IR 05000443/1986039
| ML20212B493 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/01/1986 |
| From: | Mcfadden J, Shanbaky M, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20212B490 | List: |
| References | |
| 50-443-86-39, NUDOCS 8608070057 | |
| Download: ML20212B493 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION s
REGION I
Report No.
50-443/86-39 Docket No.
50-443 License No.
CPPR-135 Priority Category B
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Licensee:
Public Service of New Hampshire P. O. Box 700 Seabrook, New Hampshire 03874
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Facility Name:
Seabrook Power Station, Unit 1 Inspection At:
Seabrook, New Hampshire Inspection Conducted:
June 23-27, 1986
Inspectors:
4.N 7 - El - M 6
[prJ.McFadden,RadiationSpecialist date 4~
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7-T l-I W8
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S. Sherbini, Radiation Specialist date Approved by:
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'date Radia rotecti Section Inspection Summary:
Inspection on June 23-27, 1986 (Inspection Report No. 50-443/86-39)
Areas Inspected:
Routine unannounced preoperational inspection of the occupa-tional radiological controls program including:
status of previously identified items, organization and management controls, training and qualifications, external exposure control and personnel dosimetry, internal exposure control I
and assessment, control of radioactive materials and contamination, surveys, and monitoring, facilities and equipment, and maintaining exposures ALARA. Two regionally-based inspectors were onsite for this inspection.
Results: No violations were identified.
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DETAILS 1.0 Persons Contacted During the course of this preoperational inspection, the following personnel were contacted or interviewed.
1.1 Licensee Personnel H. Anderson, Radwaste/ Utilities Department Supervisor (NHY)
M. Chaisson, Engineer, Engineering Services (NHY)
D. Iseman, I&C Supervisor (NHY)
M. Johnson, Startup System Test Engineer (UE&C)
J. Linville, Chemistry Department Supervisor (NHY)
- T. Pucko, Licensing Engineer (NHY)
V. Sanchez, Licensing Engineer (YAEC)
R. Sterritt, ALARA HP, Operations (NHY)
- Attended the exit interview on June 27, 1986.
Additional licensee personnel were contacted or interviewed during this inspection.
2.0 Purpose The purpose of thi's preoperational inspection was to review the operational readiness of the licensee's radiological controls program, especially as regards requirements for initial core loading, with respect to the follow-ing elements:
status of previously identified items
organization and management controls
selection, training, and qualification of personnel external exposure control and personnel dosimetry internal exposure control and assessment control of radioactive materials and contamination, surveys, and monitoring facilities and equipment the ALARA Program
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3.0 Status of Previously Identified Items 3.1 (0 pen); Follow-up Item (50-443/86-16-02): Data to support adequacy of beta dose assessment methodology to be gathered / developed. During NRC Inspection No. 86-25, this issue was further clarified, and the licensee committed to obtain additional dosimeter response data; this data was to be the result of dosimeter irradiations performed using Pm-147 beta spectra. During NRC Inspection No. 86-39, the licensee demonstrated that beta irradiations had been performed on their dosimeters using SR-90/Y-90, T1-204, and Pm-147; preliminary results indicated that the correction factor at the Pm-147 energy should be approximately twenty-five; more irradiations are to be carried out using the Pm-147 and T1-204 sources as separate and as mixed sources; these irradiations are expected to yield a series of correction factors vs. beta energies; a function will be fit to these data points to allow calculation of correction factors from dosimeter readings, down to the Pm-147 energy; the licensee stated that this function will be incorporated into the dose assessment computer program. This item should be resolved before initial criticality.
3.2 (Closed); Follow-up Item (50-443/86-25-01): The fact that computer failure (both computers) would allow access to locked high radiation areas (HRAs) to any keycard holder was identified as a potential problem which was to be addressed by the licensee.
During NRC Inspection No. 86-39, it was noted that the licensee's procedure for keycard controlled locked HRAs had been revised; this revision requires that these locked HRAs be switched to a regular key-control mode in the case of a dual computer failure.
Based on this finding, this item is closed.
3.3 (0 pen); Follow-up Item (50-443/86-25-02): During a plant walkdown of the areas for which provisions are under way to control as locked HRAs, an unlocked access point to one such area (PDT degassifier) was noted by the inspector and pointed out to the licensee. The licensee stated that an internal review had already recognized this situation and that it would be corrected before the PDT degassifier area becomes a locked HRA. During NRC Inspection No. 86-39, a licensee intra-company business memo was reviewed by the inspector; this memo was entitled " Locked High Radiation Area Controls" and was dated June 24, 1986; in this memo, areas throughout the station, which would meet the criteria defining a locked HRA, were identified; any deficiencies with existing access control provisions for each area were documented; remedial recommendations and milestones for each area were also documented.
