IR 05000245/1990023
| ML20062G247 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/15/1990 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20062G246 | List: |
| References | |
| 50-245-90-23, 50-336-90-25, 50-423-90-23, NUDOCS 9011290054 | |
| Download: ML20062G247 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-245/90-23 50-336/90-25
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F0-423/90-23 Docket Nos.
50-245 50-336 EDT21 License Nos. DPR-21 Category C D W 65 T
NW -49 C
Licensee:
Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Generating Station,'Un'its 1, 2 and 3 Inspection At: Waterford, Connecticut Inspection Conducted:
October 1-5,'1990 Inspectors:
u fl5 ffb R. L. Nimitz, CHP, Senior Radiation Specialist _
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L Approved by:
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W. J. Pasciak, Chief, Facilities Radiation date V
Protection Section
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l Inspection Summary:
NRC Inspection on October 1-5, 1990 (NRC Combined Inspection Report Nos. 50-245/90-23; 50-336/90-25; and 50-243/90-23).
Areas Inspected:~ This ir.;pection was a routine, unannounced inspection of the
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radiological controls program at Millstone Station, 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 enntrols organization, external and internal; exposure controls, ALARA, radioactive and contaminated'~
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material controls, radioactive source control and surveillance,-_and worker
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concerns.
Results: No violations were identified. :The licensee implemented good radiological controls, for the Unit' 2 outage.
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DETAILS 1,0 Individuals Contacted f
1.1 Northeast Nuclear
- H F. Haynes, Director, Unit 1
- F. Dacino, Director, Site Services
- J. Sullivan, Manager, Health Physics Operations i
- C, Palmer, Manager, Health Physics Operations
- D. Hagan, Radiation Protection Supervisor, Unit 2
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- S. Turosuski, Supervisor, Radioactive Materials'
- R. Sachatello, Radiation Protection Supervisor, Unit 3
- J. Laine, Senior Scientist 1.2,NRC q
W. Raymond, Senior Resident Inspector i
- P. Habigherst, Resident Inspector
- W. Pasciak, Chief, Facilities Radiation Protection Section
- Denotes those individuals attending the exit meeting.-
2.0 Purpose and Scope of Inspection i
This inspection was a routine, unannounced radiation protection l
inspection. Areas reviewed were as follows:
-licensee action on previous findings
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-organization, staffing and training L-external and internal exposure controls
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-ALARA-radioactive and contaminated material controls-radioactive source control and serveillance
-worker concerns 3.0 Licensee Action on Previous Inspection Findings
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3.1 (Closed) Unresolved Item (50-245/89-23-002) NRC to review the
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implementation of corrective actions for contaminated material
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shipped offsite. This item is discussed in Section 3.4.
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3.2 (Closed) Violation (50-245/90-04-001) The licensee did not adhere to radiation protection procedures.
The inspector' reviewed the i
implementation of the licensee's corrective-action documented in the
licensee's April 10,.1990- letter. The violation involved personnel
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exiting radiologically controlled areas without frisking,.use of an
inadequate radiat. ion work permit to control radiological work
activities and failure to properly label a radioactive material container.
The' licensee modified the' level 3 radiation worker
trd ning to discuss the ide' tified contamination ccotrol problems.
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The licensee also clearly labeled,inside and outside doors as _to the
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health physics access control requirements. -The licensee also fenced in outside areas.to provide better control of. radiological activities outside station buildings.
Regarding use of an inadequate-radiation work permit, the licensee included the lessons learned in; annual health physics training, the' radiation work permit was.evisedi to enhance the job planning process and establish essentially a work check list to be used for radiation work permit planning.
Appropriate personnel.were trained.in the procedures.
The licensee _
l reviewed applicable procedures for air sampling and concluded the procedures were adequate.
The licensee _is currently developing a-procedure for operation and use of HEPA filtered portable ventilation
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systems and vacuum cleaners.
Regarding labeling of containers.the
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licensee discussed the item with appropriate personnel.and the licensee revised procedures to clarify the requirements for labeling _
of radwaste material containers.
This item is closed.
3.3 (Closed) Unresolved Item (50-245/89-17-002) On August 19, 1989,ca plant equipment operator failed to frisk out of the radiological'
a controlled area by use of a personnel contamination monitor outside-
the Unit 1 Reactor.
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The operator exited the radiological controlled area without
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frisking. The inspector's review indicated that the licensee issued a plant incident report for the event. The individual was counseled.-
The individual had been in the Unit 1 reactor clean-up pump room.
