IR 05000029/1988017
| ML20207L593 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 09/23/1988 |
| From: | Markley M, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207L496 | List: |
| References | |
| 50-029-88-17, 50-29-88-17, NUDOCS 8810170359 | |
| Download: ML20207L593 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
88-17 Docket No.
50 29 Category C
License No.
DPR-3 Priority
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Licensee: Yankee Atomic Electric Company 1671 Worcester load Framingham, Massachusetts ol70T Facility Name: Yankee Nuclear Power Station Inspection At: Rowe, Massachusetts Inspection Conducted: August 15-18. 1988 Inspector:
Y-37-88 M. Markley, Radiatio ocialist date 23df Approved By: '
cd A e
M.' Shanbakf, Ghief. Fa,cflities Radiation
date Protection Sv'ction v
Inspection Summary:
Inspection on August 15-18, 1988 (50-29/88-17)
Areas __ Inspected:
Routine, unannounced inspection consisting of a pre-outage evaluation,l controls. previous inspection findings, and observation of inplant review of radiologica Areas reviewed included: management and organization, training of personnel, facilities and equipment, internal and external exposure controls, control of radioactive material and contamination, and ALARA.
Results: Within the scope of this review, no violations were identified.
However, weakness was noted in air sample analysis calculations.
8910170359 800923 DR ADOCK 0500
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DLTAILS 1.0 Persons Contacted During the course of this inspection, the following personnel were contacted or interviewed:
1.1 Licensee Personnel D. Ash, Radiation Protection Technician Radiation Protection Technician
- W. Blackador, Radiation Protection Manager
- G. Babineau, Senior Chemist
- J. Gedutis,
- J. Geyster, Radiation Protection Engineer M. Heckman Radiation Protection Technician
- M. Hedges,, Chemistry Manager
- P. Hollenbeck,hnical DirectorRadiation Protection Engineer
- R. Mellor, Tec
- J. Spitulnik, Training Superv hor
- N. St. Laurent, Plant Superintendent s. Wisla, Radiation Protection Engineer 1.2 NRC Personnel
- C. Carpenter, Resident Inspector H. Eichenholz, Senior Resident Intiector
- J. Kottan, Radiation Laboratory Specialist
- N. McNamara, Laboratory Technician Other personnel were contacted or interviewed during this inspection.
- Attended the exit meeting on August 18, 1988.
2.0 Purpose The purpose of this inspection was to review the licensee's outage planning, previous inspectinn findings, and to observe inplant radiological controls.
Specific areas reviewed were:
status of previously identified items;
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management and organization;
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training of personnel;
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facilities and equipment;
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internal and external exposure controls;
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control of radioactive material and contamination; and
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3.0 Status of Previously identified Items Labols w)hich meet 30 CFR 20 color coding requirements. Ensure licensee is using fClosed 88 04-01 LUnresolved).
which meet The licensee has purchased containers (polyethylene bags)ive material 10 CFR 20 color coding criteria. Observation of radioact labelinc in the facility indicated that these containers were being used as requirec
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Previously used containers manufactured without the correct color coding specification requiremenfs were noted to have additional closed.gwhichwasconsistentwithregulatoryrequirements.
labelin This item is 4.0 Management and Organization Evaluation of the licensee's radiation protection management and organization was based on:
review of site Technical Specification requirements;
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review of Yankee Atomic Audit No. Y 88-03A;
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discussion with licensee management;
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review of station procedures; and
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observation of work activities.
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4.1 Staffing Evaluation of the licensee's management and organization indicated that the current staffing level is adequate to support routine plant operations. Manegementoversightofworkactivitieswasgood.
The licenseo recently initiated a Work Activity Observation and Plant Inspection Program." The inspector observed this program being implemented during a work evolution on August 16, 1988. Although the evolution did not go well (section 8.3), the observation program was effective in identifying weaknesses and opportunities for improvement.
The inspector considered this to be a good licensee initiative designed to improve program implementation.
The licensee is scheduled to begin the refueling outage on November 12, 1988.
Staffing plans entail bringing contractor t)chnician support onsite November 1.
Specific radiation protection staffing objectives include 24 25 ANSI-18.1 lified technicians, 6 ANSI-3.1 decontamination technic (3 for Al. ARA)qua qualified technicians
, 12 junior technicians, and 24 l-ians (3 supervisors.
The licensee stated that these objectives were consistent with the s)taffing levels needed for previous outages.
