ML18038A186
| ML18038A186 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/16/1986 |
| From: | Kaminski M, Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18038A184 | List: |
| References | |
| 50-220-86-08, 50-220-86-8, 50-410-86-19, NUDOCS 8607240151 | |
| Download: ML18038A186 (26) | |
See also: IR 05000220/1986008
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
50-220/86-08
50-410/86-19
Docket No.
50-220
50-410
License
No.
CPPR"112
Category
C
B
Licensee:
Nia ara
Mohawk Power
Cor oraton
300 Erie Boulevard
West
S racuse
13202
Facility Name:
Nine Mile Point Nuclear Station
Units
1 and
2
Inspection At:
Oswe
o
r
Inspectors
PL R.L. Nimitz, Senior Radiation Specialist
a
M. Kaminski, Radiation Specialist
d te
da
e
Approved by:
M. Shanbaky,
Chief
Fa
lities
date
Radiation Protection
Section
Ins ection
Summar
Routine
announced
Radiological Controls inspection.
The
following matters
were reviewed:
Unit
1 - licensee
action
on previous find-
ings; radiological controls for the outage;
ALARA, worker concerns;
Unit 2-
licensee
action
on previous findings; preoperational
testing.
Results:
Two violations were identified (failure to perform surveys
in
accordance
with 10 CFR 20.201;
section
3; failure to properly instruct worker s,
section 7.)
8607240l51
860716
ADQCK 05000220
G
DETAILS
1.0
Individuals Contacted
k
- T. Perkins,
General
Superintendent
- R. Abbot, Station Superintendent,
Unit 2
T.
Roman, Station Superintendent,
Unit
1
"M. Ray,
Manager,
Special
Projects
'E.
Leach,
Superintendent,
Chemistry
and Radiation Protection
Management
- J. Duell, Supervisor,
Chemistry
and Radiation Protection
"D. Barcomb, Unit 2 Supervisor,
Radiation Protection
~R. Gerbig, Unit
1 Supervisor,
Radiation Protection
- T. Irving, ALARA Coordinator
1.2
NRC
"R. Grahm,
Senior Resident
Inspector,
Nine Mile 2
C. Marschall,
Resident
Inspector,
Nine Mile
1
- Denotes those individuals attending
the exit meeting
on
May 23,
1984.
2.0
~Pur
ose
The purpose of the routine radiological controls inspection
was to review
the following:
Unit
1
Licensee Action on Previous
Inspection
Findings
Radiological controls for the current outage
including:
external
exposure controls,
internal
exposure
controls;
controls
Worker Concerns
Unit 2
'icensee
Action on Previous
Findings
'reoperational
Testing
e
3.0
Licensee Action On Previous
Findin
s
3. 1
(Open) Unresolved
item (50-220/86-04-03)
Licensee identified vio-
lation:
failure to perform surveys
in accordance
with 10 CFR 20.201
to ensure
compliance with 10 CFR 20. 103.
On March 28,
1986,
an
technician did not perform
a
smear
survey of a valve being repaired.
As a result excessive
airborne radioactivity was generated
whose
peak
concentration
exceeded
the protection factor of the respiratory pro-
tection device being
used
by the worker performing the grinding.
The
inspector
reviewed the adequacy,
effectiveness,
and implementation of
corrective actions for the violation.
The following was identified:
The licensee's
Radiation Protection
( RP) Supervisor
issued
a
hand written memorandum
to
RP foreman
on March 28,
1986 re-
garding what actions to take based
on loose surface
contamina-
tion levels
on components.
It was
found that:
1)
no review had
been
performed to determine if all foreman were cognizant of the
memorandum,
2)
RP technicians
were
unaware of all the criteria
contained
in the
memorandum,
and 3)
no criteria for using res-
pirators or engineering
controls
when grinding or lapping
on
components with fixed contamination
was established.
Although required
by licensee
procedures,
no radiological in"
cident report (RIR) was issued for the incident.
No specific administrative
requirements
were in place requiring
personnel
to adhere
to memorandums.
(i.e.
RP supervisor
log
book)
The lack of adequate
correction action resulted
in part in a
second
incident of excessive
airborne radioactivity occurring
one month later.
(See section
6 of the report.)
