IR 05000029/1979008

IE Insp Rept 50-029/79-08 on 790709-12.Noncompliance Noted: Improper Wearing of Dosimeters,Errors in Dosimetry Records & Radwaste Transfer in Unauthorized Form

ML19260A961
Person / Time
Site:	Yankee Rowe
Issue date:	09/17/1979
From:	Plumlee K, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19260A944	List: IR 05000029/1979008 ML19260A943 ML19260A950 ML19260A953 ML19260A958
References
50-029-79-08, 50-29-79-8, NUDOCS 7912060201
Download: ML19260A961 (10)

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U.S. NUCLEAR REGULATORY CCMMISSION 0FFICE OF INSPECTION AhD ENFORCEMENT

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Region I

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Report'No.

50-29/79-08 _

Occket No.

50-29 License No. DPR-3 Priority

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Category C

Licensee:

Yankee Atomic Electric Company 20 Turnpike Road

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Westborough, Massachusetts 01581 Facility Name:

Yankee Nuclear Power Station (Yankee-Rowe)

Inspection at:

Rowe, Massachusetts Inspection conducted:

July %12,1979

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Inspectors: /' E. Plumlee, Radiation Specialist K.

date signed date signed date signed kcn 7h7/77 Approved by:

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J. P.

O r,. Chief, Rhdiation Support

' date signed Secti FF&MS Branch Inspection Summary:

Inspection on July 9-12, 1979 (Recort No. 50-29/79-08)

Areas Inspected: Routine, unannounced inspection by a regional based inspector of radiation protection during operation including:

internal and external expo-sure control, procedures, posting and labeling, shipping of waste, notifications and reports, and outstanding items. The initial inspection and area examination commenced during non-regular hours (7 a.m. on July 9, 1979).

This inspection involved 32 inspector-hours onsite by one NRC regional based inspector.

Results:

Of the six areas inspected, no items of noncompliance were identified in three areas. Three items of noncompliance were identified in three areas (Infraction - improper wearing of personnel dosimeters, Paragraph 3.a; Deficiency -

errors in personnel dosimetry records, Paragraph 3.b; and, Deficiency - radwaste transfer in a form the recipient was not authorized to receive, Paragraph 5).

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7919060

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DETAILS 1.

Persons Contacted

• G. Babineau, Technical Assistent to Plant Health Physicist W. Billings, Chemistry and Health Physics Supervisor

• B. Colby, Engineering Assistant to the Plant Health Physicist

• L. French, Engineering Assistant to the Plant Superintendent J. Gottardi, Tester,1st Class (Union President, INUW Local No.1)

F. Newton, Station Shift Supervisor

• N. St. Laurent, Assistant Plant Superintendent (Acting Plant Superintendent)

• J. Staub, Technical Assistant to the Plant Superintendent J. Trejo, Plant Health Physicist

• denotes those present at the exit interview, July 21,1979, 2 p.m.

2.

Licensee Action on Previously Identified Items (Closed) Item of Noncompliance (78-19-01):

Form NRC-4 error.

Review of recently completed Form NRC-4's did not identify any errors.

The inspector had no further questions on this item.

(Closed) Item of Noncompliance (78-19-02): Adherence to instructions on radiation work permits (RWPs).

Observation of work practices during this inspection did not identify any items of noncompliance with instructions on RWPs.

The inspector had no further questions on this item.

(Closed) Item of Noncompliance (78-19-03):

Posting of radiation areas.

Observation during confirmatory surveys on tours of the facility did not identify any items of noncompliance involving posting or control of radiation hazards on this inspection.

The inspector had no further questions on this item.

(0 pen) Item of Noncompliance (78-19-04):

Training records - not reviewed on this inspection.

(0 pen) Unresolved Item (78-19-05):

Respiratory protection program policy statement - not reviewed on this inspection.

(0 pen) Inspector Followup Item (78-19-06):

Review spent fuel transfer tube shielding - not reviewed on this inspection.

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(Withdrawal) Item of Noncompliance (78-19-07):

Failure to maintain correct Form hRC-5 information.

Information provided during a management meeting held at the licensee's request, March 6, 1979, indicated that routine licensee review of computer data transfer operations would correct these errors before completion of Form NRC-5's.

