IR 05000245/1991002
| ML20029C240 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/14/1991 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20029C233 | List: |
| References | |
| 50-245-91-02, 50-245-91-2, 50-336-91-03, 50-336-91-3, 50-423-91-03, 50-423-91-3, NUDOCS 9103270037 | |
| Download: ML20029C240 (15) | |
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NUCLEAR REOULATORY COMMISSION I
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REGION I
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Report Nos. _ 50-336/91-03-50-245/91 02
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50-423/9103 ~
f Docket Nos.-- 50-245 g}-334 -
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-50-423-License Nos. DPR 21
~ Category:
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.C NPF-49 C
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l Licensee:
L Northeast Nuclear EneryCompany
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g" P. O. Bod 20
- Hartford. Connecticut 06101
- Facility Name:
Millstone Nuclear Generating Station; Units 1. 2 and 31
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Inspection At:1 Waterford Connecticut
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. Inspection Con' ducted:
February 18'- 22. 1991
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sInspectors:--
OLN M N M k it-R. L. Nimitz, CHP, Senio'r' adiation Specialist Date
= Approved byf La
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y f f W. J. Pasciak,- Chief, Facilities Radiation'
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VY : Protection.Section
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Inspection Summary: _.NRC Inspection on February 18 - 22,1991 (NRC Combined -
Inspection Report Nos.-50 245/9102; 50 336/9103; and 50 423/91-03).
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4 Areas Raviewedi LThis inspection was a routine unannounced radiological controls l Inspection. Areas reviewed were: the licensee's action on previous inspection findings,.
organization and. staffing, training and qualification, external and internal exposure
. control, radioactive and co'ntaminated material control, ALARA, and process and area
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radiation monitor calibration and surveillance testing.
Resnits: - No violations were identified. The licensee implemented good radiological controls-for the. Unit 3 outage. Apparent weaknesses were identified in the area of-industrial ~ safety.
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. DETAllJi 1.0l LIndividuals Contacted.
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' 1.1 - ' Northeast Nuclear-l
- S! Scace, Millstone Station Director
- R. Factora, Unit SeMees Director
- H. Haynes, Director ; Unit 1..
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- C, Clement, Director - Unit 3
- *J. Harris, Unit 3 Engineering Manager
- J.-Sullivan, Manager, Health Physics Operations
- C. Palmer, Manager, Health Physics Support
- R. Enoch, Manager, Unit 3_ Instrumentation and Control
M.~ Gentry, Operations Manager - Unit 3
- J;- Folleth Sr., Senior Safety Administrator
- R.-Rothberg, Unit 3 Maintenance Manager
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- J. Laine, Senior Scientist.
- T. Burns, Health Physics Training Supervisor L1.2 USNRCf
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=W. Raymond, Senior Resident inspector:
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- T.:Vegel, Reactor Engin'eer
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- R. Arrigh, Reactor Engineer
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' Denotes those individuals attending the exit meeting on February 22,1991.
'The inspector also contacted other licensee employees.
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Purpose and Scone of Insnection
.This inspection was n ' routine, unannounced radiological _ controls inspection..
Areas reviewed were a's follows:
the licensee's action on previous inspection findings-o Torganization..and staffing
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training and qualification;
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- external and internal exposure control-
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cALARA
. radioactive and contaminated material control
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radioactive source control and surveillance -
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~ calibration and surveillance testing of process and area radiation monitors-
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observations during station tours
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3.0 Licensee Action on Previous inspection Findings (Closed) Unresolved item (50 245/90-04 03):
NRC review found that the licensee had reorganized the radiological controls organization but had not updated administrative procedures to reflect the reorganization, the Radiation Prctection Manager was not identified, and all operating organization positicas within the radiological controls organization were not defined in appropriate documents to identify lines of authcrity, responsibility and communication. The inspector's review found that the licensee revised procedure ACP-OA-1.02, Organization and Responsibilities, to identify newly created positions. The licensee also issued a new procedure, HP953/2953/3953, Health Physics Organization and Responsibilities of Key Radiological Personnel, to define the responsibilities of all key radiological personnel within the Health
- Physics Organization. The licensee also revised the Northeast Utilities Topical Report to specify that the Health Physics Operations Manager or Health Physics Technical Support Manger can fulfill the Radiation Protection Manager position identified in Technical Specifications. This item is closed.