Based
on the above,
the inspector
concluded that the licensee
had not
taken
adequate
corrective actions
and did not meet the applicable
criteria specified
in
10 CFR 2 relative to non-issuance
of a vio-
lation.
Consequently,
failure'o perform
an adequate
radiological
evaluation
in accordance
with 10 CFR 20.201 to assure
compliance with
10 CFR 20. 103 consitituted
an apparent violation.
3.2
(Open)
Follow-up Item (50-410/85-32-04)
Licensee
to complete preoperational
testing of area radiation
monitors
(ARMS).
Testing of ARMs is not complete.
3.3
(Open)
Follow-up Item (50-410/85-20-07)
Licensee
to train and qualify sufficient radiological controls per-
sonnel
and radwaste
operations
personnel
to support fuel load and
power operations.
The licensee
has established
training programs for
the individuals.
Training is not yet complete.
-
0
3.4
(Open) Follow-up Item (50-410/85-47-03)
Establish
and implement high
radiation area control for Unit 2.
The licensee
has not yet fully
established
and implemented
the key control program.
The licensee
has yet to complete
an office instruction regarding
key use.
Also
lock cores for Unit 2 have yet to be changed.
3.5
(Open)
Follow-up Item (50-410/85-32-01)
Establish
a method to ensure all appropriate
personnel
are cognizant
of new procedures
and procedure
changes.
The licensee
stated that
procedure
AP-2 has
been revised to address
this matter.
Due to time
constraints
during this inspection the revised procedure
was not
reviewed
by the inspector.
3.6
(Closed)
Follow-up Item (50-410/85-32-07)
License to establish
and implement procedures for radwaste
handling
in Unit 2.
The licensee
established
procedures for radwaste
handling
in Unit 2.
3.7
(Closed)
Follow-up Item (50-410/85-20-80)
Licensee
to establish
procedure
control for cross
connecting Unit 1 and Unit 2 radwaste
systems
to prevent inadvert contamination of non-radioactive
systems
from radioactive
systems.
The licensee
has in place administrative
controls which are applicable to this system interconnection
(AP-2,
AP-6).
3.8
(Open)
Follow-Up Item (50-410/85-32-02)
License to ensure action taken,
as appropriate,
on outstanding
bulletins, ci rculars,
and information notices.
(Open)
- Procedure
in draft which addresses
this circular.
(Open)
-
NRC to verify incorporation of guidance into training program.
(Open)
- Operations
procedures
to be reviewed
by the licensee
to
ensure
adequate
controls in place for transient
high rad-
iation areas.
IE Information Notice 80-22 (Closed)
- The licensee
established
adequate
procedure
controls to
address
concerns
discussed
in this notice.
IE Information Notice 82-12 (Closed)
- The licensee
established
adequate
procedure
controls to
address
concerns
discussed
in this notice.
4.0
Prep erational
Testin
Unit 2
The inspector
reviewed the status
of the preoperational
testing of the
following systems:
area radiation monitoring system
safety related ventilation system
The review was with respect
to criteria contained
in the following:
November
1978, "Preoperational
and
Initial Start-up Test Program for Water Cooled
Power Reactors";
Final Safety Analysis Report,
Section 6.5, "Habitability
Systems";
Final Safety Analysis Report,
Section 6.5, "F'.ssion Product
Removal
and Control Systems";
Final Safety Analysis Report,
(FSAR) Section
11.5, "Radiation
Monitoring System";
FSAR, Section
12.3, "Radiation Protection
Design Features";
Final Safety Analysis Report
( FSAR), Chapter
14, "Initial Tests
Program";
ANSI N42. 18-1980, "Specification
and Performance
of On-Site
Instrumentation for Continuously Monitoring Radioactivity and
Effluents";
and
ANSI N13. 1-1969,
"Guide to Sampling Airborne Radioactive
Materials in Nuclear Facilities".
Area Radiation Monitorin
S stem
Findin
s
The licensee
is currently performing tests
of the
ARM System.
Preoperational
testing is not complete.
This matter remains
open.
Safet
Related Ventilation
S stem Testin
The licensee
has
completed
preoperational
testing of safety related
ventilation system.
The licensee
has not started
in-place filter
testing.
This matter
remains
open.
0
5.0
Radiolo ical Controls
Unit
1
The inspector
reviewed the implementaton
of radiological controls for the
current outage.
