IR 05000245/1992026
| ML20128E172 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/24/1992 |
| From: | Nimitz R, Noggle J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20128E134 | List: |
| References | |
| 50-245-92-26, 50-336-92-28, 50-423-92-22, NUDOCS 9212080015 | |
| Download: ML20128E172 (21) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos. 50-245/92-26 50-336/92-28 50-423/92-22 Docket Nos. 50-245 50-336 50-423 License Nos. DPR-21 Category C DPR-65 Category .C -
NPF-49 Category C Licensee: Northeast Nuclear Energy Comoany P. O. Box 279 Hartford. Connecticut 06141-0270 Facility Name: Millsne Nuclear Generating Station Units 1. 2. an.1L3 -:
Inspection At: 'Waterford. Connecticut Inspection Conducted: Oc:ober 19-23 and November 2-6.1992 Inspectors: R l_ N e"d i d2.o l et t ,
R. L. Nimitz, CHP date Senior Radiation Specialist b (Tg 4 - O 'Y 7 L J. NogglyIbqiatj() Stibcialist ' dat'e
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l Approved by: . //b, s . /
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6 #- // -2 Y- 7L l
/W."J.14sdaCChief date L Facilitic Radiation Protection Section l
l l Areas Reviewed: The inspection was an announced inspection of the radiological controls, l radioactive waste handling, and radioactive waste transportation programs. Areas reviewed were
, important to health and safety and included : act un on previous findings; audits; organization l' and staffing; solid radwaste streams; transportation and solid radwaste- steam generator p shipment preparation; radioactive and contaminated material, and contamination . controls; I radiological controls; and housekeepin .
-9212080015 921127 PDR ADOCK 05000245 G PDR
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- Restlts: Action on previously identified matters was good. The radwaste and radiological controls organizations were adequately staffed. Good control of radioactive and contaminated -
material and contamination was identined but two issues associated with identi0 cation of a contaminated gauge in a warehouse and lack of denned alarm set points for site egress portal monitors were identified as issues needing further review. The circumstances surrounding the release of the contaminated gauge is considered an unresolved item. Preparation and planning for shipment of the Unit 2 No. 2 steam generator were good.^ The radiological controls program ,
was considered overall to be effective in reducing aggregate radiation exposure of personne One cited violation was identified. The violation involved failure to collect representative samples of Unit 2 resin shipments for purposes of curie determination (Details Section 6.0). One non-cited violation was identified. The non-cited violation involved failure to post certain High radiation Areas within containment (Details Section 9.3).
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DETAILS Individuals Contacted Northeast Nuclear Energy Company .
1,2 M. Nappa-Althouse, Supervisor Radiological Protection 1 M.13rennan, Radioactive Material Health Physics Specialist -
1 T. Burns, Health Physics / Chemistry Training Supervisor 1 G. Closius, Assessment Services Supervisor -
1 J. Doroski, Senior Engineer 2 R. Factora, Unit Services Director J. Feluso, Unit 2 Reactor Operator J Hill, Unit 3 Reactor Operato G. Holts, Health Physics Support W. Koste, Radwaste Systems Engineering Supervisor 1 J. Laine, Senior Scientist 1 A. LaMan, III, Radioactive Material Health Physics Specialist L. MacNielson, Health Physics / Chemistry Instructor G. Newburgh, Station Engineer i C. Palmer, Manager, Health Physics Support 1 F. Perdomo, Site Compliance Licensing 1 W. Robinson, Assistant Radiation Protection Supervisor - Support ,
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M. Ross, Unit 1 Assistant Operations Manager 1,2 R. Sachatello, Unit 3 Radiation Protection Supervisor 1 G. Seckinger, Assistant Radioactive Materials Handling Supervisor 2 P. Strickland, Unit 1, Radiation Protection Supervisor S. Turowski, Radioactive Material Handling Supervisor 2 J. Sullivan, Health' Physics Operations Manager .2 LISNRC 1 K. Kolaczyk, Resident Inspector 2 A. Assars, Resident inspector 1.3- Ditten 1 R. Haight, Connecticut Yankee Radwaste 1 R. Tucker, Senior Engineer, Yankee Atomic 1, Denotes those individuals attending the exit meeting on October 23,199 , Denotes those individuals present at the exit meeting on November 6,1992.
j' The inspector also contacted other licensee employees.
