IR 05000336/1985010

Insp Rept 50-336/85-10 on 850301-02.No Violation Noted.Major Areas Inspected:Alara Implementation,Surveillance, Activities,Personnel Training,Dose Control & Steam Generator Repair Activities

ML20127H373
Person / Time
Site:	Millstone
Issue date:	05/03/1985
From:	Cioffi M, Mark Miller, Myers L, Shanbaky M, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127H326	List: IR 05000336/1985010 ML20127H321
References
50-336-85-10, NUDOCS 8505210285
Download: ML20127H373 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report N /85-10 Docket N License No. DPR-65 Priority --

Category C Licensee: Northeast Nuclear Energy Corporation P.O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Unit-2 Inspection At: Waterford, Connecticut

. . Inspection Conducted- arch 1-2,1985

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Inspectors:

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, F ,diation Specialist //

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M. ioffi, j adi tion / Spec'ialist / / da b-

<G'. 2 P S-M. Mill r, Radiation Specialist / /.dite

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L. Nfers, R&diation Specialist Wu/ss'

' dat6 Approved by: M ,II# f3 5'

M. M. Shanbaky,~Chfef ~/

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' date Reactor Protection Branch, DRS Inspection Summary: Inspection on March 1-2, 1985 (Report No. 50-336/85-10)

Areas Inspected: Routine, ' unannounced safety inspection - of the ' licensee's radiation protection program during outage condition Areas reviewed included: ALARA implementation, surveillance activities, personnel training, dose ~ control, steam generator repair activities, radiological area contro The inspection involved 81 hours9.375e-4 days <br />0.0225 hours <br />1.339286e-4 weeks <br />3.08205e-5 months <br /> onsite by four_ inspector _

Results: No violations were identifie PDR G ADOCK 05000336 PDR

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DETAILS : Persons Contacted 1.1. Licensee Personnel

• Mr. J. Kelly, Unit 2 Superintendent

• Mr. J. Kangley,, Radiological Service Supervisor

• Mr. 8. Granados, Health Physics Supervisor

• • Mr._E. J.'Mroczka, Millstone Station Superintendent

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• • Mr. B. Granados, Health Physics Supervisor

• • Mr. R. Herbert, Station Services Supervisor

• • Mr. W. Varney, Unit-1 Maintenance Supervisor

• • Mr. E. Laine, Unit-2 Radiation Protection Supervisor

• • Mr. W. Romberg, Unit -1 Superintendent

• • Mr. J. Summa, Unit-1 Engineering

• • Mr. R. L. Peterson, Unit-1 Maintenance Engineer

• Denotes personnel attending the exit interview on March 2, 198 ** Denotes personnel-attending the exit interview on March 29, 198 During the course of -this inspection other licensee personnel and contractors were_also contacted or interviewe . Purpose The purpose of this reactive. inspection was to review the licensee's radiological controls used to -support Unit-2 outage activities, particularly in regard to steam generator. repair and maintenanc .0. Status of Previously Identified Items (Closed) .-Inspector Follow-up (83-07-02). Licensee to determine and implement method (s) to assure the operability of beta gamma and neutron survey meters prior.to use in an unknown radiation fiel The licensee has- purchased and uses a Shepherd Model 28-5 Calibrator with a 120 millicurie cesium-137 source. The calibrator is used to perform functional ' checks' of the survey instruments' higher ranges prior to use in the field when necessar The licensee uses a 5.8 curie americium-beryllium neutron -source to functionally test neutron remmeters prior to use in the fiel ,

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(Closed) Inspector Follow-up. (84-22-02). Health Physics to evaluate use of check source for radiation monitor on fuel handling bridge during fuel

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reconstitution.

