IR 05000423/1986017
| ML20206R792 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/01/1986 |
| From: | Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20206R767 | List: |
| References | |
| 50-423-86-17, NUDOCS 8607070228 | |
| Download: ML20206R792 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-423/86-17 Docket No.
50-423 i
License No.
NPF-49 Priority Category C
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Licensee:
Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101
Facility Name:
Millstone Nuclear Generating Station, Unit 3 l
Inspection At:
Waterford, Connecticut Inspection Conducted:
June 2-6, 1986
_J'da te 'bohG Inspector:
d, A. Weadock, Radiation Specialist Approved by:
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M.'N. ShanEaky, Ihief //
/date Facilities Radiation Protection Section i
Inspection Summary:
Inspection on June 2-6, 1986 (Report No. 50-423/86-17)
Areas Inspected:
Special announced inspection to review the performance and t
results of the licensee's startup testing radiation survey program and the
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status of previously identified items.
One region-based inspector was onsite
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for this inspection.
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Results: Within the areas inspected, no violations were identified.
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I DETAILS
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a 1.0 Personnel Contacted J. Burdick, Health Physics Technician P. Burke, Health Physics / Chemistry Instructor T. Cummins, Health Physics Technician B. Granatos, Health Physics Supervisor
R. Haynes, Assistant Training Supervisor i
- J. Kangley, Radiological Services Supervisor N. Knudsen, Health Physics Technician F. Kuzmenko, Health Physics Technician
- E. Laine, Radiation Protection Supervisor, Unit 2
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J. Nickerson, Fire Training Instructor i
F. Perry, Assistant Radiation Protection Supervisor, Unit 3
- W. Romberg, Station Superintendent
- R. Satchatello, Radiation Protection Supervisor, Unit 3 H. Siegrist, Supervisor, Radiological Protection P. Simmons, Radiological Protection Support Supervisor
- S. Turowski, ALARA Coordinator J. Waggoner, Senior Health Physics Instructor
- Denotes attendance at the exit meeting.
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2.0 Purpose
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The purpose of this inspection was to review the adequacy of the licen-see's start-up radiation survey program and to review the status of q
selected follow-up items identified during previous inspections.
3.0 Status of Previously Identified Items 3.1 (0 pen) 76-CI-03 (Circular) Radiation Exposure in Reactor Cavities.
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Since the previous inspection in this area, the licensee has installed lockable gates at all entrances to the Moveable Incore Detector (MID) or reactor cavity area.
The licensee has also developed the following procedures which define the admiaistrative
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policy for controlling access to the MID area:
HP 3920A, Health Physi:s Pequirements for Entry to MID System:
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Controlled Radiation Areas, OP 3361A, Personnel Access Control to the MID System Ccmponents Inside Containmert.
These procedures require that multiple briefings and sign-offs by
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appropriate levels of Operations and Health Physics Supervision occur prior to issuance of the Extreme High Raciation Area (EHRA)
key. The above procedures appear adequate to control access to the
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MID (i.e., reactor cavity) area.
Installation of the lockable gates could not be verified during this inspection, due to the status of reactor operations. This item will remain open pending NRC verifi-cation of lockable gates at all MID area access points.
3.2 (0 pen) 85-19-03 (Follow-up Item), Training of Health Physics Person-nel in Radiation Monitoring System (RMS) operation.
Since the previous inspection in this area (NRC Report No. 85-56),
the licensee's Training Department has' developed and presented a training module to all house HP technicians on the operation of the RMS system. This training was given in November 1985. The module was developed by the Training Department with the cooperation of the station I&C and Computer Services Groups.
The inspector reviewed the lesson plan for the training module and procedure HP 3908J, Health Physics KAMAN Control Console.
The lesson plan was still in a draft, unapproved form.
The licensee indicated that the RMS training module is destined for inclusion in the " Health Physics Initial Training Program," which is currently being developed. Tnis training program, consisting of a
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series of modules, will be required for all new entry-level Health Physics Technicians. This item will remain open to track the following:
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review and approval of the RMS training module in a final form, 2.
inclusion of the RMS training module in the Health Physics Initial Training Program.
3.3 (0 pen) 78-BU-08, Fuel Transfer Tube Shielding Control.
A previous NRC inspection (No. 85-56) discussed the need for the licensee to develop physical and administrative access controls for the " shake space" area between the containment and fuel buildings.
Radiation levels in this area could become prohibitively high during the transfer of a spent fuel element from the containment to the fuel building.
The inspector verified during this inspection that a lock-able gate has been installed which, when locked, would prevent foot traffic access to the shake space area. A procedure defining admin-istrative access controls to this area has not been developed.