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4 Purpose and Scepe of Inspection The following areas were reviewed during this routine, unannounced radiological controls inspection:
RadwastrJitorage. Handling and Tranjoortation
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action on previous findings
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organization and staffing
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audits
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waste streara analysis __
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transportation and solid radwaste Jtadiological Controls
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action on previous findings
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audits
- routine radiological controls activities
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preparation of Unit 2 No. 2 steam generator for shipment
- radioactive and contaminated material control; and contamination controls Previousiv Identified items (Closed) Unresolved item (50-245/92-03-01) Unrestrichd release of waste oil at efnuent Lower Limit of Detection (LLD) level The licensee has procured the instrumentation and provided on-site ~
laboratory facilities for counting oil samples to environmental LLD level A new procedure was written," Environmental Spectrometer Operation",
HP 90ST, Rev. O, which reflected the appropriate low counting levels for the release of oil and granular solid wastes. Technicians have been trained and have demenstrated successful operation of this facility. This item is close .2 (Open) Inspector Follow-up Item (50-245/90-15-01) Process evaporator bottoms in Tank C. The licensee has processed most of the radioactive liquids in the "C" concentrated Waste Tank and plans to empty the tank bottom sludge and permanently remove the tank by the end of 1992. The inspector will revisit this area upon completion of the radwaste removal activities during a future inspectio .3 (Open) Violation (50-336/92-16-01) The licensee did not provide training of personnel in use of certain respiratory protective device The inspector reviewed this matter relative to the corrective and preventative
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5 l actions outlined in the licensee's September 18, 1992, response to the
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Notice of Violation (Reference NRC letter dated August 5,1992). The inspector's independent review indicated that the licensee implemented all t 4 short term corrective actions identified in the iv.,er. The licensee temains ;
to complete continuing training for appropriate personnel (due December 31,1992), upgrade the respirator training program (due January 1,1993), I and assess the respirator training program content and implementation (due December 31,1992). This item remains open pending NRC review of completion of the above item .4 (Open) Violation (50-336/92-16-02) Personnel did not perform adequate radiation surveys. The inspector reviewed this matter relative to the corrective and preventative actions outlined in the licensee's September 18,1992, response to the Notice of Violation (Reference NRC letter dated
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August 5,1992). The inspector's independent review indicated that the
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licensee implemented all short term actions identified in the letter but remained to complete continuing training. The training is scheduled to be completed on December 31,1992. This item remains open pending NRC review of completion of training.
1 MLditt s 4,1 Opmend The inspector reviewed the licensee's audits of radwaste and radiation protection activities The review was with respect to criteria contained in Technical Speci0 cations, p . r:R 71, and 10 CFR 2 The evaluation of the licensee's performance in the area of audits was based on independent observations of on-going activities, reviews of selected records and reports, and discussion with cognizant -licensee
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persoime ,2 Midits of R_adwaste Processing.3.terge,_liandlipg. and TrrAspurialica .
The most recent Quality Assurance Audit of the licensee's solid
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radwaste/ transportation prog was dated August 14, 1990. This audit was reviewed dr * - a previv .spection. The biennial Tdit of the licensee's progt . As being conducted during this inspection. The
results of this audit will be reviewed during future periodic inspections of this area. An in-house radwaste appntisal was performed during June and l
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July of 1992. The results of this appraisal had not yet been published t.ut the inspector reviewed a draft version of the program appraisal, No signincant safety items weie identiDe ;
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6 , htdits of Radia..un Protection The following audits, assessments, and appraisals were reviewed:
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NRB Audit A21046,1991 Technical Specification Audit
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NR13 Audit A22046,1991 Technical Specl0 cation Audit, Millstone
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- 1992 Unit Staff Training and Qualification Audit
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1992 Yankee Appraisal of Radiological Controls
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1992 Industry Audits of the Millstone Station
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Quarterly Radiologleal Controls Performance Tracking Documents .
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Weekly Walk Through Surveillances The following matters were identified:
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The licensee had not yet performed a new audit of the radiological controls program area. The inspectors had reviewed the previous audit. The licensee's radiological controls personnel and QA personnel were initiating effem to develop an audit scope document to ensure that all applicabic radiological controls program areas were audite T' e licensee performed an audit of radiological controls personnel training and qualifications. The audit was considered goo The licensee's corporate radiological controls group had performed appraisals of selected radiological controls program areas and had performed weekly station walk through assessments. These were considered of generally good qualit The inspector's review indicated that the licensee had improved audits of the radiation protection area, that audit findings were brought to station management's attention, and that audit findings were properly addressed.
