IR 05000423/1987001
| ML20211P475 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/11/1987 |
| From: | Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20211P440 | List: |
| References | |
| 50-423-87-01, 50-423-87-1, NUDOCS 8703020373 | |
| Download: ML20211P475 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 87-01 Docket No.
50-423 License No. NPF-49 Category C Licensee: Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Generating Station, Unit 3 Inspection At: Waterford, Connecticut Inspection Conducted: January 5-9, 1987 / Inspectors: M.
5 41M,M 2////f[7 A. A. Weadock, Radiation Spe'ialist date c /- Approved by: Arf. %Md z ////"7 M. M. Shanbaky,' Chief</br>/</br>d'te a</br>Facilities Radiation Protection Section Inspection Summary:</br>Inspection on January 5-9, 1987 (Report No. 50-423/87-01)</br>Areas Inspected:</br>Routine, unannounced inspection to review the implementa-tions of the licensee's Radiation Protection Program. Areas inspected included posting and labeling, exposure controls, radiological surveys, training, audits, and the status of previously identified items.</br></br>Results: Within the areas inspected, no violations were identified. The licensee appears to be effectively implementing their Radiation Protection Program l</br>l 8703020373 870212</br>~</br>PDR ADOCK 05000423 G</br>PDR b</br></br>.</br>DETAILS 1.0 Personnel Contacted M. Brown Supervisor, Technical Training</br>*C. Clement Unit 3 Supervisor R. Enoch Instrument and Control Supervisor</br>*B. Granatos Health Physics Supervisor</br>*I. Haas Supervisor, HP Programs</br>*J. Kangley Radiological Services Supervisor A. Klotz Scientist B. Koen Maintenance Technical Training J. Maher, Jr.</br></br>Supervisor, General Nuclear Training</br>*D. Moore Unit 3 Operations</br>*J. Niswander Scientist F. Perry Asst. Radiation Protection Supervisor</br>*R. Sachatello Radiation Protection Supervisor</br>*S.</br></br>Scace Millstone Station Superintendent</br>*H.</br></br>Siegrist Supervisor, Radiological Protection P. Simmons Radiation Protection Support Supervisor P. Strickland Supervisor, HP and Chemistry Training S. Turowski ALARA Coordinator J. Waggoner Sr. Instructor, HP</br>* Attended the exit meeting on [[Exit meeting date" contains a listed "[" character as part of the property label and has therefore been classified as invalid.. 2.0 Purpose The purpose of this routine, unannounced inspection was to review the licensee's implementation of their Radiation Protection Program. The following areas were included in this review: Status of Previously Identified Items; - Posting and Labeling; - External Exposure Controls; - Training; - - Radiological Survey Program; Audits; - - ALARA.
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. 3.0 Status of previously Identified Items 3.1 (Closed) 85-19-01 (Follow-Up Item): Operational status of the Radiation Monitoring System (RMS).
Testing and operability status of the licensee's area, process and effluent radiation monitoring systems has been period-l ically reviewed and updated in ongoina NRC reviews (see Inspection ibport Nos. 423/85-19, 423/85-42, 423/85-65, 423/86-06).
The inspector reviewed , the current status of the RMS system and compared it with the status ' reported in Attachment I to NRC report No. 423/86-06. Monitor operability as reported in that Attachment remains essentially unchanged except for the following: Monitor Comments 3HVCRE16A/B Experiencing spiking problem 3CHSRE69 Radiation alert alarm cleared 3SSRRE08 Never in service; sample flow rate too low 3RMSRE05 Not operable; cable repaired, on-site, awaiting installation 3RMSRE04A, 3RMSRE05A Installed, operational 3.2 (Closed) 85-19-02 (Follow-Up Item): Status of RMS procedure development.
Development, review, and approval of generic and surveillance procedures for the RMS have received continuing review in ongoing NRC inspections (see Report Nos. 423/85-19,423/85-42,423/85-65,423/86-06). The in-spector discusssed the status of I&C RMS procedures with I&C personnel during this inspection.
Currently all I&C generic and surveillance pro-cedures for the RMS are in an approved form.
RMS surveillance procedures will be reviewed at the end of April,1987.