In addition, the Health Physics group has submitted an engineering modification request (PMR #3-86-62) to provide additional shielding on a portion of the fuel transfer tube between the containment and fuel buildings. This item will remain open pending the development of administrative controls for the shake space area and the resolu-tion of the modification reques _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
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4.0 Startup Radiation Surveys 4.1 Startup Survey Performance The licensee's Radiation Survey Startup testing program was reviewed against the following criteria:
ANSI /ANS-6.3.1, 1980, " Program for Testing Radiation Shields in LWRs,"
ANSI-N323, 1978, " Radiation Protection Instrumentation Test and Calibration,"
Regulatory Guide 1.68, November 1978, "Preoperational and Startup Test Program for Water-Cooled Power Reactors (LWR),"
10 CFR 20, " Standards for Protection Against Radiation,"
Test Procedure No. 3-INT-8000, " Radiation Monitoring System,"
Final Safety Analysis Report, Table 14.2-2, "Startup Test - Radiation Survey."
The radiation survey startup test was performed to fulfill several objectives, including:
verify that shielding is effective and area dose rates are consistent with the Final Safety Analysis Report,,
insure all potential radiation and high radiation areas have been identified and controlled,
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verify the operability of selected area radiation monitors.
NRC review of the radiation survey startup testing indicated the licensee's performance was thorough and effective.
Extensive survey measurements were made, with approximate corrective actions being taken upon the identification of shielding deficiencies.
The licensee performed a comprehensive series of radiation surveys, designating 378 Radiation Base Points (RBPs) which were surveyed at selected power levels. The scope of the licensee's surveys compares favorably with performance at other startup plants.
Surveys outside containment were conducted at the 0, 30, 50, 75, 90 and 100% power levels. Due to ALARA considerations and an airlock inoperability problem in containment, surveys at the 75 and 90% power level were not performed inside containment.
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The inspector reviewed completed licensee surveys and determined documentation was complete and survey RBPs were appropriately located to verify shielding effectiveness. The inspector verified that ALARA concerns were appropriately reflected in the performance of the survey, in that specific survey locations were dropped at higher power levels when appropriate review indicated unanticipated information would not be gained. The inspector reviewed test pro-cedure 3-INT-8000, App. 8007, and determined it was generally adequate in controlling the performance of the startup radiation survey.
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Measurements were also made during the startup survey to character-ize the neutron energy spectrum inside containment during power operations.
Once~ characterized, neutron spectrum factors will be developed for use in determining neutron dose equivalent.
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inspector verified that the licensee provided appropriate neutron monitoring in accordance with USNRC Regulatory Guide 8.14 for per-sonnel entering containment during power operation.
Timekeeping techniques and neutron doserate measurements were used to provide
an estimate of neutron dose; individuals also wore neutron dosimeters which were read to provide the dose of record. At the time of this inspection, the licensee had not completed their review of the neutron spectrum measurements.
Licensee analysis of data and development of neutron spectrum factors will be reviewed during a subsequent inspection (423/86-17-01).
4.2 Survey Results All measured doserates inside containment were consistent with anticipated area doserates contained in the FSAR. Outside contain-ment, five survey points in three areas were determined to be in excess of the radiation zone limit designated for that area in the FSAR.
These discrepancies were generally due to dose contributions from adjacent piping and not to a failure of the shield.
Licensee response to these discrepancies included:
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Posting and controlling an unanticipated radiation area in the
ESF building; 2.
Submitting two Plant Modification Requests (PMRs) to provide shielding for the letdown lines to CHS-RE-69 and add delay coils to the primary sample lines.
The above PMRs should address the two discrepancies in area radi-ation doserates noted in the Auxiliary Building. The status of these proposed changes will be reviewed in a' subsequent inspection (423/86-17-02).
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4.3 Startup Survey Instrumentation The inspector reviewed calibration records for selected portable survey instrumentation to verify neutron and gamma detectors used to perform the start-up radiation survey were appropriately calibrated.
No instances of out of calibration instrumentation were discovered.
Two conditions exist in the Millstone Unit 3 containment at power which complicate the performance of radiation surveys; the presence.
of a high energy N-16 gamma in the loop area, and the sub-atmospheric conditicn of the containment. The inspector verified that the licensee had anticipated these conditions in a timely manner and had taken appropriate actions.
Representative survey instruments were sent to the University of Lowell to be exposed to a N-16 gamma field.
The licensee also performed in-house evaluations to determine instru-ment response in sub-atmospheric conditions.
Based on these results, the licensee designated certain instrument types to be used for the in-containment start-up survey.
The licensee also used start-up survey radiation measurements to evaluate the response of installed area radiation monitors.
Survey points were selected next to area monitors and survey instrument response was compared to monitor response.
The licensee also located TLDs at selected monitors to evaluate monitor response.
This in-field testing of the monitors indicated monitor response was generally good.
