IR 05000245/1990004
| ML20012D247 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/06/1990 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20012D243 | List: |
| References | |
| 50-245-90-04, 50-245-90-4, 50-336-90-05, 50-336-90-5, 50-423-90-05, 50-423-90-5, NUDOCS 9003270095 | |
| Download: ML20012D247 (17) | |
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,1-s-sis lV U.S. NUCLEAR REGULATORY COMMJSSION
REGION I
Report Nos'. 50-245/90 04
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50 33579F03'
50-423/9F05 Docket Nos. 50-245.
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50-336 50 M 3 License Nos. DPR-21 Category C
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DPR 53
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c NPF 49 c
Licensee: Northeast Nuclear Energy Company P. O. Box 270 Hartford, connecticut 06101 Faclility Name:
Millstone Nuclear Generating Station, Units 1,2, and 3 f
Inspection At:
Waterford, Connecticut Inspection Conducted: February 12-16, 1990 Inspector:
R L tJumdi 3/$/96 R. L. Nimi tz, CHP, Fenior Radiation Specialist date c- /# d Approved by:.
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W.-J..Pasprak, Chief, facilities Radiation
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Inspection Summary: NRC Inspection on February 12-16, 1990 (NRC Combined Inspection Re 50 245/90-04; 50-336/90-05; and 50-243/90-05) port Nos.
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.~ Areas Inspected:
This inspection was a routine -an
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- radioloolcal-controls p.'egram at Millstone Station,nounced inspection of the Units 1, 2, and-3. Areas reviewed were the licensee's action on previous inspection findings, the organization and staffing of the station's radiological controls organization, A
contamination controls, and observations during plant tours.
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Results: 0ne apparent violation was identified during the inspection. The apparent violation involved three examples of failure to follow radiological controls procedures (Details Report Sections 5.4, 6.0, and 7.0).
Several areas
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needing licensee attention were also identified. These were contamination i
control and definition of the radiological controls organization.
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Details T
1.0: Individuals Contacted 1.1 Northeast Nuclear
- H. Haynes, Station Services Superintendent
- J. Sullivan, Manager Health Physics Operations.
- J. Laine{ello Unit 3 RPSUnit 2 Radiation Protection Supervisor (RPS)
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- R.
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- C Palmer, Manager Health Physics Support
1.2 Nuclear Regulatory Commission j
L W. Raymond, Senior Resident Inspector
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- K. Kolaczyk, Resident Inspector
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- D. Dempsey, Resident Inspector-j
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- Attended the exit meeting on February 16,1990
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Other licensee personnel were also contacted during the course of tiiis
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inspection.-
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2.0 Purpose and Scope of Inspection The purpose of this routine, announced inspection was to review the following areas:
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l the status of previously identified-items l
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organization and staffing of the radiological controls organization
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contamination controls J
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observations of radiological controls during plant tours including.
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- external and internal exposure controls
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- posting, labeling and access control, as appropriate to
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radiologically controlled areas
- housekeeping
- industrial safety
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- ALARA activities j
The evaluation of the licensee's performance in the above areas was based i
on observations during plant tours, discussions with cognizant station
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- personnel, and review of documentation.
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3.0 _ Status of Previously Identified Items
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(Closed Violation The licensee's unit 2 containment I
3.1 atmosphe)re gaseous a(50-336/88-22-02)ivity monitor was out of service and irborne radioact i
the licensee did not implement the Technical Specification limiting
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'4 The~ inspector reviewed the adequacy and implementation of the corrective-P actions outlined in the licensee s December 7, 1988 letter to the NRC.
Theinspector'sreviewindicatedthelicenseemodifledswitchesonthe Nuclear Measurements Corporation instrument panels to prevent the switches-from being left in the test position.
Leaving-the switches in the test position disables the instruments. This issue does not exist at Units 1
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and 3 because they do not have similar switches. This violation is closed.
