IR 05000245/1990014
| ML20059E234 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/16/1990 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059E222 | List: |
| References | |
| 50-245-90-14, 50-336-90-15, 50-423-90-13, NUDOCS 9009100097 | |
| Download: ML20059E234 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
Report Nos.. 50-245/90 14 50-336/90-15 M 23/90-13
Docket Nos.
50-245 5UU35 -
50-423
' License Hos. DPR-21 Category C
DPR W C
NPF T9 C
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l Licensee: Northeast Nuclear Energy Company P. O. Box 270 l
Hartford, Connecticut 06101 Facility Name: Millstone-Nuclear Generating Station, Units 1,2, and 3 Inspection At: Waterford, Connecticut Inspection Conducted: July 23-27, 1990 Inspector:
Md I Who L
R. L. Nimitz, CHP, SeniorUtadiation Specialist 7.c Approved by:
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ILM O
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W. J.-Pasc<1aK4 Chief, facilities Radiation d' ate'
Protecti'odSection Inspection Summary: NRC Inspection on-July 23-27,1990(NRCCombined Inspection Re 50-245/90-14; 50-336/90-15; and 50-243/90-13) port Nos.
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radioloc'ical controls program at Millstone Statlon, announced inspection of the Areas Inspected:
This inspection was a routine un Units 1, 2, and 3.
Areas revieweiwerethelicensee'sactiononpreviousinspectionfindings,the organization and staffing of the station's radiological controls organization, outage planning and preparation the ALARA Program, radioactive and contaminated-material control and contaminatlon controls, external and internal exposure controls, and observations during plant tours.
Results: One non-cited violation was identified during the inspection. The violation involved failure to. post a radioactive materials storage area (Details Section7). Areas for improvement identified included definition of radiation protection manager responsibilities, improvement in contamination control procedures, and improvement in external exposure control program procedures.
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9009100097 900816 POR ADOCK 05000245l
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Det ai_1_s 1.0 Individuals Contacted 1.1 Northeast Nuclear
- S. Scace, Millstone Station Director
- H. Haynes, Director, Unit 1 Station Services Superintendent
- J.
Stetz,
- J. Sullivan, Manager Health Physics Operations.
- J. Laine, Senior Scientist
- C. Palmer, Manager Health Physics Support
- H. Siegrist, Supervisor, Radiological Protection
- F. Libby, Supervisor Assessment Services 1.2 Nuclear Regulatory Commission K. Kolaczyk, Senior Resident Inspector W. Raymond Resident Inspector D. Dempsey, Resident Inspector
- P. Habighorst, Resident Inspector
- Attended the exit meeting on July 27, 1990
Other licensee personnel were also contacted during the course of this inspection.
2.0 Purpose and Scope of Inspection The purpose of this routine, unannounced radiological controls inspection was to review the following areas:
the status of previously identified items
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organization and staffing of the radiological controls organization
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audits
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contamination controls
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external and internal exposure controls
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ALARA activities
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3.0 Status of Previously Identified items (Closed Unresolved Item There were no Technical Specific)ation requirements (50-245/90-04-02)for testing the spent fuel pool area radiation 3.1 at Unit 1.
monitors, for purposes of identification of criticality events Such provisions were usually contained within Technical Specification '
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Inspector review indicated a criticality monitor was in the Unit I new fuel vault and 10 CFR 70 did not require a criticality monitor for material stored in water filled pools. This matter is closed.
The inspector review, however, indicated that the new fuel vault at Unit 2 did not have a criticality monitor. The licensee provided information that indicated that exemptions had been received from the requirements.
However,for initial fuel handling was terminated.the exemptions were apparently termina license Terminations also occurred for Unit 3.
The licensee plans to re-apply for the exemption.
This matter will remain unresolved pending resolution of exemption-requests. (50-336/90-15-01; 50-423/90-13-01)
3.2- (0 pent Unresolved Item (50-245/90 04-03) The licensee was not able to identhfy whom the radiation protection manager was. Also, the responsibilities of all positions within the radiation protection organization did not appear to be well defined.
The licensee identified the positions and defined the responsibilities for Radiation Protection Supervisors, however, other positions in the organization (e.g., Assistant The licensee) were not defined in the licensee's administrative documents.ha Supervisors described the responsibilities of the RIN.
contamination control procedures.) The licensee did not establish adequate (0 pen) Violation (50-245/89-13-01 3.3 The licensee implemented the corrective actions outlined in the attachment to the licensee s October 2,1989 letter to the NRC letter. At the time of this inspection, the licensee had not reviewed and evaluated the long term corrective actions outlined in a special contamination control / unconditional release task force report completed as part of the long term corrective actions to prevent future violations.
