ML17053D175
| ML17053D175 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/20/1982 |
| From: | Baer R, Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17053D173 | List: |
| References | |
| 50-220-81-04, 50-220-81-4, NUDOCS 8206070371 | |
| Download: ML17053D175 (20) | |
See also: IR 05000220/1981004
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
Report
No. 50-220/81-04
Region I
IZHg
P~~'ocket
No. 50-220
License
No.
Priority
Category
Licensee:
Nia ara
Mohawk Power Cor oration
300 Erie Boulevard Mest
~Sracuse
13203
Facility Name:
Nine Mile Point Unit
1
NMP-1
Inspection at:
NMP-1
Oswe
o
Inspection
conducted:
March 3-6 and 24-27
1981
Inspector:
R.
E. Baer, Radiation Specialist
d Po-8K
date
signed
date
signed
date
signed
Approved by:
Ad
8'Z
E.
G.
Greenman,
Chief,
Fa i
ties Radiation
date
signed
Protection Section,
Technical
Programs
Branch
Ins ection
Summar
Ins ection
on March 3-6 and 24-27
1981
Re ort 50-220/81-04
Areas Ins ected:
Routine,
unannounced
safety inspection
by a region based
inspector of the Radiation Protection
Program at Unit
1 during refueling
outage conditions including:
procedures,
training, planning
and preparation,
posting
and control, surveys,
radioactive
and contaminated
material control,
and the Radiation Protection
Program
upgrade.
The inspection
involved
sixty(60) inspector
hours
on site by one region based inspector.
Results:
Of the
seven
areas
inspected
no violations were identified in
five areas
and two violations were identified in two areas;
(fai lure to
follow procedures,
paragraph
3,
and failure to adequately
survey,
paragraph
7).
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DETAILS
Persons
Contacted
- Mr. J.
- Mr. J.J.
- Mr. J.N.
""Mr. TOM.
""Mr. E.M.
'Mr. T.E.
'"Mr. T.W.
- 'Mr. M.A.
Aldrich, Training Superintendent
Blasiak, Assistant Supervisor,
Chemical
& Radiation Protection
Duell, Supervisor,
Chemical
& Radiation
Pt otection
Kurtz, Assistant Supervisor,
Chemical
& Radiation Protection
Leach, Superintendent,
Chemical- & Radiation
Management
Lempges,
Vice President,
Nuclear Generation
Roman, Station Superintendent
Si lliman, Technical
Superintendent
Other Personnel
Mr. S.
Hudson,
Resident
Reactor Inspector,
The inspector
also interviewed several
licensee
and contractor
employees
including health physics technicians,
operations
and maintenance
personnel.
- denotes
presence
at the exit interview March 5,
1981 only.
- denotes those
persons
present at exit interviews March
5 and
March 27,
1981.
2.
Licensee Action on Previous
Ins ection Findin
s
(Open) Inspector
Followup Item (50-220/81-06-01).
The licensee is to
initiate actions to resolve the leakage
problem from the ventilation
duct
on the 318'levation of the Reactor Building (east side).
The
licensee
has referred this problem to their Staff Engineering
Department.
A plan for corrective action will be available
by May 1,
1981.
(Open) Inspector
Followup Item (50-220/81-06-02).
In accordance
with
the licensee's
Action Plan of 11/26/80,
Items III.C 1 and 2,
a written
policy statement
incorporated
into APN-12,
and upgrading of procedures
and equipment for respiratory protection,
were expected to be completed
by January
and March,
1981, respectively.
(Open) Inspector
Followup Item (50-220/81-06-03).
In accordance
with
the licensee's
Action Plan 11/26/80,
Item III.D.2, air sampling
improvements
should
be completed
by March,
1981.
New air sampling equipment
had
been
purchased
at the time of this inspection (3/26/81).
Not all of
the equipment
was in service,
nor had training been
completed, for the
operation of the equipment.
3.
Procedures
Unit
1 Technical Specifications (TS) 6.8. 1 requires that the applicable
procedures
in Appendix "A" of Regulatory Guide 1.33,
November
1972
be
~ ~
k
established,
implemented
and maintained.
TS 6.8.2 requires that the
'bove procedures
be reviewed by the Site Operations
Review Committee
(SORC)
and approved
by the General
Superintendent
Nuclear Generation.
