ML17055E496
| ML17055E496 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/01/1989 |
| From: | Geyer A, Loesch R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055E494 | List: |
| References | |
| 50-220-89-03, 50-220-89-3, 50-410-89-02, 50-410-89-2, NUDOCS 8902070335 | |
| Download: ML17055E496 (18) | |
See also: IR 05000220/1989003
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
50-220/89-03
Report
No.
50-410 89-02
Docket No.
License
No,
Licensee:
50-220
50-410
NPF-54
Priority
Nia ara
Mohawk Power Cor oration
rie
ou evar
es
racuse
ew
or
Category
Facility Name:
Nine Mile Point Units
1 and
2.
Inspection At:
Oswe
o
Inspection
Conducted:
Januar
9-13
1989
Inspectors:
. oesc
,
a ia ion
pecia is
a
e
. eyer,
a ia ion
pecia is
a
e
Approved by:
an
a y,
ie
,
a
>>es
a ia ion
Protection Section
a
e
Inspection
Summary:
Ins ection conducted
on Januar
9-13
1989
Combined
Ins ection
Re ort Nos.
Areas
Ins ected:
Routine,
unannounced
Radiological Controls Inspection at Units
an
.
reas
reviewed included previously identified items,
management
and
supervisory controls,
ALARA, internal
and external
exposure controls,
and
allegation followup.
Results:
Two violations were identified:
1) T.S. 6. 12.2, failure to lock a High
Faa7~a
ion Area (see Section 7.0),
and 2) T.S. 6. 11, failure to follow procedures
(see Section 8.0).
No Notice of Violation will be issued for the second
violation in accordance
with the Commission's
new policy statement
on
(53 FR 40019) .
8902070335
890202
ADOCK 05000220
Q
PNU
i
1.0
Individuals Contacted
~Ill
Mh
k
DETAILS
J.
Wi 1 1 i s
M. Falise
R.
Remus
K. Dahlberg
R. Abbott
N. Rademacher
P. Volza
E.
Gordon
J.
Gray
D. Barcomb
B. Tomson
1.2
Others
General
Station Superintendent
Superintendent,
Maintenance
Superintendent,
Chemistry
and Radiation
Management
Station Superintendent,
Unit
1
Station Superintendent,
Unit 2
Director, Regulatory
Compliance
Radiation Protection
Manager
Supervisor,
Radiological
Support
Radiation Protection Supervisor,
Unit
1
Radiation Protection Supervisor,
Unit 2
Training Supervisor
P.
HacEwan
New York State Electric and
Gas
The above individuals attended
the exit meeting
on January
13,
1989.
The inspector also contacted
other licensee
personnel
during the course of
this inspection.
2.0
Pur ose
and
Sco
e of Ins ection
This inspection
was
a routine,
unannounced
Radiological Controls inspection
of Units
1 and 2.
The following areas
were reviewed:
- Previously identified ite'ms;
- Management
and supervisory controls;
- ALARA;
- Internal
exposure controls;
- External
exposure controls;
and
- Allegation followup.
3.0
Previousl
Identified Items
3.1
(Closed)
Inspector Follow Item (50-410/88-12-01):
Turbine
LHRA controls.
The licensee
has installed
an enclosure
("appearance
lagging" ) around the
High Pressure
Turbine which encompasses
those
areas
greater
than
1000
mr/hr.
The door on the enclosure
is controlled
as
a locked high radiation
area.
Normal
access
to the turbine area
has
been
downgraded
to
a high
radiation
area
(greater
than
100 mr/hr but less
than
1000 mr/hr). This item
is closed.
3.2
3.3
3.4
3.5
4.0
(Closed) Violation (50-220/86-16-03):
Licensee did not adhere
to high
radiation
area surveillance
requirements.
Licensee corrective actions
were
reviewed in Combined Inspection
Reports
Nos. 50-220/88-04;
50-410/88-05.
All items were complete except for the formal issuance
and training
on the
revised
RWP procedure.
Procedure
No. S-RP-2,
Rev.
10, "Radiation Work Permit Procedure",
was
formally approved
and issued
March 1,
1988.
Inspector review of the
Traininq Lecture Attendance
Reports
indicated that personnel
training on
the revised
procedure
was completed
March 4,
1988.
This item is closed.
Closed)
Unresolved
(50-220/84-22-01):
Review licensee
actions
on audit
~
~
indings.
Licensee
actions
were reviewed in Inspection
Report
No.
50-220/85-18.
The licensee
was unable at that time to provide closure
summaries for audit findings in the -area of radiological controls training
and qualifications.