The inspector had no further questions in this area.
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i 4.2 Audits Ins)ector review of annual audit report Y-88 03A determined that Tec1nical Specification (TS)ll program areas ware evaluated. evaluation requirem audit was balanced in that a Audits
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included both programatic and compliance based reviews.
Findings were
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thorough and compreheuive with an appropriate emphasis on field evaluation.
Licensee response to the findings was adequate, i
5.0 Training of Personnel The licensee's training program was evaluated cased on the following:
criteria contained in 10 CFR 19, "Notices and Instructions to Workers";
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site Technical Specifications;
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station procedures and
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discussionswithIIcenseepersonnel.
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Within the scope of this review,d relative to licensee audits and to no violatior.3 were identii'ied.
Radiation protection training was evaluate Radiation Work Permit (RWP)ing program included procedure).
implementation (section 8.1 No weaknesses were identified.
The train training for the controll ng guidance.
The involved individuals received the appropriate training.
1he licensee recently( pgraded its General Employee Training (GET) and radiation protection P) technician training programs. Annual GET and RP technician retraining.i scheduled for October 1988.
Lesson plans new include industry developments and site specific concerns such as hot particle exposure controls. ALARA training for steam generator maintenance is scheduled for the outage.
The licensee plans to videotape this training for classroom guidance. Also, the inspector ooserved a GET videotaping session for the proper dress-out and removal of protective clothing.
The licensee denronstrated good initiative in this area.
6.0 Facilities and Equipment Evaluation of the licensee's facilities and equipment was based on the following:
obse;vation of in uso equipment;
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operatianal testing of equipment;
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reviow of station procedures; and
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discussion with licenseu personnel.
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For the outage the licensee will be utilizing)onsite contractor senices for the processing of protective clothing PC laundry.
The licensee has also purchased a state of-the-art laundry m(onitor. Although it was not onsite at the time of inspection, delivery is scheduled for early October 198 _ -_____- ____.
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t Other equipment acquisitions include the steam senerator mockup and arm t
contamination monitors.
The arm monitors provice survey capability not afforded by the whole body contamination friskers. At the inspector's request, the licensee demonstrated a source check test of the whole body's
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friskers.
Performance in this area was very good in that the instrument t
detectors accurately identified and located low levels of radioactivity
l(2050cpmper15.5squarecentimeterprobearea)unevenlydistributedover arge surface areas (500 square centimeters).
01scussions with licensee personnel indicated that an adequate supply of
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protective clothing, discussed with cognizant licensee personnel was survey instrumentation, and respirator repair parts was available. Also real-time air monitoring for "quick sort" identification of increased i
airborne radioactivity in the vapor Container (VC)but limited in that only These discussions
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indicated that this capability would be available l
one instrument is available for that purpose.
The licensee is evaluatin l
additional instrumentation to expand this capability for future outages.g
One weakness identified during NRC Inspection 88-04 was the source to detector distance being outside the guidance (unacceptably close) provided by ANSI N-323,1978.
Initial licensee evaluation has determined that the ANSI criteria cannot be met in the current calibration facility.
The r
I licensee is conducting a study to evaluate the technical viability of continuing to calibrate instruments using the present configuration. The
inspector will review this area durina a future inspection.
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7.0 Internal Exposure Controls
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The licensee's program for internal exposure controls was reviewed against criteria contained in the following:
10 CFR 20, "Standards For Protection Against Radiation";
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Regulatory Guide 8.15 "Acceptable Programs for Respiratory Protection";
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Regulatory Guide 8.26, "Applications of Bioassay for Fission and
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Activation Products";
ANSI N13.l 1969 "Sampling Airborne Radioctive Materials in Nuclear i
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facilities ; and, g
NUREG 0041, "Manual of Respiratory Protection Against Airborne
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Radioactive Materials".
Licensee performance relative to the above criteria was based on:
observation of work activities *
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reviewofairsamplingandwhoiebodycountingrecords; E
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review of station procedures; and
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discussions with licensee personnel.
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l Within the scope of this review, no violations were identified.
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7.1 Air Sampling The inspector identified errors in the licensee's air sample analysis calculations. The calculation errors resulted in reported sample activities of three orders of magnitude lower than the actual sample activities. Due to the fact that the actual sample activities, after correcting for calculational error, were well below 10 U R 20.103 controls or) precautions in the plant. The inspector noted that theconcentratio (Appendix B erroneous data was reviewed and ap) roved by two levels of su)ervision.