Status and implementa-tion of RfiS procedures will continue to be reviewed during subsequent NRC inspections, however, it is no longer necessary to carry a follow-up iten in this area. This iten is considered closed.
3.3 (Closed) 85-47-04 (Folllow-Up Item): Licensee to proceduralize the prac-tice of setting out and reviewing blank TLD badges around site. The licensee has developed and approved procedure HP 947/2947/3947, " Area , ! Monitoring", Rev. O.
This procedure provides guidelines and assigns responsibility to the Health Physics Supervisor for the implementation of i l a station TLD area monitoring program. This program is performed in
addition to monitoring performed as part of the Radiological Environmental l Monitoring Program.
3.4 (Closed) 85-56-01 (Follow-Up Item): Review capability for Post-Accident Sampling per NUREG-0737. The licensee's capability for post-accident sampling and assessment was reviewed during a special NRC inspection in August, 1986 (NRC Inspection Report No. 423/86-27). This review generated several specific follow-up items in the post accident sampling area which will receive subsequent review. This item is closed.
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. 3.5 (Closed) 86-23-01 (Follow-Up Item): Licensee to revise TLD quality assur-ance procedure #941/2941/3941 to include time requirement for generating investigation reports. The inspector reviewed Revision 7 of licensee procedure HP 941/2941/3941, " Performance Audits for Personnel Monitoring Equipment" and noted this revision states that written investigations of unacceptable TLD results should be completed within 90 days. This item is considered closed.
3.6 (Closed) 86-17-01 (Follow-Up Item): Review Licensee analysis of neutron measurement data and development of neutron spectrum factors. This item is considered closed and is discussed in section 7.2.
3.7 (Closed) 86-17-04 (Follow-Up Item): Licensee to evaluate whether medical pre-screening is necessary prior to worker donning of respirators during initial radiation worker training. During NRC inspection 423/86-17 it was identified that no requirement was in place to insure workers had passed a respirator medical prior to donning a respirator in radiation worker training. The inspector did verify that successful completion of a res-pirator medical examination is a requirement prior to individual quanti-tative fit testing. The licensee reviewed their current practice and determined a change to the system was not necessary, based on the follow-ing: individuals are not required to don respirators in training and - do not fail training if they feel uncomfortable and refuse to don respirators; - the instructors observe all workers undergoing practical factors and are alert to any problems that might develop.
The inspector had no further questions in this area. This item is considered closed.
4.0 Posting and Labeling The licensee's posting and labeling of contaminated areas, radiation areas, high radiation areas, and radioactive material was reviewed with respect to the following criteria: , l Technical Specification 6.12, "High Radiation Area," - 10 CFR 20.203, " Caution signs, labels, signals and controls," - - Procedure HP 905/2905/3905, Rev. 9, " Control and Accountability of Radioactive Material".
The licensee's performance in this area was reviewed by inspector tour of
the various Unit 3 radiological work and storage areas and discussion with cognizant HP personnel.
Within the scope of the above review, no violations were identiftad.
( Radiological posting and housekeeping generally appeared quite good.
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, The Unit 3 Auxiliary building contains numerous permanently installed high radiation area gates at the accesses to cubicles anticipated to become high radiation areas. All such gates were found to be appropriately locked and appear to enhance control over the areas.
During the above review, the following posting-labeling problems were noted: On January 6,1987, an unlabeled, untaped yellow bag containing a -
used tygon line was noted outside the contaminated area located in the charging Pump Cubicle A.
Licensee procedure 905/2905/3905 re-quire all radioactive material outside of posted contaminated areas to be labeled with a tag featuring the radiation caution symbol and appropriate wording. On a subsequent tour on January 7,1987, the same bag, still unlabeled, was noted outside the contaminated area located inside charging Pump Cubicle C.
The tygon line was apparently being used to drain oil from the charging pumps and was being moved from one cubicle to another by the workers. Although failing to label the bag containing the tygon line technically con-stituted a procedural violation, no citation was issued since in both instances, the bag was located inside the locked high radiation area gate to the cubicles within the radiologically controlled area of the plant.
- On January 8,1987, the inspector noted the temporary radiation area posting between the MRRF facility and the adjacent warehouse had blown down.
