ML17053C725
| ML17053C725 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/02/1981 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Lempges T NIAGARA MOHAWK POWER CORP. |
| Shared Package | |
| ML17053C717 | List: |
| References | |
| NUDOCS 8107100079 | |
| Download: ML17053C725 (22) | |
See also: IR 05000220/1980011
Text
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Docket No. 50-220
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
631 PARK AVENUE
KING OF PRUSSIA, PENNSYLVANIA19406
02 M~A lg8~
Niagara
Mohawk Power Corporation
ATTN:
Mr. T.
E.
Lempges
Vice President
Electric Production
300 Erie Boulevard West
Syracuse,
13202
Gentlemen:
Subject:
Health Physics Appraisal
The
NRC has identified a need for licensees
to strengthen
the health physics
programs at nuclear
power plants
and
has
undertaken
a significant effort to
assure
that action is taken in this regard.
As a first step in this effort,
the Office of Inspection
and Enforcement is conducting special
team appraisals
of the health physics
programs,
including the health physics
aspects
of radio-
active waste
management
and onsite
emergency
preparedness
at all operating
power reactor sites.
The objectives of these appraisals
are to evaluate
the
overall
adequacy
and effectiveness
of the total health physics
program at each
site
and to identify areas of weakness
that need to be strengthened.
We will
use the findings from these appraisals
as
a basis
not only for requesting
individual licensee
action to correct deficiencies
and effect improvements
but
also for effecting improvements
in
NRC requirements
and guidance.
This effort
was identified to you in a letter dated January
22,
1980,
from Mr. Victor
Stello, Jr., Director,
NRC Office of Inspection
and Enforcement.
During the period of October 3-10,
1980,
the
NRC conducted
the special
appraisal
of the health physics
program at the Nine Mile Point Nuclear
Power Plant, Unit
l.
Areas
examined during this appraisal
are described
in the enclosed
report
(50-220/80-11).
Within these
areas,
the appraisal
team reviewed selected
"procedures
and representative
records,
observed
work practices,
and interviewed
personnel.
It is requested
that you carefully review the findngs of this
report for consideration
in effecting improvements to your health physics
program.
The findings of the appraisal
at Nine Mile Point indicate that your radiation
protection
program is particularly unsound
in respect
to the areas
examined
and requires substantial
upgrading.
In this regard,
we issued
Immediate
Action Letter (IAL) 80-38
on October
17,
1980 to effect assurance
that your
program would be adequate
to present
operations until an upgraded
program
could be sufficiently maintained.
c
8107100079
810325
- DOCK 05000220
8
0
Niagara
Mohawk Power Corporation
02
MAR lg8]
Particular findings are discussed
in detail in Appendix A, "Significant Appraisal
Findings."
Me recognize that
an explicit regulatory requirement pertaining to
each significant weakness
identified in Appendix A may not currently exist.
However, to determine
whether adequate
protection will be provided for the
heath
and safety of workers
and the public, you are requested
to submit
a
written statement within twenty (20) days of your receipt of this letter,
describing your corrective action for each significant weakness
identified in
Appendix A including:
(1) steps
which have
been taken;
(2) steps
which will
be taken;
and (3)
a schedule for completion of action.
This request is made
pursuant to Section 50.54(f) of Part 50, Title 10,
Code of Federal
Regulations.
During this appraisal, it was also found that certain of your activities did
not appear to have
been
conducted
in full compliance with NRC requirements
as
set forth in the Notice of Violation enclosed
herewith as Appendix B.
The
items of noncompliance
in Appendix
B have
been categorized
into the levels of
severity
as described
in our Criteria for Enforcement Action dated
Dece'mber
31,
1974.
Section
2.201 of Part 2, Title 10,
Code of Federal
Regulations,
requires
you to submit to this office, within twenty (20) days of your receipt
of this notice,
a written statement
or explanation
in reply including:
(1)
corrective
steps
which have
been
taken
by you and the results
achieved;
(2)
corrective
steps
which will be taken to avoid further items of noncompliance;
and (3) the date
when full compliance will be achieved.
You should
be aware that the next step in the
NRC effort to strengthen
health
physics
programs at nuclear
power plants will be the imposition of a requirement
by the Office of Nuclear Reactor
Regulati'on
(NRR) that each licensee
develop,
submit to the
NRC for approval,
and implement
a Radiation Protection
Plan.