The licensee did not functional 1 3.2.(Closed Violation (50-336 89-13-07) location ) for the unit 2 spent fbel check t e alarm horn (at t e remote pool criticality monitors. The inspector reviewed the adeguacy and implementation of the corrective actions outlined in the -licensee's letter to the NRC. The licensee revised procedure December 8,1989,ber 8,l ti SP2404AN on Novem 1989 to include local alarm and horn check requirements.- This vio a on is closed.
The inspector reviewed the criticality alarm checks for the remote alarm locations for the spent fuel pool monitors for units 1 and 3.
The requirements and-testing of the unit 3 monitors were considered adequate.
However there were no Technical Specification requirements for testing the
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spent fuel pool area radiation monitors, for purposes of identification-of u
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criticality events, at unit 1.
L The inspector noted that 10 CFR 70.24, Criticality Accident Requirements, e
specifies minimum criticality accident monitoring instrumentation. The l
detectors must be able to detect an event that produces a specified
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absorbed dose and must have detector alarms set as specified in 10 CFR 70.24. At the time of this inspection, the licensee could not provide information to demonstrate meeting the requirements of 10 CFR 70.24. The L
need for and appropriateness of current spent fuel pool monitoring at unit i:
1 is an unresolved item (50-245/90-04-02).
l (0 pen Unresolved Item (50-336/89-13-13 The licensee's unit 2 control room proced)ure did not)rovide adequate guida)nce for bypassing area radiation 3.4 monitor alarms. T1e licensee had not taken any action on this matter. This
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L item will be reviewed during a subsequent inspection.
(0 pen) Violation (50-245 The licensee did not establish-adequate contamination control co/89-13-01)ntrol-procedures. The-inspector reviewed the 3.5 matter with respect to the corrective actions outlined in the licensee's October 2,1989 letter to the NRC. The licensee innlemented the corrective actions outlined in the attachment to letter. At tie time of this l
inspection, the licensee had not reviewed and evaluated the long term corrective actions outlined in a special contamination
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control / unconditional release task force report completed as part of the long term corrective actions to prevent future violations. This matter is discussed in Section 5.0 of this repor.
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requirem)ents of 10 CFR 71.5 for shi)ing radioactive material (two (Closed Violation (50-245/89-13-02 The licensee did not adhere to the 3.6 examples). The inspector reviewed le adequacy and implementation of the letter to corrective actions outlined in the licensee s October 2,1989,ified the NRC. The licensee implemented the corrective actions spec therein. This violation is closed. This matter is further discussed in Section 5.0 of this report.
(Closed) Violation 50-245/89-13-03) The licensee did not complete shipping papers as required b(y 49 CFR 172.200. This violation was incorporated into 3.7 violation number 50-245/89-13-02 (See 3.6 above) as a second example of failure to adhere to 10 CFR 71.5.
Therefore this item is closed for administrative purposes.
3.8- (0 pen) Follow-up Item (50-245/87-24-01; 50-336/87-21-01; 50-423/87-19-03)
The licensee is to review the calibration, and surveillance of radiation monitoring systems. The licensee performed a detailed two phase review of the calibration and surveillance of all station process, effluent, and area.
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radiation monitors. The licensee's reviews were performed against appropriate regulatory guidance and were considered thorough. At the time of this inspection, the licensee could not provide the status of several monitors for which the review had indicated the monitors did not meet minimum requirements. The monitors were the unit 3 component cooling water monitor the unit 3 steam generator blowdown monitor, the unit 3 waste
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neutrallzer sump monitor, and the unit I service water monitor. The licensee initiated an immediate review of these monitors.
(0 pen) Unresolved Item 50-245/88-03-02 The unit I high range containment radiation monitor is sub(ject to inaccura)cy because of temperature response.
3.9 The inspector review indicated the licensee was unable to indicate at the time of this inspection whether the monitor response was in conformance with NUREG 0737 accuracy requirements. This matter remains unresolved.
4.0 Organization, Staffing, and Qualifications The ins ector reviewed the organization and staffing of the licensee's radiolo ical controls organization. The inspector also reviewed the qualifi ations of selected individuals within the organization. The
licensee's Technical Specifications for units 1, 2, and 3 and applicable procedures were used as acceptance criteria. Attachments 1 and 2 to this report depict the current approved radiological controls organization.
no violations were identified.
