IR 05000245/1996003

Insp Repts 50-245/96-03,50-336/96-03 & 50-423/96-03 on 960205-09.Violation Noted.Major Areas Inspected:Radiation Protection & Radwaste,Including Maintaining Occupational Exposures ALARA & Radiological Housekeeping

ML20149L152
Person / Time
Site:	Millstone
Issue date:	02/13/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20149L149	List: IR 05000245/1996003 ML20149L146
References
50-245-96-03, 50-245-96-3, 50-336-96-03, 50-336-96-3, 50-423-96-03, 50-423-96-3, NUDOCS 9602230323
Download: ML20149L152 (6)

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U. S. NUCLEAR REGULATORY COMMISSION Region I DOCKET / REPORT NOS:

50-245/96-03 50-336/96-03 50-423/96-03 LICENSEE:

Northeast Nuclear Energy Company Hartford, Connecticut FACILITY:

Millstone Units 1, 2, and 3 LOCATED AT:

Waterford, Connecticut INSPECTION DATES:

Februar

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INSPECTOR:

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Josph I'urM, Sr. Radiation Specialist Date Rad'iation Safety Branch Division of Reactor Safety 2-D %

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APPROVED BY:

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John ly. Whi te, Chie,f Date Radiation Safety Branch Division of Reactor Safety l

AREAS INSPECTED:

Radiation protection and radwaste programs at Millstone Station, including maintaining occupational exposures as low as is reasonably achievable (ALARA), radiological housekeeping, procedures and control of work, and training.

RESULTS: One apparent violation of NRC requirements was identified.

This involved the failure to conduct operations in Unit I liquid radwaste in accordance with the Unit Updated Final Safety Analysis Report (UFSAR) and without analyzing these changes in accordance with 10 CFR 50.59.

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DETAILS i

i 1.0 INDIVIDUALS CONTACTED 1.1 Licensee Personnel

• J. Althouse, Radwaste Remediation Project Leader

• J. Bauer, Unit 1 Operations Assistant

• K. Beagle, Unit 3 Technical Support

• D. Beauchamp, Nuclear Information Services

• B. Benchal, Unit 1 Design Engineering Manager

• P. Calandra, Unit 2 ALARA Coordinator

• F. Dacimo, Vice President - Operations

• R. Decensi, Unit 3 Radiation Protection Supervisor

• R. Doherty, Unit 1 ALARA Coordinator

• M. Finnegan, Unit 1 Health Physicist

• F.. Gault, Unit 1 Radiation Protection Supervisor

• J. Geary, Unit 3 Health Physics

• D. Harris, Nuclear Licensing

• S. Horner, Site Health Physics

• J. Johannemann, Unit 3 Health Physics

• R. King, Unit 3 ALARA Coordinator

• N. Knudsen, Unit 3 Health Physics

• J. Laine, Radiological Engineering Supervisor

• G. McElhone, Assessment Services

• P. Mirer, Nuclear Licensing

• M. Nappi-Althouse, Unit 2 Radiation Protection Supervisor

• W. Nevelos, Director, General Services

• C. Palmer, Manager, Waste Services

• P. Przekop, Manager, Unit 1 Operations

• D. Regan, Unit 3 Assistant Radiation Protection Supervisor

• W. Riffer, Unit 1 Director

• J. Rigatti, Technical Training Supervisor

• F. Rothen, Vice President - Work Services

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• P. Simmons, Health Physics Support Supervisor

• T. Stafford, Unit 1 Assistant Radiation Protection Supervisor

• P. Strickland, Health Physics Manager

• S. Strout, Nuclear Licensing

• B. Thumm, Nuclear Licensing

• I. Turner, Unit 3 Health Physicist

• A. Vomastek, Technical Training

• J. Waggoner, Technical Training

• D. Wilkens, Unit 1 Chemistry Supervisor

• T. Wilson, Health Physics Secretary 1.2 NRC Employees R. Arrighi, Resident Inspector D. Beaulieu, Resident Inspector

• A. Burritt, Resident Inspector T. Cerne, Senior Resident Inspector

• P. Swetland, Senior Resident Inspector

• Denotes those present at the exit meeting on February 9, 1996.

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The inspector also interviewed other licensee and contractor personnel.

