ML17055D749
| ML17055D749 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/01/1988 |
| From: | Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055D747 | List: |
| References | |
| 50-220-88-04, 50-220-88-4, 50-410-88-05, 50-410-88-5, NUDOCS 8804120327 | |
| Download: ML17055D749 (34) | |
See also: IR 05000220/1988004
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
.50-220/88-04
50-410/88-05
Docket Nos.
50-220
50-410
License
Nos.
CPPR-12
Pri ori ty
Category
C
C
Licensee:
Nia ara
Mohawk Power
Com
an
301 Plainfield Road
S racuse
13212
Facility Name:
Nine Mile Point Units
1 and
2
Inspection At:
Scriba
Inspection
Conducted:
Februar
15-19
1988
Inspectors
Approved by:
R.
L. Nimitz, Senior Radiation Specialist
M.
M.
hanba y, Chief,
acilities
Radiation Protection
Section
date
date
Ins ection Summar:
Ins ection of Februar
15-19
1988.
Combined Ins ection
Re ort Nos.
50-220/88-04
50-410/88-05
radiological controls during the Unit
1 outage
and during routine operations
at
Unit 2.
Areas inspected
included:
organization
and staffing, training and
qualification,
ALARA, external
exposure control, internal
exposure control,
radioactive
and contaminated
material control, housekeeping,
and licensee
action
on previous 'inspection findings.
Results:
One violation was identified (fai lure to have approved
procedures
for
use of supplied-air
sand blasting
hoods; details
Section 7). Several
weaknesses
in the radiological controls program were also identified.
8804120327
880404
ADOCK 05000220
9
DETAILS
1.0
Individuals Contacted
~Ill
N
T. J. Perkins,
General
Superintendent
T.
Roman,
Superintendent,
Unit
1
C.
L. Stuart,
Superintendent,
Chemistry
and Radiation Protection
Management
P. Volza, Radiation Protection
Manager
R. Gerbig,
Radiation Protection Supervisor,
Unit
1
D. Barcomb,
Radiation Protection Supervisor,
Unit 2
E. Gordon, Supervisor,
Radiological
Support
K. Dohlberg, Site Superintendent,
Maintenance
P.
D. MacEwan,
New York State Electric and
Gas
P.
D. Eddy, Public Service
Commission
1.2
NRC
- M. Cook, Senior Resident
Inspector
- Denotes
those individuals attending
the exit meeting
on
February
19,
1988.
The inspector also contacted
other licensee
personnel.
2.0
Pur ose
and
Sco
e of Ins ection
This inspection
was
a routine radiological controls inspection during the
Unit
1 outage.
The following matters
were reviewed'.
Unit
1
licensee
action
on previous finding
organization
and staffing
training and qualification
external
exposure controls
internal
exposure controls
radioactive
and contaminated
material control
housekeeping
Unit 2
licensee
action
on previous inspection findings
external
exposure controls
radioactive
and contaminated
material control
housekeeping
3.0
Licensee Action on Previous
Findin
s
3.1
(Open) Violation (50-226/86-16-01)
Licensee did not p'erform radiological
surveys
in accordance
with
10 CFR 20 '01.
The licensee
responded
to the violation in a letter
(NPMIL0154) dated
Hay 19,
1987.
Review of licensee corrective
actions
occur red during combined Inspection
Nos. 50-220/87-17;
50-410/87-34.
Corrective actions
were completed with the exception
of two matters
which remained
open
as follows:
Item
1
Trainin
'
Training Modification Request
was issued
and implemented to
discuss
the incident
and its lessons
learned with site personnel
as
part of the General
Employee/Radiation
Protection Training Program.
~indincis
During this inspection,
the inspector
found that the licensee
incorporated
the findings into the specified training program.
This
item is closed.
Item 2
General
Pro rammatic
Im rovements
'mprove
management
assessment
and involvement in the Site Radiation
Protection
Program through formalized training and
on the job
evaluation of work in progress.
~Findin
s
Inspector review during this inspection
found that the licensee
pro-
vided
INPO Assessor
Training to Radiation Protection Supervisors
and
management.
