IR 05000245/1993022
| ML20056G965 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/27/1993 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20056G962 | List: |
| References | |
| 50-245-93-22, 50-336-93-16, 50-423-93-18, NUDOCS 9309080012 | |
| Download: ML20056G965 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION l
REGION I
l Repon Nos. 50-245/93-22
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50-336/93-16 l
50-423/93-18 Docket Nos. 50-245 50-336
DPR-65 Category.C NPF-49 Category _C Licensee:
Nonheast Nuclear Enerev Company P. O. Box 270
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l Hanford. Connecticut 06141-0270 Facility Name:
Millstone Nuclear Generatine Station Units 1. 2. and 3 l
Inspection At:
Waterford. Connecticut
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Inspection Conducted: Aueust 2-6. 1993 ez
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S*233 l
Inspector-
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R. L. Nimitz,MP date i
Senior Radiation ialist
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cr> i b D33 Appmved by:
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W.TPas(tak, Chief date
l Facilities Radiation Protection Section Areas Reviewed: This inspection was an unannounced radiological controls inspection. The areas reviewed included progmm changes, organization and staffing, tmining and qualifications, audits and assessments, effons to maintain radiation exposures as low as is reasonably achievable
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(ALARA), external and internal exposure controls, instrument calibrations, control room l
ventilation system testing, radioactive material and contamination controls, process monitor l
testing, and station housekeeping. The inspection principally focused on the planning and
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preparation for, and the adequacy and implementation of, radiological controls for the refueling outage at Millstone Unit 3. The inspector also reviewed activities at Units 1 and 2 including the
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entry of personnel into Unit 2 containment, with the reactor at power, to perform leak repair activities on a letdown valve.
i 93090B0012 930827 PDR ADDCK 0500
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Findings:
The inspection identified that, overall, very good radiological contmis were implemented for the Unit 3 outage and the work activities reviewed at Units 1 and 2. Areas that were panicularly notewonhy included planning and coordination of work act.vities for the outage, the general material condition of the station, and control of ratioactive and contaminated material. The radiological contmls provided for the repair of the Uei? 2 letdown
valve were considemd good. Your effons to maintain the conditions inside the Uni 6 3 teactor i
containment to allow personnel entry with stmet clothing was commendable. Also, station efforts in the ALARA area continue to be very good. One unresolved item was identified. The item involved the training and qualification of personnel performing instmment calibrations or using instmments.
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DETAILS
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l.0 Individuals Contacted 1.1 Northeast NucMr Enerev Company F. Dacimo, Director, Millstone 3
- R. Factora, Unit Services Director
- J. Sullivan, Manager, Health Physics Operations
- C. Palmer, Manager, Health Physics Support
- J. Laine, Radiological Engineering Supervisor
- H. Siegrist, Supervisor, Radiological Protection
"T. Burns, Health Physics Training Supervisor
- R. Sachetello, Radiation Pmtection Supervisor, Unit 3
- D. Regan, Assistant Radiation Protection, Unit 3
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- T. Stafford, Assistant Radiation Protection Supervisor, Unit 1
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- R. Doherty, Unit 1 ALARA Coordinator l
"D. Harris, Licensing Engineer 1.2 USNRC P. Swetland, Senior Resident Inspmor, Millstone l
R. Arrigi, Resident Inspector, Millstone Unit 3 D. Dempsey, Resident Inspector, Millstone Unit 2
- K. Kolaczyk, Resident Inspector, Millstone Unit I 1.3 Others I. Haas, Radiation Pmtection Group, NUSCO W. Koste, Supervisor of Radw:.;te Engineering, NUSCO
- Denotes those individuals attending the exit meeting on August 6,1993.
The inspector also contacted other licensee employees.
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2.0 Purpose and Scope of Inspection The following areas were reviewed during this routine, unannounced radiological controls inspection:
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changes;
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planning and preparation;
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organization and staffing;
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training and qualifications;
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audits and assessments;
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extemal and internal exposure controls;
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instrument calibration;
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Unit 3 Control Room Emergency Ventilation System testing;
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radioactive material and contamination controls; process radiation monitor testing; and
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station conditions.