TS 6. 11 requires that radiation protection procedures
be prepared
consistent with the requirements
of 10 CFR Part 20 and
be approved,
maintained
and adhered
to for all operations
involving personnel
radiation exposure.
The following procedures
were reviewed against
the requirements
of TS
6.'8 and 6.11:
NI WHP-1
"Required
Documents
Concerning
Packaging
and Shipping of
Radioactive Waste,"
Revision 0, dated 6/24/80.
NI WHP-3
"Cask Handling Procedure,"
Revision 0, dated 6/24/80.
NI WHP-6
"Van Handling Procedure,"
Revision 0, dated 1/26/81.
RP-1
RP-2
"Access
and Radiological Control," Revision 0, dated 8/25/80.
"Radiation Work Permit Procedures,"
Revision
1, dated 2/13/79.
On Tuesday,
March 3,
1981, .at about 10:00 p.m.,
a safety valve
on the
shell
side of the regenerative
heat exchanger
in the Reactor Water
Clean
Up (RWCU) System
began
leaking.
The valve discharges
to the
Reactor Building Equipment
Decay Tank (RBEDT), located
below the
198'levation
of the Reactor Building.
The rate of inleakage
to the
was greater
than the
pumping capacity of the two RBEDT pumps.
The
RBEDT overflowed to the 198'loor,.
Thi,s water then flooded the floor
to approximately
one inch and entered
the Reactor Building Floor Drain
The
RWCU system
was isolated
and leakage
stopped at
approximately 6:30 a.m.
on March 4,
1981.
The inspector
requested
a radiation
survey
on March 4,
1981, at approximately
10:00 a.m.
Transferable
contamination
was detected
up to 112,000
disintegrations'er
minute per
100 centimeters
square
and airborne
radioactivity was measured
as follows:
xenon-135 (8. 19 E-ll microcuries
per milliliter(uc/ml)), cesium-137
(3.9 E-10 uc/ml) and cobalt-60
(4.94 E-9 uc/ml).
A second air sample
was taken
between
10:45 and
11:30 a.m. while work was being performed in this area.
Airborne
concentrations
measured
were cesium-137
(4.46 E-10 uc/ml) and cobalt-
60 (1.26 E-8 uc/ml).
No sample of the water
was taken for analysis.
Operations
personnel
entered
the Reactor Building and descended
through
a locked gate posted
"Caution High Radiation
Area-RWP Required for
Entry," to the, 198'levation.
Entry was
made without a valid
RWP or
the
use of a radiation
survey meter to determine
the cause for the Hi-
Hi alarm on the
RBEDT liquid level.
After it was determined that the
RBEDT pumps were operating
and the tank was overflowing, operations
personnel
installed
a "Sand Piper"
pump.
~
II
An existing extended
RWP (Number 5), which permits operators
to perform
inspections
in the Reactor Building, requires
them to sign in on the
"High Radiation Area Entry Log," available to them in the Control
Room.
No attempt
was
made to use this option by operations
personnel
to
document their entry to the High Radiation Ar'ea.
Five operators
and
the Station
Radwaste
Supervisor
entered this area
between
10:00 p.m.
on March 3,
1981
and 12:30 a.m.
on March 4,
1981.
An undetermined
number of. operators
replaced
these
personnel,
and
made
an undetermined
number of entries
between
12: 15 a.m. to 8:00 a.m.
on March 4,
1S81
without using the High Radiation Area Entry Log.
The inspector
reviewed radiation
surveys
performed
on March 4,
1981 at
the 198'levation of the Reactor Building.
The highest
observed
radiation levels were
50 mrem per hour
3 inches
from a tagged line,
and
20 mrem per hour - around the floor drain
sump.
The area
was not
a
High Radiation Area as posted.
The inspector
reviewed the licensee's
Site
Emergency
Plan
and determined
that the conditions present did not fall within the guidelines for any
one of the four emergency
classes
listed.
This occurrence
is classified
as
an operational
event,
a non-emergency
class.
If the licensee
classified this event
as
an emergency,
the lowest severity class
would
have
been
an "Unusual
Event" under the
Emergency
Plan Section
4. 1.2,
and the licensee
would have
been required to notify the
NRC operations
center in accordance
with 10 CFR 50.72
and to follow the following
procedures:
EPP-20 Classification
and Notification of Emergency
Conditions;
EPP-4 Personnel
Injury or Illness;
EPP-6 Inplant Emergency
Surveys;
and
EPP-15 Health Physics
Procedures.