Within the scope of this inspection, discussed with the licensee's However, the following matters were personnel:
The licensee reorganized the radiological controls organization about L
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one and one half years ago. However, the licensee's administrative
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procedures have not yet been revised to reflect the new organization
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and responsibilities.
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u The licensee has not formally identified which individual-within the
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-organization is the radiation protection manager (RPM..The RPM is an lJ important position identified in the Technical Specif cations. The inspector questioned the current key individuals within the radiolo ical controls organization as to who the RPM was. These j
individ als were not able to identify who the RPM was.
The licensee's Technical Specification 6.2.1 for units.1 and 3
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require that all-operating organization positions be def ed in ap ropriate documents to identif lines of authority, res onsibility an communication.
In li ht of he above observation th ins questioned whether adequa e documentation was available to meekector
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the-l Technical Specification requirements for the radiolo ical controls
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l organization.
In addition, it was not clear that al organizational positions were described as required.
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The inspector stated that the above matters, identification of the RPM and was an unresolved item.
definition of organizational responsibilities,but will be tracked against This matter-is applicable to units 1,2 and 3, unit 1. (50-245/90-04-03).
L 5.0 Contamination Control
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5.1 General l.
The inspector reviewed the contamination control program. In particular, the-' inspector focused on the two following events:
Event 1-release of a hydrolazer with undetected radioactive contamination from the protected area on May 11, 1989.
Event 2-identification of contaminated tools-at various tool storage facilities outside the rotected area and identification on September 6,.
1989 of a second conta inated hydrolazer located in a tool storage l
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The inspector reviewed the circumstances surrounding the identification of the above twe events and the licensee's corrective actions taken.
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station tours, the inspector also reviewed general contamination control
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practices.
5.2 Event 1 H
On May 11,'1989, the licensee released a hydrolazer with undetected
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contamination from the protected area of the Millstone Station. The e
hydrolazer ap arently was contaminated with water from the unit I reactor l
cavity. The RC issued a Notice of Violation and a civil penalty on August 31, 1989, for this event. The inspector reviewed the adequacy and im lementation of corrective actions outlined in the licensee's October 2, 19 9, letter to the NRC.
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The inspector also reviewed the licensee's action on the broader issue of control of radioactive material outlined in the NRC's August 31, 1989, letter to the licensee. This broader issue was the need to improve the planning,f radioactive material at the facility. review, and control of activities that can control o The inspector's review indicated the licensee implemented the defined, corrective actions outlined in the attachment to the licensee's October 2, 1989, letter to the NRC.-
These actions included the following:
the requirement that all vehicles and equipment leaving the
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protected area of the station be surveyed by radiological controls l-
. personnel and that property passes for material leaving the protected area are co-signed by radiological' controls personnel the requirement that radiological controls personnel shall survey all
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items leaving the radiological controlled areas submission of an informational licensee event report
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the surveying of all potentially contaminated tools and material that
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had been inside the radiological controlled area the establishment of a Contamination Control / Unconditional
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Release Task Force to review the contamination control program P
the licensee's station superintendent directed all plant operations
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review committees to be alert to potential concerns which could cause a similar problem procedures were revised to require radiological controls personnel
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notification when tying into potentially contaminated systems.
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The ins)ector reviewed the Final Task Force Report, dated JanuaryIstration, 1990, and noted-t1at the report covered the areas of lessons learned, admin
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facilities, training, technology, and motivation.
The report contained 15 major ucommendations.
l The inspector also noted that the report. included recommendations to improve oversight of activities by a proposed reorganization.
The inspector concluded that the licensee's immediate corrective actions to
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control removal of potentially contaminated material from the protected area appears to be adequate. However, the licensee's task force report recommendations) to improve identified a' number of long term actions (time of this ins)ection, the control of contaminated material. At the l
licensee's personnel could not provide information as to w1at actions would l
be taken on the recommendations. The licensee's personnel indicated that an action plan would be developed to act on the recommendations.