L No safety concerns or violations were identifie .0 D1gamration 5,1- General The inspector reviewed the on site staffing of the radiological controls and L
radwaste/ transportation organizations, The inspector reviewed this area
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with respect to criter;a contained in the licensee's Technical Specifications, f
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7 i The evaluation of the licensee's performance was based on review of i
, select d records and documentation, mdependent observations of on-going {
work activities, and discussions with cognizant personne ,
i Itadwaste/Transoortation :
The Radioactive Material llandling (ItMil) group processes wet solid i radioactive wastes, compacts dry activated waste (DAW) and provides
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some decontamination and material handling capabilities as well as providing for the shipments of radioactive wastes from all three unit The radwaste/ transportation organization was stablu and conshted of: a supervisor, a technical support staff of three, and an assistant supervisor -
who directed approximately 11 radioactive material . handlers and y
approximately eight laborers. The organization was expanding to include dedicated health physics (llP) technicians to support the survey requirements of this organization, llistorL tily, this had been provided by y the unit operations llP group on an as necced basis. The inspector noted that the llP technicians were performing various dedicated functions and ,
were on permanent loan to the RMII group, r
No safety concerns or violations were identine .3 Radiological Controls Organization j
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There were no significant changes in the radiological controls organization since the last inspection in this area. The organization was stable and the licensee was atinuing to 011 positions, previously Rlled by contractors, vith permanent personnel, b o safety concerns or violations were ident10cd.
! Solit tRadwaste Waste Streams The inspector reviewed processing of radioactive waste and the licensee's evaluation of the various waste streams at each of the three units. The L following was noted:
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Unit 1 produces fuel pool demineralizer and Reaceor Water Cleanup demineralizer bead resins as well as condensate
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demineralizer resins, floor and equipment drain radwaste filters,
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and Door and equipment drain demineralizer waste. There were
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nine separate waste streams sampled for Unit ;
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Unit ? produces letdown and primary demineralizer bead resins
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and aerated waste filter and demineralizer resin waste Eight i waste streams were sampled for Unit j j
- Unit 3 produces aerated demineralizer resin wastes, letdown !
wastes, and boron deminerallrer wastes. Unit 3 also produces ;
spent resins from processing of the primary system liquids, spent resins from the processing of the liquid waste system, and ;
demineralizer head resins from the condensate polishing facilit Eight waste streams were sampled at Unit 3. All station spent ,
demineraliter resins are discharged into liigh Integrity Containers ,
(IllCs) and de watered prior to shipment and buria !
- Each unit also had an additional waste stream consisting of Dry l Active Wastes (DAW). 1
lloth Units I and 3 used vendar supplied filling of high integrity containers, sampling, and de watering service which utilized an in-line I
resin sampling device to achieve representative samples of each lilC during the fill operation. The samples of the Unit i and Unit 3 waste streams adequately represented the waste streams mentioned above. The various wastr Mms were sampled within NRC time guidelines' (within -
two years for class A wastes and within one year for class 13 and C t wastes). The inspector noted that the on site collection of Dry Active Waste (DAW) wa kept segregated by each unit to allow unit specific >
scaling factors to be applie ;
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The following apparent violation was identified:
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The Unit 2 radwaste facility has a lilC filling system.- Resins are de-watered using plant equipment ud procedures. The spent resin tank and lilC filling components'have no provision for resir mixing or in-line sampling. Several demineralizer vessels contenta are normally sluiced into the spent resin tank prior to discharging the tank into a 111C. These contents would be expected to stratify in both the spent. resin tank and in the 111C. The inspector's review indicated that the licensec - determined radionuclide
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concentration for each shipment by taking one dip sampl af resin from the top of the filled radwaste 111C. The inspector % review ~ ,
of past shipping records indicated dose rate readings from past i Unit 2 spent resin shipments had shown wide spatial variation in dose rates on the same 111C. The lack of any mixing apparatus i May 1983 Branch Technical Position on Waste classification
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suggests the potential for stratification, as indicated 'uy spatial !
variations in dose rates in individual lilCs, that suggests the dip sample method does not provide for representative sampling and i does not provide reasonable assurance that accurate radionuclide concentration determinations, for purposes of shipping and burial
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of wastes were made. Further, the licensee has not performed an evaluation that correlates their sampling method with actual :
measurements. This was an apparent violation of 10 CFR 61.55 (a)(8) which states that "The concentration of a radionuclide may i
be determined . . . If there is reasonable assurance that the indirect methods can be correlated with actual measurements."(50-336/92-28 01) )
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The licenso identified several options which would improve their
sampling txhnique. These included: modification of the spent resin tank piping to provide a recirculating pump to promote mixing, installation of an in line sampler !n the piping between the spent resin tank and the HIC fill station, and the use of a multi-port sampling tube for manual grab samples of filled HIC .0 Transportation and Solid Radwasig
, General L
The inspector reviewed the transportation and solid radwaste programs at each of the three Unit .