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During the fuel rec'onstitution, the licensee did initiate a daily opera-tional check! on the Victoreen Area Radiation Monitor to ensure that the monitor was responding to background radiation. The _ instrument was source checked weekly _ to ensure that the alarm set point (10 milliroentgens per hour) was responding properl (Closed)- Unresolved (83-20-03). Review deficiencies identified in li-censee's respiratory protection progra Details appear in section (Closed) Violation (84-22-01). Fa'ilure' to follow procedure SP-84-2-11 requiring _ railroad roll-up door closure during fuel movemen The licensee's corrective action, as stated in Inspection Report Number

~84-22 appears sufficient to prevent recurrenc ~ 4.0 Steam' Generator Nozzle Dam Installation 4.1 Mockup Training, Nozzle Dam Installation and Tube Repair / Maintenance Activities

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A Westinghouse Steam generator mockup complete with supports and con-tainment was used to train and qualify personnel and verify equipment operabilit Inlet and outlet nozzle dams, including the rubber seal, support plates and air manifold were provided to approximate the actual equipment. Support personnel (including health physics technicians) and television monitors were used in training the per-sonnel selected to ' enter the channel heads (jumpers). The jumpers were given written task instructions and then directed on how to ac-complish specific actions within the allowable stay time. The jumpers were required to practice such task assignments in the same protec-tive equipment (anti-contamination clothing, respiratory protective equipment, and personnel monitoring equipment) that would be required for actual wor The training activity included a system to document end. certify in-dividual qualification prior to actual work assignmen No violations'were found in this are .2 Surveys to Support Nozzle Dam Installation The inspector reviewed the adequacy of licensee radiation and air-borne radioactivity surveys performed in support- of the planned in-stallation of sixteen nozzle. dams in Millstone Unit 2 steam gen-erators. The review utilized:

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a' 10 CFR 20.201, " Surveys" -

• Technical Specification 6.11, " Radiation Protection Program" The licensee's performance in this ' area was based on discussions

- with cognizant personnel, observation by the inspector, and review-of the following documents:

• Radiation Surveys of Steam . Generator No. 1, dated March 1 and March 2, 198 ~

• Licensee Memorandum, Subject, Millstone Unit 2 Steam Generator Radiological Survey's for Cycle 6 Refuel Outage, dated February 22, 198 * Radiation Surveys of Steam Generator No. 2, dated February 24, 27 and 28, 198 * Airborne Surveys of Steam Generator No. 1, dated March 1, 198 * Airborne Surveys of . Steam Generator No. 2, dated February 28 and March 1, 198 * Radiation Survey Analysi '

Within .the scope of the review, no violations were identifie However, due to the work area physical constraints, but with con-

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sideration to extremely short stay-times (in 3 minutes), the pro-tection factor of 2000 afforded by the supplied air hoods, the engineered ventilation arrangement in the channel heads, the hydro-lase of interior channel head surfaces to reduce loose surface ac- -

tivity, and . the. downstream' air monitoring of the ventilation flow path for changing trends in airborne ' activity, the licensee did' not elect to use breathing zone air (BZA) samples during work perfor-

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mance, but rather relied on either pre- or post-job ~ air sampling. In view of the extensive controls that were established, the lack of BZA sampling did not adversely. affect or compromise worker safet However, in order to better validate worker exposure (and in response e to NRC -concerns in this area), . the licensee initiated a program on March 3, 1985 to accomplish both pre and post-job air sampling in the channel head for each worker entry. The licensee's action was veri-fied as acceptable on March 26, 198 .3-- Exposure Control, Nozzle Dam Installation The inspector reviewed the issuance and use of personnel monitoring devices during the licensee's installation of steam generator nozzle dams.

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The review utilized:

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• 10 CFR 20.202, " Personnel Monitoring"

10 CFR 20.401, " Records of surveys, radiation monitoring and disposal"

• Licensee Memorandum, Subject, Steam Generator Entry: TLD Placement, _ dated February 26, 1985, and revised memorandum dated March 1, 198 * Licensee Memorandum, Subject, Beta Dose Rate Determination in Steam Generator Channel Heads, dated March 25, 198 The licensee's performance in this area was based on discussions with licensee personnel, direct observation of dosimetry placement by the. inspector, and review of personnel exposure records associated with the nozzle dam installatio Within the scope of this inspection, no violations were identifie The inspector also noted that the expended dose for installation of sixteen nozzle dams was 41.5 man-rem, which compared well to the 38.000 man-rem ALARA estimat . 5.0 Personnel Training and Retraining-The training and retraining of plant personnel, radiation workers, radiation protection personnel, and contractor personnel was reviewed with respect to:

• 10 CFR 19.12, " Instructions to Workers"

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• Regulatory Guide 8.27, " Radiation Protection Training for Personnel at Light Water Cooled Nuclear Power Plants," March, 198 * ANSI-N18.1, 1971, " Selection - and Training of Nuclear Power

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Plant Personnel."