Inspector review of finding closure
summaries
indicated
adequate
basis
was
being provided for closure of audit findings. Closure
summaries
for
radiological controls training and qualifications were reviewed
and found
adequate.
This item is closed.
(Closed) Violation (50-220/86-16-04):
Licensee did not perform surveys
in
accordance
with 10 CFR 20.201.
Review of licensee corrective actions
was
performed in Combined Inspection
Report Nos. 50-220/88-04;
50-410/88-05.
Corrective actions
had
been
completed
except for improving management
asses'sment
and involvement in .the Site Radiation Protection
Program.
Licensee
management
has
implemented additional
inspections
to improve
assessment
and involvement in the Site Radiation Protection
Program.
(See
section 4.0 of this report). This'tem is closed.
(Closed) Violation (50-220/88-04-01):
Violation of TS 6. 11, workers using
supplied air hoods
(sandblasting)
with no approved
procedures
for use or
maintenance.
The inspector
reviewed the implementation of corrective
and preventive
actions
documented
in the licensee's
May 9,
1988 letter
(NMP34064).
The
licensee
had
implemented the actions
as specified.
This item is closed.
Mana ement
and
Su ervisor
Controls
The inspector
reviewed
management
and supervisory controls
and oversight
for Units
1 and 2.
This review was with respect
to criteria in applicable
Technical Specifications,
licensee
procedures
and licensee
commitments.
Evaluation of licensee
performance
in this area
was
based
on:
- review of applicable
documents;
- observations
of work in progress;
and'
discussions
with cognizant personnel.
jl
5.0
Within the scope of this review,
no violations were identified.
The
following observations
were made:
'- The position of Superintendent,
Chemistry
and Radiation
Management,
has
recently
been filled by an individual
on loan from INPO.
The position
was vacated
in early
1988
and abolished
in the recent site
reorganization.
The licensee
stated that the recent reinstatement
of the
Superintendent's
position
was temporary
(15 to 24 months) with the
objective of further strengthening
the overall Health Physics
and
Chemistry programs.
Progress
in this area will be reviewed in a
subsequent
inspection.
- The licensee
is currently in the process of developing
and implementing
a
new Radiological
Performance
Program.
An evaluation of past
performance
and
INPO recommendations
has identified multiple areas of interest for
which indicators
and goals
have
been developed.
The current performance
monitoring reports
are to be revised to better assist
management
in
evaluating
the progress of the overall
program.
In addition to current
routine site management
and supervisory tours,
a Radiological
Inspection
Program utilizing a Radiological
Performance
Observation
Checklist
has
been
instituted
on
a trial basis.
The licehsee
stated that plans
are for this
checklist to be used
by all plant personnel
during routine plant
inspections
to document radiological observations.
- Discussions
with workers
and inspector review of security
access
logs for
the Units
1 and
2 Reactor Buildings indicated
adequate
oversight of work
at the supervisory level.
However, the security logs also indicated that
over the four month period prior to the inspection,
Radiation Protection
(RP) management
had infrequently entered
the Reactor Buildings,
indicating that increased
oversight
by
RP management
may be warranted.
The inspector
reviewed the adequacy
and effectiveness
of- selected
aspects
of the
ALARA program.
Particular
emphasis
was placed
on recent site
exposure
performance
and future goals.
The review was with respect
to
criteria contained
in applicable licensee
procedures
and regulatory
,guidance.
Evaluation of licensee
performance
in this area
was
based
on review of
on-going work, discussions
with cognizant personnel,
and review of
documentation.
Within the scope of this review,
no violations were identified.
The
following observations
were made:
0
- The licensee
has
made several
improvements
to the site
ALARA program
which included:
-
a Corporate
Health Physics position dedicated
to ALARA;
- software
changes
to the
REHS computer
system;
- ALARA hold-points
on jobs not requiring
ALARA reviews;
- - reduction in the use of miscellaneous
RWPs;
and
- increased
participation
by individual departments
in the
formulation of plant exposure
goals.
- Inspector review of recently completed jobs indicated .that appropriate
ALARA reviews
and sufficient on-the-job
ALARA oversight
was being
performed.
- The 1989 Unit
1 goal
was set using
a new approach.
Each department
was
provided with their own historical
exposure
information.
From this data,
they were requested
to supply action plans for reducing
exposures
and
goals
based
upon
a
10% reduction.
Departmental
goals were reviewed
and
approved
by the site
ALARA committee.