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Contamination levels, due to over flow of floor drains, measured about-
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30 mR/hr with an R0-2 survey meter.
The licensee. issued a memorandum-
on August 28, 1989, to all site personnel regarding the need'for j
personnel to perform personnel monitoring and monitoring of -
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f The recent generic corrective acticns thatLthe licensee had'taken to
enhance contamination control were~ placing signs on RCA exit doors to alert personnel of RCA requirements, the fencing'in of'RCA areas jl outside the buildings, the installation of video cameras to' monitor-
egress points or stationing of personnel;at;RCA~ egress points. This; item is closed.
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3.4 (Closed) Violation (50-245/89-13-01) The licensee did not establish a
adequate contamination control procedures. ' This matter was reviewed during combined inspection (50-245/90-14; 50-336/90-15; 50-423/90-13). The licensee's Unit Site Director issued-the Task.
Group Report recommendations to each unit director for review.
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The licensee's radiological group obtained 'the recommendations and-
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comments of each unit director and formulated.a. plan to implement'
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the recommendations, es appropriate, of the contamination' control task i
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A contamination control plan-was established.and implemented. The following has been accomplished:
-minimization of RCA access and egress points-construction of RCA fencing-installation of video monitoring of contamination
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control points-i-approval of warehouse 9.for continued use as an uncondition
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release facility-enhancement of contamination control procedures l-improvement in RCA boundary identification
removal of laundry processing outside door 101 l
purchase and use of additional personnel contamination monitors
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-enhancement of control and monitoring of material laaving the
RCA and the protected area
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l-vehicle egress monitoring at the protected area boundary -
-secondary checking of clean trash-
1 Improvements currently under review include establishment:of an onsite clean tool warehouse, the establishment of a: hot machine shop.
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and expansion of health physics offices. This item is closed j
3,5 (open) Unresolved Item (50-245/90-04-03) The licensee was not able to identify who was the radiation protection-manager. 'Also, the-responsibilities of all positions' within the radiation protection organization did not appear *o~be well defined. The licensee revised procedure ACP-QA-1.02,' Organization 'and Responsibilities,-
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Revision 20, to add a description of the assistant Radiation Protection
Supervisor-0peration's responsibilities.
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l The licensee is currently revising the procedure to incorporate l
responsibilities of the radiation protection manager, j
3.6 (Closed) Follow-up Item (50-245/87-24-01; 50-336/87-27-01; l
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50-423/87-19-03) The licensee performed a detailed review of the calibration and surveillance of all station radiation monitors.
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inspector's review of.the licensee's. report of-the review indicated
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did not meet appropriate minimum requirements.
The inspector:
l reviewed the licensee's actions on each of the monitors. The licensee's review found that there were no requirements to y
document the performance of a periodic source check on the Unit I service water monitor.
The check was being performed. The-1.1censee
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revised procedures to-include a requirement to perform the documentation.
The licensee's review'found a need to place criteria
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on allowable activity in the Unit 3 component cooling water system.
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~5 to reduce service water sampling. 'However, this action was deemed unnecessary-and no actions were taken with Unit-3 component cooling-i water monitors.
The Unit 3 steam generator blowdown monitor had the wrong set point and operations procedures did not' indicate.that the steam generator blowdown surveillance was a~ Technical'
Specification (TS) requirement.
The' licensee revised the set point'and operation procedures to reflect.the surveillance was' a TS requirement.
The licensee's review also found that the Unit 3 waste' neutralizer:
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sump monitor. functional test failed to verify that the sump tanksi discharge auto-closure actually worked. This condition existed since
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plant start-up.
The auto-closure was found.to subsequently work but
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was not periodically surveilled.. The' licensee's review 11ndicated:
adequate compensatory measures were-in place to preclude inadvertent -
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releases of radioactivity. The licensee issued a Licensee Event Report (89-018) for this item and revised procedures to require the auto-closure verification. The licensee plans to provide training on this event by December 31, 1990, c
The licensee also found that procedures did not require a discharge permit to be issued for. discharges from the waste neutral.izer sump.
The licensee revised procedures on August 29, 1990, to require a permit.
Procedures did require sampling and analysis.
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l Based on the above review, the inspector concluded the' licensee
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appears to have taken acceptable corrective action-for the;above'
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The above open item is closed.
However,' unresolved item (50-423/90-23-01)'will be_ opened to.
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i evaluate the circumstances surrounding the incorrect alarm set point
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on the Unit 3 steam generator blowdown monitor and the circumstances surrounding the failure to test the auto-closure feature'of the.