Since the event
was
classified
as
a non-emergency
the above actions
were not taken or
required.
The inspector later determined that the Chemistry and Radiation Protection
Group was not informed of this occurrence until approximately
10:00
a.m.
on March 4,
1981.
At about 4:30 p.m.
on March 4,
1981,
the
inspector
asked
what follow-up action
had
been
taken,
or was planned
regarding
personnel
who entered
the area,
in view of the fact that the
airborne concentration
measured
in the area at 10:30 a.m.
on March
4,'981
was
145% of the concentration
specified in 10 CFR 20, Appendix B.
The licensee
expedited
arrangements
to perform whole body counts
on
those operators
who worked on the 4:00 p.m. to 12:00 p.m. shift and to
call in involved operators
who worked on the 12:00 p.m. to 8:00 a.m.
shift for whole body counting.
A review of the records of these
whole
body counts,
which were subsequently
suppl-ied
on April 28,
1981
and later
calculations,
indicated that
no uptakes greater
than
5% of the allowable
quarterly uptake limits, specified in 10 CFR 20, Appendix B, Table I,
Column I were detected
(assuming all the activity was deposited
in
the lung).
~ ~
Procedure
RP-2, Radiation
Work Permit Procedure,
states
in Section
II.B.3, "A Radiation
Work Permit is required for all work involving
any of the following conditions...5)
Unknown condition in the
area to be entered..."
Procedure
RP-1,
Access
and Radiological Control, states
in Section
8.6, "Items negating
use of extended
RWP...c) Excessive
steam
or
water leakage
from contaminated
system (Potential
airborne hazard)."
The inspector's
review indicated that
on March
3 and 4,
1981, six
operations
personnel,
although uncertain of the radiation
dose rates,
entered
and worked in a posted
High Radiation Area which also contained
unknown airborne radioactivity concentrations
(due to leakage of
primary reactor coolant condensate)
without a valid Radiation
Work
Permit.
This constitutes
a violation of Technical Specifications
6. 11
(81-04-01).
4.
~Tnainin
The licensee
used
a series of videotapes
augmented
by lectures to meet
the training requirements
of 10 CFR 19. 12.
At the end of the training
session
a written examination
was given.
Individuals were required to
pass
the examination before they were allowed unescorted
access
to
radiologically controlled areas.
The licensee's
training program for contractor radiation protection
technicians
included training on selected
plant radiation protection
procedures
and site specific instrumentation.
Examinations,
both
written and oral, were given
on the material
covered.
Training records
and examinations
of 12 contractor radiation protection technicians
were reviewed.
No violations were identified.
5.
Plannin
and Pre aration
Increased Staffin
The inspector
examined the qualifications of 41 contractor
technicians
against
the criteria given in ANSI N18.1-1971 for technicians
in
responsible
positions.
Twenty-two technicians
met the criteria and
were classified
as senior technicians.
Nineteen did not have the
required
minimum experience
of 2 years.
These
personnel
were classified
as junior technicians.
The junior grade technicians
were
used primarily
as control point monitors
and did not independently
perform the duties
of a technician
in a responsible
position.
No violations were identified.
~ ~
Instruments
and
E ui ment
The licensee's
stock of anti-contamination
clothing at various
change
areas visited by the inspector
appeared
adequate.
The licensee
experienced
a heavy
demand
on protective clothing and respirators.
Three portable
dry cleaning units were obtained to handle clothing.
Respirators
were
cleaned
in the regular laundry area.
The inspector's
review indicated
a shortage
of hand held, ionization
type, radiation monitoring equipment.
Several
times the inspector
noted that instruments were,not available
and people
were waiting for
instruments to perform surveys before
a job could begin.
Licensee
representatives
stated
that additional instrumentation
had been ordered
as part of the Action Plan submitted
on 11/26/80
and delivery was
expected
in May, 1981.
This item will be examined further during
a
subsequent
inspection (81-04-02.)
No violations were identified.
Postin
and Control
Several
contaminated
areas,
radiation areas,
and
radioactive material
storage
areas
were examined against
the posting
requirements
and licensee
procedures.