The training was given to enhance
assessment
capabilities
of personnel.
However, inspector review and discussio'ns
with
cognizant
personnel
indicated
few entries into the Radiological
Control Area, particularly the Reactor Building, were
made
by
Radiation Protection
Supervisors
and management
to review ongoing
work.
This was based
on
a sampling of personnel
entries
made
by
personnel
in a two week period prior to the arrival of the inspector.
In addition, although the licensee
had obtained
"Assessors"
to be
.used to over'see
ongoing work activities, these individuals were
being
used to provide on-the-job training to contractor radiation
protection technicians
rather than performing their "Assessor's"
responsibilities.
The training of the contractors
was necessary
to
support the outage
which had started earlier than scheduled.
The inspector concluded that although assessment
training had
been
provided,
management
assessment
and involvement in the Site Radiation
3.2
Protection
Program through
on the job evaluation of work in progress
was in need of improvement.
This matter remains
open.
(Closed) Violation (50-220/87-17-01)
Licensee did not adhere
to the radiation protection
procedure for
performance
of airborne radioactivity intake assessment.
The
inspector
independently
reviewed implementation of the corrective
and preventive action documented
in the licensee's
November ll, 1987
letter (NPMlL0200) to NRC.
The licensee
implemented
the action
specified therein.
This item is closed.
3.3
(Closed)
Inspector
Fol low Item (50-220/84-14-02)
Licensee to evaluate
the performance characteristics
of'the Post
Accident Sample Station
atmosphere
sampling critical flow orifice and
containment
atmosphere
sample line heat tracing.
The licensee
developed
a performance
curve for the critical flow orifice.
The
curve was incorporated into appropriate
procedures.
= The licensee
evaluated
the containment
atmosphere
sample line heat trace
temperature
relative to design basis
containment
atmosphere,
temperatures
and humidities to be encountered.
The licensee
concluded
the heat trace temperature
was adequate.
This item is
closed.
3.5
(Closed)
Inspection
Fol low Item (50-220/84-14-08)
Licensee to evaluate alternate
means of sampling the stack effluent
in the event that the
RAGEMS monitoring system is partially or fully
The licensee
revised appropriate
procedures
to
incorporate alternative
means of sampling.
This item is closed.
(Open) Violation (50-220/86-16-03)
Licensee did not adhere
to high radiation area surveillance
requirements
specified'n
Technical Specifications.
The licensee
responded
to this violation in a letter (NMPlL-0154) dated
May 19,
1987.
The licensee's
response
stated,
in part, that "Radiation
Protection
procedures
were revised
and implemented to provide use of
additional
options (b and c) discussed
in Tech
Spec
6. 12. 1.
This
revision also required Radiation Protection Technicians
to alert
personnel
of the method of monitoring to be used
and to include
a
statement
of this method
on the. Radiation
Work Permit."
Inspector
review during combined Inspection
Nos. 50-220/87-17;
50-410/87-34
indicated the procedure
revision
had been
made.
However, the
procedures
did not adequately
describe
terms to be indicated in
Radiation
Work Permits to implement the surveillance
requirements
of
the Technical Specification (e.g.
What constitutes
"continuous
monitoring?" ).
Ins'pector review during this inspection indicated
a major revision to
the access
control procedure
had
been
made to provide clear guidance
for implementation of the Technical Specification high radiation area
surveillance requirements'owever,
the inspector
found that:
1) the
procedure
was not approved
and scheduled for implementation until
March 1,
1988;
2) numerous drywell radiation work permits did not
indicate
methods
to be used to implement the surveillance
requirements;
and 3) the Radiation Protection Supervisor did not have
a clear under-
standing of surveillance
methods
being
implemented.
Licensee
personnel
indicated the procedure
had been
scheduled
for
implementation
on March 1,
1988 but because
the-outage
was begun
early, the procedure
implementation,
including personnel
training,
had not yet been
completed.
The licensee
immediately initiated
action to approve
and implement the procedure,
train appropriate
personnel
on its requirements,
and revise applicable
Radiation
Work
Permits to clearly identify methods to implement high radiation area
surveillance.
