ML20035E287
| ML20035E287 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/30/1993 |
| From: | Eckert L, Joseph Furia, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20035E284 | List: |
| References | |
| 50-220-93-04, 50-220-93-4, 50-410-93-03, 50-410-93-3, NUDOCS 9304150133 | |
| Download: ML20035E287 (9) | |
See also: IR 05000220/1993004
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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50-220/93-04
Report Nos.
50-410/93-03
50-220
Docket Nos.
50-410
License Nos.
Licensee:
Niagara Mohawk Power Corpomtion (NMPC)
3_00 Erie Boulevard West
Syracuse. New York 13202
Facility Name:
Nine Mile Point Units 1 and 2
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Inspection A?:
Lycoming. New York
Inspection Conducted:
March 22-26.1993
Inspectors:
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J. Furia," Senior Rabiation Specialist,
date
Facilities Radiation Protection Section (FRPS),
Facilities Radiological Safety and Safeguards
Branch (FRSSB), Division of Raciation Safety
and Safeguards (DRSS)
h9 73
W
[ Ec Mt[fiati i Specialist, FRPS, FRSSB, DRSS
'date
Appmved by:
.M. /N
7 70/Q3
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4 W'.' PasFiak, Chief, FRPS, FRSSB, DRSS
da(e
Areas Inspected: Inspection of the licensee's radiological pmtection programs during outages
including: management organization, ALARA, radiological contmls during normal and
outage operations and implementation of the above programs.
Results: Your mdiation protection program for outage operations at Unit 1, and for nonnal
operatbns at Unit 2 continued to show improvements, especially in the areas of work control
and maintaining exposures as low as reasonably achievable (ALARA). Continued strong
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performance in the area of Qualit: Assurance / Quality Contml was also noted; However, one
violation of NRC requirements was identified in the area of personnel monitoring and
procedural compliance (Section 3.1).
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DETAILS
1. Personnel Contacted
1.1 Licensee Personnel
- D. Barcomb, Radiological Operations Supervisor, Unit 2
- J. Burton, Manager Quality Assurance Operations
- N. Carns, Vice President Nuclear Generation
- R. Cole, Radwaste Supervisor, Unit 2
W. Connolly, Lead Qr.ality Assurance Engineer
- K. Dahlberg, Plant Manager, Unit 1
- L. Dick, Quality Inspection Surveillances
- R. Gerbig, Dosimetry Supervisor
T. Hogan, Supervisor - ALARA, Unit 1
- M. McCormick, Plant Manager, Unit 2
- J. Pavel, Site Licensing
K.. Pushee, ALARA Specialist, Unit 1
K. Rowe, ALARA and Radiological Engineering Supen'isor, Unit 2
- P. Smalley, Radiation Protection Manager, Unit 1
- P. Swafford, Radiation Protection Manager, Unit 2
- J. Torbitt, General Supervisor - Radwaste, Unit 1
- A. Zallnick, Supervisor Site Licensing
1.2 NRC Personnel
- W. Mattingly, Resident Inspector
R. Plasse, Resident Inspector
W. Schmidt, Senior Resident Inspector
- Denotes those present at the exit interview on March 26, 1993.
2. Previously Identified items
(Closed) Violation (50-220/92-21-01) Greater than 1% free standing water in waste
liner. The licensee completed both its short and long term corrective actions,
including revisions to procedure FO-OP-023 for liner dewatering. The licensee
subsequently has made numerous shipments of waste material that met the
freestanding water requirement. This item is closed.
(Closed) Violation (50-220/92-21-02) Improperly manifested laundry shipment. All
proposed corrective actions have been completed, including amending implementing
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procedurec S-RPIP-7.7 and S-RPIP-7.8, and conducting independent reviews. The
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licenn. m made numerous subsequent shipments oflaundry successfully. This item
is closed.
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3. Radiation Protection - Unit 1
Since the last inspection conducted in this area, the licensee's previous Radiation
Protection Manager (RPM) left the site at the end of 1992. For approximately 6
weeks the General Supervisor - Radiological Operations filled the RPM position on an
acting basis, and subsequently was selected to fill the position on a permanent basis.
The inspector reviewed the licensee's analysis of the new RPM's qualifications against
the requirements of the licensee's Technical Specifications (TS). The inspector noted
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that this analysis had been performed in January,1993 and was done to demonstrate
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that the individual could perform the RPM function on an acting basis. This review
was conducted against 11' provisions of Regulatory Guide 1.8, Revision 2, April
1987, which reference: American National Standards Institute (ANSI) Standard 3.1-
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1981. The licensee's TS 6.3.1 requires in part that the RPM meet or exceed the
qualifications set forth in Regulatory Guide 1.8, September 1975, which references
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A.NSI 18.1-1971. The licensee's review was not conducted against this standard, and
was not performed against considering the individual the permanent RPM. A review
against the appropriate standards was subsequently made by the license, and the
inspector determined that the new RPM met the Technical Specifications for the
position.