-* Technical Specification 6.3, " Facility Staff Qualification."

• Technical Specification 6.4, " Training."

• Procedure ACP - 8.26, Revision 0. " Radiological Worker Training and Retraining for Company and Contractor Personnel."

The evaluation of licensee performance in this area was based on:

• Discussions with cognizant personnel

• A review of training and retraining lesson plans and objectives

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• Inspector discussions with workers in the field The inspector noted that all personnel were being adequately instructed. The training and qualifications . included practical

factors-and procedure training, as well as a written exa ~ Annual retraining of all site personnel was updated to include attention to problems identified in the work place during the year and any. changes in the regulatory requirement There were no violations identified during this revie .0 Respiratory Protection The. adequacy and effectiveness of. the licensee's respiratory protection program was reviewed with respect to the following criteria

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10 CFR 20.103, " Exposures of individuals to concentrations of

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radioactive materials in air in restricted areas".

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Procedure SHP 4905, Revision 6, " Radiological Surveys", dated January 9, 198 Procedure SHP. 4931, Revision 2, " Selection and Use of Respiratory Protective Equipment," dated September 9, 198 Procedure HP 4932, Revision 0, " Maintenance and Quality

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Assurance Program for Respiratory Protection Equipment," dated August 1, 198 Procedure SHP 4933, Revision 2, " Breathing Air Supply and Utilization," dated September 15, 198 Procedure - HP 4934, Revision 0,. " Medical Screening Program for Respirator Users," dated August 1,198 Procedure SHP 4935, Revision 1, " Respiratory Man-Fit Testing

, Using the Face Aerosol Test System."

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Procedure 943/2943A, Revision 0, " Respiratory Fit Testing Using the Air Techniques, Inc., T0A-50," dated September 22, 198 Procedure 946/2946, ' Revision 0, " Respirator Filter Cartridge Quantitative Testing Using the Air Techniques TDA-100 Aerosol Penetrometer Q127," dated May 31, 198 Procedure CP 801/2801 H, Revision 6, " Air Testing," dated March 26,'198 .

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. The licensee's performance in-this area was based on review of records, discussions with personnel, and observations by the inspecto .

The licensee was using temporary person'nel to handle the cleaning and- maintenance of the respirators and to perform the quantitative fit tests -cn radiation worker All personnel interviewed were well-trained in'the performance of'their task A-previous inspection (Inspection Report 50-336/83-20) identified

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deficiencies in the licensee's' respiratory protection program. It s was found that the licensee was using _ unapproved hose lengths 'and airline fittings. Furthermore, the licensee could not provide data to ensure that the proper air flow rate was being provided to radia-

- tion workers with the use of this equipmen The licensee has ceased this practice and now. purchases only

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pre-approved hose lengths with factory installed airline fitting Inspection Report 50-336/83-20 also identified that the licensee was using a combustible gas meter to measure the presence of gaseous i hydrocarbons in the supplied air. This technique originated from ,a

, : state of Connecticut regulation which endorsed the combustible gas

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meter as an acceptable technique for measuring gaseous hydrocarbons-in' Grade D ai After a more thorough investigation of the ' technique, the licensee concluded that the combustible gas- meter did not provide the sen-

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siLivity required to measure gaseous hydrocarbons at the maximum concentration of 5 milligrams per cubic mete Under procedure CP' 801/2801 H, " Air Testing," the licensee now uses both gas

- chromatography _ and the. National Draeger Aerotest Breathing Air ,

Tester to tcst - the quality of breathing : air supplied to radiation workers in respirator Item 83-20-03 is considered close There were no violations identified in this revie .0 Radiation Detection Instrumentation Calibration and Use The licensee's program for portable radiation detection instrumentation and use was reviewed against the criteria in:

• 10 CFR 20.201, " Surveys"

• - ANSI N323-1978, "American National Standard Radiation -

Protection Instrumentation Test and Calibration."

