IR 05000443/1992022

Insp Rept 50-443/92-22 on 921005-09.One non-cited Violation Noted.Major Areas Inspected:Radiological Controls Program, Predominately Involving Observation of Field Activities During 1992 Refueling Outage & Review of HP Program

ML20128C053
Person / Time
Site:	Seabrook
Issue date:	11/27/1992
From:	Chawaga D, Mann D, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128C040	List: IR 05000443/1992022 ML20128C036
References
50-443-92-22, NUDOCS 9212040212
Download: ML20128C053 (6)

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U. S. NUCl.11All itEGULATORY COMMISSION RiiGION 1 Report No. $1443L92-22 Docket N7 50-443 1.icense No. NPE56 Licensee: hihlk_Smks_Compally of New Uattuuhite P. O. Itox 330

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Mimcht31ct. New IPmpshire 03105 Facility Name: Scabrook NuckaI_SlatiOD inspection At: Seabrook. New llantptitc insp lon Conduct ' Og10her 5 - 9.1992

inspector: -

)hc I 11 ' D D. Chawaga, Senior Radiation Specialist Date FRPS,FI St DRSS ,

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Inspector:

w (m cs n b l'1 'l 1 D. Mann, Ra ' lon Specialist Date IKtPS, FI 'll, D SS

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I Approved by:

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V- o% CN( I L '[7 #1L W. Pasciak, Chief, FRPS, FRSSil, DRSS Date Areas Insoccted: This unannounced inspection of the radiological controls program predominately involved observation of field activities during 1992 refueling outage. inspection activities included direct observation of outage work and radiological control efforts in the Geld, including a focus on outage exposure estimates and high radiation area entry control Results: One non-cited violation of Technical Specification requirements for entry to liigh Radiation Areas was noted (see Section 4.0). One unresolved item was closed which involved sealed source survey requirements (see Section 3.1). Overall, the inspector concluded that outage planning had significantly improved and work vas progressing in a radiologicaHy safe manner. A few weaknesses were obsermi in the implementation of radiological wor' control PDR ADOCK 05000443 o PDR

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Dl! TAILS jndividuals contacled i NotilLA11anlie Energy _Servlees conmunipal

• J. Ilourassa, Quality Assurance Engineer - Radiation Protection (YAEC)

• J. Cady, ISEO Supervisor W. Cash,11P Radiation Protection Supervisor

• 11. Clark, Rad Services Supervisor - Instruments & Respiratory Protection

• D. Covill, NQ Surviellance Supervisor

• E. Darois, llP Supervisor ,

• W. DiProfio, Station Manager

• S. Dodge, Rad Services Department Supervisor

• II. Drawbridge, Executive Director of Nuclear Production

• D. Flahardy. IIP Supervisor - Operations

• J. Grillo, Operations Manager

• W. Leland, Chemistry /lkdth Physics Manager

• J. March, Lead Auditor, Nuclear Assessment

• 1. McCabe, Rad Services - IIP Recordi

• J. Peshccl, Regulatory Compilance Manager

• T. Pucko, NRC Coordinator

• J. Rafalowski,11calth Physics Department Supervisor

• F. Straccia, Senior IIcalth Physicist

• R. Sterritt, llP Supervisor - ALARA

• J. Tarzia, Senior licalth Physicist NJLC

• N. Dudley, Senior Resident inspector

• R. Laura, Resident inspector

• W. Pasclak, Chief, FRPS

• Denotes attendance at the exit meeting on October 9,1992, Purpose and Scope of Inspection This unannounced inspection involved a review of the station's health physics (HP) program with regard to the following elements: sealed source leak testing, control of entry to liigh Radiation -

Areas, radiological control of outage work, ALARA program activities, qualificat';on of personnel, internal exposure control,

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3 Ercylmuly identined Items Scaled Source Leak Testing Closed, UNR 50-443/92 19-01. On September 2,1992, during an self assessment audit, I licensee personnel identified a deficiency in station practices for surviellance of scaled source

1. NE-90 2 (X-MET 880 Analyrcr)._ The radiation source is required to be surveyed at six month intervals in accordance with the requirements of Technical Specifications and 10 CFR 31.5. An earlier review of source surveillance records indicated that these surviellance requirements may not have been met. A more complete review, which included source receipt 1 and shipment survey records and records held under the licensee's Radioactive Material Storage Area surviellance program, indicated that the six month leak check was adequately performed since the source was acquired on May 22,1990. The source was found to be free of detectable contamination during each survey. Licensee personnel noted that the leak check surveys, although conducted, were not performed under the Source Control Program as intende Fortuitously, adequate surveys were performed under the Radioactive Material surviellance program. A detailed review of this incident revealed other minor weaknesses in the Source control progra Licensee management discussed this incident with ifP personnel and made plans to further review and, as appropriate, rv w the source control program and training program after completion of this year's refueling, outage. This item is close .0 lijgh Radiallon Area Entry Technical Specification (TS) 6.11.1 requires that any individual or group of individuals ri .11tted to enter liigh Radiation Areas (IIRAs) shall be provided with or accompanied by onur mre <

of the following: A radiation monitoring device that continuously indicates the radiation dose rate in the area; or A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them; or An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified in the Radiation Work Permit (RWP).