. 4.0 Organization and Staffing The inspector reviewed the organization and staffing of the radiological controls organization. The licensee's Technical Specifications for Unit 1,2 and 3 and applicable procedures were used as acceptance criteria.
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The licensee's performance in this area was evaluated by review of documentation and discussions with cognizant personnel.
The inspector's review found that the licensee established and implemented a defined augmented radiological controls organization to support the Unit 3 outage. There was ample staffing to support work activities.
The licensee issued a Unit 31991 Refueling Outage and Health Physics Handbook. The handbook identified the key individuals within the radiological controls organization and provided their phone number. This was considered a good licensee initiative.
No violations were identified.
5.0 Training and Qualifications The inspector reviewed the training and qualification of radiological controls personnel and radiation workers. The review was with respect to applicable requirements including Technical Specifications,10 CFR 19 and program procedures.
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- The evaluation of the licensee's performance was based on discussions with personnel, review of documentation, discussions with workers and review of on-going work activities.-
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5.1 Permanent Radiolocical' Controls Personnel and Lo'ne Term Contractor
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Radiological Controls Personnel
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The following was-noted:
The licensee provid5d specific formal (Unit specific) training on plant
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systems via a documented lesson plan. - Systems covered included:
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- chemical and volume control system -
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safety injection
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- containment system
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-water system
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- spent fuel pool cooling :
- sh_utdown cooling
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radwaste processing system
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primary ventilation system
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secondary, system
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The lesson plans included radiologica'. hazards of systems. Indust.y
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experience was included in the training.
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yThe licensee provides special training on other topics such as
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response'to a fuel handling accident-
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health physics response to a medical emergency
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- response to a fuel cladding failure'
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response to a reactor coolant leak
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response to a steam generator tube rupture and.
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t hot particle training
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LThe licensee provides procedure training which includes on the job -
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evaluation'of performance.
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The inspector noticed;that some instructor activity comments (e.g. discuss HP:
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actions'on. inadvertent. removal of incore detector from water) were not transferred to revised instructor activities sheets..The licensee initiated a review -
of this obsetvation.
' No violations were identified. The licensee's training program in this area
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- provided a' good focus on the radiological hazards of plant systems on a-unit specific basis.
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5.2 Short Term Radiological Controls Contractors The following was noted:
The licensee provided a review of industry operating experience to
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incoming contractor radiation protection personnel. These included recent NRC Information Notices and Nuclear Network Notices.
The license does not provide a formal program on plant systems for short
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term contractors unless the contractor is invol._d in high risk radiological work activities. The licensee has developed a generic training matrix for all short term contractors. The matrix includes 25 separate on the job evaluations ranging from setup and operation of a radiological controls point to operation of continuous air mon. tors. The licensee also proWdes specific procedure training on applicable plant procedures including hot particles.
The licensee has developect the following special on-the job training
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modules:
steam generator work
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underwater surveys
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diving operations
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moveable incore detectors
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The licensee also provides special instruction to chemistry personnel on use
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Nol violations were identified.' The licensee was providing specific training to contactors on radiologically significant work activities.
5.3 Radiation Worker Training The following was noted:
The licensee has three programs which workers are put through. These are
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Radiation Wolker Level 1,2 and 3. The Level I course is a basic course and includes video tape lectures and takes about 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to complete-including a 50 question written examination and hands on practical factors.
The program is given to personnel who will be working in the radiological control area.
The Level 2 course is for experienced radiation workers and lasts about 2
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1/2 hours and includes a video tape which covers site specific information and a 50 question exam,
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The training is only taken by personnel who have gone through a INPO certified radiation worker training program or appropriate vendor training within the past year.
It was unclear as to what constituted appropriate vendor training that was acceptable in lieu of the licensee's approved training program.
