IR 05000336/1986020

Insp Rept 50-336/86-20 on 861006-10.No Violations Noted. Major Areas Inspected:Radiological Controls Program, Including Mgt Controls,Personnel Selection,Qualification & Training,External Exposure Control & ALARA

ML20214J044
Person / Time
Site:	Millstone
Issue date:	11/17/1986
From:	Kaminski M, Shambaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214J006	List: IR 05000336/1986020 ML20214J002
References
50-336-86-20, NUDOCS 8612010129
Download: ML20214J044 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-20 Docket N License N DPR-65 Category C Licensee: Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Point Nuclear Power Station, Unit 2 Inspection At: Waterford, Connecticut Inspection Conducted: October 6-10, 1986

Inspector [s-

1. h' M-A. Weadock, Radiatio / Specialist

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/>*1 % //f/?lW M. Kaminski, Radiatf orySpecialist date Approved by: #.n /

M. Shanbaky, Chi'ef, Faci)(ties Radiation

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' date Protection Section, EPRPB, DRSS Inspection Summary: Inspection conducted on October 6-10, 1986 (Inspection Report No. 50-336/86-20)

Areas Inspected: Routine, unannounced inspection of the licensee's implemen-tation of a Radiological Controls Program during the current outage. Areas reviewed included: management controls, personnel selection, qualification and training, external exposure control, and ALAR Results: Within the scope of the above review, no violations were identifie The licensee appears to be effectively implementing their Radiological Controls Program in support of outage activities.

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PDR ADOCK 0500 I G l

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l DETAILS I

1.0 Persons Contacted

• W. Romberg, Station Superintendent

• S. E. Scace, Unit 2 Superintendent

• J. P. Kangley, Radiological Services Supervisor ,

• B. Granados, Health Physics Supervisor l

• J. E. Laine, Unit 2 Radiation Protection Supervisor P. Simmons, Support Radiation Protection Supervisor R. Gault, Unit 2 Assistant Radiation Protection Supervisor  !

D. Fitts, Unit 2 ALARA Coordinator S. Turowski, Unit 3 ALARA Coordinator M. Niswander, Scientist

• Denotes those individuals attending the exit interview on October 10, 198 Other licensee employees were also contacted or interviewed during the course of this inspectio .0 Purpose The purpose of this routine safety inspection was to review the implemen-tation of the licensee's Radiological Controls Program during the current outage. The following areas were reviewed:

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management controls,

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personnel selection, qualification and training,

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surveys,

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external exposure control, and

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ALAR .0 Status of Previously Identified Items (C'.. sed) Inspector Follow-Up Item (245/86-12-02, 336/86-12-02, 423/86-23-02). Review licensee corrective actions and resolution of internal controlled routing item to upgrade control over station High Radiation Area (HRA) doors. The inspector reviewed licensee memo MP-S-4422, "High Radiation Area Control", which details an action plan of generic and specific improvements to be made to improve HRA control. These include replacing temporary cage doors with permanent steel doors, installation of automatic closure devices, replacing the existing lock and key system, installation of alarms for all doors, and increasing the surveillance frequency on HRA doors. An attach-ment to this memo lists all station HRA doors and the specific plan-ned improvements for each doo . .

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i The licensee indicated that, due to the extensive amount of modifi-cations to be made, a commitment date of August 1937 was established for closeout of the internal controlled routing item. During the current inspection, HRA control appeared to be effective. No in-stances of unlocked or unattended HRA accesses were note Based on the above observations, and the obvious good intent of the licensee, this specific item can be close Implementation and effectiveness of the licensee's proposed modifications to their HRA control system will continue to be reviewed during subsequent Radiation Protection inspection .0 Management Controls In response to recent radiological controls problems at other plants during outage situations, the Unit 2 Radiation Protection Supervisor applied specific radiological controls, over and above those required by station procedure, to take effect during the outage. Although the major-ity of these controls applied to Steam Generator (S/G) activity, several had a general applicability to the radiological controls program. These included:

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requirement of a dositec alarming dosimeter for all entries into specific areas,

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minimizing worker use of High Radiation Area keys by requiring Health L -