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Contrary to the above, on September 15,1992, TS monitoring centrols had not been established for two individuals who were found by a NAESCO IIP Technician within the Reactor Coolant Pump (RCP) cubical "D", a Iligh Radiation Area. Specifically, workers were not equipped with dose rate meters or alarming dosimeters and, although an individual qualified in radiation protection procedures may have monitored the workers' exposure to some extent, a radiation surviellance frequency was not specified on the RWP controlling their work. In fact, the need for IIRA control measures was not specified on the RW According to the workers, a contract ilP Technician unlocked the access to the area and periodically surveyed the area during '. heir work. The workers were unable to identify the contract lip Technician and none of the Hp Tuhnicians interviewed could remember if they had assisted with the entr Subsequently, the contract lip Technician's identity was never established and the inspector was unable to verify the details associated with the surviellance provided. Although dose rates within the area were not in excess of 1,000 mrem / hour, the entrance to the area was locked and would have required IIP assistance for entry. The area was posted as a llRA. Another posting on the door detailed the station's IIRA entry requirement Good performance was noted on the part of the NAESCO IIP Technician who discovered the workers and began the implementation of corrective actions. The workers were escorted from the RCP cubical and the llP Technician promptly called the control point to determine the workers' RWP requirements. At that time it was noted that the RWP requirements were

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inadequate for entry to the area. Exposure rates at the work location were less than 0.2 mR/hr and no significant exposure was received during the entry. Ilowever, once inside the RCP cubical, workers could access areas in excess of 100 mR/ hour without encountering a posted barricad On September 15th a Station Information Report (SIR) was initiated and the if P Technician who wrote the RWP was counseled. On September 16th, the station " Outage liighlights" newsletter was issued containing a description of the event and a clarification of HRA entry controls. A checklist was created to assist in assuring that the proper controls are included on an RWP prior to issue. On September 29th the workers involved in the event were counseled. On October 3,1992, an IIP Department Outage Newsletter entitled "Ifigh Radiation Area Access Controls" was issued to all lip Technicians. The newsletter discussed the September 15th event and ,

emphasized the need for compliance with HRA entry requirements and postings in the fiel The SIR was completed on October 3r Corrective actions taken in response to this event were timely and comprehensive. As a result <

of good performance in handling this event, in accordance with Section V.G. of the NRC Enforcement Policy, the violation is not being cite ,0 Plant Tours With only minor exceptions, postings were well maintained and provided clear radiological

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harard information to workers. Posting weaknesses were expeditiously and appropriately corrected immediately after identification. Those workers observed in the field demonstrated proficiency in donning and removal of protective clothin Overall, the inspector's field .

observations indicated that work was progressing safely from a radiological perspective. All llP  ;

Technicians interviewed were well informed of work in progres j l Radiation Work Permits The licensee's Radiological Occurrence Reports (RORS) contained documentation of several incidents which occurred as a result of weaknesses in the Radiation Work Pennit process. For example, the HRA entry incident described in Section 4.0 of this report could have been prevented if the RWP had been properly writte< w ,; . dre pner monitoring provisions, in other cases, personnel failed to strictly adhere to WP .% ,

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ant merformed work outside of the scope of existing RWPs. Licensec pe, we r4 . @ wy had recognized that improvements to the RWP system were warranted, w e eter to Make changes until after the outage. The inspector will monitor progress in this ar A during future inspection .0 ALARA Uodalg During past NRC specialist inspections, it was noted that personnel exposure estimates did not closely approximate actual exposures received in the field. In most cases, projections exceeded actual exposures by a considerable margin (see NRC Inspection Report #50-443/9219).

The inspector reviewed ALARA performance during the current inspection. As of October 5, 1992, estimates for all major radiological work efforts were tracking very closely with anticipated levels. For example, the resistance temperature detector bypass climination, which was the highest exposure job of the 1992 outage, was near completion and had an actual exposure of 63 person rem as compared to the estimate of 65 person-rem. The outage goal to .

date (10-5-92) of 110.5 person-rem showed a strong correlation (approximately 105 %) with the 116 person-rem which had actually been accumulated. Actual exposure results may be adjusted to some degree once the official TLD results have been recorded. The inspector will again review performance in this area after the final results for the outage are compile .0 Internal Exposure Control The inspector reviewed the licensee's program for tracking internal exposures to radionuclides as a result of airborne concentrations of radioactivity. The licensee's procedure HD0958.21

"MPC-hout Calculation", Section 8.1.6 specifies that radiation workers with 0.1 MPC-hrs or greater, determined by air sampling, will be documented on the MPC-hour' Worksheet, HD0958.21 A. This worksheet is then forwarded to HP Records to be included in the Exposure Status Report. At the time of the inspection, no MPC-hrs had b:en assigned to individuals, l:

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The inspector reviewed the licensee's program for investigation of internal exposure incident There were five and appropriate investigations had taken place in each cas .0 lixit Mecilog The inspector met with the licensec representatives listed in Section 1.0 of this report on October 9.1992. Inspection findings were discussed during the inectin ,

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