IR 05000245/1988006

Insp Repts 50-245/88-06,50-336/88-09 & 50-423/88-07 on 880411-15.Violations Noted.Major Areas Inspected:Radiation Protection Activities,Including Internal & External Exposure Controls & Station ALARA Practices

ML20154R806
Person / Time
Site:	Millstone
Issue date:	05/24/1988
From:	Gresick J, Shanbaky M, Thomas W, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154R787	List: IR 05000245/1988006 ML20154R782 ML20154R799
References
50-245-88-06, 50-245-88-6, 50-336-88-09, 50-336-88-9, 50-423-88-07, 50-423-88-7, NUDOCS 8806080198
Download: ML20154R806 (10)

Text

-

'

. .

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-06 50-336/88-09 50-423/88-07 Docket N License No. DPR-21 Category C DPR-65 NPF-49 Licensee: Northeast Nuclear Energy Company P. O. Box 270 ,

Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Generating Station Irspection At: Waterford, Connecticut Inspection Conducted: April 11-15M988

- K x s/4 Inspectors: a 0 , > M2 h FMc>dy'

W. Th6 mas, RadiatFon Spbcia st fRPS, FRSSB /date'

// i % a:7

&J.~ Gresick, Radiation Specialist /

5~ okf

' date' l

/ FRPS, FRSSB  ;

/r I" > < -rk [

'

OhY date' !

ggvA.'We~adock,RadiationSpecia'ltst FRPS, FRSSB l

Approved by: g// f V M. Shanbaky,' thief FacilfMis Radiation ' date Protection Section, Facilities Radiological l Safety and Safeguards Branch Inspection Summary: Inspection on April 11-15, 1988, (Report No /88-06, 50-336/88-09, 50-423/88-07)

8806080198 880527 PDR ADOCK 05000245 Q DCD

' -

. .

.

2  :

Areas Inspected: Routine, unannounced inspection to review radiation '

protection activities, Areas reviewed included internal and external exposure controls and station ALARA practices. The inspection also included a review of the Unit 1 spent fuel pool cleanup, radiation protection organization and management controls, and Unit-3 containment entrie Results: One violation was identified, however, the remainder of the radiation protection program was being effectively implemente _ _ _ _ - _ - -

.

- -

.

l Details 1.0 Persons Contacted T. Arnett, Unit 2 I&C Control Engineer

• Brennan, Unit 1 Radiation Protection Supervisor (RPS)

R. Crandal, NUSCO Supervisor Radiological Engineering D. Fitts, Unit 2 Alara Coordinator

• B. Granados, Station Health Physicist

• H. Haynes, Station Services Superintendent

• J. Laine, Unit 2 RPS

• F. Perry, Unit 3 Asst. RPS

• Sachatello, Unit 3 RPS

• Schleicher Jr. , Unit 2 I&C Assistant Supervisor

• M. Sforza, Senior Engineer, Quality Services Department

• J. Stetz, Acting Millstone Superintendent Station

• Attendeo the exit meeting on April 15, 1988

Other licensee personnel were also contacted during the course of this inspectio .0 Purpose The purpose of this routine, unannounced inspection was to review the implementation of the Radiation Protection Program. The following areas were included in this review:

-

Status of Previously Identified Item Organization and Management Control External Exposure Controls,

-

Internal Exposure Controls,

-

ALARA,

-

Unit 1 Spent Fuel Pool Cleanup

-

Unit 3 Containment Entrie .0 Status of Previously Identified Items 3.1 (Closed) Inspector Follow-up Item (245/87-15-04; 336/87-17-02; 423/87-14-02). Documentation and certification of "Auditor / Lead Auditor" qualifications to meet ANSI N45.2.23-197 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ - -

-

t

}

1

'

The inspector noted that Nuclear Engineering and Operations Procedure NE0 3.01, dated March-28, 1988, now restricts the Lead Auditor position to fully ANSI qualified personnel from the Quality Services Departmen This item is close .2 (Closed) Inspector Follow-up Item (245/87-15-05; 336/87-17-03; 423/87-14-03). The RAB Audit Program is directed by the Supervisor of Radiological Protectio The inspector noted that, although RAB personnel may be utilized as a resource in performing these audits, the audits are performed under the independent direction and cognizance of the Director, Quality Services with Quality Services personnel serving as Lead Auditor This item is close .3 (Closed) Inspector Follow-up Item (245/87-31-01; 336/87-26-01; 423/87-27-01). Revise procedure HP 911/2911/3911 to clearly specify qualification requirements for respirator issue personnel. Procedure HP 911/2911/3911 has been revised to include the requirement for training and qualifying respirator issue personnel. This procedure also referenced a training guide, MP-TT-HPIT-Respir-T01006, "Issue Respirator 0JT Guide", which describes the specific training require-ments for respirator issue personnel, provides areas for supervisory sign-offs of completed lessons, and requires supervisory evaluation of the respirator issue personnel performing this tas This item is close .0 Radiation Protection Organization and Management Controls The licensee's radiation protection organization and management controls were reviewed by the following methods:

-

discussions with licensee personnel,

-

review of Technical Specifications, Section 6.0, Administrative Controls,

-

review of Technical Specifications, Sections 6.1, Responsibility, 6.2, Organization, and 6.4, Trainin The Station Superintendent is responsible for the overall operation of the Millstone site while the Unit Superintendents are responsible for the operation of each of the three unit _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ - _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _

... _ _ - -- . . . . . _

'

..