The following matters
were reviewed:
worker adherence
to radiation work permits;
use
and placement of personnel
monitoring devices;
adequacy of airborne radioactivity surveys,
contamination
surveys,
and radiation surveys;
high radiation area posting
and control;
selection
and
use of proper respiratory protection
equipment.
The evaluation of the licensee's
performance
in the area
was based
on:
Inspector
performance
of independent
radiation surveys;
observation
of on-going work;
discussions
with personnel;
tours throughout the facility including the drywell.
Within the
scope of the review,
no violations were identified.
The following matter
was identified:
radiological controls staffing was found to be lacking to cover dry-
well work on one occasion.
One
HP technician
was noted to be cover-
ing drywell work activities including the drywell access
control
point.
The work load was considered
excessive
for one
HP technician.
This matter
was brought to the licensee's
attention.
6.0
ALARA Unit I
The inspector
reviewed the implementation of the
ALARA Program.
The
following matters
were reviewed:
generation
of ALARA man-rem exposure
goals
licensee
review of accumulated
exposure
summaries
licensee
review and resolution of exposure
anomalies
total accumulated
exposure
to date
0
~Q
Within the
scope of the review, the following was identified:
Station
exposure
goals
are being generated
by the corporate
radiological controls group.
In some cases,
due to
a lack of clearly
defined work scope,
man-rem goals are being underestimated.
The
licensee
should ensure
an adequate definition of work scope is
provided those individuals establishing
ALARA goals.
The licensee
recently changed his vendor
who supplies
personnel
monitoring devices.
The licensee's
current man-rem totals (i.e.
pocket dosimeters
as
compared
to TLD readings)
were not corrected for
response
differences of the pocket dosimeters
versus
the
TLD badge
supplied
by the
new vendor.
As
a result,
the licensee
sustained
an
additional unanticipated
100 man-rem of exposure
when the personnel
monitoring devices
were first read out as
compared to pocket dosi-
meter s.
This resulted
in the licensee
exceeding
some outage
man-rem
exposure
goals.
The licensee
is currently reviewing and evaluating
the above
two
matters.
I
7.0
Worker Concerns
Unit
1
7. 1
~Back round
On May 15,
1986,
two contractor
employees
contacted
the
NRC and
expressed
concern that their supervisor
was deliberately "cutting
corners" to minimize the amount of time personnel
spent
on
a job
in order to reduce
labor costs.
This had been
done without regards
to the health
and safety of the personnel
involved.
The workers
cited as
an example
an incident which occurred
on April 28,
1986
and
involved personnel
exposure
to airborne radioactive material
sus-
tained
as
a result of the rupture of a glove bags
The incident
involved lapping
on valve 33-02 in the drywell.
An onsite inspection
was initiated by the
NRC of the workers
concerns
on May 19,
1986
7.2
NRC Review
The inspector
reviewed the following matters associated
with the
workers concerns:
adequacy
and effectiveness
of inter
and intra radiological
control group communications
adequacy
and effectiveness
of inter and intra contractor
group
communications
adequacy
and effectiveness
of radiological controls provided for
drywell work including the April 28,
1986 glove bag incident
number of Radiological
Occurrences
Reports
issued
throughout the
outage for the applicable contractor's
personnel
number of radiological
nonconformances
issued
through out
the outage for the applicable contractor
personnel
The evaluation of the workers concerns relative to the above matters
was determined
by the following
meetings
and discussions
with selected
individuals including:
licensee
supervisory
personnel
licensee
radiological controls technicians
contractor radiological controls technicians
various contractor supervisory
personnel
(day and night
shift)
various contractor workers (day and night shift)
licensee
ALARA personnel
individuals involved with April 28,
1986 glove bag incident
independent
review of on-going drywell work during both day and
night shifts
7.3
Descri tion of A ril 28
1986 Glove
Ba
Incident
In order to meet
10 CFR 50 Appendix J testing requirements
the li-
censee
elected to replace
the suction
and return valves of the re-
actor water clean-up
system (valve 33-02
and 33-01 respectively).
Conceptual
planning of the job was performed
in early
November
1985.
Subsequent
actions
on the planned work were
as follows:
On February
10,
1986,
licensee
ALARA personnel
meet with the
contractor
pipe fitters'eneral
foreman
( Individual D) (Note:
This individual is normally
a second line supervisor
on day
watch).
