IR 05000029/1981008
| ML20053A773 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 05/04/1982 |
| From: | Greenman E, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20053A767 | List: |
| References | |
| 50-029-81-08, 50-29-81-8, NUDOCS 8205270264 | |
| Download: ML20053A773 (10) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION Region I Report No.
50-29/81-08 Docket No.
50-29 License No. DPR-3 Priority _ --
Category C
Licensee:
Yankee Atomic Electric Company 1671 Worcester Road Framingham, Massachusetts 01701 Facility Name:
Yankee Rowe Inspection at:
Yankee Rowe, Monroe Bridge, Massachusetts Inspection conducted:
April 30-May 1, June 3-5,1981 d~' Y - 8.2 Inspectors:
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J. R. White, Radiation Specialist date signed Approved by:
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E. G. Greenman, Chief, Facilities date signed Radiation Protection Section, Technical Programs Branch Inspection Sunmary.
Insp_ect_ ion on April 30-Dy_1, June 3-5,1981 (Report No. 50-29/81-08)
Areas Inspected:
Routine, unannounced safety inspection by a region based inspector to examine / evaluate the licensee's planning and preparation effort for a refueling outage commencing May 2, 1981, and selected aspects of the implementation of the Radiation Protection Plan during that outage.
The inspection involved 42 inspection hours on site by one region based inspector.
Results:
No violations were identified.
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DETAILS 1.
Persons Contacted
- Mr. H. Autio, Plant Manager
- Mr. J. Trejo, Health Physics Supervisor
- Mr. D. O'Donnell, Health Physics Foreman
- Mr. F. McWilliams, Technical Advisor Mr. T. Shippee, Health Physics Shif t Leader Mr. R. Panciera, Health Physics Foreman, General Dynamics Mr. C. Young, Health Physics Coordinator, Numanco Mr. M. Vandale, Technical Advisor Ms. K. Worrick, Records Maintenance Ms. L. Passardi, Records Maintenance Mr. T. Foley, Resident Inspector, Yankee Rowe
- Mr. N. St. Laurent, Assistant Plant Manager
- Mr. J. Staub, Technical Assistant to Plant Manager
- Mr. L. French, Technical Assistant
- Denotes those present at the exit interview on June 5, 1981.
2.
Scope The purpose of this inspection was to review the licensee's plans and preparations for a refueling outage, scheduled to begin May 2, 1981, to assure that material resources and radiological controls would be sufficient to support the Radiation Protection Program.
After verifying the preparations, the inspector reviewed the licensee's Radiation Protection Program during the outage to verify that it was properly established, implemented and maintainea.
3.
Radiation Protection Procedures The establishment, maintenance and implementation of the licensee's procedures relating to radiological controls were examined pursuant to the following requirements.
a.
Code of Federal Regulations, Title 10, Part 20 b.
Yankee Rowe Technical Specifications (1) Specification 6.8, " Procedures" (2) Specification 6.12, " Radiation Protection Program" b.
ANSI N18.7-1972, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants"
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Regulatory Guide 1.33, " Quality Assurance Program Requirements" The liceasee's established procedures related to radiation protection were revi> wad.
This review included about 30*; of the procedures selected for applica ility to outage conditions.
The procedures selected were verified to oe developed in accordance with ANSI-18.7, addressed at least the topics presented in Regulatory Guide 1.33, and were consistent with the requirements of 10 CFR 20.
The inspector noted that the development of certain procedures, particelarly those associated with monitoring of alpha activity, were not fully completed at the time the outage began.
The procedure for alpha spectrometry using a silicon surface barrier detector was not established as of June 5,1981, but it was in the final stage of preparation and was planned for submission to the Plant Operation Review Committee (PORC).
The use of the alpha spectrometry at that time had not been required to evaluate personnel exposure.
No violations were identified.
4.
Advanced Planning and Preparation Previous coolant analyses had alerted plant management that the potential for fuel clad failure existed, and that alpha contamination might be involved in certain maintenance and repair operations planned for the outage.
Particular operations included steam generator eddy current testing (S/G-2), and replacement of a Reactor Coolant Pump (RCP).
In an effort to preclude the impact of personnel exposure to alpha activity, the licensee instituted several actions including:
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The acquisition of a alpha spectrometer;
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the acquisition of additional gas proportional counters and portable instruments;
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the development of procedures and techniques to minimize the spread of loose surface activity during S/G and RCP maintenance;
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the assignment of additional health physics technicians and supervisors in support of the outage;
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arsuring that plant personnel associated with the outage were aware of the potential problems that might result as a consequence of failed fuel cladding; and,
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the institution of a continuing decontamination effort to minimize the risk and spread of loose surface contamination.
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This effort involved the development of a special Radiation Protection Organization, as shown below.