This matter remains
open.
4.0
Or anization
and Staffin
The inspector
reviewed the staffing of the Radiological
Control
organization for Unit
1 and Unit 2.
The review was with respect
to
criteria contained
in applicable Technical Specifications.
Licensee
performance
in this area
was evaluated
by:
review of applicable
documents;
observation
of shift manning,
including backshifts;
and
discussions
with cognizant personnel.
Findin<is
Within the
scope of this review,
no violations were identified.
The
following observations
were
made:
The licensee is currently planning
a major reorganization
of the site
organization.
A transition organization will be implemented
in
approximately March,
1988.
5.0
Trainin
and
uglification
The inspector
reviewed the training and qualification of radiation
workers
and .selected
radiological controls personnel.
The review was
with respect to criteria contained
in Technical Specifications,
licensee
procedures
and
10 CFR 19. 12, "Instruction to Workers."
Evaluation of licensee
performance
in the ar'ea
was based
on:
verification of training completion
by selected
radiation workers
verification of completion of training by technicians
performing
responsible
oversight of ongoing radiological work activities.
~Findin
s
Within the
scope of this review,
no violations were identified.
Personnel
were found to have received appropriate training and were
qualified for their assigned
duties.
Radiation workers were found to have received appropriate
general
employee radiation safety training.
Within the
scope of the review, the following observation
was made:
The licensee
enhanced
his General
Employee Training program to include
training
on the radiological
hazards
of hot particles.
6.0
External
Ex osure Control
The inspector
reviewed the adequacy
and effectiveness
of selected
aspects
of the External
Exposure Control
Program.
The review was with respect
to
criteria contained
in applicable
licensee
procedures,
Technical
Specifications,
and regulatory requirements.
The following matters
were reviewed:
generation
and
use of appropriate
Radiation
Work Permits for
radiological work
'erformance
and documentation
of radiological
surveys to pre-plan
and
support ongoing work
use
and placement of appropriate
personnel
dosimetry devices
use of calibrated
and checked radiation
survey equipment
'osting
and barricading of radiation
access
control to high radiation areas.
Evaluation of licensee
performance
in the area
was based
on:
performance
of independent
radiation surveys
by the inspector during
plant tours
'bservation
of ongoing work activities including control
rod drive
removal operations,
turbine work, and initial dry well entry
~ independent verification of access
control to selected
high radiation
areas
performance
of independent
key audits
by the
inspector
Within the
scope of the review,
no violation was identified.
Radiological
surveys
were considered
adequate
to support pre-planning
of. work and
selection of radiological controls.
Posting of, barricading of, and access
control (as appropriate)
to radiation
were in
accordance
with applicable
requirements.
Radiation'urvey
instrumentation
was found to be calibrated
and checked prior to use.
The following observations
were discussed
with licensee
personnel:
A senior radiation protection technician
improperly placed dosimetry
on
two individuals preparing to perform inspection of the reactor vessel
support skirt.
Although the Radiation
Work Permit specified that the
dosimetry was to be placed
on the head of workers,
the technician left the
TLD badges
on the chest of the workers
and taped the pocket dosimeter to
the head.
Since the
TLD badge is the monitoring device of record, it was
to have
been
placed
on the head.
The technician
immediately corrected
the
placement
when the error was brought to his attention.
This indicates
a
lack of understanding
of dosimetry placement
requirements
in dose gradient
areas'.
The licensee initiated
a review of the matter.
'n outdated
key inventory list was found attached,
as
an operator aid, to the key locker located in the Unit
1 Control
Room.
The inventory did not reflect the actual
number of keys in the locker.
Inspector
review indicated all keys were present
and accounted for based
'on an inventory check against
the proper
key inventory list.
The
operator aid was
removed
and
a licensee
review initiated.
7.0
Internal
Ex osure Control
The inspector
reviewed the adequacy
and effectiveness
of selected
aspects
of the internal
exposure
control
program.
The review was with respect
to
criteria contained
in applicable
licensee
procedures
and regulatory
requirements.