Physics (HP) technicians to <ontrol access, _

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briefing all HP technicians on specific potential areas of concer Review of the above requirements and controls specifically relating to the S/G work (section 7.0) indicated the controls were being effectively implemented and were providing an additional level of control over radiological activities. The inspector also noted during tours of the Unit 2 containment that upper-level station man-agement was notic ably present during both shifts, providing additional management presence and control at the worksit .The licensee's corporate Radiological Assessment Branch (RAB) per-forms monthly audits of station HP activities during power operations

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and weekly audits of HP activities during outages, to meet the re-l quirements of corporate ALARA Procedure #3; " Audits and Appraisals of the Stations Health Physi Program" The inspector reviewed both a monthly pre-outage audit, ierformed on September 4 and 11 and an outage audit, performed September 22, 1986, and noted the licensee's 7 B group is complying with the requirements of ALARA Procedure #3.

l A previous NRC inspection at this facility (combined report numbers 245/86-12, 336/86-12, 423/86-23) reported that, in addition to the above RAB audits, additional audit responsibilities are held by the

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Nuclear Review Board (NRB). That report stated that the NRB conducts a quarterly review of RAB performed audits. Subsequent review of procedure NE0 3.01, " Conduct and Format of Nuclear Review Board Audits", indicated that this procedure actually requires that a quarterly summary of the P.AB HP audits be submitted annually to the respective NRB/SNR .0 P_ersonnel Selection, Qualification and Training 5.1 Radiation Protection Personnel The selection, qualification and training of contractor radiation protection technicians and support personnel were reviewed with respect to the following criteria:

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ANSI-N18.1, 1971, " Selection and Training of Nuclear Power Plant Personnel",

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Procedure SHP 4920, " Contracted Health Physics Personnel Training Program",

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Procedure HP #911/2911/3911A, " Health Physics Department Services Training Program".

The licensee's performance in this area was evaluated by:

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discussion with supervisory personnel,

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discussion with contracted HP technicians and service personnel,

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review of selected technician training records and resume Within the scope of the above review, no violations were identifie In addition to the ANSI N18.1 criteria of two years of HP experience for a fully qualified HP technician, the licensee required that in-coming vendor technicians have a minimum of 16 months senior tech-nician experience in high-risk radiological areas. The inspector verified that vendor HP technicians brought on-site were trained in station procedures and instrumentation in accordance with SHP 492 The licensee routinely uses personnel provided by a temporary employ-ment firm, rather than HP technicians, in the Dosimetry and Respira-tory Protection areas. The Inspector reviewed training records for selected individuals, and interviewed and quizzed selected personnel concerning routine job functions in these areas. All individuals had received adequate training and appeared knowledgeable of applicable restrictions on their work activitie . .

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5.2 Radiation Workers The training of radiation workers was reviewed with respect to cri-teria contained in 10 CFR 19.12, " Instructions to Workers," and 10 CFR 20.103, " Exposure of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas." Implementation of the above criteria was reviewed by the following methods:

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interviews of randomly selected radiation workers,

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review and cross-check of RWP sign-in sheets and S/G entry sheets against radiation worker training, respirator medical examination fit-test, and whole body count record tour of the steam generator mockup facilit Within the scope of this review, no violations were identifie In addition to the basic radiation worker training, the licensee re-quired steam generator mockup training for individuals performing S/G maintenanc Interviewed workers felt the level of pre-job and mock-up training was appropriate and felt comfortable with both the pace of S/G activities and the level of HP coverag .0 Surveys The licensee's performance and documentation of radiation and contami-nation surveys were reviewed with respect to the following criteria:

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10 CFR 20.201, " Surveys,"

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Procedure SHP 4905, " Radiological Surveys."

Licensee implementation of a radiological survey program was evaluated by the following methods:

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review of routine radiation, contamination, and airborne activity surveys,

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review of survey information accessibility at various radiological control points,

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review of selected surveys used to generate specific Raoiological Work Permits (RWPs),

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review of radiation surveys to support S/G work activitie Within the scope of the above review, no violations were noted. Current survey information was accessible to workers at the various radiological control points. Workers interviewed in the field were generally aware of area radiological conditions; however, it was noted some S/G workers were