No carryover of previously identified errors was identified (Paragraph 3.b).

3.

Exposure Control a.

Dosimetry Part of the inspection effort was to review compliance with requirements of 10 CFR 20.202 " Personnel monitoring," that:

"(a) Each lic;asee shall supply appropriate personnel monitoring equipment to, and shall require the use of such equipment by:

(1) Each individual who enters a restricted area under such circumstances that he receives, or is likely to receive, a dose in any calendar quarter in excess of 25 percent of the applicable value specified in paragraph (a) of 520.101...

(3) Each individual who enters a high radiation area.

(b) As used in this part, (1)

" Personnel monitoring equipment" means devices designed to be worn or carried by an individual for the purpose of meas.cing the dose received (e.g., film badges, pocket chambers, pocket dosimeters, film rings, etc).

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During tours of the facility, the inspector identified two chemistry technicians who were wearing their TLD badges loose in their trousers pockets, which were below the level of the work surface in the laboratory where they were working.

One indicidual was identified at about 9 a.m. on July 9, and the other at about 8:30 a.m. on July 11, 1979, at the same location.

In each example a bottle of primary system water rested unshielded on the work surface.

The inspector measured 3 mrem /hr at the point where the TLD badge was worn as found; 15 mrem /hr at the shirt-pocket level; and,100 mrem /hr on contact with the bottle.

With the bottle placed in the designated shielded position, the inspector measured 1 mrem /hr at the point where the TLD badge was worn as found; and 31/2 mrem /hr at shirt-pocket level.

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The inspector noted that the dosimeters worn c the trousers pocket appeared to monitor less than 1/3 the whole boa / dose rate, in either Case.

The inspector noted tnat self-reader dosimeters were worn at the shirt-pocket level in each example; however: the TLD badge information routinely excludes the self-reader dosimeter information from the Form NRC-5's.

The Form NRC-5's completed for these two individuals at the end of 1.he first calendar quarter,1979, indicated first quarter total doses to the whole body of 62 and 44 mrem, respectively.

Licensee records indicated that each of these individuals was authori;9d to receive a whole body dose up to 600 mrem in a week and 1,000 mre,

in a calendar quarter, as well as to enter high radiation areas.

The inspector identified the above as examples of noncompliance with requirements of 10 CFR 20.202 (29/79-08-01). As described under paragraphs 4.a and 11, these two individuals were not, as found, in full adherence with a licensee procedural requirement to wear the personnel monitoring equipment above the belt.

In each example, the individual appeared to be aware of this requirement and stated he had overlooked it momentarily.

b.

Dosimetry Records Part of the inspection effort was to review compliance with requirements of 10 CFR 20.401 " Records of surveys, radiation monitoring and disposal" that:

"(a) Each licensee shall maintain records showing the radiation exposures of all individuals for whom personnel monitoring is required under 520.202 of the regulations in this part.

Such records shall be kept on Form NRC-5, in accordance with the instructions contained in that form or en clear and legible records containing all the information required by Form NRC-5.

The doses entered on the forms or records shall be for periods of time not exceeding one calendar quarter."

Instructions contained in Form NRC-5 require the entry of the total exposure received during the calendar quarter.

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On a previous inspection, No. 29-78-19, licensee dosimetry record errors were identified which the licensee subsequently stated would be identified and corrected during the routine transfer of information in preparing Form NRC-5's.

A letter dated May 2,1979, notified the licensee of the withdrawal of the apparent item of noncompliance identifying the above errors, which the licensee believed would not carry over into completed Form NRC-5's.

Review of Fonn NRC-5's on this inspection did not identify any carryover of previously identified errors.

Routine review of dosimetry records of 10 individuals identified an omission to obtain computer printout of the Form NRC-5 for one individual at the end of the fourth calendar quarter, 1978, and failure to include the fourth quarter dose in the total occupatior,al dose shown on his Form NRC-5 prepared at the end of the first calendar quarter,1979.

Noting that his record was the only one of 10 that involved a lest badge, the inspector selected sir additional files indicated to involve lost badges, and fin additional examples were identified of omissions of part or all of the. indicated dose to each individual during the fourth calendar quarter, 1978, in their Form NRC-5's.