Level 3 training is only for licensee employees and long term contractors
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who have completed Level 1 training anytime in the past and any other level training in the past year. It is essentially a requalification course with a 50 point exam. All new employees must go through Level 1 training.
A limited course entitled safety, security and emergency plan (SS&E) is
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provided to persons who will not wear dosimetry and will not ente.r the.
radiological control area. All contractors get SS&E. New permanent employees get General Employee Training or New Employee training which covers safety, security and the emergency plan. The course does not cover radiological work activities.
Use of a survey meter is discussed in Level 1 training. This includes the
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purpose of the survey meter and functional testing (calibration sticker, battery check and source check). The training program document states that "When issued, specific instruction on the use of the meter wHl be provided." It also states that "if any meter is not functioning properly, return it to the health physics department and get another one." The inspector noted that no specific instructions are provided to personnel when the meters are issued. The licensee's training personnel were
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unaware that no survey meter training was being performed by radiation protection personnel issuing survey meters.
Personnel are not provided instruction on how to determine whether a survey meter is malfunctioning. In 'aadition, personnel are not provided the limitations of the meter. Training on survey meters in Level 2 is briefer
' than Level 1. The Level 2 lesson plan states that "if you are issued a survey meter and are unfamiliar with its use, you will receive further instruction at that time". Level 3 training does provide training on use of survey meters including such matters as what to do if the survey meter goes off scale or reads less than zero. Neither Level 1,2, or 3 training requires hands on use of a survey meter. The Level 3 test requires interpretation of -
meter reading.
The inspector noted that the licensee principally issues integrating alarming dosimeters to personnel for High Radiation Area personnel surveillance and thus provides the surveillance required by Technical Specification.-.
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This is further discussed in Section 7. However the issuance of survey meters to personnel without specific instructions as to how to use the meters was considered a poor practice. The licensee initiated a review of this matter.
Hot particle training is provided in Level 1 and 2 training courses as are
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precautions to be taken when encountering unidentified potentially irradiated debris.
No violations were identified.
5.4 Oualifications The inspector reviewed the qualifications of selected personnel. The evaluation was based on review of resumes and discussions with cognizant individuals. The reviews indicated that the recently assigned Unit 1 Radiation Protection Supervisor met applicable qualification requirements. The review also indicated that radiation protection technicians, providing coverage for on going radiological work activities, meet applicable qualification criteria outlined in Technical Specifications.
No violations were identified.
5.5 Instrument Issue Traininn
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The inspector also reviewed the training and qualification of personnel issuing and
. source checking radiation survey instruments. The licensee had recently instituted a program to-control issue of survey meters and source checking of instruments.
The licensee's program now provides for source checking of all ranges of survey meters.
The licensee constructed a new source device containing a 2 millicurie Sr-90 source.;The inspector noted that the technicians using the source had been trained in accordance with Health Physics Instruction 90-07. This was a draft instruction for response checking the RO 2 and RO-2A. The draft instructions were transmitted to personnel in a January 18,1991, memorandum and was subsequently approved on February 21,1991. All personnel authorized to use the source have received training. The inspector questioned personnelin the use of the source checking device. Personnel were knowledgeable in use of the source.
The licensee provided training to individuals using the device in small groups. A specific lesson plan was used to provide the training. The lesson plan included objectives and topics to be covered in the training. The training fcir use of the L
RO 2 and RO-2A check device specifically included hazards of improper use of the device and high radiation dose rates which would be encountered.
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-The licensee also provided specific training on the use of a source check device for checking friskers (C-76). The device used several Technetium 99 sources of low activity. The licensee provided training using draft Health Physics Instruction
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90-08 wh)ch was also issued in the January 18,1991 memorandum. This instruction was subsequently approved on February 21,1991.-
The licensee had designed a special source check device for integrating alarming
. dosimeters. The device used a 20 millicurie Cs 137 source. The licensee developed a specific on the job training module for use of the integrating alarming I
dosimeter source check device. Personnel using the device had been trained in its
=i use and were knowledgeable in use of the device. There were no procedures for-using the device. The licensee subsequently issued an instruction for use of the device.