2.0 PURPOSE OF INSPECTION

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An announced inspection of the licensee's radiation protection and radwaste programs was conducted. The inspection included a review of the licensee's program for maintaining occupational exposures as low as is reasonably achievable (ALARA), radiological housekeeping, procedures and control of work,

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and training.

3.0 RADWASTE By letter dated December 13, 1995, from D. B. Miller to the NRC, in response to a request for information, the licensee provided the results of its root cause analysis for the conditions found in the liquid radwaste facility at Unit 1.

The initial NRC identification of concerns with the conditions was contained in NRC Report Nos. 50-245/95-35; 50-336/95-35; and 50-423/95-35.

The letter also contains proposed corrective actions for the root causes, and

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also addresses other NRC concerns with regard to operation of the facility in a manner consistent with the Unit 1 Updated Final Safety Analysis Report (UFSAR) and the potential for releases of radioactive material to the environment.

Regarding the root cause of the conditions of the liquid radwaste facility, the licensee concluded that it was the direct result of a lack of management attention, and that corrective action processes of the past were ineffective.

A secondary cause was attributed to an apparent absence of ownership for the radwaste systems. Corrective actions proposed include the desigration of an operations assistant to be responsible for the liquid radwaste facility, along with a systems engineer.

Similar actions are also proposed for Units 2 and 3, where the management emphasis was also weak in this area.

The licensee concluded that the potential for environmental releases of radioactive materials spilled within the radwaste facility is negligible, due to the facility construction (the facility is a Class I seismic structure, due

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to the presence of the Unit 1 control room on an upper elevation).

Regarding the UFSAR concerns, the licensee examined the issue from the perspective of the completeness and accuracy of the facility drawings, and concluded that no significant deviation occurred. The licensee did not, however, address the operation of the facility in a condition in which transfer piping from the reactor and turbine buildings was degraded, pipe supports and pipe restraints were improperly installed, in-service tanks and vessels were leaking radioactive materials, and radioactive spent resins were deposited on the floor of a closed cubicle floor ("A" Concentrator Room).

These conditions were not methods of operations discussed in the UFSAR, and

represent changes in the operation of the system that were not described, analyzed, or evaluated in accordance with the requirements of 10 CFR 50.59,

" Changes, tests and experiments. This is an apparent violation (50-245/96-03-01).

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A review of the licensee's corrective actions for the inadequate ownership and

management oversight of the facility indicated that the proposed structure of

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this oversight is essentially the same as has been present at the facility

over the past several years and failed to address the degraded condition in

the past.

In addition, in the licensee's letter of December 13, 1995, t

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reference is made to an attempt several years ago by senior station management

to have the Unit 1 management address concerns with the conditions in the

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i radwaste facility.

It also stated that the actions taken were inadequate or improperly implemented. This apparent lack of adequate corrective actions is

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of particular concern to the NRC.

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i Discussions held by members of the NRC Region I staff also indicate that during the period 1990-1992, several discussions were held between a region-

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based health physics inspector and then-members of the Unit I technical staff,

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and between a resident inspector and the then-Unit 1 Radiation Protection

Supervisor regarding the material conditions of the Unit I radwaste facility.

These inquiries were made in light of a previous event that nad occurred in i

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i the radwaste building of another nuclear facility in 1989.

During these l

discussions, and in response to verbal inquiries, the licensee representatives did not indicate that the conditions in the facility had significantly

degraded, or that there were waste materials in the form of resin beads, sludges or evaporator concentrates on the floor of the facility.

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4.0 RADIATION PROTECTION PROGRAM

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l 4.1 Maintaining occupational Exposures ALARA At Unit 1, the refueling outage (RF015) which commenced in November 1995, has been indefinitely extended, in part, due to the need to conduct extensive examinations of various piping welds, and conduct repairs, as necessary.

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original outage exposure goal was 315 person-rem, but as of this inspection, total outage exposure had already exceeded 550 person-rem. The majority of

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i the over-budget exposures were traceable to the expanded work scope. At the time of this inspection, work in the reactor building and in the drywell

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continued, especially on the low pressure core injection and emergency i

condenser system piping. Most of the work in the drywell was occurring on the 32' elevation, where general area dose rates typically ranged from 60-100

i milliroentgens per hour (60-100 mR/hr).

Due to the constantly expanding scope of work,' pre-planning for these inspections was limited, and ALARA initiatives to reduce exposure were generally restricted to the use of lead shielding.