Radwaste workers in the area were noted to respond appropriately and in a timely fashion by replacing the posting and making efforts to notify the area HP technician. The inspector later verified during an interview with the area HP technician that a follow-up survey was performed to insure the posting had been appro-priately replaced.
The inspector noted during the above review that the licensee is making extensive efforts to control contamination and limit the extent of contaminated areas within the controlled area.
Supervisors HP and Operations are regularly performing tours of the Unit 3 con-trolled areas to identify situations creating or leading to the i spread of contamination (leaking valves, etc.). The inspector re-i viewed a November 9, 1986 memo from the HP and Operations staff to Unit 3 Supervision which generated 209 trouble reports calling for valve repacking or leak repairs. These routine surveillances also have identified engineering concerns with specific vent connections, sample connections, and pump drains which, although functioning, could be modified to reduce contamination problems.
The inspector also noted the HP staff has been aggressively acting to provide temporary fixes for identified contamination problems with the use of catch containments, etc.
Repeated and substantial decon-tamination efforts in cubicles where recurring contamination exists have also been performed.
The inspector noted that, at this point, _..
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, the quick fixes have generally been made; long-term resolution of identified contamination concerns will require significant attention and follow-up by Plant Maintenance with appropriate prioritizing by plant management.
5.0 External Exposure Controls The licensee's implementation of a Radiation Work Permit (RWP) system to provide control over exposure and radiological work activities was re-viewed by the following methods: discussion with HP Supervision; - - review of the following documentation: RWP 01222, Tighten Valve Packing on 3RHS*MV8701C, and associated - ALARA review, RWP 00705, Investigate then remove 3RCS*PCV456, - RWP 007033, Move PORV to Tent Area.
- RWP 00761, Disassemble PORV 456 to Inspect, Clean and Repair, - - RWP 00851, Reassembly of PORV 456, - RWP 00956, Install PORVs 455A & 456, - review of associated radiological surveys and RWP sign-in sheets.
Within the scope of the above review, no violations were identified.
RWPs were generally complete, clearly written, and appeared to require ade-quate radiological controls commensurate with work activities. All radio-logical samples and surveys required by the RWPs were found to be in place.
Safety concerns addressed by the RWPs were not limited to radiological areas; the inspector noted RWP 00705, controlling cut-out of a PORV, required a hydrogen air sample of the system prior to any cutting or disassembly. This sample was performed to identify any potential flam-mability concerns with work on the system.
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6.0 Training 6.1 Radiation Protection Personnel Station procedure SHP 4921, Station Health Physics Training Program, i requires that all station Health Physics (HP) technicians complete an ! initial radiological controls course with supplemental annual retraining.
This procedure also requires all station HP technicians to receive a formal plant systems course, with systems retraining every two years.
This procedure also requires the HP supervisor to maintain all training records associated with the above procedural requirements.
l Station procedure HP 911/2911/3911, " Health Physics Department First Aid and Procedure Training Program" requires that HP procedures should be ' reviewed annually by all Station HP personnel.
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. The inspector reviewed the licensee's implementation of the above pro-cedural requirements by the following methods: review of HP technician document acknowledgement sheets, - review of 1986 Phase I training class attendance records, - and discussion with cognizant training personnel.
- The inspector verified records were in place to indicate that all in-house Unit 3 HP technicians received an initial Plant Systems Famil-iarization course, received annual HP retraining in 1986, and per-formed an annual review of HP procedures in 1986.
The inspector noted that plant systems retraining is currently presented as part of the HP Phase I requalification training, which technicians receive at least annually. During 1986, systems training was limited to approximately 4 hours of training on the Unit 3 containment and ventilation systems.
The inspector noted that, although procedure SHP 4921 does not specify the amount. of hours of systems retraining required biennially, four hours per year appeared inadequate to insure technicians received an effective requalification on plant systems. The licensee indicated that the proposed HP technician training schedule for 1987 includes 16 hours of plant systems train-ing. The scope and content of plant systems training presented to HP technicians will be reviewed in subsequent inspections.
- The inspector noted during the above review that HP technician train-ing records are not. maintained in accordance with SHP 4921 require-ments. Unit 3 HP supervision does maintain on-site 'all the proced- - ural review sheets and a check off sheet indicating the dates of completion of required training for all technicians. However, actual class attendance sheets are maintained by the station's training' staff at the training facility. The licensee indicated during the exit meeting that problems in the area of training records had been identified and efforts were underway to resolve accountability.