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Based on the inspector's observations-(see Section 5.4 of this report)
there appears to be a need to strengthen egress controls from the i
radiological controlled areas of the station, particularly unit 3.
In-addition, borne radioactivity event in tho unit I reactor building the recent loss of control of radioactive material which resulted i
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in an air Section 6 of this report) indicates an apparent need to strengthen (see oversight and control of work activities.
5.3 Event 2 j
As a result of the contaminated hydrolazer. event (discussed above) the licensee initiated a review of its contamination control practices. This -
review and the results of an outside audit determined that other contaminated material may have left the radiological controlled area of the Millstone Station. The licensee initiated a survey program to determine the extent and magnitude of contaminated tools and components that may have been released from the licensee's facilities. During this survey on September 6,1989, the licensee found a second contaminated hydrolazer from unit I at a tool warehouse located outside the protected area. The Task Force (discussed above) also reviewed this event.
The inspector's review indicated that as of the date of this inspection, the licensee had surveyed all offsite facilities where potentially contaminated material may be stored. The licensee also surveyed private facilities where appropriate.
The survey program lasted 7 months and involved surveys of in excess of 450 000 items. The total-radioactivity estimatedtobeonthetools,-identifiedascontaminated,wasabout8 microcuries. About 6 microcuries of radioactivity was contained-in the internal components of the second hydrolaser stored at the licensee's tool warehouse.
l The licensee concluded that the remaining 2 microcuries distributed among
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the tools identified as contaminated presented no-significant risk to the public. The inspector noted that the licensee continues to survey some onsite areas located within the protected area.
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The inspector. concluded that the licensee took appropriate action to identify and return contaminated material to the radiological controlled area.
In addition the licensee established administrative controls to ensure material and vehicles are surveyed prior to release from the protected areas to offsite areas. The licensee also strengthened controls
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l for removal of material from the radiological controlled areas of-the station.
However as discussed below (Section 5.4, additional attention to egress control,from the radiological controlled) areas appears warranted.
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5.4 General Contamination Control Practices The inspector reviewed general radioactive contamination control practices during tours of the station.
Practices reviewed included posting and barricading of radiological controlled areas, personnel frisking,. and frisking of material removed from the radiological controlled area.
.Within-the scope of this review, one apparent violation was identified as follows:
Technical-Specification 6.11 for units 1,2, and 3 requires in part that radiation protection procedures be prepared consistent with the requirements of 10 CFR Part 20 and adhered to for all operations involving personnel radiation exposure. The licensee's Administrative Control
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Procedure (ACP) 6.18, Revision 0, Potentially Contaminated Material Control and Personnel Friskin Radiological Control Area Egress, g Requirements, states in Section 6.1.2,l Control Area that all personnel exiting a Radiologica will either perform a frisk consisting of the monitoring of hands and soles of the shoes or pass throuch a whole body contamination monitor, specific requirements will be postec at the exit area.
On February 12, 1990, at about 3:00 P.M. the inspector observed two individuals leave-the radiological controlled area of the Millstone unit 3 radwaste truck bay without performing the required frisking. The ins)ector.
noted that a sign posted in the area specified that a whole body fris( was
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required prior to exiting.
In addition, a portable frisking station, suitable for monitoring the hands and soles of the feet, was in close proximity to the exit point but was not used.
The inspector indicated that failure of the personnel to frisk prior to exiting the radiological controlled area as specified in procedures was an apparent violation of Technical Specification 6.11. (50-423/90-05-01)
The licensee immediately initiated action to identify the individuals and counsel them. The licensee also placed additional posting at the exits of the unit 3 radwaste truck bay to preclude personnel from exiting unless personnel frisking for contamination was performed.
The inspector noted the following during tours:
The radiological controlled area at Millstone unit 3 was not clearly
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posted to indicate that personnel would be either entering or exiting
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a radiologically controlled area. The posting was not similar to units 1 and 2.