The following matters
were reviewed:
performance,
documentation,
and
use of appropriate
pre-job and ongoing
work airborne radioactivity surveys to establish
appropriate
radiological
controls for work
o'.use of appropriate
engineering
controls to reduce potential
levels of
airborne radioactivity to precl.ude
use of respiratory protection
equipment
selection
and
use of appropriate
respiratory protection
equipment
when
'needed
including the training and qualification of personnel
authorized
use of such equipment
o'control
and issuance
of respiratory protection
equipment
whole body counting
and internal
exposure
assessment.
The evaluation of licensee
performance
in the area
was based
on:
'ndependent
review and observation
of ongoing work
review of documentation
'iscussions
with cognizant personnel.
Within the
scope of this review, the following apparent violation was
identified:
The licensee
has constructed
an enclosure
on the Unit
1 turbine deck in
which the turbine rotors are
sand blasted.
The enclosure
acts
as
an
engineering'ontrol
to minimize general
area airborne radioactivity on the
turbine deck.
Workers in the enclosure
wear supplied air sand blasting
hoods (Bullard 77/46 series)
when
sand blasting the rotors.
Since airborne
radioactivity levels inside the tent have
exceeded
200xMPC during sand
blasting operations,
the licensee
is making allowance for use of the
hoods
in controlling and assessing
airborne, radioactivity intake
by personnel.
During review of the operation
on February
17,
1988,
the inspector
noted
the following:
'here
were
no licensee
approved
procedures
for use of the equipment.
Procedures
had apparently
been
generated
several
years
ago, but were
apparently deleted.
'he licensee's
Respiratory Protection Coordinator
was unable to provide
the inspector
a detailed
documented
description of the hoods
and breathing
air lines to demonstrate
that the
as installed configuration was consistent
with applicable
10 CFR Part 20 requirements.
'ubsequent
inspector
review indicated the breathing air lines,
suppling air
to the workers
sand blasting,
were modified by addition of pipe couplings
and fittings not referenced
or described
in the
NIOSH/MSHA approved parts
list (No. TC-19C-84).
The inspector
noted that the installed configuration did not appear to
affect the adequacy
of air supplied to the workers.
However,
the lack of
approved
licensee
procedures
did not ensure
adequate
administrative control
over the
use of the
system which includes
system installation
and
modification.
The inspector
noted that Technical Specification
6. 11 requires that
procedures
for personnel
radiation protection
be prepared
consistent with
the requirements
of 10 CFR 20 and
be approved,
maintained,
and adhered
to.
The failure to have
approved
procedures
for use of the air supplied
sand
blasting
hoods is an apparent violation of Technical Specification
6. 11
(50-220/88-04-01).
The licensee
immediately halted the
sand blasting work and initiated
action to establish
and approve
procedures.
Within the
scope of the review, the fol,lowing observations
were
made
and
discussed
with licensee
personnel:
Some personnel
working under the Unit
1 reactor vessel
(e.g.
Control
Rod
Drive removal workers)
used supplied-air respirators.
The breathing
airlines to the workers were not adequately
protected
from internal
contamination.
The inspector
observed
unprotected airline fittings on
February
16;
1988.
Subsequent
licensee
contamination
checks of the inside
of the fittings indicated
up to 8,000
dpm of removable activity.
The
licensee
immediately
suspended
the work and whole body counted all
individuals who may have
used
the hoses.
Independent
inspector
review of whole body count results did not indicate
any intake of radioactive material.
The licensee initiated action to
decontaminate
or replace
the breathing
airlines'he
licensee
has constructed
a sand blasting tent (discussed
above)
on the
Unit
1 Turbine Deck.
Sand blast residue
in the tent is vented to
a dust
collecter located outside the tent.
The dust collecter is subsequently
vented to
a
HEPA ventilation system.
On February
17,
1988,
the inspector
found the
hose
leading
from the dust collecter to the
HEPA ventilation
system to be disconnected
thereby rendering
the
Inspector
,review indicated the following:
r
The hose
leading to the
HEPA system
had been poorly attached with duct
tape.