The inspector also noted there were no procedures for using a 400 cune
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calibrator.1The lack of use procedures for this device was considered an unresolved l'em (50-245/9102 02).-
No violations were identified.
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A The inspector reviewed selected aspects of the licensee's ALARA Program. The review was with respect to criteria contained in the following:
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R Regulatory Guide 8.8, Info'rmation Relevant to Ensuring that Occupational
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= Radiation Exposures at Nuclear Power Stations will be As Low As is -
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Regulatory Guide 8.10, Operating Philosophy for Maintaining _ Occupational
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Radiation Exposures As Low As is Reasonable Achievable NUREG/CR4254, Occupational Dose Reduction and ALARA an Nuclear-
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. Power Plants; Study on High Dose Jobs, Radwaste' Handling and ALARA -
-Incentives.
The evaluation of the licensee's performance was based on discussions with-cognizant personnel, review of documentation,'and independent observation during tours of the facility including observation of on-going work activities in Uni'.
- 3_ containment.
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The following was noted:
ALARA low dose wait areas were conspicuously posted through the station
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including Unit 3 containment.
The licensec posted general ALARA instructions at the Unit 3
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Containment Control Points.
The following observation was discussed with licensee personnel:
The inspector discussed, with an in Service Inspection (ISI) inspector the
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ability to readily find the equipment (i.e. struts, welds, or snubbers) to be inspected. The individual indicated drawings used by ISI personnel for locating equipment only identified an area. Equipment was sometime difficult to locate. Inspector review indicated strut ISI work sheets included general location while weld ISI work sheets did not include a location.
The in:pector noted that peconnel could receive unnecessary exposure
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searching for components in radiation areas. The licensee concurred with.
the inspector's observation and initiated a review of the above observation.
No violations were identified.
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External and Internal Exposure Controls 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
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Radiation,'and Airborne Radioactivity Areas High Radiation Area access point key control
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control of radioactive and contar.iinated material
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personnel adherence to radiation protection procedures, radiation work
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-permits and good radiological control practices use of personnel contamination control devices
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use of tosimetry devices
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. use of respiratory protective equipment
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adequacy of airborne radioactivity sampling to support on-going work
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timeliness of analysis of airborne radioactivity samples including supervisory
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review of sample results
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installation, use and periodic operability verification of engineering controls to minimize airborne radioactivity bioassay and personnel airborne radioactivity intakes
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records and reports of personnel exposure
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radioactive source inventory and control
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adequacy of radiological sureys to support pre planning of work and on-
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going work breathing air quality
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hot particle controls.
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The review was with respect to criteria contained in applicable licensee x
procedures and 10 CFR 20, Standards for Protection Against Radiation.
The inspector independently reviewed on going work activities including personnel entry into Unit 3 steam generators, Unit 3 steam generator sludge lancing activities, Unit 3 reactor vesse.1 head work, Unit 3 refueling activities and observations throughout Units 1 and 2.
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The licensee personnel monitoring devices were accredited by the National
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Vohmtary Laboratory Accreditation Program (NVLAP) in ANSI-N13.11-1983, Categories I-Vill. The certificate of accreditation was effective until
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January 1,1992.
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Posting and barricading of radiological control areas throughout the station
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was good.
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The licensee implemented good radiological controls for Unit 3 steam
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generator work activities.
The inspector observed that the licensee was providing integrating alarming
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dosimeters to all personnel catering the Unit 3 containment loop areas, a posted High Radiation Area.. The integrating alarming dosimeters were source checked once per day. The check involved setting the alarm at 50 millirem and irradiating the dosimeter for 60 seconds in a special calibrator.
If the integrated dose was between 33 50 millirem, the check was a
considered acceptable. The inspector's dosimeter indicated 42 millirem
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when checked in the device. The inspector noted that the licensee's check appeared to check only the integrating feature, but not the alarm feature.
The licensee initiate a review of the matter. The licensee subsequently revised the procedure for checking alarming dosimeters to provide for alarm of the dosimeters during testing.
