IR 05000029/1985023

Insp Rept 50-029/85-23 on 851028-1101.No Noncompliance Noted.Major Areas Inspected:Radiation Protection Program, Including ALARA Implementation During Outage,Control of Work & Frisking

ML20137U227
Person / Time
Site:	Yankee Rowe
Issue date:	11/27/1985
From:	Dragoun T, Mcfadden J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137U222	List: IR 05000029/1985023 ML20137U216
References
50-029-85-23, 50-29-85-23, NUDOCS 8512090235
Download: ML20137U227 (7)

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4-U'.S. NUCLEAR REGULATORY COMMISSION

REGION I

~ Report N . Docket N License No. OPR-3 Priority -

Category C

= Licensee: Yankee Atomic Electric Company 1671 Worcester Road Framingham, Massachusetts 01701 Facility Name: Yankee Nuclear Power Station

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Inspection At: Rowe, Massachusetts u

L Inspection Conducted: October 28 to November 1, 1985 Inspectors: _

wjm // 27 Tifcfna , Radia' tion Specialist ' date sails JohnMcFadd'en','RadiafionSpecialist n date Approved by: M.%4 Mohamed Shar:Taky, Chief,/

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dat'e PWR Radiation Protection Section Inspection Summary:

Inspection on October 28 to November 1, 1985 (Report No. 50-29/85-23)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program includirig: ALARA implementation during the outage; control of work;-frisking; posting and control of high radiation exclusion areas; control of radioactive material; and the evaluation of a worker uptake. This inspection involved 74 inspector-hours onsite by two region-based inspector Results: No items of noncompliance were identifie as120ph [

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DETAILS

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1.0j: Persons Contacted

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!Duringthecourseofthisroutineinkpection,thefollowingpersonnel

"were contacted or. interviewed:

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1.'l-, Licensee Personnel-

,N.- St. Laurenti Plant Su'perintendent T. K. Henderson,-Technical Director B. L. Drawbridge,' Assistant: Plant Superintendent G. M..Babineau,. Radiation Protection _ Manager R.;Mellor,' Chemistry Manager e

. NRC Personnel

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H. Eichenholz,; Senior Resident Inspector

- All personnel listed above attended -the exit interview on November 1,198 .

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12.0 ^LPurpose c IThepurpo_se-ofthisroutineoutage.frspsetionwastoreviewthEIfcensee's-radiation protection program with . respect to the following. elements:

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• - .ALARALImplementation:

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. Radiation Work Permits-

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se Frisking. . .

~*- ; Control of/High; Radiation Exclusion. Areas

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-* ;. -Control'of Radioactive Material p;f

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Evaluation of Worker llptake' of Radioactive Material

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?3.0EALARA Implementation

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jThe'11censeei s' implementation-of.an ALARA program for the refueling outage

.was-reviewed against criteria containcJ in:

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• ' 10 CFR 20.1 Purpose . .

-*: . Regulatory. Guides:8.8 and'8.10

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, .* - Procedure No. OP-8020,' "Alara Review Procedure," Revision 1

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i a: . Draft; Procedure No.-0P-8020A,'" Implementation and Documentation of-

-ALARA: Job Reviews"

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4 The.-licensee's; performance relative to these criteria was determined from V-  ; discussions with the Radiation Protection-Manager and ALARA coordinator, ,

f 1ALARA reviews, and'observationeof work in progress.

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p LWithin the. scope of thit review, no violations were identifie Licensee 4 strengths ~and weaknesses were noted as follows:

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-The:ltcensee has drafted but has not fully implemented an improved ALARA procedure. The corporate HP_ group demonstrated good preplanning by

' publishing ALARA. reviews :of all :significant Engineering Design Change .

' Requests:. scheduled to be done this outage. Reactor. fuel integrity will be-

' checked with~ ultrasonics rather.than sipping which should result in dose

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1The ALARA Coordinator position'_has been vacant for several months an'd was filled by a temporary subcontractor at the beginning of the outage. Ther o :has been no formal corporate'or station policy regarding an ALARA' progra .Althoughian annual-goal for personnel exposure: exists, there have been-no-exposure goals established.for the outage. .There is no system to track exposure associated with ~a specific work package. Implemen_tation of these _ ,

ALARA program elements is unresolved and will be reviewed in a future

inspection (85-23-01).