No procedures
or guidance
was in-place regarding periodic verification of
proper operation of engineering
controls to reduce airborne radioactivity
concentrations.
The dust collector vented to the general
area
where other
personnel
were
working.
" Although
a small
HEPA system
was installed
on the vent of the
dust collecter,
no equipment (e.g.
a magnahelic)
was installed to
determine if the
HEPA filter was intact.
- The licensee
did not have
any continuous air monitors (cams) in the area
to alert personnel
of unexpected
airborne radioactivity concentrations.
The licensee
immediately stopped
the
sand blasting in the tent
and re-attached
the
HEPA filter system to the dust collector.
A grab air sample in the
area indicated
about
23% of MPC.
Personnel
in the area
were whole body
counted.
No intakes of airborne radioactive material
was identified.
10
The inspector
noted several
examples of personnel
wearing respiratory
protection
equipment
draped
about their
necks while in a contaminated
area,
which may result in internal contamination of the respirator.
The licensee initiated
a review of this matter.
8.0
The inspector
reviewed the adequacy
and effectiveness
of selected
aspects
of the
ALARA Program.
Particular
emphasis
was placed
on review of
ongoing work.
The review was with respect
to criteria contained
in
.
applicable
licensee
procedures
and regulatory guidance.
Evaluation of'icensee
performance
in the area
was based
on review of
ongoing work, discussions
with cognizant personnel,
and review of
documentation.
~Findin
s
--'ithin the
scope of this review, the following observations
were
made
and discussed
with licensee
personnel.
I
'ecause
of facility design,
Unit
1 Control
Rod Drive (CRD) operations
(e.g. flushing, disassembly,
inspection
and storage)
are performed in the
hallways of the 237'levation of the Reactor Building.
A personnel
walkway is located
between
the
CRD storage
rack and
CRO disassembly
table.
Measured
dose
rates
in the walkway ranged
up to 30 mR/hr.
On
February
16,
1988,
the inspector
observed
workers working on accumulator
valves
near the flange
end of the storage
rack in up to 10mR/hr radiation
fields.
Also, the workers periodically walked through the walkway
between
the storage
rack and disassembly
table to get to the
This was considered
a poor practice
since
an area with
dose rates
in the order of 1mR/hr was in close proximity to the
The inspector
informed
a Radi'ation Protection
Supervisor
in the area
who immediately requested
the workers to move their work
table to the
low dose rate area.
The inspector
observed Unit
1 Control
Rod Drive (CRD) Removal Operation
at about
10:00 p.m.
on February
17,
1988.
The following observations
were made:
- Workers experienced difficulty in removing the selected
CRD.
The
CRD would not align properly on the
CRD elevator.
Also,
an
electrical malfunction resulted
in abandonment
of efforts to lift
and
remove the drive.
The inspector
noted personnel
repeatedly
attempting to correct the problems while working in an approximately
100 mR/hr radiation field.
Inspector discussions
with maintenance
personnel
indicated the removal
equipment
was old and subject to
some failures.
Licensee
personnel
indicated
new
CRD removal
equipment
was being evaluated.
0
11
- While the workers discussed
above
were attempting to remove the
drive, several
other workers were waiting inside the drywell but
outside
the biological shield with a
CRD cart to accept
the drive
and transport it outside
the drywell.
The workers were waiting in
an 80-100 mR/hr radiation field.
The inspector
noted that
an
extensive
array of television
cameras
was positioned outside the
drywell in a low dose rate
area
which clearly
showed
ongoing
work.
The inspector
concluded
the television
cameras
were not
effectively utilized to dispatch workers for CRD work.
The inspector
discussed
the waiting with a Radiation Protection
Foreman in the area
who immediately removed
the waiting workers.
The inspector
discussed
these
observations
with 'licensee
personnel
and
indicated these
observations
indicated
a lack of sensitivity to
unnecessarily
working or waiting in radiation fields by both workers
and
radiation protection personnel.'
The licensee
has elected
to perform work in the drywell by working multiple
jobs in the drywell in one area (i.e. quadrants).
This, according to
licensee
personnel,
allows for i~proved radiation protection
coverage
of
the work and
improve'd ALARA planning.