At this meeting the following matters
were discussed:
scope of job; methodology of job performance;
and engineering
controls (e.g.
glove bags).
On March 10,
1986,
the onsite
ALARA group generated
the initial
ALARA review for the work.
f
On April 2,
1986,
the initial ALARA review for the job was
modified to change
the method of cutting out the valves.
On April 12,
1986,
an individual from the licensee's
ALARA group
(Individual F) met with a third line contractor supervisor
( Individual E).
The following was discussed:
use
and instal-
lation of glove bags;
non-use of air grinders;
lack of rear
exhaust grinders;
use of electric grinders;
and availability of
tools.
On April 22,
1986 (between
about 9:30 - 10:45 p.m.)
an indivi-
dual
from the
ALARA group
( Individual
F) met with the contractor
foreman
and pipe fitters from the night shift crew and demon-
strated
use
and set
up of glove bags.
(Similar training was not
provided for all day shift crew personnel)
In the early morning hours
on April 23,
1986,
a second
individual from the onsite
ALARA group ( Individual G) held
a
pre-job planning meeting with the night shift crew expecting to
perform the work.
On the morning of April 23,
1986,
the licensee'
ALARA super-
visor ( Individual H) met with about
14 contractor personnel.
One worker who performed
lapping
on valve 33-02
and this in-
dividual's
foreman attended this training session.
The
following matters
were not discussed:
non-use of air tools,
use
of electric grinders.
The workers were not provided the
summary or the
ALARA instruction for installing
a glove bag.
On April 23,
1986,
an
ALARA review (which contained
minimum
requirements
for work on valve 33-02)
was allegedly sent to the
contractor onsite superintendent
for distribution.
This in-
dividual indicated
he did not receive or see
the submittal.
On April 23,
1986 valve 33-01 (return valve) was cut out.
Two
HEPA ventilation systems
were
used
to minimize airborne
radioactivity.
No significant problems
were encountered.
At about
9 p.m.
on April 27,
1986,
a planning meeting
was held
with the night shift crew who removed valve 33-02.
The follow-
ing matters
were discussed:
use of cutting saw;
non-use of air
tools;
and
use of electric grinders.
On April 27,
1986 valve 33-02 was cut out.
Some problems
were
encountered
with the cutting
saw.
The
saw was not tested in-
accordance
with recommendations
of the
ALARA summary.
Due to
problems with the
saw,
time was not available to grind and lapp
the pipe ends to prepare
for the installation of the
new valve.
(33-02)
10
At about
1:00 p.m.
on April 28,
1986,
a contractor
foreman
( Individual C) contacted
two of his
men (individual A and B) and
directed
them to go into the drywell and prepare
the pipe ends
for installation of a
new valve.
Although the
foremen
and
one
of the workers
had attended
glove bag training session,
no
new
instructions
were provided to the work crew at the time
The
ALARA group was not notified of the planned work and the workers
were
unaware of the
ALARA summary or glove bag installation
procedure.
At about 2:00 p.m.
on April 28,
1986,
the workers
and foreman
signed in on
RWP No.
2017
and proceeded
to the drywell check
point.
The individuals were challenged
by the drywell access
control point technician
as to where their glove bags were.
The
workers stated that they did not use
a glove bag to lapp
and
grind on valve 33-01
and were unaware of the
need to use
a glove
bag
on 33-02.
Because
valve 33-02 was the suction valve to the
reactor water clean-up
system, it and its associated
piping was
substantially
more contaminated
than valve 33-01
and its piping.
The technician (individual H) contacted
a
HP foreman (individual
I) who stated that
a glove bag must
be used.
This was relayed
to the worker.
Two glove bags
were located after the contractor
foremen,
the
two workers
and the technician
went to the work site.
The glove bag
was found to be difficult to install.
The tech-
nician foreman
was contacted
again
and again indicated
a
glove bag must be used
when grinding.
The technician
(individual H) cut the glove bag
and provided instruction to the
workers
on
how to install the glove bag.
This
HP technician
had
not attended
glove bag training given by the licensee.
Although the glove bag
was not installed in accordance
with the
Glove
Bag instruction,
and
no verification was performed that
air tools were not going to be used,
the technician (individual
H) told the workers that, the bag installation
was acceptable
and
respirators
need not be worn.