The radwaste and transportation programs were the responsibilities of l cach of the hiillstone unit's Operations Departments and the responsibility of the Radioactive Materials Handling (RhiH) Group that was common to ,
all three units. The individual power plant unit Operations Deprtment was responsible for the processing of liquid radwaste and provided the various fdter media and waste resins for the RMH group to de-water, sample and ship for buria .2 Transoortation .
The inspector reviewed the following radwaste/ transportation procedures:
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Shipment of' Radioactive Material - General Guidelines, RW 46000, Rev. 0
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Shipment.of De-watered Waste - Waste Processing Facility, RW -
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Compliance with 10CFR61 - Waste Classification, RW 46041, Re Receipt of Radioactive Material, RW 46046, Rev. 0
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Shiptnents of Radioactive Material - 1.ow Specific Activity, RW 46004, Rev. 0 *
- Shipment of Dry Active Waste - Waste Processing Facility, RW 46017, Rev. 0
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Shipment of Solidified Waste - Barnwell Waste Management !
Facility, RW 46022, Re }
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Shipment of Dewatered . Waste Barnwell Waste Management Facility, RW 46021, Re Shipment of Irradiated Waste - Ilarnwell Waste Management Facility, RW 46024, Re Cask llandling Procedure - CNS 1419011, RW 46071, Re Cask llandling Procedure - CNS 1419511, RW 46072, Re :
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Handling and Loading of the TN RAM Shipping Cask, Waste Chem 1006
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Resin Drying (Dewetering) System, NuPac Services OM 43, Rev.-
The inspector found the procedures to be of good quality and the self contained procedures incorporated all of the regulatory and Millstone Process Control Program requirement The inspector witnessed the loading, surveying, and placarding of a
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Reactor Water Cletm Up Resin shipment no.92-059 1 on October 22, 1992. The licensee utilized a company owned shipping cask to allow an open air transfer of a filled lilC to the shipping cask. The liner was surveyed to read 40 R/hr. The RMil group organized ~ several HP technicians to cordon off the surrounding area prior to the transfer. All ,
essential personnel were well briefed and signed in on an RWP. The lilC was transferred very smoothly and the lip technicians proved to be stationed at the 4 mR/hr dose rate level and were effectively.able to control exposures. The RMH group with conwnt QC accompaniment ensured a thorough survey was performed, the truck inspection was-completed, the cask seal and lid ratchets inspected and the cask was secured by a calibrated torque wrench. A thorough job was performed, with no unnecessary exposures involved, and all regulatory requirements for shipmer.t were met. ,
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The following shipping records were reviewed by the inspecto , _ _ . _
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Shipment N Activity (Ci) Volume (Ft') Type 92-133-2 1320 6411 Steam Generator 92-059-1 177 132 Ilesin 92-032-3 0.02 901 DAW 92-113-2 0.01 700 Laundry
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92-054 1 3E-4 Samples 92-034-3 I E-5 Samples 92-051-1 0.06 720 Equipment 92-046-1 9.37 174 Ilesin 92-053-2 0.22 570 DAW 92-025-3 .
570 DAW All shipping records were determined to be complete and to meet the applicable requirements of 10 CFit Parts 20, 61, and 7 and 49 CFR Parts 171 178. The inspector reviewed the shipping cask CertiGcates of Compliance and veriGed that all consignee licenses were on file as require ~
No safety concerns or violations were identine .3 StralAGt0Clal0LShipment Preparation The inspector reviewed the Ucensee's preparation of the Unit 2 N steam generator for ,hipment to llarnwell, South Carolina. The inspector mdependently revbwed the on-going preparation. The inspector reviewed the preparation . elative to the steam generator's Certincate of Compliance (C of C) as a stand alone package. The inspector also reviewed the licer/,ee's conformance with criteria contained in the Safety Evaluation lleport submitted to the NR The inspector did not identify any anomalies. The licensee was preparing the shipment consistent with criteria contained in the C of C and Safety Evaluation Repor _ _ _ _ - _ _ - _ - - _ _ _ _ _ _ - - _ - _ _ - _ _ _ _ - - __ _ _ _ _ _ _ _ _ _ _ _ _ _
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The documentation associated with the shipment of Unit 2 No. 2 steam generator was also reviewed (See Section 7.2.).