• Procedure 904/2905, Revision 5, " Calibration of Health Physics Instrumentation," dated August 9, 198 .

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• Procedure 904/2904B, Revision 5, " Calibration of Health Physics Air Sampling Equipment," dated October 26, 198 * Procedure 908/2908, Revision 1, " Health Physics Dose ~ Rate Instrumentation," dated March 22, 197 The licensee's ' performance relative to the criteria was determined by observations by the inspector, a review of records and supplies of equipment, and interviews with Health Physics Technician The licensee maintained adequate supplies of calibrated instrumen-tation for the ~ outage activitie Additionally, computerized in-

, .ventory records track the status and approximate location of all instrumentatio A check source is conveniently located - near supplies of survey meters for verification of functional instrumentaticn prior to taking into the fiel The licensee also has two Shepherd calibrator sources in the reactor building to check high range response if necessar There.were no items of noncompliance identified in this are .0 Radiological Control 8'.1. Organizational Arrangement and Staffing Figure 1 depicts the organizational arrangement used- to support radiological control activitie Several senior level, station HP technicians were temporarily upgraded to first line supervisory post-tions to support this expanded arrangement. Other HP technicians were assigned as. lead personnel for' specific radiological control

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implementation such as access control, control point management, work area surveillance, and support services. Contractor technicians.were assigned 'to support activities in these various areas, under the direction of the designated station HP personne Such arrangement permitted the licensee to maintain a high degree of control and awareness over all outage - related activities involving personnel. exposure to radiatio Staffing composition included about 48 station personnel (i.e., 37 technicians,- and 11' supervisors); about 40 contractor senior level technicians from Combustion Engineering; and about 24 junior level and clerical personne staffing =and arrangement appeared sufficient

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Such to effect adequate radiological controls in support of the outag . .

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' 8;2- ALARA Implementation The licensee's ' implementation of the ALARA concept was reviewed against the guidance of Regulation Guides 8.8 and 8.10, and the

specifications of the Millstone Administrative Control Procedure 6.02, Revision 9, " Maintenance of Occupational Radiation Exposures-ALARA", and the Corporate Management Program for Maintaining Occupa-

.tional Exposures As Low As Reasonably Achievable".

The licensee's performance in the area .was based on review of ALARA Job ' Planning' Packages, utility reports of exposure expenditures, re-view and audit of the -implementation of specified exposure reduction techniques, and ' interviews with various ALARA coordinators and specialist The following outage projects were reviewed:

' Cycle 6 Refueling Steam Generator Eddy Current Testing Steam Generator Secondary Side Inspection Steam Generator. Chemical Cleaning Core Support Barrel Inspection Steam Generator Tube Sleeving The licensee's 'HELPORE .II system permits the development of an ex -

tensive data base for all tasks that are controlled by a Radiation Work Permit'. Inputs pertaining to RWP. number, Plant System Involved,

.. Task Description,' Man-hours Expended, Man-Rem expended, Estimated Ex-posure,- Task Goal, and other discreet identifiers are sorted and

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analyzed on a daily- basis to provide near real-time performance values. . Weekly summary reports are made to station and corporate-management' to facilitate decision -making _ at those levels. The system permits first line supervisors and task managers the opportunity to keep aware of personnel exposure expenditures for specific projects and specific tasks in each projec Estimation of exposure expenditures was performed based on previous -

performance values with consideration to ' applied dose reduction method Lessons learned from previous jobs were reviewed _ and-incorporated into the job planning and preparation of the current work effort. Cost-benefit analysis was performed for. certain select tasks to determine man-rem savings relative to cos . ALARA Job Evaluations were performed for major tasks having Man Rem estimates in excess of l'.0. Specific radiological controls and task performance methods were formally detailed and included with job

. briefing Periodic audits were performed to assure that' all specified~ requirements were implemented, and that the ALARA job specifications were posted at the control poin .