Each licensee will be expected
to include in the Radiation Protection
Plan
sufficient measures
to provide lasting corrective action for significant
weaknesses
identified during the special
appraisal
of the current health
physics
program.
Guidance for the development of this plan will incorporate
pertinent findings from all special
appraisals
and will be issued
by
NRR later
this year.
In accordance
with Section
2.790 of the NRC's "Rules of Practice,"
Part 2,
Title 10,
Code of Federal
Regulations,
a copy of this letter .and the enclosures
will be placed in the
NRC's Public Document
Room.
If this material
contains
any information that you believe to be proprietary, it is necessary
that you
make
a written application within 20 days to this office to withhold such
information from public disclosure.
Any such application must be accompanied
by an affidavit executed
by the owner of the information, which identifies the
document or part sought to be withheld,
and which contains
a statement
of
reasons
which addresses
with specificity the items which will be considered
by
the Commission
as listed in subparagraph
(B)(4) of Section
2.790.
The informa-
tion sought to be withheld shall
be incorporated
as far as possible into a
separate
part of the affidavit. If we do not hear from you in this regard
within the specified period, this letter and the enclosures will be placed in
the Public Document
Room.
Niagara
Mohawk Power Corporation
02
MAR 1981
Should you have
any questions
concerning this inspection,
we will be pleased
to discuss
them with you.
Sincerely,
Boy e H. Grier
Dir ctor
Enclosures:
l.
Appendix A, Significant Appraisal
Findings
2.
Appendix B, Notice of Violation
3.
Office of Inspection
and Enforcement Inspection
Report
Number
50"220/80"11
cc w/encls:
M. Silliman, Acting General
Superintendent,,
Nuclear Generation
T.
Roman, Station Superintendent
R. Abbott, Operations
Supervisor
E.
B. Thomas, Jr.,
Esquire
A ~ ~
~
APPENDIX A
Si nificant A
raisal
Findin
s
In the course of this. appraisal,
the following items were identified as needing
improvement in order to achieve
an acceptable
program.
A.
Organization,
Responsibilities,
Staffing
2.
The organizational
structure
as currently implemented is not in
agreement with the description provided in the licensee's,Technical Specification 6.2.2.
As of October 9,
1980 the licensee
had not
initiated any action to amend the existing technical
specification.
In addition,
supporting administrative
procedures
such
as
APN-2 a'nd
APN-2A were not subject to any revision necessary
to reflect the
reorganization;
and personnel
job descriptions
were not revised to
recognize
new or added responsibilities
or authorities
as
a result
of the reorganization.
Although an organization exists, 'it has not
been formally established
within the licensee's
own administrative
system nor in accordance
with the normal regulatory process.
(Section 1.1.1)
There is no professional
level health physics
support available to
the designated
site Radiation Protection
Manager
(RPM) from either
the corporate
organization
or within the site organization.
In
addition there is no individual within Niagara
Mohawk having the
necessary
capabilities
(managerial
and technical expertise) suffic-
ient to meet the requirements
"Personnel
Selection
and Training" to provide back-up support to the
RPM.
(Section 1.1.2)
3.
There is an overall lack of technical
depth in regards
to the ability
of the current staff to perform sufficiently to assure
an adequate
radiation protection
program is established,
implemented
and maintained.
Insufficient technical
depth appears
to be the result of (Section 1.2,
1.3):.
inordinate deference
to select
and qualify individuals based
on
ability to perform in the area of chemistry;
~ $ h
lack of any substantial
education
or training programs provided
to upgrade individual s in the area of health physics;
the discouragement
of tendencies
to develop personnel
as specialist
in the area of health physics, particularly in the case of
technicans
who are regarded
as
a generic all-purpose
work force
capable of performing .in any needed
capacity.
0
0
Appendix A
4.
There are insufficient numbers of qualified personnel,
particularly
supervisors
and technicians
to assure
that adequate
radiological
controls are established
and implemented for normal operations.
5.
Licensee
management
has not developed
Job Descriptions for individuals
associated
with the area of radiation protection that specify autho-
rity commensurate
with responsibilities,
particularly in the position
of Superintendent,
Radiochemistry
and Radiation Protection,
supervisors,
technical
coordinators
and technicians.
B.
Personnel
Selection, gualification and Training Program
1.