Unit 3 waste neutralizer sump monitor.
4.0 Organization, Staffing, Training and Qualification The inspector reviewed the organization and staffing ofLthe licensee's radiation protection organization'. The licensee's Technical
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Specifications for_ Unit 1, 2_and 3 and applicable procedures were'used as.
acceptance criteria.
The inspector also reviewed thelqualifications_ and traini_ng of members of the Radiological Controls Organization with respect.to criteria contained; in Technical Specifications. The licensee's performance'in this area was JE evaluated by review of documentation and discussions.with cognizant personnel.
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The inspector's review in this area. focused on the qualification and training of contractor radiological controls personnel hired to augment the organization during the unit 2 outage. The inspector also reviewed
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the adequacy and effectiveness of the performance'of these personnel during review of work activities.-
Within the scope of this review, no violations were identified.
The following matters were identified and discussed with the licensee:
-The licensee established a well defined radiation protection
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organization to support the Unit 2 outage. Job descriptions for lead
radiation protection technicians were identified. Also special'
control point instructions were established as well as special instructions for High Radiation Area Access Point door monitoring.
personnel.
-Radiation Protection Supervisors appeared to be spending a good deal of time in the radiological ::ontrolled area observing plant.
conditions and on going work activities.
-The inspector's selective review of personnel qualifications indicated personnel were qualified in accordance with Technical
.i Specification requirements,
-The licensee established and implemented a defined. training and qualification program for contractor radiation protection.
personnel. The inspector's review of on going work activities did-not identify any performance deficiencies.
-The licensee's training group provides plant systems training-for radiological controls personnel including, radiological hazards of systems operations.
-The licensee has provided special ALARA training for steam generator-
work activities and reactor coolant pump seal. replacement.
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The following matters were brought..to the-licensee's attention:
-Although there is a training program for radwaste ; supervisory personnel, there is no defined. training. program' for other supervisory personnel and managers..The -licensee is -currently -
developing this program.
-There'was no defined training, qualif.ication-program for-
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-decontamination personnel.
-The licensee provides training of personnel in new procedures during-
-continuing training.
However, there was no method in place
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to ensure that personnel review safety significant procedure changes-prior to performing tasks associated with those procedures.
The licensee initiated a review of these matters.
5.0 ALARA i
The inspector reviewed selected aspects of the licensee's ALARA Program..
i The review was with respect to criteria contained in the following:
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o-Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As Low As Is Reasonably Achievable; a
lF-Regulatory Guide 8.10, Operating Philosophy for Maintaining'
Occupational Radiation Exposures As Low As is Reasonably Achievable;
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-NUREG/CR-3254,-Licensee Programs for Maintainin'g Occupational
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Exposure to-Radiation As Low As Is Reasonably Achievable;
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-HUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power Plants; Study on High-Dose Jobs,-Radwaste Handling and ALARA
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The evaluation of the licensee's performance was based on.;iscussions j
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with cognizant personnel,. review of_ documentation,.and 4.idependent-observation during tours of the facility including observation of '
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on going work activities in Unit 2 containment.
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i Within the scope of the review, no violations were-identified.
The inspector's observations indicated good efforts were being made by the-i licensee to reduce occupational radiation exposure of personnel.
The following observations were made, j-The licensee installed and used video cameras to review on going I
work activities in High Radiation Areas.
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-Work activities received good ALARA planning.
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-:ow dose rate waiting areas and-up-to-date radiation surveys were ce sp 9uously posted in Unit 2 containment.
-Job specific ALARA requirements were posted at the Unit 2 f
containment radiation precettion check points.
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-In 1986, the licensee identified-ainumber of initiatives to reduce
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occupational exposure at the station.
Thirteen short-term
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initiatives and nine long term initiatives were identified.
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8 licensee identified _ lead persons for the initiatives and has been providing management with quarterly status reports of the initiatives.
The initiatives to reduce exposure i_ncluded snubber
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reduction, cobalt' reduction, decontamination improvement, utilization of robotics, and work practices ~ review.
Inspector discussions with cognizant personnel indicated the initiatives are being implemented.
-ALARA personnel are performing exposure tracking of on going work activities. Aggregate exposure values are discussed-at morning station meetings.
The following matters were brought to the licensee's attention:
-Graffiti was observed on the.22 foot elevation of the' Unit 2 containment. Application of graffiti in a' radiological control area indicates lack'of worker sensitivity to ALARA.
-The licensee's ALARA program procedures did not require ALARA review to be conducted for work whose aggregate exposure ~is less then 5 person-rem.