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Station policy assigns stop work ' authority to senior station management, on-the-job supervisors, Job / Task Department Heads, and health physics staff when radiological conditions or job practices

' indicate that- to proceed will or may result in conditions that violate' NRC regulations, station procedures, or ALARA controls

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the ALARA staff in instances of incompleted ALARA controls being

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identified during work area audits, indicating that the program is actively engaged in implementing ALARA concept .3 Administrative Control of Personnel Dosimetry Administrative Control of Personnel Dosimetry was reviewed against the criteria specified in 10 CFR 20.101, " Radiation Dose Standards for Individuals in Restricted Areas." The licensee's performance relative to this. criteria was determined from review of procedures used for control, and review of current exposure summary reports for all worker On a daily _ basis, the licensee inputs dosimetry information from RWPs and personnel exposure devices (personnel ion-chambers) into the HELPORE syste Current printouts are maintained ct each control-point,, in addition to being subject to daily management revie The printouts list the exposure status of each individual in terms of cur-rent quarterly exposure, year-to-date exposure, and total intake of airbor_ne activity. The system automatically _ flags individuals who are approaching administrative limits, who have exceeded administra-tive limits, or when there is a question or concern about their exposur From this printout several personnel were selected by the inspector for verification of exposure, and completion of personnel exposure records. All records -were. found to be complete and in accordance with -regulatory requirement Reported personnel ' exposures were verified to be an accurate assessmen No violations were identifie .4- Radiological Controls Implementation The actual implementation of radiological controls was reviewed against the following criteri Title 10 Code of Federal Regulations, Section:

20.105 Permissible levels of radiation in unrestricted areas 20.201 Surveys 20.202' Personnel monitoring 20.203 Caution signs, labels, signals and controls 20.207 _ Storage and control of. licensed materials in unrestricted areas

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The licensee's performance relative to this these criteria was

- determined from . interviews with radiation protection management-

. personnel, direct observation of -jobs in progress, observation of work conditions and areas, and review of pertinent surveillance record ' Posting Land labeling of radiological conditions in the plant were

.found to be in accordance with the regulatory requirements. High radiation areas were conspicuously posted and barricaded. Areas greater than 1000 mrem / hour were locked or under the direct control of' cognizant health physics personne For the purposes of this outage the containment was maintained in a 1 condition to allow general access to authorized personnel. A general-access RWP was not. required nor was there a need for protective clothing since accessible areas were maintained at less then 1000 dpm/100 cm2 ,

Special control points, continuously manned, were set up in the containment to control -worker exposure and access to work ; area Generally,10 to 12 health physics technicians were in containment-continuously to provide radiological control . support. Tasks having high radiological risk were provided with continuous health physics coverag All ,RWP and task-related ALARA controls were verified to -

be implemented for the following tasks:

Steam Generator Eddy Current Testing Steam Generator Tube Plugging Steam Generator Chemical Cleaning Core Barrel Inspection CEDM Cutting

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Fuel Rod Ultrasound-Inspection Surveillance activities, i.e., radiological surveys 'to support these tasks were performed adequatel Airborne radioactivity -concentrations were generally 1E-9 uC1/ml in the -steam generator Respiratory protective devices used by in-dividuals in the area afford' sufficient protection. Whole body count-ing results of persons involved in actual entries did not-indicate.any positive intak No violations were found in this are '

9.0 ' Exit Interview-The. inspector met with licensee representatives (denoted in Section 1) at

.the conclusion of the -inspection on March 2 and 29,1985. The inspector summarized the purpose, scope, and findings of the inspection. At no time during this inspection was written material provided to the licensee by the inspecto _

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training /Proiects Dayshift Unit 2 ALAh4 Health Physictets

Support asdietsen Protecteor R. Eustafson Assistant Radiatsoo Coordinator Eadiation Pr ete6 Lie Protection Sup Superviser Erpstvisor I I

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