No safety concerns or violations were identifie .4 OtnntLOn-site inventoty_amLntimtimuim_QuittStorage Plans The licensee maintains a sizable radioactive material inventory in warehouse no. 9 consisting of reusable contaminated equipment for potential future use. Each sontainer is scaled and contamination free on the external surface 3. A bat code reader system is used to provide an accurate computer inventory. No significant dose rates existed and effective controls were being maintained in this equipment storage area. At the time of g this inspection, the backlog of on site shippable radwastes consisted of four compacted waste boxes and two compacted waste drums. The licensee successfully minimized the on site accumulation of radwastes with no safety hazards detecte The inspector reviewed the licensee's plans for the interim on site storage of radwasics following burial site closure at the end of 1993. In 1981, a concrete bunker was built at Millstone for the storage of radwastes The bunker structure dimensions are 105 feet by 100 feet by 13 feet high for a storage capacity of approximately 144 lilCs of spent resin that the licensee estimates will be suiReient capacity for four to eight years of station produced spent resin wastes. Storage for station produced DAW is still in the study phase with no final plans yet developed. This issue will be revisited in a future periodic inspections of this are No safety concerns or violations were identifie .0 Bildicattirtinld Corliaminated Matttiakand Cont sinatian Controls On1 tral The inspector toured each of the units and reviewed controls for radioactive and contaminated material and contamination controls. The inspector also reviewed the licensee's controls for unrestricted release of equipment and material The inspector reviewed the equipment survey monitoring operations, the Itadiological Controlled Areas (RCAs) access point monitors, and the station protected area access point monitors to evaluate the licensee's control of radioactive material leaving the station. The inspector also reviewed two automatic equipment monitoring operation In addition, the inspector used a radioactive smear paper sample to challenge contamination monitoring equipment at selected egress point I
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The following matters were identified:
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The Radioactive Material llandling (RMil) Group provided for monitoring and release of equipment and material. Approved procedures provided material ^
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release criteri A wood frisking station was in use that consisted of an array of beta gamma detectors located above a controlled speed conveyor system. This counting _ ,
system adequately alarmed when tested by the inspector with a smear of plant derived radionuclides at an activity level corresponding to the plant release criteri ;
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The inspector witnessed the operation and tested the alarm sensitivity of a scaffold pole monitor that consisted of four scintillation detectors mounted in a squar array. Cylindrical metal scaffold poles were fed into the detector array by a conveyor belt system. The alarms sounded when the test smear was placed inside of a clean scaffold pole 'and fed between the detectors by the fixed speed conveyo Other equipment was being surveyed by conventional hand held friskers with
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appropriate instrument alarm set point The inspector reviewed the RCA boundary controls and noted that a minimum number of access points were provided for each of the three units in addition,
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whole body personnel _ contamination monitors were provided at each of these egress points to monitor personnel. These units appropriately alarmed when teste ;
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For the release of hand held equipment, gamma sensitive Small Article Monitors (SAMs) were frequently provided to release objects smaller than 1 cubie' foot in size. Standard 0 M pancake probe friskers were also available at each egress point from the RCAs. These equipment monitors alarmed when tested by the inspecto The following matter was brought to the licensee's attention:
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At both the North and South Access Points (NAP and SAP) to the Millstone Protected Area,' there were several portal monitors. None of these monitors ,
would alarm when tested with the specified test sample. The inspector reviewed the calibration criteria with the licensee #rocedure up 904/2904/3904D, Re I1 entitled," Calibration of Fixed Monitors"). The procedure did not specify a ,
particular source strength to use during calibration nor did it provide any
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requirement for setting the alarm or provide any guidance for adjusting the alarm set poin 'Ihe inspector noted that although the licensee provided for monitoring of all personnel and (quipment leaving the station's radiological controlled areas md the portal monitors provided back-up monitoring, the lack of defined alarm set points was considered a weskness. The licensea agreed to revise this procedure to maximize the sensitivity of the portal monitors to prevent the inadvertent release of radioactive material off-sit The inspector noted that equipment and material to be removed from the protec'ed area was required to be surveved for contamination by a radiological controls technician prior to its release. A clearance tag was then affixed to the material or equipment, lloth radiologier.1 controls personnel and security personnel sign-off on the clearance ta The following additional matter was identified:
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The inspector's discussions with licensee personnel indicated that a gaage, located in a warehouse outside the radiological controlled area (RCA), was found to be internally contaminated. A technician, who had obtained the gauge from the warehouse, became suspicious that the gauge may be contaminated when he found residue inside the gauge after he disassembled it. The technician contacted radiological controls personnel who subsequently surveyed the internals of the gauge and identified contamination levels of about 50,000 disintegrations per minute (dpm). The gauge was immediately returned to the RC In light of the above, the inspector reviewed the licensee's procedures for release of material from the RCA in order to evaluate the adequacy of control of release of material that may potentially be internally contaminated. The inspector found the procedures to be more than adequate in this area. The licensee indicated that the gauge may have been released prior to strengthening of the program for cointrol of contaminated material. The licensee immediately initiated a program to inventory and survey equipment located in the warehouse where the gauge was found. The inspector indicated the circumstances surrounding the contaminated gauge found outside the RCA was an unresolved item (50 245 /92-26-01).