Three of the above involved omissions of 479, 44, and 40 mrem, respec-tively, in Form NRC-5's of individuals authorized to receive 600 mrem dose to the whole body in a week and 1,000 mrem in a calendar quarter.

The inspector identified the three examples as noncompliance with the above requirements. The inspector noted that the remaining examples were not in full adherence with licensee procedures (Paragraph 11)

(29/79-08-02).

The licensee representative stated that all of the records of personnel receiving in excess of 1,000 mrem during a calendar quarter were revicwed by the licensee.

The inspector observed that none of the above cxamples of noncompliance involved in excess of 1,000 mrem.

Review of routine computer diagnostic printout showed that the completion of data transfer was not indicated in the above example of a failure to print out one Form NRC-5, but completion of data transfer was indicated in the other examples.

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4.

Procedures Part of the inspection effort was to review compliance with requirements of Technical Specifications Section 6.11, " Radiation Protection Program," that procedures for radiation protection shall be prepared, approved, maintained, and adhered to for all operations involving personnel radiation exposure.

a.

Wearing of TLD Badges and Dosimeters Procedure No. OP-8403, Revision 3, "Use of Personnel Monitoring Devices,"

requires " wear the TLD and dosimeter on front of the trunk of the body, above the bel t..."

Observation and brief interviews with several individuals during tours of the facility indicated four individuals who had inadvertently placed their TLD badge in their trousers packets.

In two examples, described in Paragraph 2, this resulted in identifying examples of noncompliance with requirements of 10 CFR 20.202.

The inspector noted that about 10% of the persornel checked were found at that time to have their TLD badge below the belt.

In each example the individual stated thn this was an oversight and that he was aware of the above requirement.

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This item was reviewed during the management interview, Paragraph 11.

b.

Lost Badge Reports Procedure No. OP-8409, " Lost or Damaged Film Badges or TLD," requires that if an individual's badge is lost, a form, No. OPF8409.1 " Lost (Damaged) Film Badge /TLD Report," is to be completed, and if the badge remains lc3t the pocket dosimeter for the above period should be used as the official record of exposure for the individual involved.

Review of files of seven individuals (Paragraph 3.b) identified lost badge reports in only 3 of 7 instances indicated by computer printout to involve lost badges.

In those 3 instances there were two examples where the pocket dosimeter was not used correctly in the record.

1:e licensee representative stated that in one instance the input was delayed and the computer data processing routinely identified the lack of input of TLD information for the period as a lost badge.

In six of these examples, the computer failed to print the total required in Form NRC-5, Columns 12 and 13.

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Three examples involved individuals who were authorized to receive 100 mrem in a week and 250 mrem in a calendar quarter.

The inspector noted that although 10 CFR 20.401 did not specifically require the keeping of these records of exposures to these three individuals, the licensee procedures indicated the records would be maintained as for all individuals monitored.

This item was reviewed in the management meeting, Paragraph 11.

5.

Transfer of Radioactive Waste A requirement of 10 CFR 30.41, " Transfer of Byproduct Material," is that,

"(a ) No licensee shall transfer byproduct material except as authorized pursuant to this section," and "(c) Before transferring byproduct material...

the licensee shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of byproduct material to be trans-ferred."

A letter dated January 2,1979, from H. G. Shealey, Chief, Bureau of Radio-logical Health, South Carolina Department of Health and Environmental Control, addressed to G. W. Kerr, Oft ka of State Programs, NRC, informed of leakage of LSA liquid from containers u# low level waste shipped by Yankee Atomic Electric Company, as the licenzae, from this licensed facility.

The leak resulted in contamination of the transport vehicle and a parking apron on December 18 and 19,1978, at Barnwell, S.C.

The transferee's license does not authorize receipt of liquid waste (South Carolina License No. 097, Conditions 19 and 20).

The quantity of liquid on the pavement was estimated to be 100 ml.

The major radioactive isotopes in the liquid were indicated to be those listed bel ow.

Isotope S. C. Analysis Yankee-Rowe Analysis *

Cs-134 0.070 uCi/ml 0.059 uCi/ml Cs-137 0.074 uCi/ml 0.063 uCi/ml Co-60 0.010 uCi/ml 0.009 uCi/ml Co-58 0.003 uCi/ml 0.002 uCi/ml I-1 31 0.002 uCi/ml 0.004 uCi/ml I-133

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0.001 uCi/ml Mn-54 0.011 uCi/ml

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Fe-59 0.001 uCi/ml

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• This is the licensee batch analysis prior to the solidification process, Batch No. 765, December 7,1978, (evaporator bottoms) Shipment No.78-181.