Recently the licensee had made significant changes to its access and egress point for
the Radiologically Controlled Area (RCA), moving it from outside the south end of
the Turbine Building on the 261' elevation, to outside the 250' elevation tunnel on the
east side of the Turbine Building. This new location allows for shorter response
times to portal monitor alarms, as the Radiological Protection (RP) Operations section
was also located in this area.
3.1 Outage Operations
In order to support Refueling Outage 12 (RF012), the licensee had augmented
its permanent staff of health physics technicians with 47 contractors, and 32
temporary technicians, and was operating on 2 twelve hour long shifts. Each
shift had assigned to it an outage Radiation Protection shift supervisor, along
with coordinators for the drywell, refueling floor and balance of plant. In
addition to the normal access and check-in point, the licensee had established
check-in points on the Turbine Deck, Turbine Building 340' election, outside
the refueling floor access point, and on the 237' elevation of the Reactor
Building, near the drywell access.
Unlike previous outages at Unit 1, during RFO12 the licensee required all
personnel entering the RCA to be on either a standing or general Radiation
Work Permit (RWP). This action was taken at both Units, in part to better
track radiation doses for personnel who were working in the RCA, but not
entering an area requiring a special RWP, such as entry iato a High or locked
High Radiation Area. Self Reading Dosimeter (SRD) to Thermoluminescence
Dosimetry (TLD) dose ratios have significantly improved as a result, so that
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now the estimated doses entered on the dose tracking system based on SRD
dose are within 10% of the "true" TLD dose, which was determined on a
monthly basis.
As part of this inspection, tours of the RCA were conducted to observe work
in progress during the outage. At the time of this inspection, most of the
drywell work was completed, and the licensee was anticipating closing the
drywell witL5 a week. Tours of the drywell indicated that extensive shielding
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of piping, valves and pumps was accomplished, which helped to significantly
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reduce the dose rates in the drywell. At the time of this inspection, one
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Control Rod Drive (CRD) was being replaced due to defects discovered when
attempts were made to couple it with the control rod blade. As a result, this
CRD and another which was determined to be slightly damaged, were
replaced. Contractor workers removed the two CRDs while working on the
under vessel platform located above the 225' elevation in the drywell. Two
workers on the platform were dressed in bubble suits, and wore special
dosimetry due to the dose gradient present in this area, ranging from 200
millirem per hour (mR/hr) at head level to less than 50 mR/hr at knee level.
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Control of this work evolution was maintained via the use of communications
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headsets and video cameras in the work area. As is further discussed in
Section 3.2, this resulted in significant dose savings while performing thisjob.
Tours of other areas of the RCA indicated that, in general, radiological and
housekeeping controls were being effectively maintained during the outage.
All radiological discrepancies, except that described belcw, were of minor
significance, while housekeeping was generally good except in the feedwater
heater bays in the Turbine Building. The licensee promptly addressed all
identified deficiencies.
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During a tour of the refueling floor during cavity drain down and
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decontamination, several instances of improper industrial safety practices were
observed. These included: a worker on a ladder not utilizing his safety
harness; leaning out away from the ladder while standing with only one foot
on the ladder rungs, and; moving the ladder a couple of inches to the left
while still standing on the ladder. These concerns were brought to the
attention of one of the radiation protection technicians who were on the
refueling floor to provide job coverage, and subsequently to the refuel floor
radiation protection coordinator.
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During a tour of the RCA conducted on March 22,1993 the inspectors found
a security badge, key card, TLD and SRD clipped to a radiological posting
sign next to a step-off pad on the 247' elevation of the Old Radwaste Building
(ORW). The inspectors immediately notified licensee personnel in the
radwaste control room, who removed the dosimetry and badges, and began a
search of the RCA to locate the person assigned these items. The person
involved was performing decontamination tasks, and when removing his
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protective clothing in order to leave the area on 247' ORW had attached his
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dosimetry and badges to the posting, but failed to collect them when he exited
the area. The worker was subsequently located in the RSSB, where he, along
with several other workers were deconning a stairway. The licemee estimated
that the worker remained in the RCA without his dosimetry for gproximately
15 minutes, and that the areas he traversed and/or entered had dose rates at or
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less than the area where his dosimetry was located. As a result, the licensee
chose to assign the worker the dose measured by the TLD. The worker was
esconed out of the RCA by a health physics technician, and subsequently left
the site for the evening. The ORW and RSSB are part of the licensee's RCA
which meets the definition of a restricted area contained in 10 CFR Part 20,
and personnel entering these areas need to be wearing personnel dosimetry in
accordance with 10 CFR 20.202 and licensee procedure AP-3.3.3.