No violations were identifie .0 Ihdiological Controls General The inspector reviewed the implementation and adequacy of radiological controls at Units i
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The evaluation of the licensee's performance was based on discussions with cognizant personnel, review of inspector selected documents, and independent inspector observations of on going work activities during tours of Millstone Units 1,2 and 3, 9i2 Un!!s I and 3 The inspector reviewed routine radiological controls activities at Units 1 and 3. The following matters were reviewed:
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posting, barricading and access control as appropriate, to Radiation, liigh Radiation and Althorne Radioactivity Areas s !
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liigh Radiation Area access control .
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personnel adherence to radiation protection procedures, radiation work permits and good radiological control practices and ,
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use of appropriate and accredited dosimetry devices Yhe evaluation of the licensee's performance in this area was based on discussions with cognizant personnel, observations during tours, and review of document The following matter was identitled:
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During review of radwaste activities, the inspector noted that a relatively high scaling (actor was used for Pu-241 for Unit 1 dry activated waste (DAW). This was determined from the latest-Unit 1 DAW off site
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radiochemical and spectremetry analysis of the Unit -1 surface -
contamination constituents l The current scaling factor infers a Pu-241 contribtition based on _14% of the Co-60 activity (cobalt 60 being the i predominaat radionuclide at Millstone). As the DAW samples are taken ,
from representative areas within the plant, the scaling factor analysis should also correspond to the contamination work environment of the l radiation worker.
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The inspector noted that the Maximum Permissible Concentration (MPC) in air.
l for losoluble Pu-241 is 100 times lower than the MPC in air for Cobalt 60,
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therefore the MPC value for Pu-241 would be more limiting than the Co-60 MPC value when present at a 14% value.- Pu.241 cannot be directly measured with standard radiation detection instrumentation at this station, but can be inferred based on the measurement of a related tadionuclide that is measurable (e.g. other transuranics).
The inspector reviewed the adequacy of the air monitoring program to detect and -
measure the potentially limiting Pu-241 radionuclide. The inspector reviewed this
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program and air sample records to ensure appropriate instrumentation and limits were included in the program to account for these non-gamma emitting '
radionuclides. Appropriate procedures and past air sample records indicated a routine alpha measurement of high contamination samples. The inspector's review determined that the licensee had evaluated this matter and had selected the most appropriate MPC based on potential alpha emitters present, llowever, the
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following matters were brought to the licensce's attention:
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The licensee did not have a formal program to review periodically the mix of radionuclides found at the station to ensure that the radionuclide mix was periodically evaluated and that the MPC of the appropriate rad;onuclide (as appropriate) found at the station, was selected for personnel protection purpose The licensee did not have a formally described program to ensure that the radionuclide iaix at the station was periodically reviewed to ensure that radionuclide calibration sources were evaluated to ensure that the appropriate radionuclide was selected as a calibration standard. However, this review was being informally performed
- The licensee was using the concept of " effective" MPC for selecting the most appropriate MPC for the radionuclides present. This concept was not specified in regulatory requirement The inspector did not IOntify any indication that workers were not provided appropriate radiological protection relative to selection of appropriate MPC values. The licensee's personnel indicated that the above matters would be reviewe The following additional matter was reviewed:
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The inspector noted that on October 2 /, J92, during clean-up of the Unit I spent fuel pool, a smali piece of radioactive debiis (hose) floated to the surface of the pool. The inspector reviewed the actions taken by the radiological controls personnel overseeing the work when the debris floated to the surface. The inspector's review indicated that personnel took effective actions to minimize personnel exposure in that the area was evacuated and long handled tools were used to extract the debris from the pool for disposal. Maximum contact exposure rate on the hose was about 50 R/h The inspector's review of this matter relative to suggestions contained in NRC Information Notice No. 90-33, Sources of Unexpected Occupational Radiation Exposures at Spent Fuel Storage Pools, dated May 9,1990, and NRC Information Notice No. 90-47, Unplanned Radiation Exposures to Personnel Extremities Duc
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i to Handling of Potentially Highly Radioact've Sources, dated July 27, 1990,
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indicated personnel were aware of these information Notices and ptecautions tc, preclude unplanned exposures, suggested in the information Notices, had been
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adopted by the license No "lolations were identified D Umt2 The inspector reviewed the lleensee's radiological controls for the on going removal and replacement of steam generators at Unit 2. The inspector teviewed ALARA controls fo ,