There were numerous entry points into and out of the unit 3 radiologically controlled zone. Also, there were no postin indicate that tools and equipment removed must be surveyed.gs to
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l Inspector' discussions with unit 1 operations personnel. indicated that u
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operators routinely exit radiological controlled areas (e.g. upper
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elevation of radwaste building) without frisking.
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Established frisking locations ( e.g., unit I radwaste building and
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the unit 3 radiological controlled areas) allow personnel who have not
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potential for spreagle with people who have frisked creating a frisked to intermin i
of contamination.
l-The inspector indicated the above observations indicate the need to improve egress control from the radiological controlled area to ensure personnel,
L equipment, and material, as appropriate, are subjected to contamination
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6.0 Radwaste Loading Event 31, 1990, the unit I reactor Atabout10:30A.M.onJanuarbeingcontaminated. workers exitin!1 of 19 people were were identified as A tot building,have low level contamination on their shoes.
I found to Two individuals exhibited low level contamination on other portions of their person.
i Because..of the lack of any other significant on-going work, the licensee j
H quickly traced the source of the contamination to a radwaste loading
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operation on the 108 foot elevation of the unit I reactor building.
Personnel-on the 108 foot elevation had' dumped dry control rod drive (CRD)
'l a shipp ng cask. g up to 35 R/hr on contact, from a bucket into the top of l
filters measurin
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l The licensee concluded that an apparent airborne
l radioac ivity event associated with the loading deposited low level
L contamination on various areas of the unit I reactor building.
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'the reactor building was posted as a contaminated area
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technicians were dispatched to' collect airborne radioactivity samples
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the control room was notified'
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a plant incident report was initiated
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personnel working in the reactor building-were whole body counted I.
the event was discussed with the entire health physics operations
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department on February 1,f the event was initiated
1990 a root cause evaluation o R
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The licensee developed preliminary root and contributory causes of the event. The licensee's preliminary root cause of the event was the failure to perform adequate planning, and lack of supervision to review the work activity and recognize the potential for airborne radioactivity.
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licensee's preliminary root cause evaluation identified weaknesses in airborne radioactivity controls, documentation of surveys, adequacy of the radiation work permit, and job supervision.
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The inspector reviewed the above event. The following matters were reviewed:
- circumstances associated with the event including initial corrective actions
- adequacy and timeliness of the licensee's root cause evaluation
- extent of-personnel contamination and internal exposure to airborne radioactivity extent of external ersonnel exposure
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- adequacy of radiolo ical controls applied to the work activity-
- training and qualif cation of personnel. using respiratory protection equipment
- qualifications of radiological controls technicians providing coverage for the activity The inspector concluded that the licensee's initial response to the contamination event was timely and appropriate. The licensee's establishment of an investigation team to evaluate the event and develop root and contributory causes of the event was commendable.
The inspector's overall conclusions were consistent with the licensee's preliminary evaluation of root and contributory causes.
Within the scope of this review, one apparent violation was identified as follows:
The licensee's Technical Specification 6.11 for units 1, 2, and 3, requires that radiation protection procedures be prepared consistent with the requirements of 10 CFR Part 20 and adhered to for all operations involving personnel radiation exposure. The licensee's radiation protection procedure SHP 4912, Revision 11, Radiation Work Permit Completion and Flow.
-Control,- s)ecifies in Section 8.1.4 that radiation work permits (RWPs) when signed by lealth~ physics (HP) signify adequate radiation controls have been specified and are (or will be ) in effect for the RWP.
-The loading of the CRD filters into the shipping cask was controlled by RWP No. 22 (undated) entitled,hed addendum sheet for details." Tools, Equipment, Irradiated
" S.F.P. Cleanup:
Hardware in SFP. See attac Tho inspector noted that RWP No. 22 did not specify any engineering controls to minimize airborne radioactivity on the job.
The inspector noted that a small HEPA ventilation system was used during the dumping of the filters into the shipping cask. However it was inadequate to contain the high airborne radioactivity levels generated during the dumping operation. The dry, highly radioactive CRD filters were physically dumped into the top of the shipping cask which created airborne radioactivity.