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more conscious of allowable stay times in the S/Gs than the actual dose rates. When brought to their attention, the licensee indicated that both channel head dose rates and applicable stay times would be emphasized in future pre-job briefing Surveys performed to generate, or in support, of specific RWPs were found to be of adequate scope to allow appropriate assessment of radiological hazards. Extensive surveys were performed in the S/G channel heads to identify dose gradients and determine the beta contribution to the overall field prior to worker entr The inspector noted during a review of the licensee's air sample counting log that very few air samples showed significant levels of activity. The licensee attributed this to the standard of their work practices and use of engineering controls. As a follow-up, the inspector reviewed whole body count records extending back prior to the outag The general absence of significant positive counts substantiated the licensee's re-mark .0 External Exposure Control The licensee's program for controlling work activities and worker exposure during the outage was evaluated by:

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interviews of the radiation protection supervisor and other selected

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review of surveys, RWPs, S/G entry sheets, dosimetry results and ALARA controls associated with the S/G maintenance activities,

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tour of the S/G control points, observation of S/G entry activities, and interview of selected S/G workers and HP technicians,

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review of RWPs and associated surveys controlling the reactor head lift, S/G decontamination, ISI work, and valve maintenance,

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tour of other containment and auxiliary building radiological work area Within the scope of the above review, no violations were identified. Just prior to the week of this inspection, the licensee had removed manways from and performed surveys inside both S/Gs. During the week of the in-spection, the licensee was performing worker entries or " jumps" into the S/Gs to install nozzle dams prior to chemical decontaminatio Special controls implemented to support this activity included the revision of the S/G entry procedure to require additional information on the entry logs, the use of S/G mock-up training, the use of conservative stay-times, direct observation and timekeeping by camera, and the use of a shielded waiting area on the S/G platform. The inspector viewed selected worker

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preparation, suit-up, and ongoing S/G jump activities. Overall, the noz-zie dam installation appeared well-controlled. Initial surveys in the S/G's prior to worker entry were adequate in assessing radiological con-ditions. Appropriate protective clothing, respiratory protection, and multiple dosimetry were being used. Additional licensee administrative measures adopted in light of recent experience at another facility appear-ed effective in insuring positive control of S/G maintenance activitie In contrast to the effectiveness of radiological coverage and control of S/G operations, the inspector noted a need for increased attention by the licensee in the surveillance of more routine radiological activitie During tours of the containment and the auxiliary building the inspector noted a variety of poor work practices, including: l

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worker failures to sign-in and out on controlling RWPs when entering or leaving a work area,

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worker failure to perform a whole body frisk, frisking only hands and feet, after undressing from full anti-C's,

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worker leaning over contaminated area boundary in street clothes to assist in work being performed in the area,

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radiological posting signs dow The licensee indicated that, since the outage had just begun, the focus of HP attention had been on control of the major evolutions. The licensee recognized the need for upgrading routine radiological performance and indicated greater attention would be focused in tnis area as outage scheduling permit .0 ALARA The inspector reviewed the licensee's ALARA effort for the ongoing outag The licensee's performance in this area was evaluated by:

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discussions with the Unit 2 ALARA Coordinator,

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discussions with station Health Physics personnel,

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discussions with station management,

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discussions with steam generator jumpers,

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examination of ALARA exposure control summaries, i

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examination of steam generator jump sheets,

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examination of training and dosimetry records of steam generator jumpers on the HELPORE system,

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examination of the steam generator mock-up,

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observation of steam generator jumps in progress,

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observation of other work during plant tours, Within the scope to this review no violations were identified. The in-spector noted the following strong points in the licensee's ALARA progra The licensee ALARA policy allows an expenditure of up to $20,000 for the saving of one man-re *

The licensee exhibited good pre-outage planning in researching jobs and providing dose estimate *

The licensee was tracking doses for a number of outage task *

The licensee posted ALARA exposure control summaries in addition to radiation work permits and survey map *

The licensee has contracted two additional ALARA technicians for the outag The inspector determined that the licensee's ALARA program is basically good but noted the following shortcoming _

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Pre-outage ALARA efforts fell behind schedule due to poor feedback from some department *

The licensee is operating under two sets of ALARA goals, one promul-gated by the Radiological Assessment Branch and the other generated by the station ALARA grou _ .-

The inspector discussed these shortcomings with licensee managemen Management agreed with these findings and stated that efforts are being made to resolve these shortcoming .0 Exit Interview j

The inspector met with licensee representatives (denoted in section 1 of this report) at the conclusion of the inspection on October 10, 1986.

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

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