3.0 Changes The inspector reviewed changes at the licensee's facility, in the area of radiological contmls, since the previous inspection. Areas reviewed were:
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organization and staffing; procedures and programs; and
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facilities and equipment.
i No major changes were identified that would adversely affect the effectiveness of the
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radiological controls pmgram.
The inspector did note that the licensee was in the pmcess of reviewing and planning to
place in service an interim low level waste storage facility. The facility would apparently utilize an existing structure at the station (Warehouse 1). Reviews were on-going to evaluate the facility relative to applicable regulatory guidance. The inspector will review the status of this facility during a future inspection.
i The following observations were made:
The licensee constmeted an add-on radiological controlled area (RCA) access
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control facility for the Unit 3 outage. The add-on was considered a very good licensee initiative.
No safety concerns or violations were identified.
4.0 Orcanization and Staffing i
The inspector reviewed the organization and staffing of the on-si' :sdio1~. ontrols organization. The review was with respect to criteria contained rn6ble Technical Specifications and licensee administrative documents.
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The inspector evaluated licensee performance in this area by review of applicable documentation, discussions with cognizant individuals, and independent observation of l
on-going work activities during tours of the facility. The inspector also reviewed the Unit 3 Refueling Outage Organization to evaluate the method of licensee oversight of contracted radiological controls personnel.
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The inspector's review indicated that the licensee implemented an adequately defined j
outage radiological contmls organization. Them was generally very good supervisory and management oversight of work activities.
The following observations wem made:
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Permanent licensee personnel were placed in supervisory positions to pmvide oversight of contractor personnel.
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Them was very good communications within the radiological controls group at Unit 3 regarding on-going and planned activities.
No safety concerns or violations were identified.
i 5.0 Trainine and Oualification
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The inspector reviewed the training and qualification of radiological controls contractor personnel supporting outage work activities. The inspector also reviewed the training and qualification of radiation workers. The review was with respect to applicable Technical Specification requirements and 10 CFR 19, Instmetions to Workers.
The evaluation of the licensee's performance in this ama was based on discussions with personnel, review of training records and qualification documents, and mview of resumes. The inspector also observed personnel performance in the field during tours and observation of on-going work activities.
The inspector reviewed a random selection of vendor radiological contmls technician training and qualification documentation and determined that contractor radiological contmls personnel, hired to augment the organization during the outage and pmvide direct oversight of on-going radiological work activities, met or exceeded the minimum training and experience requimments.
The inspector also reviewed the qualifications and training of contractor technicians himd to perform instmment calibration activities and counting activities.
The following unresolved item was identified:
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The inspector identified three individuals who wem involved with calibration of radiation survey and counting instruments for whom them was no documentation to demonstrate that they had received any training and qualification for the tasks they were performing. Discussions with training group personnel indicated a training pmgram was established for personnel perfonning instmment calibration but the three individuals had apparently not been provided the course. The inspector's discussions with personnel, including with one of the three individuals
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and his supervisor, indicated on-the-job training had been provided but not
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documented. The licensee took immediate actions to evaluate this matter and i
assure personnel had or would be provided appropriate training. The licensee provided direct supervisory oversight of these activities pending completion of the evaluation.
The inspector also reviewed the training and qualification of personnel performing counting mom activities and reviewed training records for personnel that performed such activities. The inspector's review indicated specific training and qualification pmgrams were developed for counting mom activities including operation and use of gamma spectroscopy equipment (e.g., the new gamma spectroscopy equipment at Unit 2).
The training included such matters as i
counting statistics, efficiency determinations, operations, and performance checks.
The inspector's review identified one individual, who was apparently performing
counting acdvities at Unit 3, that did not appear to have received training on use of the counting equipment. A qualified individual indicated that the technician had been observed to satisfactorily perform counting activities.
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The training and qualification of personnel performing calibration and counting i
room activities is an unresolved item (50-423/93-18-01) pending further NRC review.