The PDT degassifier area was identified in this memo as requiring additional access control measures. The implementation and timing of changes to locked high radiation areas will be reviewed in a future inspectio.
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3.4 (Closed); Follow-up Item (50-443/86-25-03): The licensee committed to have an approved procedure for calibration of the whole-body counter by the time of initial fuel load. During this inspection, a procedure, "Whole Body Counter Calibration," was available and was reviewed by the inspector; this procedure appeared adequate; this procedure was approved and effective on June 23, 1986.
Based on this finding, this item is closed.
3.5 (Closed); Follow-up Item (50-443/86-25-04): A procedure (s), for review of bioassay results with actions to be taken based on those results and for calculating MPC= hours from bioassay data for correlation with MPC= hours from air sampling data, was (were) not available; the licensee committed to have an approved procedure (s)
within six months. During this inspection, the licensee's position and situation was as follows:
current procedures state that all positive bioassay results are separately logged and routed to HP supervision for review; that follow-up bioassay procedures to deter-mine retention characteristics are to be accomplished when a bioassay still indicates greater than a 10 percent maximum permissible organ burden after external decontamination measures were instituted; that a whole-body-count resolve function (to determine location of internal contamination) will be performed when a whole-body count is 3.3 standard deviations above background; and that HP supervision, when appropriate or necessary, will conduct investigations based on bio-assay results to further document internal deposition, to quantify intakes, and to correlate intakes to MPC* hours; the licensee indi-cated that this current procedural guidance was adequate. Current practice is to calculate MPC* hours based on activity measured by the whole body counter.
No account is taken far elimination and decay during the period between intake and counting. A computer program is being developed to make the back calculations to the time of intake.
In the meantime, the back calculations can be performed manually, if necessary; this will be done on site or with assistance from YAEC.
Based on these findings, this item is closed.
3.6 (Closed); Follow-up Item (50-443/86-16-05):
Procedure HD0 958.13 does not require that the controls developed in the ALARA Review be
included in or as an attachment to the RWP. The licensee committed to revise this, ocedure to incorporate this requirement.
During NRC Inspection No. 86-25, it was noted that the proposed revision to attach any completed ALARA Review to the RWP had been made, but the procedure had not yet been approved. During this current inspection, an approved procedure was available. Based on these findings, this item is closed.
4.0 Organization and Management Controls The licensee's organization and management controls for the radiation
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protection function were reviewed against criteria contained in:
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Seabrook Station Radiation Protection Program Manual
Seabrook Station Management Manual, Chapter 3, Station Policies; Section 3.3, interfaces The licensee's performance relative to these criteria was reviewed'in discussions with licensee representatives.
Documentation of the responsibilities and interfaces between healt5 physics and the radwaste group is to appear in the maintenance program manual.
The final draft version was available during this inspection and was reviewed.
The approved version of.this documentation will be reviewed in a subsequent inspection. (86-39-01)
5.0 Training and Qualification The licensee's training and qualification programs for HP self-monitors and for contractor HP technicians were reviewed against criteria contained in:
Seabrook Station Radiation Protection Program Manual
Regulatory Guide 1.8, Personnel Selection and Training
ANSI /ANS 3.1-1978, American National Standard for Selection and Training of Nuclear Power Plant Personnel The licensee's performance relative to these criteria was reviewed by discussions with licensee representatives and by review of documentation.
Supplemental HP training for operations personnel, chemistry technicians, and radwaste technicians has been defined, documented, and started.
The inspector reviewed the training manual, " Supplemental Radiation Worker Training (S6)." The qualification guide and card for this training and records of individual training and qualification were also reviewed.
This program appears adequate for the purpose of training an individual to monitor himself, for purposes of radiation protection, when this indi-vidual is permitted to enter a "high radiation area" under an approved RWP.
Whether this training program is intended to or is adequate for certifying participants as " individuals qualified in radiation protection procedures" was not determined during this inspection.
Per the licensee's final draft of their technical specifications, " individuals qualified in radiation protection procedures" can be responsible for providing positive control over the activities of other individuals in a "high radiation area" and for performing periodic radiation surveillance in a "high radiation area."
The licensee should document its criteria for certifying a person as an
" individual qualified in radiation protection procedures." Resolution of this item should be completed before initial criticality (86-39-02).
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i A program for contractor HP technician training and qualification is being developed.
The approved qualification guide and approved qualification card were reviewed and appeared comprehensive. A training manual, " Con-
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tracted HP Tech Training (S30)," was reported to be in draft form.