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The inspector noted that the above concentrations of individual isotopes exceeded those indicated by 10 CFR 30.70, " Schedule A - Exempt Concentrations,"

and that a 100 ml volume of the cbove concentration contained several times the quantity indicated by 10 CFR 30.71, " Schedule B - Exempt Quantities,"

thus the liquid was not exempt from the above requirement.

The identified quantity of radioactive material that leaked was about 15 uC1. Licensee records indicated that the two 55 gallon drums that leaked contained 13.2 and 12.2 mC1 (drums #80496 and 80498, respectively).

If most of the leak was from a single drum, only about 0.1% of the contents leaked out.

The drumming operation curvey sheet was dated December 7, 1978, and the shipping documents were dated December 13, 1978. The transferee was Chem-Nuclear Systems, Inc., Barnwell, South Carolina.

The inspector identified this as noncompliance with the above requirement (29/79-08-03).

The licensee stated that actions were implemented to preclude any recurrence of the above including:

a.

Solidified material will hereafter be kept indoors a minimum of 30 days before shipping.

b.

The quantity of liquid placed in each drum has been reduced.

c.

Increased effort will be placed on inspecting for liquid.

6.

Installed Radiation Monitoring Equipment The inspector observed the indications on the effluent monitoring (solid state) instrumentation that was installed during 1978, replacing old equipment.

No problems we"e identified.

Instrument maintenance will be reviewed on a subsequent routine inspection (29/79-08-04).

7.

Ventilation Systems Part of the inspection effort was to examine ventilation systems.

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The inspector found on July 9,1979, the chemistry laboratory radioactive materials hood was not being ventilated because of a pulley failure at the ventil ator.

The ventilation was restored before the completion of the inspection; however, only one belt was used because there was a failure in one double-grooved pulley.

Ventilation will be reviewed on a subsequent routine inspection (29/79-08-05).

No items of noncompliance were identified.

8.

Personnel Exposures Part of the inspection effort was to review records of internal and external exposures to personnel to verify compliance with exposure limits during 1978 and the first half of 1979.

The licensee requires routine periodic whole body counts of all personnel and a determination in all instances of terminations, new hires, and suspected ingestions of radioactive materials.

Record review did not identify any exposures in excess of regulatory limits.

Record problems were described under Paragraph 3, none being indicative of any overexposure.

9.

Reports Review of reports to individuals and to NRC pursuant to requirements of 10 CFR 19.13,10 CFR 20.407,10 CFR 20.408, and 10 CFR 20.409 did not identify any errors or omissions involving termination reports or other reports to any individual.

The record problems described under Paragraph 3 might have affected the statistical sumary submitted pursuant to 10 CFR 20.407(b)(2) and this item will be reviewed on a subsequent routine inspection (29/79-08-06).

10.

Surveys, Posting, Labelir.

nd Control Part of the inspection effort was to observe compliance with requirements of 10 CFR 20.201, " Surveys," 10 CFR 20.202, " Caution signs, labels, signals, and controls," and Technical Specifications Section 6.13, "High Radiation Areas."

The inspector toured the facility and conducted confirmatory surveys.

No improperly labeled, posted, or controlled items were identified.

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The licensee survey records appeared to be up to date and accurate.

Work in progress in the spent fuel pool appeared to be controlled in accor-dance with licensee procedures.

Increased radiation levels were evicent at the inner fence and were discussed during the management interview (Paragraph 11).

A survey of the outer fence did not identify any radiation level exceeding 0.2 mrem /hr.

11.

Management Interview The inspector met with the licensee rresentatives (designated in Paragraph 1) at the conclusion of theinspection, July 12,1979, 2 p.m.

The inspector reviewed the scope and the findings of the inspection.

The inspector stated that procedural problems would be reviewed on a subse-quent routine inspection, with emphasis on wearing of dosimeters, dosimetry records, and posting and control of radiation areas near the inner fence (29/79-08-07).

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