Staffing for the organization was as follows:
No. of Plant (P) or Title Personnel Contractor (C)
Health Physics Supervisor
P Technical Advisor
P HP Shift Foreman
(1) P; (2) C HP Shift Tester
P Decontamination and Housekeeping Supervisors
C Decontamination and
C Housekeeping Technicians HP Technicians
(4) P; (36) C Clerks and Administrative Personnel
(1) P; (6) C A total of 81 personnel were directly associated with the radiation protection aspects of the outage, 66 of whom were supplied by contractor organizations.
According to the Health Physics Supervist, representatives of the Health Physics Department have attended all outage planning meetings and have provided necessary input to assure adequate radiological controls would be implemented.
The inspector review 2d the resumes and training records of approximately 50*J of the radiation protection personnel assigned to responsible positions.
The qualifications of these personnel were found to be in accordance with the specifications of:
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ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel; and,
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Regulatory Guide 1.8, " Personnel Selection and Training" No violations were identifie _.
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5.
Exposure Control _
The licensee's program for exposure control was examined pursuant to the following:
a.
Code of Federal Regulations, Title 10, Part 20 (1)
10 CFR 20.101, " Radiation dose standards for individuals in restricted areas"
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10 CFR 20.102, " Determination of prior dose" (3)
10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas" (4)
10 CFR 20.201, " Surveys" (5)
10 CFR 20.202, " Personnel monitoring"
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10 CFR 20.401, " Records of surveys, radiation monitoring and disposal" b.
ANSI N13.6-1966, " Practice for Occupational Radiation Exposure Records Systems" c.
Regulatory Guides (RG)
(1) RG 8.7, " Occupational Radiation Exposure Records System" (2) RG 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable" (3) RG 8.15, " Acceptable Programs for Respiratory Protection" (4) RG 8.26, " Applications of Bioassay for Fission and Activation Product:"
d.
Yankee Rowe Station Procedures (1) OP-8101, " Plant Radiological Surveys" (2) OP-8105, " Breathing Zone Air Samples" (3) AP-8007, " Calculation of Internal Dose for a Single Uptake of Soluble Radionuclides"
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(4) DP-8008, " Dose Estimate to GI Tract and/or Lungs for a Single Uptake of Insoluble Radionuclides by Comparison with MPC's"
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(5) AP-8015, "MPC Hour Accountability" (6) OP-8403, "Use of Personnel Monitoring Devices" (7) OP-8405, " Bioassay Program" (8) OP-8415, " Radiation Work Permits" Review of this area determined the following:
(1) The examination of this area included the review of all personnel occupational exposure acquired during the outage (i.e. current quarterly exposure).
No individual exceeded regulatory limits (as specified in 10 CFR 20.101) as of June 5, 1981, and admini-strative controls appeared sufficient to assure that subsequent exposure would be adequately planned and controlled.
(2) The exposure records of 7 personnel (representing about 40% of all personnel having exposure greater than 1250 millirem accumulated in the calendar quarter) were reviewed.
It was determined that the requirements of 10 CFR 20.102 were satisfactorily completed in these cases.
(3) The licensee did not take credit for any protection factors afforded by respiratory protective devices at the time of this inspection, though such devices were available and were frequently used.
In lieu of protection factors, the licensee maintained accountability of personnel uptakes associated with exposure to airborne concentrations of radioactive material.
From review of measurements of airborne concentrations, the inspector noted that, generally, airborne radioactivity had been ~
maintained at suf ficiently low concentrations (ranging from 1 E-9 to 5 E-11 uCi/ml) for the majority of the outage.
There were, however, sporadic indicationsof increased airborne radio-activity, and the following occurrences were reviewed:
Date Area RWP No.
Concentration 5/19/81 Loop #1 1245 3.94 E-8 uCi/ml 5/19/81 Loop #1 1435 1.39 E-8 uCi/ml 5/22/81 Loop #3 0848 1.66 E-8 uCi/ml 5/13/81 South 1422 1.3 E-7 uCi/ml Decon Rm.
In these cases the inspector verified that the licensee was maintaining accountability for the personnel that were associated with the occurrences, in accordarice with the requirements of 10 CFR 20.103.
It was noted, however, that there was a backlog of
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MPC-hour updates that had not been inputed to the licensee's computer system that was used to maintain the record of personnel uptakes. At the time of this review (June 4, 1981), there was
evidence that MPC-hour updates had not been imputed since May 18, 1981.
Upon notification, the licensee initiated action to ensure that MPC-hour accountability was maintained sufficient to depict the current estimate of personnel exposure to airborne radioactivity.
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Additionally, the inspector noted that the licensee's system for MPC-hour accountability did not provide a mechanism for determining the individuals status with regard to the 40-hour control measure specified in 10 CFR 20.103(b)(2).
The licensee's system indicated the total intake of airborne radioactive material accumulated over a given calendar quarter did not provide for the accumulated intake over a period of seven consecutive days.
In response to this finding, the licensee indicated that action would be initiated to assure that accumulated intakes of airborne radioactivity are maintained below the 40-hour control measure for seven consecutive days.
This area will be reviewed further during a subsequent inspection.
(50-29/81-08-01)
At the time of this inspection, there was no evidence of any personnel exposure in excess of the 40-hour control measure.