This area will recieve additional review during subsequent inspection 6.2 Radiation Worker Respirator Training As part of the RWP review discussed in Section 5.0, the inspector compiled a list of radiation workers required to wear respiratory protection as part of the RWP requirements.
Licensee dosimetry records were then re-viewed to verify each worker had received current respirator training, a respirator medical whole body count, and respirator fit test.
Within tha scope of the above review, no violations were noted.
6.3 ALARA Mockup Traini_ng During this inspection, the licensee was conducting RCP seal replacement mockup training in anticipation of Unit 3 seal replacement work to be conducted in the early Spring of 1987. The inspector reviewed the scope of the training by viewing the mockup and by discussion
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. with the training instructor and review of training materials. The in-spector determined that representatives from the HP, ALARA, Maintentance, and Engineering groups were all participating in the initial presentation of the RCP Seal mockup training session. The instructor indicated input from the participants was significant and potential problems or conflict-ing interests between the groups were being identified and resolved during training, rather than in the field. The Unit 3 RCP mockup was noted to be quite realistic, allowing training on all phases of the seal package re-moval, refurbishment, and replacement.
The inspector also noted resources at the training facility included a Unit 2 RCP seal mockup, a radwaste shipping cask mockup, and an elaborate and well-outfitted chemistry lab for training of chemistry technicians. A Unit 3 steam generator (S/G) mockup is currently not available on site; however, the licensee has generated and approved a Plant Modification Request (#3-86-120) to purchase a steam generator mockup. The licensee indicated the delivery goal of the S/G mockup was 60 days prior to the starting date of the first refueling outage.
7.0 Radiological Survey Program 7.1 The licensee's performance and documentation of radiation, contamination and airborne activity surveys were reviewed with respect to the following criteria: - 10 CFR 20.201, " Surveys"; - Procedure HP 915/2915/3915, Rev. 18, " Health Physics Surveys", and accompanying survey matrix.
Licensee implementation of a survey program was evaluated by the following methods: - review of selected current routine contamination and radiation surveys maintained at the control point; review of selected radiological surveys used to generate - Radiation Work Permits (RWPs) or support work activities; discussion with cognizant licensee personnel.
- Within the scope of the above review, no violations were noted.
Proce-t dures 915/2915/3915, the controlling procedures for the routine survey program, appear to be effectively implemented. The survey matrix, in-cluded as an attachment to this procedure, appears comprehensive and is also modified during outage conditions to reflect increased traffic and contamination concerns.
Suyrveys posted at the control point were up to date and complete. The licensee also posts a list of Unit contaminated and high radiation areas at the control point, along with a status board graphically depicting plant contamination and high radiation areas.
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. Selected radiological surveys taken to support a containment entry on September 5, 1986 and in support of PORV work performed in July and August, 1986 were also reviewed.
Reviewed surveys appeared adequate to assess radiological conditions and support work activities.
Two areas for potential improvement were identified during the above re-view.
The inspector noted that routine radiological surveys inside the Unit 3 Auxiliary building did not identify boundaries of contamination in high radiation areas.
Inclusion of such boundaries on the surveys would provide another mechanism for informing the worker; in addition to the status board mentioned above or HP briefing.
The inspector also noted an apparent need to improve the timeliness of HP supervisory review of air sample forms.
NRC review of selected air-sample forms indicated supervisory review, indicated by dated signature on the form, typically occurred 10-14 days after the sample was taken.
In one case, the air sample was reviewed almost three months after the sample was taken. The inspector expressed a concern that HP supervision might not be aware of current or suddenly changing air activities, and that appropriate or timely actions may consequently not be taken.
The licensee indicated that HP supervision reviews air activity logs daily, and that supervision is informed whenever an air sample shows activity.The licensee stated that the signature on the air sample form indicates that a formal review, indicating verification of calculations, has been made. The inspector noted the licensee's remarks and indicated that HP supervision's familiarity with air activity conditions would be further reviewed during outage conditions.