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The inspector noted that removable contamination levels on the top of the shipping cask area where the bag was dumped measured up to 60 millirad /hr.
Also, removable contamination levels on the unit I reactor building elevation (fourth floor) directly below the 108 foot elevation indicated up to 20,000 disintegrations per minute (DPM).
An airborne radioactivity sample, collected some distance away from the dumping activity and not representative of the airborne radioactivity concentration values at the dumping area, indicated about 4.1 times the quarterly airborne radioactivity concentration values specified in 10 CFR 20 Appendix B.
The airborne radioactivity was principally cobalt 60 and unidentified gross alpha emitters.
The inspector noted that RWP No. 22 did not specify any requirements for airborne radioactivity sampling during the dumping activity. No airborne radioactivity sampling was performed in the work area where the filters were being-dumped into the cask.
The inspector concluded that although the RWP was signed by a health physics supervisor, adequate radiation controls to prevent high airborne radioactivity were not specified on the RWP nor were they in effect during the dumping of the CRD filters into the shipping cask.
The inspector indicated that failure to establish an ade uate RWP to control the handling of the highly radioactive material 6.11. ( 0-245/90 04)-01)
CRD filters was an apparent violation of Technical Specification The inspector noted that this apparent violation was also identified by the licensee. The inspector reviewed the licensee's identification with respect to the five criteria for exercise of discretion for non-issuance of a Notice of Violation, identified.in 10 CFR 2 Appendix C.
The inspector noted that the item was identified by the licensee and therefore the licensee meets criterion 1.
The inspector's review indicated the item did not appear to be an apparent Severity Level 3 problem and therefore the licensee meets criterion 2.
The matter was not required to be reported and therefore criterion 3 does not apply. The licensee was initiating corrective actions and therefore the inspector could not fully evaluate the licensee's conformance with criterion 4 involving timeliness and adequacy of corrective actions.
Regarding criterion 5, involving adequacy and implementation of corrective actions for previous events, the inspector noted that the licensee has experienced problems with the control and oversight of activities involving radioactive materials. These problems were weaknesses in surveys and control of radioactive materials resulting in contaminated material being released from the station and problems with packaging and shipment of radioactive material.
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As discussed above (see Section 5.1 of this report), the NRC issued a Notice of Violation and Civil Penalty on August 31 1989, for problems with control of radioactive material. The NRC concluded in the August 31, 1989, letter that the violations identified indicate.the need to improve the planning,f radioactive material at the licensee's facility. review, and control of activities tha control o The int.pector's review of this matter and discussions with the licensee's personnel indicated the root cause of the problem was inadequate planning and supervisory review for the dumping of the highly radioactive CRD filters into the shipping cask, and is an additional example of the licensee's lack of adequate planning and control of activities that could result in loss of control of radioactive material. The inspector concluded that it was reasonable for this job to have been pro)erly planned to minimize the generation of airborne radioactivity, tie spread-of radioactive contamination, and the subsequent contamination of personnel.
Therefore, the licensee does not meet criterion 5 for the corrective actions.
The inspector noted the following other matters associated with this problem:
The licensee allowed the job to be performed under an addendum to an
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RWP. It was not apparent that the licensee's procedure authorized use of an addendum to add additional work to an already existing RWP.
A RWP task force was formed to review the stations radiation work
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permit program. The licensee's Health Physics Operations Manager expressed concerns for use of an addendum to existing RWPs. On January 30, 1990, a decision was made not to use the addendum as of February 4, 1990. The incident occurred'on January 31, 1990.