6.0 External and Internal Exposure Controls
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The inspector toured the radiological controlled areas of the plant-and
reviewed the following elements of the license's external and internal exposure control program:
posting, barricading and access control as' appropriate, to Radiation, High Radiation, and Airborne Radioactivity Areas;
-High Radiation Area access point key control; i
l-control of radioactive and contaminated material; L
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personnel adherence to radiation protection procedures, radiation l
work permits and good radiological control practices;
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-use of personnel contamination control devices;
i-use of dosimetry devices;
-use of respiratory protective equipment;.
-adequacy of airborne radioactivity sampling to support ongoing work;-
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L-timeliness of analysis of airborne radioactivity samples including i
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supervisory review of sample results; I
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-installation, use and periodic operability verification of engineering controls to minimize airborne radioactivity;:
-bioassays and personnel airborne radioactivity intakes;
-records and reports of personnel exposure;
-radioactive-source inventory and control-l
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i-adequacy of radiological surveys to support pre planning-of. work and i
on going work; and'
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I-hot particle controls.
j The review was with respect to criteria contained in applicable licensee ~
j procedures and 10 CFR 20, Standards for Protection Against Radiation,
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The inspector independently reviewed on going work a~ctivities. including
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personnel entry into Unit 2 steam generators,: Unit 2 steam generator
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sludge lancing activities, Unit 2 reactor vessel head work, and Unit 2-refueling activities.
Within the scope of this review, no violatior,s were identified.'
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-The licensee provided good High Radiation Area Access Control for the Unit 2 Outage.
In addition, posting and barracading-of
- j rcdiological areas was good.
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-The licensee implemented good radiological controls for steam generator-work activities. The. licensee performed good evaluations lof q~
radiation dose rates that personnel would be exposed-to.during i
Unit 2 steam generator work activities.
Conservative control
measures were used to maintain personnel radiation exposures within
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applicable administrative limits.
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-The licensee used extensive engineering controls to maint'ain airborne
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radioactivity levels low for Unit 2 work activities. - Continuous air i
monitors were used for real-time air monitoring to. alert' personnel i
to airborne problems.
-The licensee was tracking and evaluating personnel contaminations (both skin and clothing). The licensee monitored the cause of each contamination and iden+1fied repeat offenders.
The following matters were brought to the licensee's attention:
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-The radiation work permits used to. provide radiological control for j
work activities provided limited guidance to radiation protection
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personnel regarding radiation protection coverage requirements.
The permits principally served to inform workers of protective clothing
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requirements and dosimetry use requirements.
The licensee has recognized this matter as an area 'for enhancement.
The licensee is revising the radiation' work permit to include-specific radiological controls coverage requirements.
The inspector noted that the licensee has provided memoranda. -with expanded guidance to radiation protection personnel.regarding radiological controls requirements for Unit I steam generator work activities, This was. considered a good-initiative'.
-There is no procedure that provides guidance regarding installation, operation, and surveillance of engineering controls (e.g., portable ventilation systems) used to minimize airborne radioactivity.
The licensee has developed and is. reviewing a draft procedure,
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t-The licensee's procedure for' use -of. the Delmonox Breathing Air Supply System contains an Clegible graph that is.to be used..for determi-nation of proper air pressure.to workers, Also, the graph appears to specify a breathing air hose. length.that is not permitted.
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licensee initiated an immediate review of the matter, _ Subsequent inspection review of work activities where the breathing air supply
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was being used indicated air pressure and hose lengths were correct.
-The licensee installed general. area radiation survey meters (ARMS)
on the Unit 2 steam generator. platforms'to alert personnel in the event that a hot particle was. inadvertently removed.from the generators during eddy current testing. The alarms of the ARMS were set at different alarm set points (above background radiation levels). Also there were no periodic surveillancescof the ARM and alarm set points to ensure they were working properly. The licensee.
initiated a review of this matter.
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7.0 Worker Concerns- (RI-90-A-137 item 2.b.)
7.1 General
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On August 22, 1990, a worker contacted NRC. Region I and expressed
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cc..cern that-the total radiation' exposure received during a recent
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oil addition to the A Reactor Coolant Pump was much higher than
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expected'and that no steps have-been taken to reduce total
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radiation exposure during the oil: addition.
7.2 Findings The inspectors met with cognizant'l'icensee personnel.and' discussed the addition of oil to the A Reactor Coolant Pump (RCP).
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surveys and post-job critiques.
The last addition was made on August 15, 1990.