the work relative to criteria contained in the following:
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Regulatory Guide 8.8, Information Relevant to Ensuring that Occupat -
Radiation Exposures at Nuclear Power Stations will be As Low As is Reasonably Achievable
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Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational-Radiation Exposures As Low As Is Reasonably A:hievable
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NUREG/CR4254, Occupational Dose Reduction and ALARA at Nuclear Power Phnts; Study on High-Dose Jobs, Radwaste Handling and ALARA Incentive NUREG/CR-1595, Radiological Assessment of Steam Generator Removal and Replacement: Update r.nd Rcvision The inspector toured the Unit 2 facility and independently reviewed on going radiological ,
controls activities. l'he inspector made entries into the loop areas to review on-going activities and make rtd;ation surveys to verify radiological posting:: and adequacy.of licensee controls. The following elements of the license's radiological controls program were reviewed:
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posting, barricading and access control as appropriate, to Radiation, High 3 Radiation, and Airborne Radioactivity Areas
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High Radiation Area access point key control
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personnel adherence to radiation protection procedures, radiation work permits and good radiological control practices
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use of appropriate and accredited dosimetry devices
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airbcrne radioactivity sampling and controls
- installation, use and periodic operability verification of engineering controls to minimize airborne radioactivity
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adequacy of radiological surveys to support pre-planning of work and on-going . ,
work
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calibration and checking of radiological survey instrumentation use to collect airborne radioactivity samples or perform radiological surveys
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hot particle control ;
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The inspector's review indicated generally good radiological controls were implemented for the work activities reviewed. Planning and preparation for work activities was l commendable. There was gomi supervisory oversight of these activities. Observations ;
indicated very good efforts to maintain ra#ation exposure ALAR l The following matters were identified: ,
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- During tours of the loop areas of the Unit 2 containment on November 5,1992, the inspector noted that the areas behind the reactor coolant pumps were prominently posted as ALARA ALERT areas with radiation dose rates clearly posted on the ALARA ALERT signs. The areas exhibited general area radiation ;
dose rates of between 100 mR/hr and 300 mR/hr. The inspector also noted that the areas behind the reactor coolant pumps were shown on colored charts and 6 displayed at the main access contrci point to the loop areas on the -3'6" elevation of containment. The inspector noted however, that although the informational posting clearly provided workers information on the radiation dose rates in the loop areas, the individual areas (behind each reactor coolant pump) withir, the loops that exhibited radiation levels greater than 100 mR/hr, were not individually posted as High Radiation Areas. In addition, the pressurker block house was not oosted as a High Radbtion Area but was posted as an ALARA ALERT are .
The inspector did note that the access doarway (at the 3'6" elevation of containment) to the lower elevation of containment and the loop areas was prominently posted as a High Radiation Are The licensee stated that the areas behind the pumps were not posted because of the extensive on-going work and the possibility that scaffolding or other components supporting the signs ivould be removed resulting in removal of the High Radiation Area posting. As a result, the licensee elected to post the main entrance to the loop areas and the 22' elevation of containment as a High Radiation Area in lieu of posting the individual High Radiation Areas within the ,
, loop The inspector indicated that it was appropriate that the individual areas behind the reactor coolant pumps be posted as High Radiation Areas because of the following reasons:
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- 10 CFR 20,203 (c.) specifies that each High Radiation Area shall be conspicuously posted with a sign or signs bearing the radiation caution syrnbol and the words:
Caution High Radiation Area
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The majority of the le>p areas and the -22' elevation were not liigh Radiation Areas. Consequently, the posting on the access door to these areas (located on the 3'6" elevation) indicated that the entire areas of the loop and the +22' elevation were liigh Radiation Areas when in fact they '
were no The ALARA AIERT signs were posted in a conspicuous manner indicating that signs could readily be posted to show that the areas behind the reactor coolant pumps were liigh Radiation Area Individual liigh Radiation Areas on the -22' elevation of containment were properly posted as liigh Radiation Areas The licensee requested clarincation on this matter. As a result,.the inspector initially indicated to the licensee that this matter was unresolved pending review of the particular circumstances surrounding this posting issue. On November 20, 1992, after review of the circumstances surroundmg this posting issue at the NRC
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Region 1 Ofnce, the licensce was informed by telephone that the failure to post .