On March 25,1993 plant personnel, including the Plant Manager and RPM
made an inspection tour of the RCA as part of their corrective actions for the
March 22 incident. During this tour, a worker was observed not having his
dosimetry or security badge clearly visible on his person. The TLD, SRD,
security badge and key card were found to be clipped on his shin, which was
covered by a laboratory coat. The worker was counseled by the RPM as to
the proper placement of dosimetry and security badges, and the worker
relocated these iteras to the outside of the chest pocket on the laboratory coat.
Later the worker removed the laboratory coat and left it on the 261' elevation
of the Turbine Building with the badges and dosimetry still attached. The
worker was observed by the day shift Radiation Protection Outage Supervisor
exiting the RCA without his badges and dosimetry. The Turbine Building is
part of the licensee's RCA which meets the definition of a restricted area
contained in 10 CFR Part 20, and personnel entering these areas need to be
wearing personnel dosimetry in accordance with 10 CFR 20.202 and licensee
procedure AP-3.3.3. This instance and that described in the preceeding
paragraph of 10 CFR 20.202 is an apparent violation (50-220/93-04-01).
3.2 ALAR.A
The licensee established an outage goal of not more than 350 Person-Rem
prior to the start of RF012. This goal was a revision of an earlier goal which
was significantly lowered due to outage work scope changes. As of March 26,
1993 the licensee's exposures were approximately 245 Person-Rem, and the
ALARA Section was projecting the outage to be completed at approximately
280 Person-Rem. The final outage doses will be reviewed during a later
inspection in this area.
Several of the radiologically significant jobs were completed or near
completion at the time of this inspection. A brief summary of these jobs is
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given below:
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Estimated Dose
Actual Dose
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Remove / rebuild 47 Control Rod
51.000
45.224
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Drives
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Drywell In-Service Inspection
43.472
24.795
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Estimated Dose
Actual Dose
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Drywell RP Surveys & Coverage
6.400
12.892
8.480
10.381
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- 13 Recirc Pump Cooler Replacement
9.000
10.058
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- 11 RWCU Filter Septum Replacement
5.200
2.586
In general, the licensee's ALARA program has been successful during RF012.
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Significant dose savings have accrued from significant use of closed circuit
television monitoring of high dose rate jobs by radiation protection technicians,
early installation of drywell shielding prior to commencing any insulation
removal, and prestagiag of tools and equipment for high dose rate jobs. The
most important aspect of the ALARA performance has been the extensive pre-
outage planning conducted by all working groups, including early freezing of
work scope.
3.3 Radwaste
The inspectors discussed with the licensee its plans for performing a system-
wide clean-up and upgrade to the radwaste facility. Previous inspection
reports have documented NRC concerns and observations as they relate to the
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licensee's radwaste facility, especially Old Radwaste. For 1993, the licensee
has dedicated staff in all of the maintenance crafts, operators, radiation
protection technicians and decontamination workers to begin on or about April
19,1993 to make numerous improvements to this facility. The results of this
effort will be reviewed during a future inspection.
The inspectors also reviewed three shipping records for radwaste shipments
made in March 1993. records reviewed included:
Shioment #
Activity (CD
Type
0393-025
7.00E+01
Resin
0393-022
5.53E-01
Resin
0393-024
3.75E+01
Resin
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All shipments were determined to have been made in accordance with the
applicable regulations contained in 49 CFR Parts 100-177, and 10 CFR Parts 20, 61 and 71.
4. Radiation Protection - Unit 2
Since the last inspection in this area, the licensee has outlined and begun
implementation of a radiation protection reorganization. Under the new organization,
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which was scheduled for full implementation by April 1,1993, the RPM would have
five direct reports, the Supervisors of Radiological Operations, ALARA and
Radiological Engineering, Radwaste, Instrumentation, and External Dosimetry. The
most significant changes have been the placing of the radwaste program under the
RPM. This program was previously under the management of the Operations
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Department. Additionally, the ALARA and Radiological Engineering sections have
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been combined.