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exposure goal for the remainder of the outage had been determined at the time

of this inspection, pending a determination as to the remaining scope of work.

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At Unit 2, the unit continued to operate at or near full power since the conclusion of its refueling outage in 1995.

For 1995, total unit exposure was 136.3 person-rem. This is one of the lowest annual exposure totals for the

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unit, in spite of the significant extension of the last refueling outage which commenced back in 1994 and extended well into 1995.

For 1996, an exposure

goal of 76 person-rem had been established, which included a scheduled mid-

cycle outage in April 1996. Although no major work of radiological

significance is currently scheduled to be performed, accurate ALARA

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' projections and controls continue to prove difficult to implement, in part, due to a continued lack of planning and work control. With only 7 weeks remaining before the outage commencement, the work scope for the outage had

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still not been finalized.

I At Unit 3, the unit has operated at or near full power since the forced shutdown in December 1995.

The December outage was necessitated in order to e

repair primary system leaks in the loop areas. Replacement of 16 flow taps (four per loop), resulted in an exposure of 19.6 person-rem, while the entire

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outage expended 48.7 person-rem.

Extensive use of shielding on the pri: nary

piping and the utilization of cameras to reduce the num'oer of personnal i

needing to be present in the high dose rate areas aided in reducing the total exposure for the outage. For 1996, the unit has established a goal of 41 person-rem,.which includes a contingency of 15 person-rem for a forced outage.

Should the unit remain on-line for the entire year, a challenge goal of 19 person-rem has been established.

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4.2 Control of Radiological Work As part of this inspection, tours of various areas of the plant were conducted by the inspector.

In general, with the exception of the Unit I radwaste

facility (see Section 3.0), areas of the Radiologically Controlled Area (RCA)

were found to be well maintained and posted. Appropriate radiological controls, as required by NRC regulations and plant technical specifications, t

were found at the entrances to high and locked high radiation areas.

Extensive clean-up efforts were noticeable in Unit 1 in the condenser bay and

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on the turbine deck, while Unit 3 continued to maintain a very clean facility.

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The inspector also reviewed some of the licensee's new radiation protection procedures. A current project involves the development of common radiation

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protection procedures to support all three of the licensee's sites (Millstone,

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Haddam Neck and Seabrook).

Three procedures, listed below were reviewed by the inspector, and determined to be a significant improvement over previous

procedures, especially in the area of clarity and ease of use.

The procedures

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utilizing them.

NUC RPM 5.1.1, Rev 0, " Expected or Declared Pregnant Worker Exposure Control" i

NUC RPM 5.1.2, Rev 0, " Posting of Radiological Control Areas" NUC RPM 5.1.4, Rev 0, " Annual Occupational Exposure Control and Increased Radiation Exposure Approval" 4.3 Training j

The inspector discussed, with members of the licensee's technical training staff, upcoming training sessions to be given to the health physics and waste services organizations.

For the first quarter of 1996, health physics j

training is scheduled for 2 days, and will include self-directed training,

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problem solving and industry events.

For waste services technicians, a training program on changes to 49 CFR and 10 CFR 71 (scheduled to be i

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implemented on April 1, 1996) will be provided in March.

For shipping engineers, a more extensive training on the regulatory changes is scheduled for February.

Based on a review of the training lesson plans and discussions with and observations of plant personnel, the inspector concluded that the licensee's technical training program continues to be a notable strength.

5.0 FINAL SAFETY ANALYSIS REPORT A recent discovery of a licensee operating their facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR description.

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While performing the inspections discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspector verified that the UFSAR wording was consistent with the observed plant practices, procedures and/or parameters with regard to the i

radiation protection program.

The inconsistencies noted between the wording i

of the UFSAR and the plant practices, procedures and/or parameters in the Unit I radwaste facility, observed by the inspector and discussed in Section 3.0, will be the subject of separate correspondence at a later time.

t 6.0 EXIT MEETING The inspector met with the licensee representatives denoted in Section 1.0 of

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this report at the conclusion of the inspection on February 9,1996. The

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inspector summarized the purpose, scope and findings of the inspection. The

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inspector informed the licensee that a Pre-decisional Enforcement Conference would be scheduled to discuss the inspection findings contained in Section 3.0 of this report. The licensee acknowledged the inspection findings.

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