24.0 Radiation Work Permit's

. The licensee's program to control outage work and protect workers using a radiation work permit system was reviewed against criteria contained in:

Techdical-Specification 6.8, Procedures

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' Regulatory Guide 1.33.(November 1972), Appendix A, Section G.5,-

" Personnel-Monitoring and Special Work Permit" c

t-' 10 CFR 19.'12, Instruction.to workers

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. Procedure 0P-8415,. Radiation Work Permits

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The': licensee's. performance relative to these' criteria was determined by a4 review.of the: issuance p~rocess for radiation work permits, interviews with-

. workers, . observation ,of work in . progress, and interviews ~ with HP 'techni-cians in-the work are _

..W ithin'the scope of this review, no violations were identifie Licensee

= strengths _and weaknesses were noted.as follows:

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The licensee has iss'ued a " Radiological Work. Practices Policy Statement" -

to site personnel. ' This document emphasizes the need to follow RWP requiremerits as well as other work' practices. Also included is a four-r, . step disciplinary action policy that provides for worker.te'rmination fo failure to. comply _with radiation protection requirements. The inspector

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noted that-this policy indicated-a strong and clear management support of

~_the RP requirement .

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The inspector noted thatLthe current RWP procedure does not provide guidance for issuance of extremity monitoring. A review of completed

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The licensee's performance relative to these criteria was determined by:

Tours of the reactor containment, auxiliary building, and protected area

• - Observation of surface contamination surveys and decontamination activities

• - Discussions.with RP personnel

'* : Review of RWPs'and survey records During tours of the reactor containment and protected areas, radioactive components removed during the outage appeared to be adequately labeled-and stored in adequately controlled areas. The control and removal of radioactive waste was also adequately addressed by the license Removable surface contamination surveys were being performed once per shift in six plant areas including the VC charging floor. Recent survey maps were observed on.the radiological status board in the vicinity of the main control poin ~

-Observation and discussion with RP personnel indicated that step-off pads (SOPS) were used as single units and were to be treated as being contaminated. But licensee procedure OP-8100, titled Establishing and Posting:of Con. trol Areas, did not reflect this actual practice. In addition to. defining a contamination-controlled area, this procedure states that access controls,.similar to.those shown in figures in the

procedure, are to be used. For moderately contaminated areas, one figure indicated that two contiguous SOPS (outer one clean /ianer one contamin-ated)'are to be placed at the access point. For highly contaminated areas, another> figure indicated that a clean S0P is to be placed at an outer access point,and that two contiguous SOPS (outer one pettatially contaminated / inner one contaninated) are to be placed at an inner access point. 'RP personnel stated that radiation worker training included-instruction and demonstration of access control using contaminated SOPS and that this practice was not causing any confusion. Differences between written procedures and actual plant practice is a problem which was identified in previous inspection The licensee has made a commit-ment to the NRC to review all RP procedures and to have procedures reflect practice. Continued allocation of significant resources to this review process were evident'during this inspectio Within the scope of this review, no violations were identifie .

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'9.0 Evaluation-of Worker Uptake of Radioactive Material The. licensee's methods _of-evaluating an uptake of airborne radioactive material by two worker's~on October ~22, 1985, was reviewed against criteria

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. contained .in:

4 c- 10 CFR:20.103, Exposure of Individuals to Concentrations of Radio-active Materials in Air in Restricted Area :

_ Regulatory Guide 8.9, Acceptable Concepts, Models, Equations, 'and

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Assumptions'for a Bioassay Progra Regulatory. Guide 8.26, Applications of Bioassay for Fission and Activation Product =IE Notice 82-18,- Assessment of Intakes of Radioactive Material by

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worker The;1tcercee'sLperformance relative to these criteria was determined by

. discussions with the health physicist conducting the evaluation and a

. review of bioassay data, t

The licensee's data indicates that two workers experienced uptakes of 42.8~MPC-hours and 26 MPC-hours of airborne radioactive dust. The elimin-ation of these uptakes was evaluated using urine and fecal analysis and

? .whole~ body' counting. The analytical methods were determined to be ade-squateland.no worker overexposure had occurre = 10.0 ExitvInterview-The inspector met with. licensee personnel-denoted in Section 1.1 at.th conclusion of the inspection _on November 1, 1985. The scope and findings ofo the . inspection were discussed at that time,

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