. ..

.  !

.The inspector verified that each unit organization was as shown in Figure 6.2-2 of the Technical Specification ,

j All appropriate members of the onsite Radiation Protection Organization ;

i meet or exceed the minimum qualifications of ANSI N 18.1 1971. The Unit !

Radiation Protection Managers each meet the' qualifications of Regulator ,

Guide 1.8, Revision 1, May 1977. The Radiation Protection staffs of each

'

unit contain adequate numbers of individuals to assure proper control of j j

radiation and radioactive materials. A retraining and replacement program- !

for each unit staff is maintained under the direction of the Station

Superintenden Each unit Radiation Protection Supervisor (RPS) reports ;

to the Station Health Physics Supervisor, who reports to the Station r

'

Services Superintendent, who reports directly to the Station Superinten-dent. To date this organizational scheme has assured that each unit RPS has had adequate responsibility, authority, and management support to f ensure effective control over radiation and radioactive material r i

5.0 ALARA i The inspector reviewed the implementation of the licensee's ALARA Program j

,

by the following methods * i i.

,

-

discussions with the Unit 2 and Unit 3 ALARA Coordinators,

-

review of planned job exposure estimates, Il i

d

-

review of ongoing job exposure tracking, j i

j -

review of ALARA reviews and exposure controls for the current  !

unplanned mini-outage, l i i

-

review of procedure ACP 6.02, "Maintenance of Occupational Radiation Exposures ALARA", i

}

-

review of the three year 1987-1989 exposure budgets and forecast i

! 1 j It was determined from the above review that the licensee is meeting l

,

'

commitments to make reasonable efforts to ensure that occupational l exposures are maintained As Low As is Reasonable Achievable (ALARA). The j review of the results of evaluations since the last inspection indicate

that the licensee's program is adequate. Several examples of positive

performance in the ALARA area have been noted in the past year. Among

these is a site wide commitment to reduce future outage length and the j associated outage exposure.

i

!

!

,

1 s

r

]

.

. .

.

The licensee continues to set ALARA goals below previously attained levels. The following are the 1987-1989 three year average goals and the 1990-1922 average goal for each unit:

1987-89 Three Year Average Goal 1990-1992 3 Year Average Goal Approved Proposed Revision MP1 484 447 470 MP2 585 538 525 MP3 252 316 285 Exposure estimates for ongoing activities continue to appear reasonable and are tracked on a daily basi Plant workers are aware of and involved in the ALARA Program. Also the individual plant ALARA staffs were noted to be both familiar with and actively involved in the progress and application of the ALARA Program on a job by job basi .0 External Exposure Controls The licensee's External Occupational Exposure Control Program was reviewed by the following methods:

-

discussion with licensee personnel,

-

review of selected Radiation Work Permits and radiological surveys,

-

observation of Unit 3 containment entries and the Unit 1 Spent Fuel Pool clean-up work,

-

observation of radiological area postings,

-

review of radiological investigation reports associated with Unit 1 High Radiation Area door control,

-

review of the following procedures:

i

SHP 4912, "Radiation Work Permit Completion and Flow Control", 1

HP 951/2951/3951,"High Radiation Area Key Control".

l The following licensee strengths were noted during the above review: j l

The licensee was implementing upgraded hot particle controls to support Unit 1 Spent Fuel Pool clean-up activities. These included the performance of hot particle surveys twice per shif t and the ,

requirement for workers in specified areas to undress and monitor j for contamination every two hour J

Work party entries to the Unit 3 containment during subatmospheric conditions were noted to be well controlled and coordinated. An

'

appropriate level of HP staff was on hand to support the entr I

l l

j

-

. .

Numerous dose-reduction techniques were effectively utilized during the recent Unit 3 Reactor Coolant Pump (RCP) locking cup repai These included fabrication of a shielded RCP stand to allow work in the reactor cavity, use of a spare RCP for mock-up training, extensive HP coverage, and the use of TV monitors and radio-controlled dosimetry to allow remote observation and control. Surveys of work areas and dose rates associated with this were noted to be extensive and well documente The inspector also reviewed Unit 1 High Radiation Area (HRA)

controls. Technical Specifications (TS) Section 6.12 requires that each HRA with dose rates greater than 1000 MREM / hour be locke The licensee has had recurring problems with HRA gate control (see NRC Report No. 50-245/87-15).