7.2 NRC inspection report No. 423/86-17 reviewed the performance and results of the licensee's start-up testing radiation survey program. During this program, the licensee placed neutron albedo dosimetry inside containment and made measurements of neutron dose rates to develop neutron spectrum
factors (NSFs). These NSFs are then used to correct dosimeter over-i response to the Unit 3 neutron energy spectrum. The licensee's develop-I ment of these factors was reviewed by the following methods: l l discussion with cognizant licensee personnel; - l - review of NUSCO RAB calculation titled " Millstone 3 Neutron Spectrum Factor Determination."
l The licensee's NSF measurement program originally included 33 measurement I points inside the Unit 3 containment at which water jugs supporting neutron albedo dosimeters were located.
Neutron dose rate measure-ments at these points were also made. All instruments and dosimeters used during the study were calibrated against a moderated californium source.
Licensee results indicate negligible neutron dose rates at the majority of locations monitored inside containment. A NSF of 0.5 was experiment-ally determined for the 51'4 or refueling floor elevation of containment.
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For other locations inside containment, a default NSF of 0.8 (NSF value for a moderated Californium source) is applied.
The inspector had no further questions in this area.
8.0 Audits Audits of the activities and performance of the Millstone Station Radia-tion Protection groups are performed by the NUSCO Radiological Assessment Branch (RAB). The inspector reviewed the effectiveness of the audit program by the following methods: - discussion with the Station HP Supervisor and members of the Unit 3 HP staff, - review of RAB audit dated December 5,1985, covering Unit 3 pre-criticality status, and - review of RAB audit dated October 30-31, 1986, covering the Unit 2 outage activities as well as HP programs for Units 1 and 2.
During the current inspection, the HP supervisor was changing offices; consequently, a larger sample of audits was not easily accessible for review. The inspector noted that the December 5, 1985 audit focused entirely on Unit 3 activities and appeared to be an adequate assessment of HP status.
It was noted, however, that the scope of the October, 1986 audit appeared too large and the auditor's time on-site too short to per-form an effective review of HP activities.
The station HP supervisor indicated that a need for improvement in the audit program has been recognized and discussed among station staff and the NUSCO RAB group.
Planned improvements include greater auditor time on-site, focusing of audit scope and review activities, and identification i l and communication of problem areas needing review to the RAB group by the station HP staff.
' Effectiveness and performance of station HP audits, as well as implemen-l tation of proposed improvements, will continue to receive review during l subsequent NRC inspections.
9.0 ALARA During 1986, the Millstone Station Unit 3 exposure goal was 5 man rem / month during operation. The Unit ALARA coordinator indicated this goal was set by the NUSCO corporate group. Actual exposure for 1986 totaled approximately 26.5 man rem. The Unit 3 monthly average was typically well - below the man rem / month goal; during several months the unit staff was able to operate at less than 1 man rem / month.
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. During previous NRC inspections in this area, it was noted that indepen-dent and often conflicting ALARA exposure goals, particularly for outage siti;ations, are developed by the station ALARA and RAB staffs (NRC Report No. 336/86-20). The inspector discussed the development of 1987 Unit 3 exposure goals with the licensee.
The licensee indicated that all prelim-inary goals for 1987 have been developed by the Unit ALARA staff.
Licensee memo from the Unit 3 ALARA coordinator to the Health Physics Supervisor, dated December 17, 1986, included the following proposed exposure goals for 1987 Power Operations 40 man rem Mini-Outage (three weeks) 33 man rem Refueling Outage (ten weeks) 300 man rem The inspector noted that the licensee is anticipating approximately nine months of power operations, with a consequent operational monthly goal of 40/9 = 4.4 man rem per month of power operation. The inspector noted that although this reflects a decrease from the 1986 goal of 5 man rem / month, licensee actual performance during 1986 was such that the 1987 goal might have been made more competitive. The licensee indicated that goal formulation at this stage of plant operating experience was difficult and required predictions of increasing source term. However, the licensee indicated actual exposure during 1987 would be closely scrutinized to insure performance remains competitive.
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Exit Meeting The inspector met with licensee representatives (denoted in Section 1 of this report) at the conclusion of the inspection on January 9, 1987. The inspector summarized the purpose, scope, and findings of the inspection. }}