(Note:
Respirator
usage
was at
the discretion of the
HP technician)
The technician (individual
H) said that
a second technician (individual J) would be return-
ing to the area
to collect an air sample at the start of work.
The workers'oreman left at this time also.
A second technician
( Individual J) returned to the work area
and
started
an air sample.
This technician also inspected
the glove
bag
and indicated to the workers that it was adequately
installed.
No instructions
were given to the workers related to
non-use of air tools.
The technician started
the air sampler
and left the area to wait in
a low dose rate wait area.
The workers started their grinding.
Some time during the
grinding the glove bag was over pressurized
because:
1) an air
tool was being used;
2) the bag did not have
an exhaust
and 3)
the workers
had stuffed material into the pipe end to prevent
debris
from entering the primary system.
About
10 minutes later, the technician (individual J) returned
and collected his air sample
and left the area to count it.
No
new air sample
was started.
Initial qualitative measurements
of the sample indicated high airborne radioactivity.
The workers
had stopped grinding and were changing out the wheel
on the air grinder (work duration about 2-5 minutes since the
technician
had left) when the
HP technician (individual J)
returned to the area
and evacuated
the workers.
The drywell was evacuated
of all personnel
at about the
same
time.
All personnel
in the drywell at the time were given nasal
smears
and whole body counted.
The licensee initiated an investigation
a short time later.
Subsequent
evaluation indicate airborne radioactivity concen-
tration in the work area
was about
800 time the applicable
concentration
values specified in 10 CFR 20 Appendix B.
7.4
Conclusion
7.4.1
Worker Concerns
Within the scope of this review, the inspector
was unable
to identify any apparent specific example where contractor
supervisory
personnel willfully"cut corners" in order to
reduce labor costs which subsequently
resulted in the
degradation
of health
and safety controls provided for
workers.
However,
based
on review of this incident, the
workers were subject to excessive
airborne radioactivity
concentrations.
The inspector attributed the improper glove bag installation
and
subsequent
airborne radioactivity to the following:
licensee failure to maintain adequate
oversight
and control
of contractor work activities
inadequate
training and qualification of personnel
on glove
bag installation,
and use
inadequate
radiological work controls specified
on appli-
cable radiation work permits
I
12
0
in'adequate
and ineffective communication within the radio-
logical controls organization
insufficient communications with the contractor
organziation
The inspector
stated that failure to provide the two workers
with adequate
precautions
and instructions
in accordance
with
10 CFR 19. 12 to minimize their exposure
to airborne radioactive
materials constituted
an apparent violation (50-220/86-08-01).
7.4.2
Corrective Action
The inspector
reviewed the adequacy
and effectiveness
of
licensee
corrective action taken
subsequent
to the event.
~Lon
Term
The following was noted:
The licensee
held
a meeting
on April 29,
1986 with all
involved personnel.
A decision
was
made to revise
applicable
procedures
to require incorporation of
minimum ALARA requirement into the
RWP.
A memorandum
was issued to
HP foreman
on
April 30,
1986 regarding
incorporation of minimum
ALARA requirements
into applicable
RWPs.
A radiological incident report was issued
Within the
scope of the review,
the following deficiencies
were noted:
No review was performed to determine if all radiation
protection
foreman were cognizant of the
memorandum
issued
to them regarding
incorporation of ALARA
requirement into the
RWP.
The incorporation of minimum ALARA radiological
con-
trols into RWP's
was not retroactive.
All currently
active
RWP's
issued prior to the incident were not
reviewed for short comings in this area.
Incorporation of minimum ALARA radiological controls
requirements
into new radiation work permits
was
non-uniform.
13
Some
RWP's referenced
ALARA summaries that were not
available with the
RWP for worker review.
The above deficiencies
were brought to the licensee's
attention.
7.4.3
Intake Estimates
Airborne Radioactivit
The inspector
reviewed intakes
estimate of personnel.
No personnel
sustained
intakes of airborne radioactive
material
in excess
of regulatory requirements.
The inspector
met with licensee
personnel
denoted
in Section
1 at the
conclusion of the inspection.
The inspector
summarized
the purpose,
scope,
and findings of the inspection.
No written material
was provided
to the licensees