The inspector's review of radiation worker training records indicated selected personnel observed in the radiological controlled area had received appropriate radiation worker training. The inspector also noted that the licensee provided procedure training to the Millstone Units 2 and 3 and Haddam Neck radiation pmtection personnel temporarily assigned to support Millstone Unit 3 outage activities. The licensee also provided plant systems training (with a focus on radiological controls matters) to incoming contractor radiological controls technicians hired to augment the Unit 3 organization.
The inspector further noted that the licensee also provided sepervisory skills training to the radiation protection technicians at Unit 3 temporarily upgraded to supervisors / lead technicians.
No violations were identified.
i 6.0 Audits and Assessments
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The inspector reviewed the licensee's audits and assessments of the radiological controls program. The review was with respect to criteria contained in Technical Specification 6.4.
The evaluation of the licensee's performance in this area was based on discussions witL cognizant hcensee personnel and review of selected surveillances, audits and assessments
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performed by the licensee since the previous inspection. The following documents were reviewed:
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Airborne Activity Monitoring Audit, dated March 19, 1993;
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Contamination Controls Audit, dated June 18, 1993;
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Survey Documentation Assessment Audit, dated June 25,1993;
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Second Quarter 1993 observations, deficiency reports and surveillances; and
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Plant / Count Room Operations, Audit No. A60530, dated June 15, 1993 The following area for enhancement was identified:
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The licensee's corponte radiological controls group established approved pmcedures that provide guidance for auditing the site radiological contmls pmgmm. The pmcedure included a detailed list of topical areas to be reviewed.
The inspector noted that the list did not include the corrective action pmgram for radiological controls concems. The licensee's personnel indicated that this matter would be reviewed.
In addition to the above matter, the inspector identified personnel involved with calibration and operation of radiation pmtection survey meters and counting mom equipment who did not have training records to demonstrate that they were quaWied in their tasks. This matter is further discussed in Section 5 of this report and may indicate an apparent need for enhanced oversight of training and qualification of personnel within the radiological controls gmup. The identified individuals were contractors.
The inspector concluded that the licensee implemented a generally very good
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radiological controls audit program.
No violations were idendfied.
l 7.0 ALARA Efforts The inspector reviewed selected aspects of the licensee's program to maintain personnel radiation exposures as low as reasonably achievable (ALARA). The evaluation of licensee's performance in this area was based on review of documentation, discussions with cognizant personnel, independent observations of on-going work activities, and review of activities relative to general guidance and criteria contained in the following:
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10 CFR 20.1, Purpose;
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Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As Low As Is Reasonably Achievable; and l
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i Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational
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Radiation Exposures As Low As Is Reasonably Achievable.
The inspector also reviewed the licensee's planning and preparation for the Unit 3
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i refueling outage. The following matters were discussed:
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increase in staffing of the radiological controls organization;
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special training including use of mock-ups;
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radiation protection personnel review of work packages, dose reduction methods, radwaste reduction; and
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exposure goals development and monitoring The inspector reviewed planning and preparation for the following work activities at Unit 3:
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steam generator sludge lancing; i
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steam genemtor eddy current testing;
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pit seal replacement;
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reactor core exit thermocouple replacement; and
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reactor coolant pump motor change out.
The following ALARA initiatives were identified:
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The licensee established a corporate ALARA Committee. A committee Charter was established.
The committee is chaired by the Vice-Pesident, Nuclear Engineering Services.
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The licensee will use two cubicles in Unit 2 to store Unit 2 filters. The storage and the use of two special shielded transport casks were estimated by the licensee to save about 5 person-rem / year.
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The licensee designed and constructed a special 3D,000 pound reactor flange shield. The shield will be used at Unit 3. The use of the shield was estimated by the licensee to save about 50 person-rem for the next 5 refueling outages.
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The licensee constmeted a full scale mock-up of a reactor nuclear instmment well. The mock-up will be used for training purposes for well inspections. The use of the mock-up was estimated to result in a savings of about 1 person-rem for the planned work.
