared to be insufficient to allow
for a reasonable evaluation of multiple program areas, as well as conducting personal interviews, record reviews and inspection of radiological areas.
Inspector investigation into the training and qualification of RAB auditors found this area to be weak.
Specifically, the technical a,d quality assurance content of the RAB auditor examination was very basic and appeared to be inconsistent with the level of oversight the auditors were expected to provide, Additionally, documentation and certification of " Auditor / Lead Auditor" qualifications to meet ANSI N45.2.23-1978,
" Qualifications of Quality Assurance Program Audit Personnel for Nuclear Power Plants", was weak and did not clearly meet the ANSI requirements.
The inspector discussed these items with the licensee who stated that they would improve the training and certification of RAB audit i
personnel (245/87-15-04, 336/87-17-02, 423/87-14-02).
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Another issue raised by the inspector was a perceived lack of sufficient independence or separation of the audit program. Specifically, the RAB
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Audit Program is directed by the Supervisor of Radiological Protection, j
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This individual's responsibilities also include oversight of the Dosimetry j
Laboratory which is subsequently inspected by his auditing staff. This
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l did not appear to provide the necessary independence required by l
applicable ANSI standards which the licensee is committed to in their Quality Assurance Topical Report.
The inspector discussed this weakness with licensee management, who stated they would take the necessary steps to resolve the issue and satisfy ANSI independence criteria (245/87-15-05,
336/87-17-03, 423/87-14-03).
l 8.0 Station Hot Particle Program i
NRC Information Notice 86-23, " Excessive Skin Exposures Due to Contamination With Hot Particles", alerted licensees to current skin exposure concerns resulting from personnel skin contaminations of small or microscopic particles of radioactive material with a high specific activity.
The inspector reviewed the status of the Millstone Station Hot Particle program through discussion with the station Health Physicist and review
of several memos and surveys.
The inspector was able to determine the
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following:
l The licensee is cognizant of the current hot particle problem,
The licensee had previously addressed potential measurement problems
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with " hot chips" in a memo dated February 5, 1985, I
The licensee has developed a survey technique utilizing a
j tape-wrapped paint roller which has proved successful in " capturing" i
hot particles, i
Although two hot particles were recently identified during routine
surveys, no instances of personnel contamination have been j
identified which can be attributed to hot particle contamination.
Despite the actions described above, the inspector was able to determine that no organized hot particle program, i.e., one specifying areas and frequencies to be surveyed, additional mitigating actions, and dose assessment methodology to be used, had been developed. The station. Health Physicist indicated, however, that such a program was currently under development by the station HP staff and NUSCo Radiological Assessment i
Branch (RAB) and was expected to be formalized in the near futur i I
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The inspector noted that the upcoming Unit 2 fuel consolidation activities may involve a high potential for the generation of hot particles.
The
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licensee indicated they were aware of this potential and stated specific precautions had been developed and would be taken, along with the i
performance of specific " hot particle surveys", to support fuel l
consolidation activities.
Licensee development and implementation of a
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formal hot particle program will continue to be reviewed during ongoing NRC inspections.
9.0 ALARA The licensee's ALARA program was evaluated against criteria contained in the following:
10 CFR 20.1 " Purpose;"
Regulatory Guide 8.8, "Information Relevant To Ensuring The
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Occupational Radiation Exposures At Nuclear Power Stations Will Be i
As low As Is Reasonably Achievable (ALARA);"
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Regulatory Guide 8.10, " Operating Philosophy For Maintaining
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Occupational Radiation Exposures As Low As Is Reasonably Achievable",
and, l
Regulatory Guide 8.19, " Occupational Radiation Dose Assessment In
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Light-Water Reactor Power Plants Design Stage Man-Rem Estimates."
Licensee performance relative.to these criteria was evaluated by:
{
Discussions with cognizant personnel;
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Tours of radiologically controlled areas;
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Review of station ALARA goals;
Review of the 1986 " Millstone Nuclear Power Station Annual ALARA
Report;"
Review of the "ALARA Program Appraisal" conducted by the
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Radiological Assessment Branch; Review of work in progress; and
Review of Radiation Work Permits and associated ALARA reviews.
- Within the scope of this inspection, no violations were observed.
,
The licensee appears to be adequately implementing their ALARA Program.
For 1986, a non-refueling year, a total of 162 person-rem (goal 194) was expended. For 1987, a refueling year, a goal of 680 person rem (602 rem
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for the outage and 78 rem for routine operations) has been established.
As of July 6,1987, the licensee had expended approximately 364 person-rem in support of the current outage.
Exposure tracking for scheduled
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outage tasks appeared to be effective with a close correlation between the l
estimated exposure and current actual person-rem.
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l The licensee has made significant gains in improving their goal setting methodology.
In previous years ALARA goals were developed by the Radiological Assessment Branch (RAB)' based upon meeting INPO guidelines for person-rem expenditure, often without considering the scope of actual work planned.
This made goals unrealistic as a management tool by which to judge the success of the ALARA Program.
However, for 1987, ALARA goals were established based solely upon job estimates and previous exposure histories.
Additionally, communication of these goals to station personnel appeared effective to the inspector.
One strong point was identified in that the Unit 2 and Unit 3 ALARA coordinators were being used to assist the Unit 1 ALARA coordinator with ongoing outage ALARA planning.
This provided an opportunity to broaden their skills and experience for upcoming outages at their respective units.
Several weaknesses relative to implementation of the ALARA Program were observed during tours of the radiologically controlled areas.
Specifically, Personnel do not appear to make effective use of posted ALARA
reviews.
HP technicians, as well as workers, did not know which ALARA Review went with which Radiation Work Permit (RWP).
Unlabeled radwaste containers provided unnecessary exposure to
personnel without their knowledge (See Section 4.1
)
Radwaste and protective clothing bags were handled by Radwaste
perso nel for several minutes before dose rates were determined.
l l
There was only limited use or posting of low dose rate waiting
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areas.
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The inspector discussed the above weaknesses with licensee management, who stated they would evaluate the above weakness and institute actions to improve this area.
I 10.0 Exit Meeting
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The inspector met with licensee management denoted in Section 1.0 on July 10, 1987, at the cenclusion of the inspection. The scope and findings of the inspection were discussed at that time.
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