The inspector
observed
the Drywell and Refueling Floor control points
for access
control,
adherence
to Radiation
Work Permit
(RWP) conditions,
contamination control
and exit procedures.
The inspector
noted that
the control point monitors checked
personnel
signing in on
RWPs and
maintained
exposure
control readings of persons
entering
and leaving
the area.
No violations were identified.
~Surve
s
10 CFR 20.201(b) requires that each licensee
shall
make or cause
to be
made
such surveys
as
may be necessary
for him to comply with the
regulations
in this part.
10 CFR 20. 103(a)(1) states:
"No licensee
shall
possess,
use or transfer licensed material
in such
a manner
as
to permit any individual in a restricted
area to inhale
a quantity of
radioactive material
in a period, of one calendar quarter greater
than
the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week
for. 13 weeks at uniform concentrations
of radioactive material in air
specified in Appendix B, Table I, Column 1."
As previously noted,
on Tuesday,
March 3,
1981, at about 10:00 p.m.,
operations
personnel
entered
the Reactor Building, 198'levation.
These individuals did not use respiratory protective equipment.
Upon
entry, they discovered
an area of unknown airborne radioactive material
4
concentration.
The leaking primary coolant
and associated
dissolved
gases
and
steam
caused
an airborne concentration
of radioactive material
which, because air samples
were not taken at the time,
was
unknown.
No surveys of airborne radioactive materials
were
made until the
inspector
requested
a survey (Radiation Survey
Log Sheet
50335) about
10:30 a.m.
on March 4,
1981, prior to his entry into the area,
when
the airborne concentration
was found to be
145 percent of that specified
in 10 CFR 20, Appendix B, Table
1,
Column 1.
The inspector verified that, with the exception of the air sample
he
requested,
no other measurements
of airborne radioactivity were performed
in direct support of this occurrence,
between
10:00 p.m.
on 3/3/81
and
10:00 a.m.
on 3/4/81.
The inspector
expressed
concern to licensee
representatives
about the
lack of radiological controls
by operations
personnel.
This failure
to adequately
survey constitutes
a violation of 10 CFR 20.201.
(81-
04-03)
Radioactive
and Contaminated
Material Control
The inspector observedthe
licensee's
control
and labeling of radioactive
material.
Contaminated
items and trash generated
from the outage
were
placed in black plastic
bags or wrapped,
then labeled "Radioactive
Material."
The inspector
observed,
on March 24,
1981, during
a tou} of the Turbine
Building, that door 140, which leads into the Radioactive
Haste Building,
had
a number of plastic bags filled with radioactive
waste that, if
left to accumulate,
could block the door. This door
was posted,
"Caution
Fire Door-Do Not Block."
This inspector notified a licensee
representative
of the conditions.
The area
was rechecked
on March 25,
1981.
The
bags of radioactive material
had
been
removed
from the door and
a
clear pathway
had been established.
Control of fire doors will be
examined further during
a subsequent
inspection.
(81-04-04)
No violations were identified.
Radiation Protection
Pro
ram
U
rade
In response
to Immediate Action Letter (IAL) 80-38,
issued
on October
10,
1980, to upgrade
the licensee's
Radiation Protection
Program,
an
Action Plan
was submitted to Region I on November 26,
1980.
The inspector
reviewed the following items, including commitment dates,
for actions
to be initiated or completed.
Item II.C. 1, "Training-Short Term" (due for completion
by February,
1981).
A vendor supplied
15-day cour se
on radiation protection
was presented
to all licensee
technicians
assigned
to the Chemistry
and Radiation
Management
Department
by February
13,
1981.
Item III.A.1, "Dosimetry Program."
The back-up Thermoluminscent
Dosimeter
(TLD) system
was to be replaced
by March 8,
1981.
This
action
was not completed
on schedule
because
the
new TLD reader
was found to be defective.
Replacement
electronic parts
were
on
order from the manufacturer.
The licensee's
evaluation or selection
of which type of TLD chip he will use will be reviewed during
a
subsequent
inspection.
Item III.B.l, "Dosimetry Program"
(due by March,
1981).
Procedures
are 'being prepared
by contractor personnel.
The schedule for
Whole Body Counting for station
personnel
has
been
completed.
Item III.C.1, "Respiratory Protection
Program Policy Statement,"
scheduled for implementation
by 1/81,
was not completed
as of
3/27/81.