The Unit
1 goal
was aggressively
set at 509 man-rem which was
based
upon the following assumptions:
- six months of outage
and six months of normal operation;
- six months of fuel pool clean-up;
- clean out of Flatbed Filter room, Centrifuge
room and Clean-up
Sludge
Tank room;
and
- the
complementation
of a decontaminati'on
program to reduce
contaminated floor space to less
than
10% of the total area.
- The
1989 Unit 2 goal
was
based
upon
INPO's historical data
on first year
BWR's
(NOTE:
INPO refers to the initial year
as the startup year
and the
second year
as the first full power year).
The average first year
exposure with no refueling is
184 man-rem.
The'licensee
reduced this
number
by 20%.
An additional
15% reduction
was anticipated for
improvements
in operation
based
upon optimizing the number of operator
rounds,
improved performance
in 1988
and the installation of a new video-
surveillance
system.
The
1989 goal is 128 man-rem
and compares
favorably
with INPO's best
BWR non-refueling first year for similarly designed
plants of 134 man-rem.
6.0
Internal
Ex osure Controls
The inspector
reviewed the adequacy
and effectiveness
of selected
aspects
of the internal
exposure control program.
The review focused primarily on
licensee
actions
subsequent
to the hot particle ingestion incident of
July 21,
1988.
The review was with respect
to criteria contained
in
applicable licensee
procedures
and regulatory requirements.
Within the scope of this review,
no violations were identified.
The inspector
reviewed the final analysis
and dosimetry calculations
related to the hot particle ingestion
on July 21,
1988.
The following
observations
were made:
7.0
- An analysis of the bioassay
(fecal)
sample
by Teledyne
Isotopes
indicated
approximately
1020 nCi of Co-60.
Since the analysis
was performed without
separating
the particle from the bulk fecal material,
geometry errors
would make the reported activity less
accurate
than if the particle
had
been isolated prior to analysis.
- A detailed analysis
was subsequently
performed
by Battelle Northwest
Labs.
Results verified
a discrete particle approximately
10 by 30 by 20
microns in dimension.
The particle was determined
to be pure Co-60 with
an activity of 563 nCi with an additional
100 nCi in the remaining fecal
material.
- Calculations
performed
by the licensee
indicated
an equivalent
exposure
of approximately
4 HPC-hours
based
upon the most conservative activity
measurements.
The licensee
stated that since the Gastrointestinal
tract
was the critical organ rather than the lung, it was
more appropriate
to
base
exposure
calculations
on the
HPC for insoluble Co-60 specified
in
ICRP-2 rather than
10 CFR 20, Appendix B, which assumes
the lung is the
critical organ.
Inspector review indicated the licensee
took appropriate
actions
subsequent
to the hot particle incident.
In addition, the inspector
independently
evaluated
the exposure calculations
and determined
them to be reasonable.
External
Ex osure Controls
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 aspects
of the program were reviewed:
- generation
and
use of Radiation
Work Permits;
- use of calibrated radiation survey instruments;
- posting
and barricading of radiation
and high radiation areas;
and
- access
control to high radiation areas.
Evaluation of licensee
performance
in this area
was
based
on:
- independent
radiation surveys
by the inspector during plant tours;
- review of Radiation
Work Permits
and associated
surveys;
- discussions
with cognizant personnel;
and
- .review of appropriate
documentation.
Within the scope of this review, the following apparent violation was
identified:
- On December
21,
1988, at approximately 8:30 p.m.,
a Radiation Protection
(RP) technician
performing
a routine surveillance of locked high
radiation areas
(XR doors) discovered
the door to the Flat
Bed Filter
room, located
on the 261'evel
of the Old Radwaste
(ORW) Building, to be
unlocked.
The licensee
immediately secured
the door, notified the
NRC,
and issued
both
a Work Request
(WR) and
an Occurrence
Report
(OR 88-1652).
In addition,
a tag was placed
on the
XR key, which is controlled
by the
Station Shift Supervisor
(SSS),
stating that
an operator
must
independently verify that the door is locked after all entries.
Examination of the Control
Room key log indicated that the
key to the
Flat
Bed Filter room had last
been
issued
around
noon
on December
20,
1988,
and returned
the
same day.
An entry in the radwaste
logbook stated
that all
XR doors in the
ORW building had
been
checked
and found secured
at
5 p.m.
on December
21,
1988.
On December
23,
1988, at approximately 7:30 p.m., the
same door was again
found unlocked
by the
same
RP technician during
a routine surveillance of
XR doors.
The licensee
again
immediately locked the door
notified the
NRC, issued
another
OR (88-1655),
and "blue-tagged"
the )ock mechanism
which then requires
permission
from the
SSS prior to operating
the door.
In addition,
the licensee instituted
a 2-hour door verification and
an
examination of all- XR doors for similar types of locking mechanisms.