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The licensee has two steam generator mock-ups. The mock-ups are routinely used for steam generator work plannin
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Thv licensee is planning to replace the reactor cavity pit seal at Unit 3. The licensee has been planning about 1.5 years for the task and has sent tecimical personnel, including radiological controls technicians, to the vendor's facility for training.
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The licensee plans to install 15 mmeras to monitor on-going outage activities at Unit 3.
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The licensee implemented the use of " hot" (contaminated) tool cribs at Unit 3 for the outage. The use of the tools cribs will reduce the need to bring tools into the
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l radiological controlled area (RCA) and the need to decontaminate them and survey them for removal fmm the RCA.
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The licensee was developing a five year ALARA Plan (1994-1998). The draft plan included ALARA objectives, strategies, trends, and targets.
The inspector noted that ALARA goals were reasonable and based on comprehensive l
evaluation of work scope and prior historical data.
No safety concems or violations were noted. Licensee planning and meparation for major work tasks was very good.
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8.0 External and Internal Exposure Controls i
The inspector reviewed the implementation and adequacy of radiological controls at Units 1, 2 and 3.
The evaluation of the licensee's performance was based on discussions with cognizant i
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personnel, independent inspector observations during tours of Millstone Units 1, 2 and
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3, observations of on-going work activities, and review of documentation.
The inspector's review principally focused on review of outage activities at Millstone Unit 3.
The inspector toured the radiologically controlled areas of the plant and independently reviewed the following elements of the licensee's external and internal exposure control program:
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posting, barricading and access control, as appropriate, to Radiation, High Radiation, and Airbome Radioactivity Areas;
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High Radiation Area access point key control;
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personnel adherence to radiation protection procedures, radiation work permits, and good radiological control practices;
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use of personnel contamination control devices;
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use of dosimetry devices; l
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use of respiratory protection equipment;
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adequacy of airborne radioactivity sampling and analysis to plan for and suppon
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timeliness of analysis of airborne radioactivity samples including supervisory review of sample results; l
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installation, use and periodic operability verification of engineering co:dmis to
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minimize airborne radioactivity;
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records and repons of personnel exposure;
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adequacy of radiological surveys to support pre-planning of work and on-going work; and
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adequacy of supply and performance checks of survey instmments.
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The inspector also selectively reviewed calibration of counting instruments (e.g., Ge-Li detectors) and ponable survey instruments.
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The review was with respect to criteria contained in applicable licensee procedures and 10 CFR 20, Standards for Pmtection Against Radiation.
The inspector independently reviewed on-going work activities and performed independent radiation surveys to verify radiological survey information ar.o c 'aluate the adequacy of radiological controls. Work activities reviewed included on-going Unit 3 work activities and work activities at Unit 2 associated with attempts to repair a leaking letdown valve in Unit 2.
The inspector reviewed whole body count results and personnel contamination upons for individuals attempting to repair the leaking Unit 2 letdown valve during July and August 1993.
The inspector's review indicated the licensee implemented effective radiological controls for the work activities reviewed. The inspector noted that the licensee implemented correction factors for integrating alarming dosimeters after a negative bias (i.e, low reading) was identified.
The following observation was made:
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The licensee was not able to pmvide humidity effects data for the charcoal canridges used to collect air samples, during repair of the Unit 2 letdown valve leak, for evaluation of potential airborne radioactive iodine. Although no intake of radiciodine by personnel was identified, the cartridges appeared to have been used under high humidity conditions. The licensee indicated this matter would be reviewed.
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The inspector noted that the hinges on the locked Unit 3 High Radiation Area access key box were easily removable by hand allowing access to the key !
Ahhough the keys were in constant attendance, the licensee indicated this matter would be reviewed.
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Pmcedures regarding use of extremity monitoring devices provided limited guidance for when to use the devices. The licensee indicated this matter would i
be reviewed.
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The licensee's group responsible for calibration of mdiation protection j
instruments (e.g., survey meters) maintain instrument manuals at the calibration
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area. The manuals were apparently not in the licensee's vendor manual contml pmgram. The licensee indicated this matter would be reviewed.