This policy statement
is to be incorporated into procedure
APN-12.
On 3/27/81,
APN-12 was still in the draft. stage
and
had
not received
a corporate
review.
Completion is now projected for
April 30,
1982.
Item III.C.2,
Respiratory Protection Methodology." This item was
being performed
by contractor personnel.
Equipment to test
masks
and filters was ordered in March i1981.
Item III.D.l, "Self-Monitoring Program."
The evaluation
had been
completed
by a contractor
and
a procedure
was being developed to
address
documenting self-monitoring surveys.
Item III.D.2, "Dose Rate,
Contamination, Air Sampling Procedures."
A new procedure,
RP-3,
"Performance of Radiological
Surveys,"
was
being developed to address
the various types of surveys
and
methods
for documenting
them.
Two new low volume air samplers
had been
received
and were being used.
Fourteen
high volume air
samplers
had been
received'tem
III.D.3, "Survey Instrument Sensitivity."
An evaluation
had
been
made
and instrumentation
was
on order to provide increased
sensitivity 'ver previously used instruments.
Some delays
were
being experienced
in the receipt of some of these
instruments
from the manufacturers.
Item III.D.4, "Measurement
and Documentation."
This item will
also
be addressed
in Procedure
RP-3,
"Performance of Radiological
Surveys,"
which was under development.
Item VIII.B., "Exit Point Contamination Control."
The licensee
had installed
a more sensitive portal monitoring system at the
Security Building.
Electrical
problems
had been
experienced
with
the system.
Meetings
had
been held with the vendor
and electrical
contractor to resolve
these
problems,
but erratic operation
was
still being experienced.
~ t
Item VIII.D, "Audit of Adherence to Procedure,"
On February
13,
1981,
the licensee initiated an
RWP audit program using both
contractor
and licensee
personnel
to enforce
adherence
to Radiation
Protection
procedures.
The licensee
stated
the audit program was
proving to be successful
and was making workers
aware of the
requirement to follow procedures.
Followup- on the acceptability of the licensee's
response
to this
IAL will be performed during future inspections.
(81-04-05)
10.
Ins ectors Observations
Radiation
Surve
s
The inspector
noted that personal
contamination
incidents
documented
on
a radiation
survey log sheet
were generally lacking in detai l.
An incident was recorded
on survey
number 51618,
performed
on
March 24,
1981 at 3:30 a.m., of an individual who had facial
contamination of 4000 disintegrations
per minute (dpm) before
decontamination
and less
than
100
dpm after decontamination.
No
other information was provided.
The inspector could not determine
the exact location of the facial contamination,
the
RWP the
individual was working on, or if he
had
been wearing
a respirator.
A review of radiation survey log sheets
determined that
no nasal
smears
had
been
taken of this individual.,
The inspector discussed
this with a licensee's
representative
and
indicated the
need to document precisely
the location of contamination
found on individuals.
The licensee's
representative
acknowledged
the
need for better documentation
and indicated that
a procedure
was being developed
to address this condition.
This area will be
reviewed during
a subsequent
inspection (81-04-06).
Res irator
Protection
Pro
ram
The Respiratory Protection
Program of the licensee
was not in
full accord with Regulatory
Guide 8. 15'.4. g., Regulatory
Guide
8. 15 is incorporated
by reference
in licensee
procedures.
This guide
requires
"records sufficient to permit periodic evaluation of the
adequacy of the Respiratory Protection
Program
Section 12)."
Section
12.4. 1 states
in .part,
"The a'dequacy of the
respirator
program
can only be determined
by periodic, review of
respirator
usage,
including identification of the hazard,
specification
and use of the respirators,
and analysis of the results of bioassay
and air-sampling programs."
Documentation of individuals who use
respirator
protection @uipment including identification of the hazard
in which the respirators
were worn was not available during this
inspection.
This item is considered
unresolved.
(81-04-07)
~e
10
11.
Unresolved
Items
Unresolved
items are matters
about which more information is required
to determine
whether they are acceptable.
An unresolved
item is discussed
in paragra'ph
10 of this report.
12.
Exit Interview
The inspector -met with licensee
representatives
(denoted
in Paragraph
1) at the conclusion of the Inspection
on March 27,
1981.
The inspector
summarized
the purpose,
scope
and findings of the inspection
as contained
in this report.
0
Hl