Inspector discussions
with ALARA
personnel
indicates
some difficulty was being'xperienced
with performing
ongoing job reviews in that the
ALARA Program
was not well defined to
provide for ongoing job reviews.
The licensee
was,
however,
able to
provide
an estimate
of ALARA performance after reviewing work status
and
accumulated
exposure.
'nspector
review of the
1986 Post Outage
ALARA Review Report for Control
Rod Drive Removal
indicated
a major finding was
a need for improved
training of workers
removing drives.
Inspector
review indicated planned
training for workers pulling drives for 'the
1988 Unit
1 outage
was
cancelled.
Inspector
review indicated principal training was by'working
with experienced
workers under the reactor vessel.
The inspector
considered this method of training not optimum because:
1) the attention
of the experienced
worker was directed to the inexperienced
workers
and
2) the on-the-job training was performed in radiation fields
up to
200mR/hr.
The licensee
does not have
a realistic under vessel
mock-up for
training workers in control rod drive removal.
9.0
Radioactive
and Contaminated
Material Control
The inspector
reviewed licensee
radioactive
and contaminated
material
control.
The review was with respect
to criteria contained
in applicable
licensee
procedures
and regulatory requirements.
Evaluation of licensee
performance
in the area
was based
on review of
ongoing work, review of material
labeling
and discussion with
personnel.
~Findin
s
12
Within the
scope of this review,
no violations were identified.
Posting,
labeling,
and control of radioactive
and contaminated
material
was in
accordance
with regulatory requirements.
Within the
scope of this review, the following observation
was
made
and
discussed
with licensee
personnel:
The licensee
has designated
a major portion of the 237'levation of the
Unit I Reactor Building as
a Contaminated
Area.
Entry can
be
made into
and out of the drywell on the 237'levation.
Although contamination
.levels
on the 237'levation
are kept low by decontamination,
levels
increase
as
a result of personnel
exiting from the drywell during control
rod drive work.
Surveys indicate the presence
of hot particles
on the
elevation.
The inspector indicated aggressive
controls to preclude
tracking of high level contamination
out of the drywell do not appear to
be in place.
A step-off pad is used
by personnel
exiting with plastic
suits
who worked under the vessel.
However, the inspector
observed
personnel
walking out of the drywell across
the step-off pad while
personnel
were removing plastic suits.
The licensee
indicated this matter
would be reviewed.
The licensee
indicated facility design precluded effective cost-beneficial
ALARA contamination controls
on the elevation.
The inspector indicated
this area will be reviewed during subsequent
inspection.
10.0 Personnel
Contamination
Control
10.1 General
The inspector
reviewed selected
aspects
of the licensee's
personnel
contamination
control program.
The following matters
were
reviewed:
~ calibration
and
use of portal monitors
'ersonnel
frisking practices
'ot particle control.
Evaluation of licensee
performance
in the area
was based
on review
of ongoin'g work, discussion with personnel,
and review of
documentation.
Within the
scope of this review no violations were identified.
The
following observations
were
made
and discussed
with licensee
personnel:
~ The licensee
corrected
the portal monitor calibration
and procedural
deficiencies identified during an inspection
conducted
in
January,
2987 (Combined Inspection
Report Nos. 50-220/87-02;
'0-410/87-04).
13
The licensee
is modifying the Unit
1 access
control point to provide
for installation of several
highly sensitive portal monitors.
'ersonnel
appeared
to be performing adequate
frisking with hand held
probes
and properly using the stand-up
whole body friskers.
'ersonnel
exiting the Unit
1 drywell were being provided liquids to
replenish
body fluids lost while working in bubble
hoods.
Although
the individuals removed their protective clothing and frisked prior
to drinking the liquids, the individuals intermingled with individuals
who had not frisked.
In addition,
the drinking of the liquids was
not in conformance with hand written guidance
provided in that:
1) the
drinking was not confined to the change
area
and 2) the drinking was
not under the control of radiation protection supervision.
No
radiation protection supervisor
was in the area.