Radiation protection training and experience
is not addressed
in the
criteria for advancement
of Health Physics
Personnel.
(Section 2.2)
2.
Health Physics duties are not specified in formalized Job Descriptions
for technicians.
(Section 2.2)
3.
The training program for Health Physics personnel,
particularly
technicians
and,supervisors,
does
not include on-the-job training;
lacks technical
depth,
does not provide for retraining;
and,
does
not provide for cross training
on health physics tasks.
(Sections
2.3)
C.
Exposure Control
1.
External
Exposure Control
a.
The method of posting radiologically controlled areas
does
not
provide sufficient information for adequate
exposure control.
(Section 3.3)
b.
The program for spiking vendor supplied film badges
was deficient
in that the technique utilized did not provide for a sufficient
number of badges
to be checked,
formal procedures
were not
developed,
and the data
was not adequately
evaluated.
(Section
3.4)
2.
Internal
Exposure Control
a ~
b.
No indepe'ndent verification by the licensee of the calibration
of the whole body counter
was performed.
Existing procedures
relating to the frequency established
for counting personnel
are not followed.
(Section 3.5.1)
The evaluation of internal
exposure
data is insufficient to
determine whether the protection provided by protective clothing
and equipment is adequate.
(Section 3.5. 1)
Appendix A
c ~
d.
Procedural
guidance
and action levels which specify when excreta
bioassay
samples
are to be taken
have not been developed.
(Section 3.5.1)
There are
no procedures
for collecting, handling, analyzing
and
evaluating bioassay
samples.
(Section 3.5. 1)
3.
Respiratory Protection
Program
a.
In support of the respiratory protection program:
medical
examinations
were not performed annually; breathing ai.r was not
tested to Grade
D specifications
or better; regulators
and
valves were not tested
as required
by procedures;
quantitative
test equipment
was found inoperable;
and the training/retraining
program did not inc'lude field training or examinations.
(Section 3.5.2)
b.
C.
The quantitative fit test equipment
and respirator
assembly
areas
were not adequately
located.
(Section 3.5.2)
The individual assigned
responsibility for supervising
the res-
piratory protection
program
was not adequately qualified.
(Secti on 3.6. 2)
d.
There
was
a lack of written procedures
specific to the quality
assurance
program for respiratory devices.
(Section 3.5.2)
e.
Management
review of and policy for the respiratory protection
program
was not established,
implemented
and maintained.
(Section 3.5,2)
D.
Surveillance
Program
1.
The licensee
procedures
do not adequately
define the basis for sur-
veillance activities or incorporate all of the forms used in the
surveillance
program.
(Section 3.6, 3.6.5)
2.
Surveillance
records
do not contain sufficient data
and were not
organized or maintained in a manner to allow adequate
evaluation of
the radiological status of the facility.
(Section 3.6, 3.6.5)
3.
The method for, frequencies
of and locations of radiation
and contam-
ination surveys
were inadequate.
(Section 3.6, 3.6.2)
4.
Methods did not exist to ensure that contamination related
problems
are identified, evaluated
and corrected sufficient to preclude
recurrence.
(Section 3.6.3)
5.
No formal mechanism
has
been established
for the review of surveillance
records.
(Section 3.6.5)
0
Procedures
do not exist to describe
the methods
used to count air
samples
and there is no evidence to indicate that all significant
isotopes
were identified for air samples.
(Section 3.6. 1)
i
The licensee's
procedures
do not provide sufficient guidance for
Health Physics
personnel
issuing Radiation
Work Permits
and do not
specify
a time limitation for Extended Radiation
Work Permits.
(Section 3.6.6)
The Radiation
Work Permit
(RWP) system
was deficient in that:
procedural
guidance
and training was not sufficient for provid-
ing personnel
with adequate criteria for
RWP requirement selection;
survey data
was not recorded
in a manner that permits adequate
evaluation
and review;
pre-planning meetings
were not adequately
performed.
The requirements
for and
use of protective clothing is inconsistently
applied.
(Section 3.6.6)
The licensee
does not have positive management
controls established
that would assure that individuals and equipment
are adequately
monitored for contamination prior to leaving contamination
areas
or
the licensee's
restricted
area;
and most personnel
do not adequately
monitor themselves
prior to leaving the restricted area.
(Section
3.6.7)
The procedures
for entry into high radiation areas
were confusing,
and did not completely reflect the Technical Specification requirements.