(4) The licensee's performance of radiological surveys was verified by the inspector by independent measurements made in the Vapor Container and Auxiliary Building.
Additionally, work perfc med in accordance with the following RWPs was reviewed to determine if survey performance was adequate:
Date Area RWP No.
5/19/81
$/G Loop No. I 1245 5/19/81 S/G Loop No. 1 1435 5/22/81 S/G Loop No. 3 0848 5/13/81 South Decon Room 1422 The inspector also observed work in progress in the Vapor Container associated with the examination of in-core monitoring instruments on June 4 and 5, 1981.
Although no violations were identified in this area, the inspector noted that consideration should be given to expanding the use of continuous air monitoring (CAM) equipment, to alert personnel of unusual conditions in certain areas. At the time of this
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inspection, neither the Vapor Container or the Spent Fuel Storage Building were supplied with any continuously
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operating air monitoring system (except the Ventilation Effluent Monitor that would alert personnel if airborne activity was tending to increase).
Currently, air sampling is essentially dependent on grab samples, either routine or in support of work in progress.
In response, the licensee indicated that a CAM system was currently under review for the Vapor Container; and that an installation in the Spent Fuel Storage Area would be considered.
This item will be followed up further during a subsequent inspectien.
(50-29/81-08-02)
(5)
In review of radiation records associated with personnel occupa-tional exposure, it was noted that the licensee's system appeared organized, complete and in accordance with the requirements of 10 CFR 20.401.
The inspector indicated that in the event it becomes necessary to correct information in occupational exposure records, the standard convention of deleting or inserting information by lining-out, initialing and dating the change should be followed in order to allow the admissibility of such records as evidence.
The licensee representatives concurred and indicated that such convention would be followed in the future.
(6) As previously stated, at the time of this inspection the licensee did not take credit for the use of respiratory protection devices. While the Respiratory Protection Program is still under development, it was evident that the licensee made use of engineering controls and area decontamination to reduce personnel exposure to airborne radioactivity. A review of approximately 80". of the air sampling results compiled since the outage revealed that, with few exceptions, the nominal airborne radio-l activity encountered ranged between 1 E-9 and 9 E-11 uCi/ml.
l In reviewing the medical qualification of the contractor personnel
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who were permitted to wear respiratory protective equipment, l
the inspector noted that the licensee accepts the statement of the
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contractor that such qualification has been verified.
Through discussions with the licensee's Health and Safety Director, it was found that the licensee placed the entire responsibility of medical qualification on the contractor agency without any type of quality assurance taken to ensure that such personnel were
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I actually medically qualified in accordance with the guidance of l
NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials" After beiry notified that the licensee, not the contractor, is liable (as regards to the requirements of 10 CFR 20.103) for the health and safety of personnel who may wear respiratory protective devices, the licensee initiated action to revise l
their policy on the n edical qualification of respiratory users.
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(7) The inspector reviewed the licensee's personnel contamination controls and noted that while personnel monitoring (frisking)
was required by station procedures, frisking sufficient to identify surface contamination in excess of the licensee's release limit of 100 cpm as measured with an HP-210 Frisker
Probe (i.e., about 1000 dpm/100 cm ) was not consistent with all people observed frisking.
Instructions issued by the Health Physics Supervisor indicated that the whole body must be frisked for one to three minutes. The inspector further noted that while the frisking area is in clear view of the control point it is not continuously manned by health physics technicians.
The licensee's representatives indicated that this item would be reviewed and action taken as necessary to assure that personnel are adequately monitored prior to leaving the controlled area.
The inspector indicated that this, item including procedural adherence,would be followed up in a subsequent inspection (50-29/81-08-03).
No violations were identified.
6.
PostingmLabeling and Control The licensee's efforts in posting, labeling and controlling radioactive material were reviewed pursuant to the following:
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Code of Federal Regulations, Title 10, Part 20
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10 CFR 20.203, " Caution signs, labels, signals and controls"
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10 CFR 20.207, "Stc rage and control of licensed materials in unrestricted areas" The inspector examined and toured the Primary Auxiliary Building, Radioactive Waste Treatment Building, Radioactive Material Storage Buildings, Vapor Container and other controlled areas on May 1, June 3, 4 and 5, 1981.
Independent measurements were made to verify the licensee's control of radioactive materials and areas.
No violations were identified.
7.
Licensee Action on Previous Inspection Findings (0 pen) Inspector Followup Item (50-277%1405): Revision and update of the Respiratory Protection Manual. While procedures associated with the respiratory protection program have been developed and implemented, the licensee's Respiratory Protection Manual has not yet been subject to review and revision. At the time of this inspection, a Technical Advisor
was assigned the responsibility to revise and update the manual.
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(Closed) Inspector Followup Item (50-2778-0502): Modification and Use of the Incinerator for Radioactive Waste disposal. The inspector determined that at the time of this inspection the licensee had no plans to use the existing incinerator for radioactive waste disposal.
8.
Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection.
The findings and scope of the inspection were presented, and the licensee acknowledged these findings.