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The inspector noted that the licensee was providing personnel with survey
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meters in addition to the integrating alarming dosimeters issued to comply with Technical Specification (TS) High Radiation Arca surveillance requirements. The use of survey meter was orse of the three comoliance options identified in T.S. Personnel could sign out survey meters at un issue point on the 24' elevation of the Unit 3 containment. The inspector noted that the individuals issuing the metets did not question personnel as to their knowledge and ability to properly use the survey meter. This matter is further discussed in section 5 of this report The licensee initiated a review of this ma!!er. As disscused in section 5, use of the alarming dosimeters ensured compliance with T.S. requirements, but issuance of meters to personnel without specific training was co'osidered a poor practice.
8.0 Radioactive and Conaminated Material Control The inspector reviewed the adequacy, effectiveness, and implementation of the licensee's radioactive and contamination material control program.
The following matters were reviewed.
use of portable monitors and friskers
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contamination control
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efforts to reduce the volume of contaminated trash including steps to
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minimize introduction of uncontaminated material into contaminated arear
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contamination checks of selected sealed source *
The evaluation of the licensee's performance in this area was based on observation during plant tours and discussions with cognizant personnel Within the scope of this review, no violations were identified. Inspector tours noted enhanced efforts to preclude inadvertent release of contamination from the radiological controlled area (RCA). These included enclosing of backyard areas within fences and reduction of the number of egress points from the RCA. The following matters were brought to the licensee's attention:
l On February 18,1991, at about 3:30 p.m. the inspector observed a plant
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equipment ope:ator on the 51' elevation of Unit 3 containmen: reach over a posted contamination boundary to support himself while looking down to a lower elevation of containment. The reaching over a posted contamination boundary was considered a poor practice.
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The operator recognized the coor practice when it was brought to his attention. The licensee issued a radiological occurrence report for the
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matter.
The licensee uses digital alarming dosimeters to provide High Radiation
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area surveillance. The dos! meters are placed in a plastic bag and taped to
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a worker's upper arm for ease of use. The inspector noted that after use in a contaminated area, the devices are removed from the bag and returned to a central locano, The dostmeters are not frisk checked for contamination prior to hatdling and re L.ne by personnel.
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-For examp'e, at 9:30 a.m. on Fibruary 20.1991, a worker, working on a D steam generator pbtform handled b:gtih contaminated equipment measuring up to 200 mr/hr on contact. The worker's dosimeter was removed from the bag, transferred outside the contaminated area, then returned to a technician at the centrallocation. The dosimeter was not frisked. The inspector noted that although the dosimeters were bagged, there was a potential for the dosimeter to become contaminated when
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removed from the bag. This was considered a poor practice.
The licensee immediately smear checked maorial in the dosimeter central receiving area and no contamination was found. The licensee subsequently established a program to frisk the digital dosemeter as they left the Unit 3 steam generator bay area.
The exit door from the upper elevation of the Unit I radwaste building was
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M posted in any manner to alert personnel of the need to perform personnel contamination frisking when exiting outside the building. The door was subsequently posted.
No violations were identified.
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- Process / Area Radiation Monitor Testing
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The inspector reviewed the calibration and surveillance testing of the Unit 3 Containment Area Purge Exhaust Monitor, the Unit 3 Fuel Storage Pool Arer monitor and the Unit 3 Control Building ventilation monitors. These monitor.
would provide detection and isolation of or from, as appropriate, potential-airborne radioactivity events in the identified areas. The inspector also check:d flow path isolation for the Unit 3 Control Building upon radiation monitor high alarm.
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The review was with respect to applicable criteria specified in Technical Specifications. The evaluation of licensee performance in this area was based on review of calibration and surveillance testing documentation and discussioas with cogn.'zant personnel.
Within the scope of the review, no violations were identified.
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Ln.strument Source Checking During tours of the Unit 3 containment, the insp:ctor noted that the licensee had established a respirator and instrument issue check station.