The inspector's review during this ins)ection indicated that the licensee's Site Director issued the report to eac1 Unit Director and requested each director to review the recommendations and provide a plan for implementing the recommendations with appropriate justification for any exceptions. The review is on-going. This matter remains open.
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4.0 Organization, Staffing, and Qualifications The ins ector reviewed tie organization and staffing of. the licensee's radiolo ical controls orc,d individuals within the organization.The inspector also reviewed anization.
qualifi ations of selecte The and 3 and applicable licensee's. Technical Sper.ifications for Units 1, 2,hments 1 and 2 to this procedures were used as acceptance criteria. Attac report depict the curre'.t approved radiological controls organizatio.__
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no violations were identified, WithinthescobeofthisinspectionHowever,thef110wingmatterwasdIscussedwiththelice Durinfion protection manager,was (See section 3.2 of this Combined a previous inspection the licensee could not identif whom the
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Inspection Report). The licensee indicated that two individuals would act in the capacity of the radiation protection manager (RPM) dance for The
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licensee did not have in place administrative controls or gui
'the two individuals indicating how they were to implement their
responsibilities as RPM.
5.0 Planning and Preparation I-The inspector reviewed the licensee's planning and preparation in the area of radiological controls for the upcoming refueling of Unit 2. The following matters were reviewed:
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development of an outage radiological controls organization and
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definition of individual position responsibilities and authorities increased staffing including method of ensuring supervisory control
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over contractor radiological controls personnel special training including use of mockup training
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increased supplies
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ALARA planning efforts including use of lessons learned from previous i
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outages.
The evaluation of the licensee's performance in this area was based on discussions with personnel, review of documentation and observations by the
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inspector.
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Within the scope of this mview, no violations were identified. The licensee appeared to be p:rforming acceptable planning and preparation for the upcoming outage.
6.0 Audits and Assessments i
The ins ector reviewed the adequacy and effectiveness of audits of the
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radiolo ical controls program with respect to criteria contained in applica le Technical Specifications.
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The evaluation of the licensee's performance was based on discussions with licensee personnel, review of audits and assessments, and observations by the inspector.
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Within the scope of this review, no violations were identified.- The following observations were discussed with the licensee's representatives.
L The licensee's audit group schedules audits of the Technical
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l Specifications on a five-year cycle. That is, the implementation of each specification is examined at least once in a five-year cycle.
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The inspector noted that the Technical Specifications contains provisions dealing with establishment and implementation of a radiation protection program and programs for High Radiation Area access controls. The inspector noted this frequency to be.
significantly longer than observed at other similar facilities.
The inspector also noted that portions of the audits were not routinely performed during periods of high radiation protection activity such as during an outage.
In addition, the reviewed audits indicated a
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significant portion of the review efforts were oriented to review of l
documentation rather than on-going activities.
The inspector noted that the licensee's corporate radiological
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controls group performs appraisals of station radiological controls activities. The procedures controlling the ap)raisal program recommend that the appraisals be performed quarterly. Tie inspector noted that l
two appraisals were being performed a year and that these appraisals were not specifically scheduled to be performed during outages.
The licensee's radiation protection supervisors perform tours to
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review on going activities. The licensee is planning to formalize the l
tour program. The Health Physics Operations Manager provides L
quarterly reports to management on the performance of radiation protection activities at the. station.
The licensee has in place a radiological occurrence report program.
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Inspector discussions with the licensee's radiation protection personnel indicated additional effort was needed to ensure that the progra:n is actively used to document and track to resolution radiation protection problems or concerns.
Because of the few occurrences that (
are documented,- the licensee's radiation protection personnel believed that the program was not being used.
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7.0 Contamination Control general The inspector reviewed the contamination control program,l program contamination control practices, and contamination contro procedures.
Practices reviewed included posting and barricading of radiological controlled areas, personnel frisking, and frisking of material
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removed from the radiological controlled area, i
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L The following specific matters were reviewed.
methods for contamination surveys of individuals and equipment
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procedures and guidance for radiological controls personnel response to
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alarms nature, extent, and frequency of contamination monitoring surveys
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surveys and monitoring of equipment to be removed from the
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radiological controlled area
proper use of portal monitors and friskers including consideration of
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hot particles efforts to reduce the volume of contaminated or potentially
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contaminated trash including steps to minimize the the introduction of uncontaminated material into contaminated areas monitoring d areasand release of potentially contaminated material to
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unrestricte The evaluation of the licensee's performance in this area was based on review of procedures, discussions with personnel and observations during plant tours.