The licensee's ALARA personnel expected that the oil addition would result'in an accumulated exposure of between 0.8~
person-rem to 0.9 person rem.
This-was about the exposure sustai_ned when oil was last added on October 12, 1989-(0 871 person-rem).
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The cumulative exposure estimate did not require a documented ALARA:
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review. A pre-job meeting was held.
At the pre-job meeting l
estimated radiation dose rates were discussed as well as activities to be performed, estimated stay time and heat stress requirements.
The need to stay in low dose rate wait areas was discussed.
Because of-high radiation dose rates in the area land heat stress.
concerns, the oil addition was to be' completed by three crews.
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first crew was to remove the deck grating above the A RCP,. install a--
a ladder to the oil reservoir fill area, stage :ools and leave.
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second crew was to go down the ladder and fillLthe oil reservoir. : A
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third crew was to assist. However, apparently through miscommuni -
cation or error, the se~cond crew removed'the oilf fill tube and.
removed the ladder when exiting the, area. 'Since the original plan was to leave the oil fill tube in place.so that additional oilicould
be added if needed, a re-entry into the area ~to re-install the fill tube was needed, i
The total cumulation -exposure as a_ result.of re-installing the fill-tube was 1.36 person-rem as compared,to the original: estimate of between 0.8 and 0.9 person-rem.
As a result of the problems encountered a post-job critique was held
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on August 16, 1990. The = critique identified four recommendations i
which were subsequently documented in.a memorandum to. the Unit ~ 2 Maintenance Manager to address the problems encountered. An. action-request was issued by the Station Director on September 4,1990, to review the exposure control and ALARA options for RCP oil addition at power.
7.3 Conclusion The inspector concluded that due to weaknesses in pre planning and or personnel error in failing-to follow initial plans additional i
exposure was sustained by personnel to fill the oil reservoir of the-1[
A RCP.
The inspector also concluded that the licensee recognized weaknesses-in the performance of the task and initiated corrective actions to-review and improve exposure control activities for-RCP-oil 1 addition.
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The following corrective actions were noted:
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-As discussed above, the Station Director issued an action item to review and improve RCP and additions. This occurred about two weeks after-the event.
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-A post oil addition critique was held the day following the oil addition.
Recommendations for corrective action were documented in an August 21, 1990 memorandum from the ALARA coordinator to the Unit 2 Maintenance Manager, i-The oil leak on the ARCP was located and. repaired, i-The Maintenance Foreman overseeing the oil addition was counseled regarding the breakdown in communication.
-The licensee initiated design reviews to change out hard piping
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and install flexible piping for the RCP-oil system to preclude-
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leaking joints.
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Based on the above, the concern that no steps were taken 'to reduce total radiation exposure during TCP oil addition is not substan-tiated.
This concerns is closed.
..q 9.0 Exit Meeting The inspector met with licensee representatives (denoted in Section 1) on October 5, 1990. The inspector summarized the purpose, scope and findings of the inspection.
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r DUTSTANDING ITEMS ftLE SINGLE DOCKTT ENTRY FORM
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t REPORT HDURS 1. Operations.
7. Outages
2. Rad-Con 8. Training
3. Maintenance-9. Licensing Docket No.
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4. Surveillance 10. QA j
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5. Everg. Prep.
11. Other Originator t
6. Sec/Safegrds.
12. Fire Protection /
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Action Due Date_. Updt/I3so~uD Rpt/
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OUTSTANDING ITEMS FILE SINGLE DOCKET ENTRY FORM
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REPORT 100RS 1. Operations 7. Outages 2. Rad-Con 8. Training 3. Maintenance 3. Licensing Docket No.
I SIo l-l2lytif l-4. Surveillance 10. QA
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11. Other Originator (7 rd.4P 6..Sec/Safegrds.
12. Fire Protection /.
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Action Dua Date Updt/f3so~u) Rpt/
Date 0/M Kls&
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DUTSTANDING ITEMS FILE SINf;tE DOCKET ENTRY FORM
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REPORT HDURS 1. Operations 7. Outages 2. Rad-Con 8. Training 3. Maintenance 9. Licensing Docket No.
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Date 0/M/CT14 _
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REPORT HOURS 1. Operations 7. Outages 2. Rad-Con 8. Training 3. Maintenance 9. I.icensing Docket No.
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4. Survelliance 10. QA 5. Emerg. Prep.
11. Other Originator th avk 6. Sec/Safegeds.
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Action Due Date Updt/ttselb Rpt/
Date 0/M/ h _
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