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No safety concerns or violations were identified.
t 9.0 Radioactive Material Control and Contamination Control The inspector reviewed the adequacy and effectiveness of radioactive material, l
contaminated material, and contamination controls at Units 1, 2 and 3. The following j
matters wem reviewed:
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personnel frisking pmetices;
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use of proper contamination contml techniques at work locations, including control of hot particles;
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posting and labeling (as appropriate) of contaminated and radioactive material;.
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efforts to reduce the volume of contaminated trash including steps to minimize intmduction of unnecessary material into potentially contaminated areas; and
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adequacy of contamination stuveys to support planning for and support of on-going work.
The following area for improvement was identified:
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The licensee established procedures for monitoring hot particle areas. The procedure guidance was not clear as to the need (if appropriate) to survey personnel protective clothing upon egress of personnel from a hot particle zone.
The inspector noted that hot particles on protective clothing worn by personnel could present external exposure concerns. The licensee indicated this matter would be reviewed.
No violations were identified. The inspector's review indicated contamination controls were effective.
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12 10.0 Contml Room Ventilation System Testing The inspector reviewed the surveillance testing of the control room emergency ventilation system. The review was with respect to criteria contained in Techtical Specification 3/4.7.7, Control Room Emergency Ventilation System, and applicable licensee procedures. Items reviewed included operability tests, in-place leak testing, laboratory testing of charcoal, flow testing, pressurization, pressure drops across the system, and isolation tests.
The evaluation of the licensee's performance in this area was based on discussions with cognizant personnel, review of documentation and independent walk down of both trains
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of the rystem.
The inspector's review indicated that the system was properly tested.
The following matters were brought to the licensee's attention:
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(1)A welding machine with un-chocked wheels was positioned against the system inlet dampers of A filter train. The wheels were subsequently chocked.
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(2)A dumpster with unchocked wheels was positioned next to the B filter train.
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The wheels on the dumpster were also chocked.
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(3)Two 3/4 inch holes were found in the top of each filter train. The licensee
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reviewed the matter and concluded the holes were associated with a design change and were plugged from the inside.
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(4)A ladder was found lying across electrical cables for moisture indicator 3HVC-M1168B for B filter train. The cable was partially crushed. The licensee initiated an immediate review of this matter.
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(5)A yellow sign for oxygen deficient atmosphere was found on top of B filter train. The licensee removed the sign.
The inspector noted that three of the above matters (1, 2 and 4) appeared to indicate an apparent ne:d for improved control of work around the safety related ventilation system.
l No violations were identified.
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11.0 Process and Area Radiation Monitors The inspector reviewed the calibration and surveillance testi... of the following process and area radiation monitors:
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Unit 3 spent fuel storage radiation monitor
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Unit 3 fuel dmp monitor The review was with respect to criteria contained in Technical Specification Table 3.3-6, Radiation Monitoring Instrumentation for Plant Operations, and Table 4.3.3, Radiation l
Monitoring for Plant Operations Surveillance Requirements.
The evaluation of the licensee's performance was based on discussions with cognizant personnel and review of documentadon.
i No safety concerns or violations were identified.
l 12.0 Station Tours
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The inspector toured the station periodically during the inspection. The inspector l
considered overall housekeeping to be good.
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l The following observations were brought to the licensee's attention:
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During tours of the Unit 3 spent fuel storage building, the inspector identified four segments of large wood dunnage (@ 6 inch X 6 inch X 4 feet). The j
dunnage did not appear to be treated with a fire retardant. The licensee initiated a review of this matter
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The inspector identified two locations in the Unit 3 spent fuel building where personnel safety railing appeared to need improvement. A walkway around the
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spent fuel pool required individuals to step up and over a crane support. The
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safety railing at this point was below knee level in pmximity to the sIznt fuel storage pool. Also, a location near the new fuel inspection area exhibited a gap in the safety rail. The licensee placed additional safety rails at the two locations.
13.0 Exit Meeting
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The inspector met with licensee representatives (denoted in Section 1.0) on August 6,
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1993. The inspector summarized the purpose, scope and findings of the inspection. The licensee acknowledged the findings.