Some doors
and gates
(accesses)
to these
areas
were found to be open
or otherwise
not controlled in accordance
with Technical Specif-
ications.
(Section 3.6.7)
Procedures
do not exist for the calibration, operation or setting of
alarm points for the count rate instruments
normally used to monitor
personnel
and equipment
leaving restricted areas.
(Section 3.6.7)
Adequate accountability, control, labeling and leak tests
do not
exist for all radioactive test
and calibration sources.
(Section
3.6.7)
The licensee
does not exercise control over or provide source
checks
for all survey instruments.
(Section 3.6.8. 1)
The calibration
and operation
procedures
for the majority of the
licensee's
portable radiati.on
and contamination
survey instruments
and laboratory counting equipment
are not adequately
established,
maintained or implemented.
(Sections 3.6.8)
Appendix A
16.
The methodology
and procedure for setting the portal monitor alarm
points is deficient in that the technical
basis for the technique
used did not support
an adequate
instrument calibration. (Section
3.6.8.2)
The sources
used to calibrate the laboratory counting equipment
are
17.
was not adequately
maintained;
technicians
were not adequately
trained in its theory or use;
and the device could not be used to
calibrate the higher ranges
due to source
decay.
(Section 3.6.8)
not traceable
to NBS.
(Section 3.6.8.7)
I
18.
The calibrator
used to calibrate portable radiation survey instruments
19.
Technicians
were not adequately
trained
on the theory,
set
up or use
of laboratory counting equipment.
(Section 3.6.8.7)
20.
21.
22.
Sufficient quality control procedures
had not been established
for
laboratory counting equipment.
(Section 3.6,8,5)
The air sampling
program
based
on grab
samples utilizing high and
low volume air samplers
is deficient in that breathing
zone
samples
are not collected,
100% collection efAciency is assumed for the
iodine collection media without adequate
basis
or consideration
of
the residence
time for the charcoal
as
a function of flow rate.
(Section 3.6.8.5)
The instruments
used to monitor personnel
and equipment for contamina-
tion could not detect the licensee's
release
limits and the detector
types
used did not meet the ANSI 323 recommendations.
(Section
3.6.9)
E.
Radioactive
Waste
Management
System
2.
3.
4.
5.
The Radwaste
Coordinator did not have adequate
personnel
support
or
authority commensurate
with his assigned
responsibilities.
(Section
4.1)
The training for personnel
assigned
tasks related to radioactive
waste
management
was not sufficient.
(Section 4.0)
Waste handling procedures
were not adequately
established,
implemented
or maintained.
(Section 4.2.3)
The site (}uality Assurance
Department did not provide sufficient
active participation in activities relating to radioactive waste
packaging
and shipping.
(Section 4.2.3)
There is no assurance
that all radioisotopes
that
may have signifi-
cantly contributed to the radioactive content of packages
of radio-
active material
were evaluated.
Personnel
did not evaluate
peak
indications that were not positively labeled
by the counting system's
computer.
(Section 4.2.3)
Appendix A
F.,
A corporate policy statement
or formal commitment
on ALARA did not
exist.
(Section 5.0)
2.
The licensee administrative
ALARA procedure did not specify goals or,
objectives of the program.
(Section 5.0)
3.'
management
control
system did not exist to monitor, control
and
measure
the performance of the licensee's
efforts in ALARA.
(Section
5.0)
G.
Health Physics Facilities
and Equipment
2.
The design of protective clothing change
areas
did not provide for
decontamination
showers
and sinks in close proximity or the avai la-
bility of personnel
clothing lockers.
(Section
6. 1)
Frisking stations
were not designed
or located adequately
to provide
po'sitive access
control.
(Section
6. 1)
HE
Emergency
Planning
2.
A specific and complete organizational
delineation
(reaching
to the
working levels) of the emergency
command hierarchy for all the
distinct emergency
functions, describing
the assignment
of supervisory
and non-supervisory
personnel
by title/position for each functional
area of emergency
response
was not in place.
(Section 8. 1)
The augmentation
of the onsite
emergency
organization
(Personnel
and
equipment) for a continuous
(24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)
emergency situation projected
to last
an indefinite period was not specified in the following
areas:
health physics,
environs monitoring, logistical support,
technical
support, notification of governmental
authorities
and
release
of information to the
news media.