Within the scope of this review, no violations were identified.
The following observations were discussed with the licensee.
Posting and labeling of radioactive and contaminated material appeared
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to be good throughout Units 1,2, and 3.
Personnel frisking practices were considered in need of improvement as
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follows.
Personnel in the Unit I radwaste control room were subject to
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potential cross-contamination by personnel, who had worked in a contaminated area, passing through the control room.
The radiological controlled area egress points were physically
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oriented in such a manner that personnel who had not frisked for contamination after leaving a contaminated area, may interface withpersonnelthathadfrisked, The licensee has substantially reduced the number of doors that i
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personnel are allowed to access and egress the radiological controlled-areas RCAs) of the station.
The licensee has reduced the number by decr(32(at Unit 3, 10 at Unit 2 and 26 at Unit 1).
This will serve to ease the potential for contaminated material being inadvertently removed from the RCA.
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s Although the licensee has a program to provide for separation and
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frisking of trash to reduce the amount of material disposed of as potentially contaminated, and the licensee's procedures indicate that unnecessary material is not to be brought into the RCA, the inspector
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The inspector review of contamination enntrol procedures identified the following.
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Contamination control procedures contained inconsistent and
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unacceptable criteria for release of potentially contaminated material to unrestricted areas.
Certain procedures referenced exempt quantity
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radioactive material limits referenced in 10 CFR Part 30 as release criteria.
The licensee initiated an immediate review of this matter.
Postings at RCA egress points indicate all material leaving the RCA
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must be frisked by radiation protection personnel. However licensee personnelindicatedworkersmayfrisktheirpersonnelarticlesfor release.
Procedures do not require personnel to frisk their personnel L
articles nor is guidance provided as to how the frisking is to be j
performed or what limitations may exist.
Procedures do not provide guidance as to how to respond to portal l
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l monitor alarms at the security access / egress point or what-evaluations L
are to be made following alarming of-the portal monitors.
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Procedures do not provide guidance to ensure meeting-the survey l
monitoring requirements specified in 10 CFR 20.205 for packages of radioactive material received at the station. There are no procedures
governing receipt and disposition of radioactive material by warehouse
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personnel. A memorandum is being used to provide guidance.
The
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memorandum provides inadequate guidance to ensure compliance with 10 CFR 20.205.
Procedure 6.3.1 allows security guards to frisk material out of the
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protected area in lieu of passing it through a portal monitor.
It was not clear that security personnel receive adequate training to perform the necessary surveys prior to release of material.
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Procedures provide inadequate guidance for determining if a person is contaminated with radon contamination.
Procedures allow personnel to
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be released from the RCA if it is " suspected" that the personnel are contaminated with radon. -The procedures provide no upper limits of contamination allowed to leave the RCA nor do they contain any requirements for decontamination.
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Such guidance is considered questionable if no specific guidance is in place to provide a definitive method of determining that radon is the i
contamination present.
Skin dose calculation procedures do not provide guidance for
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recognizing and responding to radioactive material imbedded in the skin.
The licensee indicated that the above matters will be reviewed.
8.0 External Exposure Controls The inspector reviewed selected aspects of the licensee's external exposure control program.. The review was with respect-to criteria contained in i
applicable licensee procedures and 10 CFR 20. The following matters were reviewed:
posting, barricading and access control as appropriate to Radiation
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. storage and control of radioactive materials
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use and proper wearing of personnel dosimetry. devices
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exposure results
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The evaluation of the licensee's performance in this area was determined by review of documentation, discussions with personnel, and observations during plant tours.
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The inspector noted that the posting and access control of Radiation and
L High Radiation Areas appeared to be good. Access points to High Radiation
Areas were well posted with signs which identified the minimum requirements necessary to enter the area.
The inspector noted that the Unit 2 new fuel storage vault was not
)osted as a Radioactive Materials Storage Area.
Such posting is required )y 10
.CFR 20.203. The licensee immediately posted the vault and subsequently revised procedures to require the postinr' when new fuel is transferred into the vault.
In addition the licensee revi ed procedures to require posting of Radioactive Material, Storage Areas. The procedures only recommended the l
posting. The vault had been locked and a radiation protection technician was in attendance during work activities. Since this matter had minor safety significance, no other examples were identified in either of the three units, and it was quickly corrected by /90-15-02)the licensee, the inspector considered this a non-cited violation (50-336 in accordance with Section V.A of the NRC's Enforcement Policy.
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The following observations were discussed with the licensee.