Personnel at the check station performed the following:
issued respirators to properly qualified personnel
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issued digital alarming dosimeters to personnel requiring their use
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issued survey meters to personnel requesting them
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performed source checks of radiation measuring instruments
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The inspector noted that the licensee used several sources to check various instruments at the check station These were a 20 millicurie Cs-137 source u;ed for checking the integrating alarming dosimeters, a 2 millicurie Sr-90 source used for checking RO-2s, and four Technetium 99 sources for checking friekers. These sources permitted the licensee to check essentially all ranges of instruments issued.
The use of the sources was considered a good licensee iniiative to verify operabiFty of radiation monitoring or survey instruments.
The inspecto'fs observation indicated personnel did not wear extremity dosimeters when using the various sources. The inspector noted that the RO-2/RO-2A source checking device (2millicurie Sr 90) produced a dose rate o an indicated 89 r
Rads /hr at 2 inches from the source and 13 Rads /hr at 18 inches.
The inspectors review of the RO 2/RO 2A source check device indicated the following:
The source check device was constructed using an approved radiation work
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permit by properly qualiDed personnel.
The individual who constructed the 2 millicurie checking device wore
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appropriate personnel monitoring devices for the extremity.
The individual constructing the 2 millicurie RO 2 checking device used
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long handled tweezers when handling the source. No significant exposure was sustained constructing the devic f
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The device was placed in service in mid January 1991.
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As discussed in section 4, personnel using the device received appropriate g
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training to use the device.
um A dratt instruction was in place for use of the device. The instruction was
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subsequently approved on February 22,1991.
The device has never malfunctioned or stuck in the open position causing
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unnecessary personnel or unmonitored exposure.
The inspector noted that the licensee had issued extremity dosimetry to one
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individual who was using the source checking devices to evaluate the extremity dose received. The !!censee's preliminary review indicated the dose to the extremity ".ouni Se minimal and would not require issuance of extremity dosimetry.
The inspector noted that personnel could put their hands in an apparent maximum radiation field of 28 mrad /hr when using the RO 2 and RO 2A source checking device and 40 mR/hr when using the digital ahuming dosimeter check source. The licensee indicated an evaluation of expected ex.;emity dose was e
underway and would be documented. Preliminary inspector review indicated expected extremity dose of personnel performing the instrument checks would not require issuance of extremity monitoring devices This item is unresolved (50-245/91 07 s '
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10.
Industrir anfety During tours et the station, the following observations in the area of industrial safety were made:
On Februaiy 18,1991, at about 4:00 p.m., the inspector observed personnel
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working in close prc 2..ity to the edge of the dry Unit 3 refue'.:ng cavity.
The individuals were not using safety belts. Also, the open upender pit area did not have any railing around it or safety barricading to preclude personnel from falling into it.
The licensee immediately required personnel to use safety lines. The c
licensee also stationed a guard at the open pit area to preclude personnel from falling into the pit. The licensee also informed personnel of the need to wear required safety equipment as specified in station procedures.
Personnel were informed at the morning outage meeting on February 19, 1991.
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On Februniy 19,1991 at about 10:30 a.m., after the morning meeting, the
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inspector observed two individuals working in close proximity to the edge of the Unit 3 Reactor Cavity ($1' elevation containment). The individuals did not b'.n,n safety lines or life vests. The cavity was pr.rtially f'.lled with wa'..:r.
T ne matter was immediately brought to the licensee's attent on. The i
licew subsequently placed signs around the cavity identifying sMety equipment to be worn in the area.
On February 21,1991, a contractor worker was observed inside a posted
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fall protectior nrea near the reactor cavity on the 51' elevation of the Unit 3 containment. The individual was involved in operation of the fuel upender. The inspector informed a licensee refueling sui
<isor who requestb4 the contractor to don the fall protection equip.m.nt.
l The above obseravtlons indicated an apparent need for enhanced worker sensitivity 'o the need to use lleensee required safety equipment.
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Exit Meeting l
The inspector met with licensee representatives (denoted in Section 1) on February 22,1991. The inspector summarized the purpose, scope and findings of the inspection. No written material was provided to the licensee, i
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