(Section 8.2)
3.
The authorities, responsibilities,
limits and interfaces of contractors,
private organizations,
and local services with the onsite
emergency
organization
was not clearly delineated.
(Section 8.2)
4.
Formally approved
lesson
plans for each functional area of the
.
emergency
organization including student
performance objectives,
tests
and practical
exercises
in which individuals demonstrate
specific abilities were not established.
(Section 9.0)
5.
Means to provide training/retraining of all individuals concerning
their specific functional duties in the emergency
organization
to
meet schedule
requirements,
and to provide additional training in
those
areas
where significant changes
in emergency
response
planning
or procedures
occur were not established
and implemented.
(Section
9.0)
Appendix A
6.
Survey instrumentation with a range to at least
1000 R/hr was not on
hand.
(Section
10. 1)
7.
Provisions for means of detecting
and measuring
radioiodine airborne
concentrations
of at least
10
uCi/cc under field conditions
and
high background radiation levels were not established.
(Section
10.1)
8.
Determination of detection efficiency for ratemeter/detector
system
for Iodine 131,
and the retention efficiency of cartridge
media for
airborne iodines
had not been determined.
(Section
10. 1)
9.
Equipment
and supplies to both
EOCs needed
to protect
and assist
personnel
coordinating
and evaluating
the
emergency
response effort
(e.g. air sample,
beta/gamma
survey instruments,
calibration sources,
site maps,
isopleths, etc.) were not on-hand.
(Section
10.4)
10.
Supplies
and equipment for decontamination
of personnel
during
serious
emergencies
were not available at each of the assembly
areas.
(Section
10.6)
Provisions
had not been established
for primary assembly
area
and
other designated
assembly
areas
so that they can
accomodate
the
number of persons
expected
during an emergency,
and having equipmen't
and- supplies
as required to ensure
the physical
safety of personnel
assembled
(e.g. respiratory protection
equipment, etc.).
(Section
10.6)
12.
Special
Operating
Procedures
developed
pursuant
to Regulatory
Guide
1.33 did not include
a step in the "Immediate Action Section" which
requires
an evaluation of emergency conditions relative to EALs and
emergency classification criteria contained
in the licensee's
Emergency
Plan
and Implementing Procedures.
(Section
11.2)
13.
Implementing Instructions which provided separate
procedures
for
each
em'ergency
category specified in the Emergency
Plan providing
a
clearly graded classification
system
and distinct EALs based
on
available quantitative indicators
had not been developed.
(Section
11.3)
14.
15.
A coherent
scheme for emergency notification of all offsite agencies,
including specific action levels for selective notification of such
agencies
in accordance
with a graded classification of emergencies
had not been developed.
(Section
11.4')
No provisions for upgrading
and maintaining
a current
"Emergency
Contact List" were in place.
(Section
11.4. 1)
16.
Provisions for recording the duration of meter readings, air sample
volume and flow rates,
background radiation levels
at, the time of
filter media counting,
and
sample counting times were not in place.
(Section
11.4.4)
Appendix A
17.
The procedure for monitoring and decontamination
of personnel
during
emergency
conditions did not include:
cross-references
to Implementing
Instructions which orchestrate all emergency actions, definition of
contamination levels,
methods,
instrumentation,
follow-up surveys
for internal contamination,
and logistics to handle
a large
number
of contaminated
persons
during
an emergency.
(Section 11.4.5)
18.
All designated
assembly
areas
in the Emergency
Plan,
Emergency
Implementing Instructions
and Procedures
were not specified.
(Section
11.4.6)
19.
Procedures
to incorporate
the interim high-range
main stack monitor
into the radiological
assessment
procedures
to measure
radioactive
release
rates
from the main stack in the event the presently installed
process
monitors with control
room readouts
are off-scale or inoperable
had not been
developed
and implemented.
(Section 11.4.8)
20.
Provisions for radiation protection during emergencies
which include:
personnel
dosimetry,
exposure
records,
positive access
controls
instructions to emergency
workers regarding the radiological conditions
due to the emergency
dose
assessment,
limiting exposures/re-exposures.
and ALARA considerations
had not been established.
(Section
11.4.12)
21.
Provisions for emergency repair/corrective
actions,
including designa-
tion of the responsible
emergency
organization
element,
team make-up,
and procedures
had not been established.
(Section
11.4. 14)