The licensee provides integrating alarming dosimeters to personnel
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entering High Radiation Areas as one of t,1e options. identified in Technical Specifications for personnel monitoring. There were no
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)rocedures or guidance to personnel issuing the dosimeters to identify low the alarms should be set.
Inspector observations indicated different alarm set points were being used at the three units.
The licensee's radiatian work permit program does not provide any
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guidance or instructions to personnel that explains how radiation protection personnel are to verify or how workers are to know that -
their radiation work permit has been revised and that the workers have read and understood any revisions to their radiation work permit.
y The licensee indicated the above matters would be reviewed.
The inspector discussed exposure results for the period January 1989 through June 1990 and noted that there were no unplanned whole-body radiation exposures at the station.
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9.0 Internal Exposure Controls The inspector reviewed selected aspects of the licensee's internal exposure controls program. The review was with respect to applicable criteria contained in the licensee's procedures and 10 CFR 20.
The evaluation of licensee performance in this area was determined h l
discussions with personnel, review of documentation, and observations L
during plant tours.
Within the scope of this review, no violations were identified. The l-inspector review of internal exposure results for the period January 1989 through June 1990 indicated no intakes of airborne radioactive material in l'
excess of 40 MPC-hours had occurred.
10.0 ALARA The inspector discussed the ALARA Program and recent ALARA initiatives with the licensee's radiation protection personnel. The inspector also reviewed the licensee's performance in the area of ALARA for the Cycle 9 (March 1988-May 1989) Unit 3. g for Unit 2 and the Cycle 2 (February 1988-July refuelin 1989) outage at
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The following matters w ere noted.
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The licensee establishei
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The licensee provides ALARan ALARA coordinator for
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The licensee's ALARA pr A goals for each unit.
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The licensee has recentlaggregate exposure is estioc
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of wor mated to personk which would result iny taken the initiativexceed 5 pe
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rem to Weekly and monthly ALARA an aggregate exposure of 100e to perform A
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The li belie)ved to reduce out of1987.censee ins
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The licensee is monitori management.
deposition ng the performanceat Unit I at cycle 12 (Au The licenseeof Co-60 on piping interi
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-core radiation fields by inhibiti
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of the zine which is with reactorwould have been or sustained about 350 personsustained dur surfaces.
ng defects vessel 0 ring leaks-rem unanticipated steam generatab and steam generator plug, re addition,al ALARA initiative outage because particular initiatives pairs.
of problems cavity clea,ning systems are b s at Unit 2 to reduce expo automated st The licensee is reviewi have such as or tube steam generator each outage thereby incre work platforms and platfeing reviewed. ud tensioners sure In ng Also The licensee
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Unit 2 does notand improved during the Unit 3 outagsustained an asing aggregate ex orms,must be constructed aggregate
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e as 11.0 E compared to a goal of 250 pexposure of abo M
n The inspector erson-rem.-rem this re met with purpose, port on July the lic 27,1990. ens 9e personnel d scope, and findings of thi At that time, the inspe tenoted in Section 1.0 of s inspection.
c or summarized the
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i 10-The following matters were noted.
The licensee established an ALARA coordinator for each unit.
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. The' licensee provides ALARA goals for each department on site.
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The licensee's ALARA procedures require an ALARA review for work whose
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aggregate exposure is estimated to exceed 5 person-rem to complete.
The licensee has recently taken the initiative to perform ALARA reviews of work which would result in an aggregate exposure of 100 person-millirem.
Weekly and monthly ALARA reports are provided to management.
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The licensee installed zinc-injection at Unit 1 at cycle 12 (August
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belie)ved to reduce out-of-core radiation 1987. The licensee is monitoring the performance o fields by inhibiting deposition of Co-60 on piping interior surfaces.
The licensee sustained about 350 person-rem above that which normally
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would have been sustained during the Unit 2 outage because of problems with reactor vessel 0-ring leaks, unanticipated. steam generator tube defects, and steam generator plug repairs. The licensee is reviewing additional ALARA initiatives at Unit 2 to reduce exposure.
In particular, initiatives such as automated stud tensioners and improved cavity cleaning systeins are being reviewed. Also, Unit 2 does not have steam generator work platforms and platforms must be constructed each outage thereby increasing aggregate exposure.
The licensee sustained an aggregate exposure of about 166 person-rem
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during the Unit 3 outage as compared to a goal of 250 person-rem.
11.0 Exit Meeting The inspector met with the licensee personnel denoted in Section 1.0 of this report on July 27, 1990. At that time, the inspector summarized the purpose, scope, and findings of this inspection.
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