7.0 Plant Tours The inspector toured the station during the inspection. The following matters were reviewed:
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posting, barricading and access control as appropriate to radiation and high radiation areas storage and control of radioactive materials
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use and proper wearing of personnel dosimetry devices
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implementation of basic ALARA practices
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housekeeping
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.Within the scope of this review, one apparent violation was identified as follows:
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. Technical Specification 6.11 for units 1, 2, d consistent with theand 3, require th'at procedu for personnel radiation protection be prepare requirements of 10 CFR Part 20 and adhered to for all operations involving
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The licensee's radiation protection procedure HP 905/2905/3905{oredwithin Revision 10, states in Section 5.5.1.1 that all radioactive material s the confines of radiological-control areas and outside of posted contamination areas shall have a tag / sticker affixed with the radiation symbol and the words Caution Radioactive Material or Danger Radioactive Material, and the radiation levels of the material or container.
14 1990, at about 3:00 P.M. the inspector. observed two.
On February (55, gallon drums) on the stairwell of the unit I radwaste containers
. building. The drums were outside a posted contamination area, and contained spent liquid waste filters. The containers were-inside a posted High Radiation Area and Technical Specification access controls were required.
The inspector made independent radiation measurements of one of the drums R
i which was labeled caution Radioactive Material. The inspector measured contact radiation levels of at least 120 mR/hr. The label indicated i
<1mR/hr.
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The other drum measured about 30 mR/hr on contact and was not labeled.
It was next to the drum measuring 120 mR/hr. The inspector indicated that failure to post containers of radioattive material in accordance with procedure requirements was an apparent violation of Technical L
Specification-6.ll. (50-245/90-04-01)
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The inspector made the following observations which were discussed with the j
licensee's personnel:
The High Radiation Area access control postings at the station were
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not consistent among the different units. The licensee initiated a l
review of this matter.
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The method of controlling access to the High Radiation Area Access key
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locker was not consistent.
Different keys were used to control-
access. The licensee initiated a review of this matter.
The High Radiation Area access door to the -5 foot unit 2 aerated
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waste tank exhibited a gap in the door whereby an individual could potentially reach around and open the door. The licensee subsequently welded a steel plate over the gap.
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The inspector noted guard railing to be missing from the unit 2 spent
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fuel pool area. A rope was being used as a guard rail. The licensee s
replaced the rope with steel guard rails.
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Numerous individuals were wearing their dosimetry on different
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portions of their person and the pocket dosimetry and TLD were
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separated. These observations were not consistent with the licensee
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recommended practices.
The licensee maintains a radwaste prccessing buildin called the MRRF.
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The inspector noted that activities in the building e.g.,radwaste compaction,dioactivity. repackaging waste, deconning of componen s) could ge airborne ra Although the specific processes had what was described as HEPA ventilation systems the inspector noted that the ventilation systems were not systematically checked for integrity.
Although air samples were collected at the exhaust of the systems, the representativeness of the sam) ling was questionable. Open doors.
. allowed air to blow through tie facility. Although the licensee indicated no significant. contamination occurred outside the process i
areas and no significant airborne radioactive material was identified, the licensee could not provide, at the. time of the inspection, a documented evaluation of the potential airborne-radioactivity releases-
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The inspector observed numerous drums of radioactive material, in the
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apparently reusable material, stored inside the protected area environment. Some of the drums were showir.g rust. Inspector checking-of one drum noted that it had been stored in the environment for at least one year. The inspector noted that the storage areas are checked once-per month but not each drum is checked.
The stacking of
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the drums prevents examination of the' integrity of each drum. The inspector questioned the acceptability of this practice.
The inspector's discussion with operations personnel indicated'that
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water puddies collect on the top elevation of the unit I radwaste building. Since portions of the area are posted as contaminated areas, the inspector questioned the licensee's personnel as to where-the water goes. It appeared that water could potentially run out through cracks in the wall area to the protected area. The licensee initiated a review of this matter,
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8.0 Exit Meeting The inspector met with the licensee personnel denoted in Section 1.0 of i
1990. At that time, the inspector summarized this report on February 16, dings of this inspection.
the purpose, scope, and fin
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Health Physcs speaalist Unit 1 UnN2 Unit 3 Radiation Protection Supervisor Radiation Protection Supervisor Radiation Protection Supervisor
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Radiation Protection Scientist Radioactive Materials Supervisor Services Handling Supervisor I
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