the individual areas behind the reactor coolant pumps in the Icop areas, including the t ottom of the pressurizer block house, was an apparent violation of 10 CFR 2P 203 (c) which requires such posting.110 wever, the inspector noted, that this fiading had minor safety significance since the areas _wcre well posted with informational signs, the main access point to the loop areas was posted with maps which identified the liigh Radiatinn Areas, and individual Illgh Radiation Areas on the -22 elevation of containment were posted, as appropriate, with liigh radiation Area sign The licensee informed the inspector on November 20,1992, of the following:
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The licensee immediately took action to post the areas in question. Five areas were identified as potentially requiring additional signs. Three areas .
In loop 2 were posted and actions were initiated to post loop I areas i following suspension of radiography in the immediate are liigh Radiation Area postings at all three units would be reviewed and-signs upgraded, as appropriate, by November 25,199 Radiation Protection Supervisors at the three units were informed of this i matter and radiation protection technicians, as appropriate, would be informed within about two week Adequacy of guidance in procedures for posting will be reviewed by December 18,1992. If appropriate, the procedures would be upgraded
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by March 199 L
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20 in light of the above, the inspector indicated that consistent with the criteria of 10 CFR part 2 Appendix A, Section Vil,11.(1), this matter was not cited as a violatio During revicw of werk activities associated with inspection of the rotating element of the A reactor coolant pump on November 2,1992, the inspector made the following observations:
- The radiation survey for the pump shaft (dated October 30, 1992)
incorrectly showed radiation dose rate data for the bearing journal of the shaft when the data was actually for the hydro-static bearing. The technician entered the data at the incorrect locatio A radiation survey used to evaluate the potential radiological hazards for beta radiation doses to the skin of the face did not clearly show that all beta radiation dose rates were attenuated by the face protection to be worn by workers to inspect the rotating element as implied by the radiation protection technician overseeing the activity. Initial beta radiation dose rates indicated greater than 100 rad /hr (upper value not determined) at the locati on to be inspected by the worker The licensee's personnel immediately evaluated the situation and concluded that all dose rates were attenuate The inspector indicated that la light of the abovn observations, additional attention to correctly documenting and evahiating beta radiation dose rates appears warranted. The licensee indicated that these observations would be reviewe ' thnntLCmclusions Regarding Radiological Contrnis The inspector's observations indicated that the .Rnsee's applied radiological controls practices generally were very good relative to measures taken to reduce overall exposure of personnel. For example, the following was noted:
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To perform inspections of thtUnit 2 A reactor coolant pump rotating assembly, the licensee used a shielded up-ender device with access windows and ports {)
(similar to a reactor coolant mmp bowel) for handling and inspection of the rotating assembly. A specially designed shielded transport container was used to transfer the rotating assembly aut of the containmen The inspector's review of accumulated exposure attributable to the licensee's Unit 2 steam generator replacement activities indicated accrued exposure was generally consisteat with a priori established exposure goal For those areas where accrued exposure exceeded goals (e.g., welding of reactor coolant system pipir.g)
the licensee was able to show that the additional exposure was attributable to an I
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emergent issue and not weaknesses in planning or on going exposure control effort .0 Etation Toun The inspector toured the station periodically during the inspection. The following matters were noted:
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Unit 1
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liousekeeping was considered goo Unit 2
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llousekeeping was considered goo Two instances of personnel reading extraneous reading material (e.g.,
magazines) inside the RCA were brought to the licensee's attention. One individual was a radiation protection technician at the Unit 2 truck ba The other individual was a fire watch at the access point to the No. I steam generator girth weld are Unit 3
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llousekeeping was consideied goo Nyion rope was found inside a conduit on the 24' elevation of the Radwaste lluildin Cardboard boxes containing filter elements were found inside the Unit 3
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radwaste building. The licensee's Ore protection personnel were aware of the boxes. The boxes were covered with fire retardant clot A caution sign that provided safety instructions to personnel accessing the spent fuel bridge was not installed and was found laying on a chai ,
The above observations were brought to the licensee's attentio I EliLMetthlg The inspectors met with licensee representatives (denoted in Section 1.0) on October 23 and November 6,1992. The iaspectors summarized the purpose, scope and findings of the inspection. No written mate ial was provideu :o the beense _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ . _ _ _ _ - _ _ - -___ _ _ _