IR 05000336/1988009
| ML20151L895 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/20/1988 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mroczka E NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 8808040172 | |
| Download: ML20151L895 (2) | |
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..e JUL 2 01988 D'cket No.
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Northeast Nuclear Energy Company ATTN: Mr. E. J. Mroczka --
Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06141-0270
. Gentlemen:
. Subject:
Inspection No. 50-336/88-09 This refers to your letter dated July 6,1988 in response to our letter dated May 27, 1988.
Thank you for informing us of the corrective and preventive actions documented in your letter..These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
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Sincerely,
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Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards cc:
W. D. Romberg, Vice President, Nuclear Operations S. E. Scace, Station Superintendent D. O. Nordquist, Director of Quality Services R. M. Kacich, Manager, Generation Facilities Licensing Gerald Garfield, Esquire Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of Connecticut 8808040172 880720 PDR ADOCK 05000336 G
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July 6, 1988 Docket Nos. 50-336 A07279 Re: 10CFR2.201 Mr. V. T. Russell, Regional Administrator U.S. Nuclear Regulatory Commission, Region I 475 Allendale Road King of Prussia, PA 19406 Reference:
(1)
R. R. Bellamy letter to E. J. Hroczka, dated May 27, 1988, Combined NRC Inspection Report Nos.
50-245/88-06, 50-336/ 88-09, 50 423/08-07.
Gentlemen:
Millstone Nuclear Power Station, Unit No. 2 Response to Notice of Violation Combined Inspection Nos. 50-245/88-06, 50-336/88-09, 50-423/88-07 In a letter dated May 27, 1988 (Reference (1)), the NRC Staff issued a Notice of Violation to the Northeast Nuclear Energy Company (NNECO)
for Hillstone Unit No.
2.
This action was the result of an unan-nounced inspection conducted April 11-15, 1988 to review radiation protection program implementation on Hillstone Unit Nos.
1, 2 and 3.
Reference (1) stated that one of NNECO's activities was not considered in full compliance with NRC requirements.
Pursuant to tiie provisions of 10CFR2.201, NNECO hereby provides the following response to the
"Notice of Violation" contained in Reference (1).
During a telephone conversation with Region I on June 9, 1988, the NRC Staf f agreed to extend the due date of this response to July 7,1988.
Reouirement 10CFR20.201(b) requires that each licensee make such surveys as may be necessary to comply with all sections of 10 CFR Part 20. As defined in 10CFR20,201(a),
"survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or
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presence of radioactive materials or other sources of radiation under
jd a specific set of conditions, Y,,.N W
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Mr. V. T. Russell A07279/Page 2
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July 6, 1988 Finding Contrary to the above, evaluations made to ensure compliance with 10CFR20.103 during a Millstone Unit No. 2 reactor containment entry on April 9, 1988 vere inadequate, in that, the evaluations were based on a remote grab sample which was neither representative of air concen-trations at the work locations nor of the tina at which vork vas performed.
As a result, an unplanned intake of radioactive iodine by six vorkers, ranging from 25 to 32 MPC-hours occurred.
This is a Severity Level IV Violation.
Admission or Denial of Violation NNECO does not contest the violation as set forth in the Notice of Violation.
Root Cause The cause of the inaccurate evaluation was the utilization of a remote containment grab sample taken approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> prior to the actual entry, which upon the actual containment entry was found to be in error.
During the actual containment entry for surveys, the 6 man health physics team measured radioactive iodine concentration levels which coupled with the entry duration, resulted in a calculated MPC to personnel ranging from 25-32 MPC-hours.
Vhile NNECO agrees with the finding as vritten, the following information is provided to explain that licensee survey data was comprehensive and accurate once entry into containment was accomplished.
The licensee survey data collection program requires both an external remote grab sample and actual containment physical entry survey to be performed for containment atmospheric evaluation.
The purpose of the 6 man short duration health physics entry was te make the required additional higher quality surveys prior to alloving general vork to begin. This survey technique is in keeping with the intent of the regulation.
The local grab samples taken inside containment vere used to calculate individual hPC-hour assignment.
The unrepresentative remote grab sample which was taken 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in advence of the actual entry is not considered by industry standards as inordinately premature to an initial containment entry.
It should be noted that the minimum time required to drav and analyze gas, particulate, iodine, and tritium samples is approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Corrective Action As a result of this event NNECO has reduced the allowed time period between when a remote sample is taken and the scheduled entry to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
It is recognized that the time differential bet';een remote sampling and actual entry is just one variable that e.an affect the actual conditions encountered in the containment workrpace.
NNECO has addressed improvements to the entry procedures aPJ remote sampling
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Hr. V. T. Russ311 A07279/Page 3
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July 6, 1988
system to minimize potential inaccuracies between remote and actual in-situ containment sampling.
Additionally, more conservative respiratory protection measures have been specified for the initial entry survey personnel.
Improvements to the containment entry procedure vere made on Aril 15, 1988 and to the containment mechanical sampling equipment during the month of April.
A brief summary of corrective actions which have been fully implemented is listed belov 1.
The cartridge sample holder on the remote sampling apparatus was replaced to provide a better seal around the iodine cartridge.
2.
The air sample pump vas replaced with a higher flow rate, continuous flow pump which significantly improves the correlation between the containment remote air samples and grab samples taken inside the Containment Building.
3.
The frequency of obtain6ng whole body counts on representative workers has been increased to provide a better bioassay program for iodine following containment entries.
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Self-contained breathing apparatus vill be used during initial entries for air quality surveys.
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The containment entry procedure, HP 2920, has been revised to specify the normal time between sampling and entry and to provide for a single entry of very short duration to establish air activity prior to allowing subsequent entries.
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Action to Prevent Recurrence
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NNECO considers the completed corrective action steps sufficient ta avoid future recurrence.
Ve trust that the above information satisfactorily responds to your concerns.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY Y%
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M'rdcika /
Sen or Vice President cct D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 V. J. Raymond, Senior Resident Inspector, Hillstone Unit Nos. 1, 2 and 3 R. R. Bellamy, Region I U.S. Nuclear Regulatory Commission Document Control Desk Vashington, D.C.
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