The licensee
revised the guidance to provide instructions to
Technicians
in the area
regarding
intake of fluids.
The practice of intermingling was permitted.
This was considered
a
poor practice.
10.2 Hot Particle
Ex osure
The inspector
reviewed the circumstances,
licensee
evaluations
and
corrective actions for a personnel
contamination
event
by a hot
particle which occurred
on December
22,
1987.
~findin
s
Within the
scope of the review, the following was identified:
As three individuals were exiting the portal monitor at the Hain
Gate about
12 noon
on December
22,
1987,
one of the individuals
alarmed
the portal monitor.
The three individuals were directed to
pass
again through the monitors.
No alarm was encountered.
The
individuals left for lunch.
\\
The indiVidual (Individual A) who'was .later
found to have
a hot
particle
on his body returned to work on the 340'levation of the
reactor building.
The individual worked
on the
new and old Unit
1
Refueling Bridge that morning.
The individual did not use
a whole
body stand
up frisker, but rather
used
a hand held frisker prior to
exiting the plant.
The individual exited the 340'levation at about 4:30 p.m. that
afternoon
and subsequently
alarmed
the whole body "friskall" at the
261'levation of the reactor building.
The individual's underwear
(left hip) was
found to be contaminated.
Contamination
levels
ranged
from 12,000
cpm to 18,000
cpm.
A dose evaluation
was
performed at that time which indicated
120 mrem to the skin.
The
14
individual was re-frisked
and allowed to exit the radiological
controlled area
(RCA).
The dose evaluation
was transmitted to the
Radiological
Engineering
Group for review.
The Radiation
Work
Permit (¹3978)
was revised to require all personnel
working on the
340'levation of the Reactor Building to use the whole body
frisker:
The individual re-entered
the
RCA the following day (12/23/87) to
continue work on the 340'levation of the Reactor Building.
't about 9:00 a.m.
(12/23/87) the Radiological
Engineering
Group
found that the initial skin dose calculation
(120 mrem) was in
error.
The actual
value was about 7. 1 rem.
The technician
performing the calculation
had used incorrect conversion factors.
Radiological
Engineering
Supervision
was notified who immediately
removed the individual from the
RCA.
The individual was restricted
from receiving
any more exposure
the remainder of the calendar
quarter.
The licensee initiated the following action:
A complete
survey of the 340'levation of Reactor Building was
conducted.
No particles
were found.
- A time and motion study was conducted for the individual.
Total skin dose
received
was calculated to'be 7.263
rem.
No
occurred.
All work on the 340'levation
was
suspended.
- The licensee
revised the applicable radiation work permit to
incorporate additional controls to minimize exposure to hot
par ticles.
Conclusion
Inspector review indicated the licensee
took appropriate
action to
minimize personnel
exposure
to hot particles
on the 340'levation
of the Reactor Building and control further exposure to the
individual once it was recognized that the individual had received
a
substantially
higher
skin dose.
The inspector also independently
evaluated
the skin'dose
calculation
and determined it to be reasonable.
Inspector observations
indicate the licensee
had designated
certain
plant areas
as hot particle areas
and placed additional controls
on
Radiation
Work Permits for entry into these
areas.
The following matters
are considered
unresolved
pending further
inspector
review.'
15
'he technician
who performed the original skin dose calculation
(120
mrem)
made
an error which allowed
an individual to re-enter
the
radiological controlled area with an unrecognized
skin dose of about
7.237
rem.
The quarterly skin dose limit is 7.5 rem.
The individual's
allowable remaining whole body dose
was about
900 mrem.
Licensee
corrective action to preclude
recurrence will be reviewed during
a
subsequent
inspection.
'he
licensee
had previously experienced
hot particle problems
on the
340'levation of the Reactor Building.
-It was not apparent
why more
aggressive
controls were not, in place to prevent the event.
'he licensee's
evaluation detailed
numerous
long-term corrective
actions to prevent recurrence.
These will be reviewed du~ing
a
subsequent
inspection.
The above matters
are unresolved
(50-220/88-04-02).
~H
The inspector
reviewed housekeeping
during plant tours of Unit
1 and
Unit 2.