The approved manual should be available for implementation before contracted HP techs are utilized (86-39-03).
An additional item to be reviewed in a future inspection is documentation of timely review of revised procedures by radiation protection technicians (86-39-04).
6.0 External Exposure Control The licensee's external exposure control and personnel dosimetry program was reviewed against criteria contained in:
10 CFR 20, Standards for Protection Against Radiation
Seabrook Station Radiation Protection Program Manual The licensee's performance relative to these criteria was determined by discussions with members of the radiation protection staff and by review of documentation.
During this segment of the inspectien, items, identified as requiring follow-up in NRC Inspection Report Nos. 86-16 and 86-25, were reviewed.
Several of these items are discussed in section 3.0 of this report. An item identified as requiring additional review in a subsequent inspection is as follows:
derivation of neutron calibration factors at startup (86-39-05)
7.0 Internal Exposure Control The internal exposure control and assessment program was reviewed against criteria contained in:
10 CFR 20, Standards for Protection Against Radiation
Seabrook Station Radiation Protection Program Manual The licensee's performance relative to these criteria was determined by discussions with members of the radiation protection staff and by review of documentation.
7.1 Administrative Controls In NRC Inspection Report No. 86-25, it was stated that a health physics foreman would be continuously present at the main radio-logical control point; based on discussions with licensee personnel during this current inspection, this is incorrect and should have stated that a health physics foreman will be routinely assigned to the main radiological control point. Another correction to this
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previous report involves the review of all active RWPs; this will
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be performed by health physics supervision and not necessarily a " health physics sup'ervisor."
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7.2 Engineering Controls The permanent ventilation systems designed to provide air flow paths from areas of low potential airborne radioactivity areas to poten-tially high areas and to provide adequate face / capture velocities for hoods / local exhausts were discussed with licensee personnel.
The control room ventilation system components were physically inspected.
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Drawings for permanent ventilation systems depicting the design air flow directions were examined.
Portable ventilation units are now available and a draft procedure for use of air handling equipment has been generated.
This procedure does not presently address a tamper seal system for the filter housings nor does it contain criteria for exhaust air monitoring results.
Items identified as requiring additional review in a subsequent inspection are as follows:
identification of hood / local exhausts servicing activities with potential for generating airborne radioactivity and testing for adequate face / capture velocities (86-39-06)
approved procedure for use of portable ventilation equipment (86-39-07)
7.3 Respiratory Protection Equipment The licensee reported that four supplied-breathing-air carts are now available.
Items identified as requiring additional review in a subsequent inspection are as follows:
approved procedure for use of supplied-breathing-air equipment (86-39-08)
approved procedure for testing supplied-breathing-air quality and for recording test results (86-39-09)
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7.4 Air Sampling for Assessing Individual Exposure
- During a previous inspection, the licensee stated that HP review of radiochemical data from reactor coolant analyses would be the
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i mechanism used to track and detect increased significance of pure beta emitters. This mechanism was used to support the use of an i
l MPC value of 9E-9 (Co-60) (insoluble) for unidentified beta / gamma
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emitters. The details of when and how the radiochemical data will i
be made available for review by HP supervision has not been i
determined.
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The mechanism for determining lower limits of detection (LLDs)
for gross airborne radioactivity determinations was reviewed.
Figure 10.3, " Daily Instrument Check," in Procedure No. HD0963.02,
" Control and Calibration of HP Instrumentation," requires that counting instrument LLDs be computed daily. The counting room log provides a space for recording the net counts per minute (NET CPM)
for samples counted. This NET CPM is input to Form HD0955.01A,
" Air Sample Results," in Procedure No. HD0955.01, " General Count Room Guidelines," where the sample activity in microcuries per cubic centimeter and percent maximum permissible concentration is determined.
Items identified as requiring additional review in a subsequent inspection are as follows:
mechanism used to track and detect increased significance of pure beta emitters was not available; resolution of this item should be completed before initial criticality (86-39-10)
extent of routine air sampling at startup (86-39-11)
7.5 Bioassays During this segment of the inspection, items, identified as requir-ing follow-up in NRC Inspection Report Nos. 86-16 and 86-25, were reviewed.
Several of these items are discussed in section 3.0 of this report.
The detection capability of the whole-body-counting system was reviewed for adherence to the 5% of MP08 detection capability recommendation in ANSI N343-1978, "American National Standard for Internal Dosimetry for Mixed Fission and Activation Products." The system was found to be capable of exceeding ANSI recommendations for all radionuclides of interest.
There is currently no in-vitro bioassay program. A search is in progress to contract with a suitable organization to perform labora-tory analyses of in vitro bioassay samples to determine activity concentration and radionuclidic composition. Once the laboratory is selected, a QA/QC program review of that organization will be implemented.