Discussion with the licensee indicated four instances since December, 1987 to the present in which posted HRA doors were found unlocked at Unit 1. One door, located in the Radwas; Building, led to the Liquid Radwaste Lower Level area. The other three doors were accesses to the Unit I turbine deck. All four instances were identified by HP technicians performing an HP audit tour. The licensee instituted the HP audit tour system after NRC inspection 50-245/87-15 identified multiple concerns in area posting, labeling, and HRA contro The inspector reviewed area surveys for the above areas and performed additional measurements on the Unit 1 turbine deck during operatio The inspector identified that no accessible general area (i.e., at a distance 18" or greater from the source) radiation levels in excess of 1000 mr/hr existed in the above area Licensee corrective actions include a comprehensive plan to reduce the number of Unit 1 HRA doors by shielding or barricading of area The HP staff hn reviewed the current number and location of HRA accesses and has made specific recommendations as to which doors can be eliminated. Licensee effort in this area and overall adequacy of '

HRA control will continue to be reviewed during subsequent inspecticn '

7.0 Internal Exposure Controls l

The licensee's program for control of internal exposure was reviewed with i respect to criteria contained in the applicable regulatory requirement The licensee's performance with respect to the above criteria was :

determined by:

-

observations of work activities made during tours of Units 1, 2, and l 3,

l

. .. . .

.

-

review of selected records and procedures, and

-

discussions with licensee personne Within the scope of this review, one violation was identifte Licensee stre.gths and weaknesses are noted belo .1 Unit 1 Activities During this inspection, the licensee was involved in cleaning up the spent fuel poo These activities included removing activated and radioactively contaminated equipment, and packaging the material in containers for disposa The inspector found the following controls in plac All work was controlled by Radiation Work Permits requiring continuous Health Physics coverag Highly contaminated material was handled and packaged in a portable tent with a HEPA ventilation uni Personnel were required to wear full-face particulate filter respirators inside the tent enclosur Air samplers were positioned to provide monitoring of the general area air activity, and of the breathing zone where appropriat .

The inspector concluded that the licensee had provided positive internal exposure controls over these activitie .2 Unit 2 Activities During this inspection, the licensee was in an unplanned outage to repair leaking valves (safety injection and pressurizer PORV) in containment. The inspector reviewed internal exposure controls during this outag On April 9,1988, an incident occurred in which unanticipated high  !

iodine airborne activity was measured in contiit. ment, resulting in the assignment of 25 to 32 MPC-hours to six nidividuals. The j inspector reviewed the following sequence of event A remote grab sample was pulled and analyzed from the containment air monitor at approximatei/ 2:30 a.m. The analysis of this sample indicated that approximately 2.7 MPCs of iodine air activity was presen; in the containment. This l sample was used as the basis for entry ints containment without i limiting stay-times or using respiratory protecti<,n to limit i potential airborne intak l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ __ _ . _ _ _ __ _ - _ _ _ _ _ _ _ _ _ _ _ _ _

. . -

,. j l

.

8  ;

-

A containment entry was made at approximately 6:30 a.m. by three teams of HP technicians, 2 individuals to a team. The purpose of this entry was to collect grab air samples of containment air activity prior to allowing other work par*s to enter. These individuals were in containment for abo half-hour. Analysis of these grab air samples indicateo that iodine airborne activity ranged from 22 to 53 MP The inspector identified two areas of technical concern. First stay-times and respiratory protection were determined based on remote containment grab samples that are not representative of actual conditions. Second, a sample taken four hours prior to containment entry is not considered a timely representative of of actual conditions. The resulting inadequate evaluation caused an unplanned exposure of six workers to airborne iodine activity ranging from 25 to 32 MPC-hours. The inspector stated that failure to perform an adequate radiological evaluation to ensure compliance with 10 CFR 20.103 constituted an apparent violation of 10 CFR 20.201(b)(50-336/88-09-01).

The licensee subsequently revised Procedure HP 2920,

"Containment Entry", on April 15, 1988, to require that any containment entry be made no longer than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after air samplin .3 Unit 3 Activities During this inspection, two entries into the Unit 3 Containment were made. The Unit 3 containment is subatmospheric, requiring the use of a closed-circuit self-contained breathing apparatus (BioPak 60) for entry. The inspector observed air sampling and respiratory protection controls in support of the entries. The following strengths were note Pre-entry and post-exit medical screenings were given to the personnel participating in this activit Air sample results fran the containment area radiation monitoring systen, the remote grab sampling station, and actual grab samples taken inside containnent during the entry were in agreemen There were adequate supplies of respiratory protective equipment to support the entrie The inspector concluded that the licensee had demonstrated positive control of internal exposure to radicactive material during this activit . _ _ _ - - _ ,

.os' *

,.

l

8.0 Exit Meeting I The inspectors. met with the licensee personnel denoted in Section 1.0 of this report on April 15, 1988. At that time, the inspector sumarized the purpose, scope and findings of this inspection. 0n May 16, 1988 the inspector discussed the apparent violation with the Unit 2 Radiation Protection Supervisor by telephon ,

+