No significant housekeeping
concerns
were identified in Unit 2 or the general
access
areas
of Unit 1.
However,
several
contaminated
areas
in Unit
1
were considered
in need of housekeeping
improvements
and were brought to
the licensee's
attention.
The 'following was noted:
'rotective clothing was piled up about
1', foot high inside the Reactor
Building Closed
Loop Cooling Cubicle (261'levation
Reactor Building).
The clothing was acting
as
a
dam to prevent water from running out the
door.
The inspector
observed
the clothing in the area for at least three
days.
'he inspector
observed
numerous
hoses
entering
and exiting the Unit
1
drywell,
Hoses of different colors
and sizes
were connected
together.
The control of hoses
was considered
poor.
'ubstantial
quantities of graffiti wert found at the Unit
1 drywell
entrance.
Graffiti was also observed
inside the drywell and in station
elevators.
It was evident that
some of the graffiti was placed
on walls
in radiation areas
indicating lack of awareness
of ALARA.
'he inspector
observed
pieces of unprotected
lumber (for fire protection
purposes)
on February
17,
1988,
on the 340'levation Unit
1 Refueling
Floor.
The lumber was
removed.
The
NRC Resident
Inspector indicated
that
he will followup on this matter.
12.0 Dr well Entr
Controls
.
'
16
The inspector
reviewed licensee controls for entry into the Unit
1 and
Unit 2 Drywel 1 during fuel movement.
The review was with respect
to
criteria contained
in the following:
General Electric Operating
Experience
Report
No. 78, Radiation
Levels and
Shielding
Recommendations
for the Upper Drywel 1 Area During Fuel Transfer
General Electric Service Information Letter No. 354, Potential
Radiation
Levels in Upper Drywel 1 Areas
Dur ing Fuel
Movement
Procedure
S-RP-l,
Access
and Radiological
Controls
Procedure
Nl-FHP-27, Whole Core Off Load - Reload
Procedure
Nl-FHP-25, General
Description of Fuel
Moves
Procedure
Nl-OP-34, Refueling Procedure
Procedure
N2-FHP-12,
General
Description of Fuel
Moves
Procedure
N2-0P-39,
Fuel Handliag
and Reactor Service
Equipment
Evaluation of licensee
performance
in this area
was based
on discussions
with personnel,
review of documentation
and tours of accessible
areas
of the drywell.
~Findin
s
The licensee
is aware of the potential for high dose rates
in the drywel 1
during fuel movement.
Specific instructions
have
been
included in the
procedures
to install special
shielding prior to fuel movement.
Access
control procedures
provide for padlocking the access
points to the upper
el evati ons of the drywel 1 s pr ior to fuel movement.
The licensee
also
installed area radiation monitors in the drywell s when workers are working
in the drywel 1 s.
Although personnel
are not provided specific instructions
in Radiation Worker Training about potential
high dose during fuel
movement,
they are informed to evacuate
the drywel 1 in the event of any
type of alarm (e.g.
area radiation monitor alarm).
Within the
scope of this review, the following matters
were discussed
with the licensee
as areas for potential
improvement:
Procedures
do not provide specific guidance
regardin'g maintaining
spent
fuel
away from wall surfaces
during transfer.
Licensee
personnel
indicated the access
control requirements
of procedures
preclude
access
to upper elevation during fuel movement.
The licensee
was unable to provide specific information regarding Unit
1
fuel transfer shielding bridge shield thickness.
The licensee
however
has not encountered
any significant dose rates
in the drywell lower
elevatipns
during fuel movement.
'
17
0 Procedures
did not ensure/require
communication
between refueling
personnel
and radiation protection personnel
during fuel movement.
The licensee
revised procedures
to address this matter.
~ Licensee
surveillance
requirements
did not provi'de for periodic
verification of drywell area radiation monitor alarm set points.
The licensee initiated review of this matter.
The inspector
met with licensee
representative
(denoted
in Section
1 of
the report) at the conclusion of the inspection
on February
19,
1988.
The inspection
summarized
the purpose,
scope
and findings of the
inspection.