4.1 Normal Operations
During this inspection, Unit 2 was operating at or near 100% of rated power,
with its next outage scheduled to begin September 11,1993 (RF03). As part
of this inspection, tours of various areas of the RCA at Unit 2 were conducted,
including the pipe tunnel, Turbine Building, Radwaste Building, Reactor
Building and Auxiliary Boiler Building. All radiological areas were
determined to be appropriately controlled and posted. No discrepancies in
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radiological work practices or plant housekeeping were noted.
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4.2 A _. ARA
During 1992, Unit 2 conducted its second refueling outage. This outage had
an established goal of not more than 300 Person-Rem, and the outage was
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completed for 275 Person-Rem. As part of this inspection, a review of the
licensee's Post Outage Rad Protection report, prepared by the ALARA
Supervisor, was reviewed. This extensive document included review of
performance in the areas of radiation protection and ALARA, external
dosimetry and respiratory protection, radwaste, plant modifications and design
changes, and an in-depth review of specific jobs.
Significant dose savings were realized via two main avenues, hot spot flushing,
which was estimated to save 26.00 Person-Rem, and temporary shielding, with
a total dose savings of 48.65 Person-Rem. All major jobs were reviewed in
this document, and include both good practices and problems and areas for
improvem~it.
For the upcoming RF03, the unit ALARA goal has not as yet been established.
Preliminary indications were that several dose intensive jobs were to be
deferred, which shodd reduce the outage dose. Final outage planning by the
licensee will be the subject of a future inspection.
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5. Dosimetry
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A review of the personnel dosimetry program used onsite was conducted during this
inspection. The licensee used SRDs in addition to the dosimetry of record. The
dosimetry of record was TLDs operated by an on-site organization reporting to the
Unit 2 Radiation Protection Manager. The Unit 1 Radiation Protection Manager was
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responsible for the station's internal dose estimation program. The licensee was
accredited by the National Voluntary Labomtory Accreditation Program (NVLAP) in
all test categories. Although accredited in the mixed neutron plus high energy gamma
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radiation category (Category VIII), the licensee used the services of a vendor to
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provide neutron dosimetry services. Additionally, the licensee utilized the services of
a vendor to provide and evaluate extremity dosimetry used at the station.
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In December, dosimetry services was moved to provide additional dedicated office
space. Staffing to support the outage was sufficient. The program was headed by the
Dosimetry Supervisor who was assisted by two permanent dosimetry technicians, 6
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permanent radiation records clerks, and 8 temporary radiation records clerks. All of
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these individuals were NMPC employees,
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A new dosimeter calibrator (Atlan-Tech Model DS-50,2 Ci, Cs-137 source) was
purchased providing a significant improvement over the previous calibrator. The new
calibrator was designed to accommodate 65 SRDs or 50 TLDs in a carousel which
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thereby provided for positional reproducibility. The calibrator room was provided
with an Area Radiation Monitor (ARM) to provide a means of detecting an interlock
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failure. The inspectors reviewed procedure N2-RTP-165, Revision 0, 3/19/93,
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" Operation and Calibration of Atlan-Tech Model DS-50 Calibrator." No procedural
ir. adequacies were noted. A new TLD magazine changer was also purchased.
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The Dosimetry Supervisor planned the following additional program improvements.
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A new neutron algorithm (NVLAP Category VII) was to be developed.
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A new mixed photon algorithm (NVLAP Category VI) was to be developed.
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New software and hardware was purchased to facilitate glow curve capture for
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permanent retention.
A new computerized digital alarming dosimeter and dose tracking system was
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under evaluation.
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The Dosimetry Superviser has established a quarterly TLD Quality Control (QC)
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surveillance conducted by a national laboratory (Battelle) in a manner similar to that
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used by NVLAP. The inspector reviewed the last quarter 1992 TLD QC surveillance
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results; no inadequacies were identified.
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Certain newly purchased Panasonic plastic TLD holders worn by personnel from
April through July 1992 were manufactured from higher density plastic than that
specified. Upon discovery, the Dosimetry Supervisor initiated Deviation Event
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Report (DER) 2-92-3611. The following corrective actions were. implemented.
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The high density TLD holders were removed from use.
The significance of higher density plastic was evaluated. It was determined
that the higher density p
could lead to misidentification of beta exposure.
One dose of record was
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Procedure S-RPIP-5.20, " External Dosimetry Program and Quality Assurance"
was revised to include testing of the density thickness of new TLD holders.
This inspectors had no further questions on this matter.
6. Exit Interview
The inspectors met with the licensee representatives denoted in Section 1 at the
conclusion of the inspection on March 26,1993. The inspectors summarized the
purpose, scope and findings of the inspection.
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