Items identified as requiring additional review in a subsequent inspection are as follows:
computer program and/or technical basis document to make back calculations from bioassay results to the time of intake (in vivo and in vitro bioassay results) was not avafiable; resolu-tion of this item should be accomplished before initial criticality (86-39-12)
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in vitro bioassay program and quality assurance program for same were not available; resolution of this item should be accomplished before initial criticality (86-39-13)
8.0 Control of Radioactive Materials and Contamination, Surveys, and Monitoring The licensee's programs for the control of radioactive materials and contamination, surveys, and monitoring were reviewed against criteria contained in:
10 CFR 20, Standards for Protection Against Radiation
Seabrook Station Radiation Protection Program Manual The licensee's performance relative to these criteria was determined by discussions with members of the radiation protection staff and by review of documentation.
8.1 Portable Survey, Sampling, and Contamination Monitoring Instruments The licensee reported that two portal monitors and four standup friskers were new available.
Use and calibration procedures for these units are being developed.
Procedure No. HD0955.05, " Operation of Portable Radiation /
Contamination Instrumentation," was available in approved form and contained appropriate references to the E-520, E-530N, and Mini-Rad survey instruments.
Procedure No. HD0955.31, " Survey Instrument Source Checks," was available in an approved form.
Records of calibration for portable survey instruments were also reviewed by the inspector.
Items identified as requiring additional review in a subsequent inspection are as follows:
use and calibration procedures for portal monitors were not available; resolution of this item should be complete before
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initial criticality (86-39-14)
use and calibration procedures for standup friskers were not available; resolution of this item should be complete before initial criticality (86-39-15)
8.2 RDMS Status
the status of specific monitors, identified as being applicable to the in plant HP operations, was reviewed, and the change in status since NRC Inspection No. 86-25 was obtained. Special emphasis was placed on reviewing the status of those monitors which both were identified as being applicable to in plant HP operations and are
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required to be operable in mode six by the final draft of the licen-see's technical specifications; approved calibration procedures for the monitors (required in mode six) were available, but Monitors 6535 A and B (Manipulator Crane) had not yet been turned over to the plant staff; the licensee stated that this turnover was imminent.
In NRC Inspection No. 86-25, the licensee indicated that an evalua-tion of the containment air monitor sample location will be performed when containment integrity is next established. This has not yet been completed.
Selected turnover reviews of the RDMS by the licensee HP staff were examined during this inspection.
Items identified as requiring additional review in a subsequent inspection are as follows:
some calibration procedures for RDMS Area Monitors for modes other than mode six were not available; a;; proved
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procedures should be available before initial criticality (86-39-16)
licensee HP turnover review of the RDMS (86-39-17)
8.3 In-Plant Surveys and Monitoring The licensee intends to evaluate their alternate noble gas sampling technique after startup. This evaluation should be completed before employing this alternate technique as the method of choice (86-29-18)
9.0 Facilities and Equipment The licensee has limited space for decon, repair, and storage of contam-inated materials and equipment.
The need for additional space has been identified by the licensee, and contingency plans for possibly building on to the present decon/ truck bay area and for using trailers for storage are being considered.
There is a 3eneric decon procedure in the Radiation Protection Program Manual which the radwaste/decon personnel intend to use. Additional decon procedures are to be developed as needed (e.g., upon acquisition of dedicated equipment for decon).
10.0 ALARA The licensee's program to maintain exposures as low as reasonably
achievable was reviewed against criteria contained in:
10 CFR 20, Standards for Protection Against Radiation
Seabrook Station Radiation Protection Program Manual i
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The licensee's performance relative to these criteria was determined by discussions with licensee representatives and by review of documentation.
During this segment of the inspection, one item, identified as requiring follow up in NRC Inspection Report No. 86-16, was reviewed and is dis-cussed in section 3.0 of this report.
Procedure No. HD0959.01, " Radiation Exposure Performance Assessment,"
was available in an approved form and was reviewed by the inspection.
During NRC Inspection No. 86-16, the licensee indicated that a need for additional ALARA training had been identified for job supervisors and management personnel above the job supervisor level; this need was based on the fact that the licensee's ALARA review and recommendation process places significant ALARA responsibilities on the various job supervisors and their management. No firm plans for this type of training have been yet developed.
11.0 Exit Interview The inspectors met with the personnel denoted in section 1.0 at the conclusion of the inspection on June 27, 1986.
The scope and findings of the inspection were discussed at that time. At no time during this inspection was written material provided to the licensee by the NRC inspectors.
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