This
particular type of lock is not self-locking but instead,
requires
the
individual to use the key to relock the door after opening.
The
licensee's
investigation revealed
approximately
8 other doors of this
type, all of which were promptly "blue-tagged.
'
WR (150296)
was issued
to replace all identified locks with the self-locking type of mechanism.
When the licensee
received
information from the Security
I&C group,
who
examined
the door and lock, that the initial incident could have
been
caused
by a failure of the lock mechanism,
the 2-hour door verification
was increased
to constant
surveillance.
On December
24,
1988, at
approximately
5 p.m., the licensee installed
an additional
chain
and
XR
padlock
on the door.
This is
an apparent violation of Technical Specification
6. 12.2.
The
inspector
inspected
the door, reviewed the administrative
OR's
and
WR's
along with the licensee's
short term and long term corrective actions.
As of this inspection,
no additional
occurrences
have
been identified.
Final resolution
as to the root cause
and long term corrective actions
will be reviewed during
a subsequent
inspection
(50-220/89-03-01).
In addition,
the following observation
was discussed
with licensee
personnel:
- The Radwaste
Sample
Tanks are located
on the 261'levation of the Old
Radwaste
(RW) Building. Access to the tanks is via
a locked high
radiation
area door installed in an approximately 20'igh shield wall.
During a routine tour of the facility, the inspector
noted
two
permanently installed ladders
which allowed access
to the top of the
shield wall. Further investigation indicated the following:
Both ladders outside the shield wall were posted
Contamination
Area, contact
HP prior to entry."
The ladders
allowed access
to platforms installed
on top of the ¹11
and ¹12 Floor Drain Tanks.
The ¹12 Floor Drain Tank had another
permanently installed ladder
which allowed access
down inside the room from the upper platform,
thereby
bypassing
the controls established
by the locked high
radiation area door.
Independent
measurements
by the inspector indicated
no dose rates
in
'xcess
of 1000 mr/hr at
18 ', the Technical Specification
(TS)
requirement for locked high radiation areas.
Inspector review of past surveys did not reveal
any information that
would indicate that dose rates
in the
room had previously exceeded
the
TS limit.
To strengthen
access
control to the
RW Sample
Tank room, the licensee
immediately installed
a locked ladder guard
on the outside of the 'shield
wall. The key to the ladder guard will be controlled in the
same fashion
as the door.
8.0
Alle ation Followu
An allegation
(RI-88-A-0092) received
by the
NRC raised
several
radiological
concerns
involving clean-up
work in the drywell,, lack of
supervision,
the use of respiratory
equipment
and personnel, leaving the
facility without the proper Whole Body Counts
(WBC).
Inspector review during this
and previous inspections
have indicated
no
concerns
in these
areas.
The area of supervisory oversight of on-going work
was previously identified as
a weakness
and
has
been
addressed
by the
licensee
(see section 4.0).
In a subsequent
communication,
the alleger
stated that the concern
was related to which personnel
were being qualified
on respiratory
equipment,
not that unqualified personnel
were using
respiratory protection equipment.
The licensee
maintains
a computerized
listing of those individuals qualified. Respirators
are
issued only to
qualified individuals after verification.
Terminating individuals are required
by procedure to obtain
an exit WBC. If
this is not feasible,
then
an evaluation is required to be performed
and
placed in the individuals dosimetry records.
Inspector review of dosimetry
.
records for selected
individuals indicated that exit WBCs were being
performed
and documented.
In one instance,
the records
indicated that
an
individual refused to be counted.
The inspector
noted
however, that the
licensee
had failed to perform the evaluation
as required
by procedure.
This is
an apparent violation of Technical Specification
6. 11.
The individual in question
had received
a
WBC approximately
5 weeks prior
to leaving the facility. Upon review of dosimetry records,
the inspector
noted
no significant radiological
work had
been
performed
by the individual
subsequent
to his last
WBC. Discussions
with cognizant dosimetry personnel
indicated
an appropriate
knowledge of the procedural
requirements
although
no formal mechanism existed to guarantee
adherence.
Due to the isolated nature of the violation and
no radiological safety
consequence
and in accordance
with the Commission's
new Policy Stat'ement
on
Appendix
C to
FR 40019),
no Notice of Violation will be
issued.
This area will be reviewed during
a subsequent
inspection.
E t~-
.q
The inspector
met with licensee
representatives
(denoted
in Section
1.0 of
this report)
on January
13,
1989.
The inspector
summarized
the purpose,,
scope
and findings of the inspection.
No written material
was provided to
the licensee.