4.4 Training of Personnel The inspector evaluated the scope and content of specific training presented to Healtn Physics (HP) technicians performing start-up surveys.
Licensee performance in this area was determined by the following methods:
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discussion with HP supervisory personnel,
interview of selected HP technicians,
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review of Startup Testing Reading Material provided~to the HP
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technicians, review of required reading and briefing attendance sign off
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sheets.
No violations were identified in this review.
The level of training provided to the HP technicians appeared appropriate for ensuring the survey program was carried out successfully.
Sign-off sheets indicated all technicians involved in performing the start-up survey had reviewed training materials and attended pre-survey briefings.
Training material provided to the technicians for review included
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an applicable ANSI /ANS Standard (6.3.1, 1980, " Program for Testing Radiation Shields in LWRs"), several industry articles on the per-formance of startup surveys, and results from other plants.
In addition, an in-containment mock-up survey was conducted at 0%
power.
This was performed to familiarize the technicians with both the use of the BIO PAK 60 SCBA units and the location of the various RBP survey points. A system walkdown and specific training on the radiological protection hazards associated with the Moveable Incore Detector (MID) system was also presented to all HP technicians.
4.5 Exposure Control The inspector reviewed the licensee's system for administrative i
control of exposure during performance of the startup shield surveys
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by the following methods:
discussion with HP supervisory personnel,
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review of Radiation Work Permit (RWP) Nos. 0070, 0249 and 0429 (Conduct Shield Survey at 30%, 50% and 100% Power, respectively),
review of associated RWP sign-in sheets and exposure records,
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review of procedure OP 3361A, " Personnel Access Control to the MID System Components Inside Containment."
Within the scope of the above review, no violations were identified.
The above RWPs appeared appropriate for controlling containment entry during power operations.
In particular, the inspector verified that RWPs specifying entry to the Moveable Incore Detector (MID) area required that all controls specified in procedure OP 3361A were in place (prejob briefings and sign-offs, instrument tag outs, etc.).
4.6 Respiratory Protection Due to the sub-atmospheric conditions inside containment during power operations at Millstone 3, a method for providing supplemental oxygen is required for personnel making at power entries. Millstone 3 used the BIO PAK 60, a closed circuit self-contained breathing apparatus, to provide this supplementation. The inspector reviewed the licensee's program for controlling the use of this device by the following methods:
discussions with cognizant Health Physics and Nuclear training personnel,
review of the following documentation:
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BIO PAK 60 Training Lesson Plan and Attendance verification,
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Procedure SHP 4931, Selection and Use of Respiratory Protection Equipment,
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Procedure HP 4932, Maintenance and QA Program for Respiratory Protection Equipment,
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Procedure HP 4934, Medical Screening Program for Respiratory Users.
Within the scope of the above review, no violations were identified.
The scope of the BIO PAK 60 training appears adequate and all per-sonnel entering containment for performance of the start-up shield surveys had received BIO PAK 60 training.
The inspector discussed the use of the BIO PAK 60 with Health Physics supervision and determined that it is currently being used to provide oxygen supplementation only, and not to provide a protection factor against airborne radioactive material. The inspector determined by review of various HP procedures that the BIO PAK 60 has not formally been included in the HP respiratory protection program.
Specifi-cally, although it is referenced in procedure SHP 4931, there is no approved procedure in place that discusses maintenance or QA for the BIO PAK 60.
The inspector also determined there is no procedure or mechanism currently in place for quantitatively fit-testing the BIO PAK 60.
The licensee indicated they were aware of the informal status of
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the BIO PAK 60 and were currently drafting procedures and reviewing methodology for performing fit-testing.
The licensee also indicated that the BIO PAK 60 would be formally included in the respiratory protection program prior-to claiming protection factors for use of the device to minimize airborne radioactivity intake. Development of appropriate procedures and a fit-testing methodology for the BIO PAK 60 will be reviewed in a subsequent inspection (423/86-17-03).
The inspector determined through discussion with cognizant Nuclear Training personnel that individuals receiving either SCBA or par-ticulate filter (PF) type respirator training are not required to have a respirator medical clearance prior to training. The inspector verified that individuals in SCBA or PF respirator training do don respirators.
Licensee procedure HP 4934 requires that personnel obtain a medical clearance prior to respirator fit-testing or respirator use.
The inspector noted that early identification of any medical conditions might be appropriate before initial donning of a respirator, even in a training environment. The licensee indicated this area would be reviewed.
Licensee evaluation in this area will be reviewed in a subsequent inspection (423/86-17-04).
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5.0 Exit Meeting The inspector met with licensee representatives (denoted in Section-1) on
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June 6, 1986 to discuss the scope and findings of the-inspection. At no
i time during the inspection was written material provided to the licensee
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by the-inspector.
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