The supervisors did not identify tie calculational errors.
.icensee management stated that action will be taken to improve performance in this area. Immediate corrective action included evaluating other air sample analysis for additional errors, discussing the problem with the radiation protection staff, and evaluating training as it related to the problem.
The inspector stated that air sampling procedures, training of RP technicians, and supervisory oversight will be reviewed during a future inspection.
7.2 Engineering Controls The licensee's engineering control program for limiting airborne radioactivity is adequate.
It consists of high efficiene particulate mainte) nance. filtration systems used primarily for steam genera or (HEPA Tents and enclosures are used in addition to and in conjunction with these systems.
7.3 Bioassay and Respiratory Protection Inspector review of whole body count records (WBC) indicated no anomalous results.
No significant intakes were apparent.
Records were well maintained and readily available.
Discussions with the licensee indicated that an adequate supply cf respirators was avsilable to support the outage.
Plans for respirator cleaning and reuse were adequate.
8.0 External Exposure Controls The licensee's program for external exposure controls was reviewed against criteria contained in the following:
10 CFR 20 "Standards For Protection Against Radiation";
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site Technical Specifications;
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review of station procedures;
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ContaminationwithHotParticles"xcessiveSkinExposureDueto Information Notice (IN) 86-23
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Information Notice
) 87-39, "Control of Hot Particle Contamination at Nuclear Power Plant 8.. valuation of licensee performance in this area was based on the following:
observation of work activities;
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discussions with licensee personnel;
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performance of independent surveys;
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review of Radiation Work Permits (RWPs)ts; andand associated surveys;
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review of personnel contamination repor
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review of the following procedures:
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AP-0805, original revision, "Use cf Protective Clothing /
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Anti Contamination Clothing";
AP-0806, Rev. 2, "Radiation Work Permits, Requests and Use";
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AP-0811, Rev. 2, "Hot Particle Contamination Control";
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OP-8415, Rev. 14, "Radiation Work Permit Issue, Update and
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Closecut"; and OP-8430, Rev. 3, "Personnel Contamination Monitoring and
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Decontamination".
Within the scope of this review, no violations were identified.
8.1 Radiation Work Permit implementation On August 13, 1988, the NRC Senior Resident inspector observed four areaposted{threeengineersandacontractorRPtechnician)insidean individuals RWP Required For Entry" without a valid Radiation Work Permit (RWP). The specific posted area was located around the Spent Fuel Pool (SFP).
The individuals entered the area using the Discussion with the technic (RCA) general access authorizatiJn.
Radiological Control Area ians indicated that there was some confusion about requirements for general access to the Radiological Controlled Area (RCA) and requirements for specific RWPs.
Subsequent inspector review indicated that the radiological conditions did not require the area to be posted as needing a specific RWP for entry, inspector review of training records indicated that the cognizant technicians were provided with the appropriate training to have aetermined the correct access requirements.
However, discussion with the contractor technician did not demonstrate a strong working knowledge of these procedural requirements, in response, the licensee initiated an evaluation to determine how program implementation of this training might be improve _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
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The inspector noted that positive radiological control was maintained throughout the evolution. No individuals became contaminated and external exposure was minimal.
Planned licensee corrective actions included the following:
counseling the RP technicians regarding the incident and
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performance expectations; sending a letter to the RP contractor firm outlining performance
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expectations; completing a Radiological Occurrence Report (ROR) directing
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licensee action; issuing a memorandum to the site staff delineating requirements for
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general acces; to the RCA and RWP requirements; and holding a meeting of the RP Training Advisory Committee to evaluate
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training;
Becausa radiological conditions in the area did not require a specific RWP and licensee corrective actions were extensive, no violation was citeo.
8.2 Hot Particle Exposure Controls
"Hot Part;cle The licensee recently implemented procedure AP 0811. logical controls Contamination Control" to specifically address radio for hot particles.
Included in this procedure was precautions and guidance necessary for identification and control. No major weaknesses were identified, however, the inspector noted several squential and typographical errors. The licensee initiated corrective measures '.o address the inspectors concerns.
All hot particle weaknesses identified in NRC Inspection 88 04 have been adequately addressed.
The licensee has corrected weaknesses
"Personnel Contamination Monitoring identified in procedure OP 8430,l monitoring equipment was acquired to and Decontamination". Additiona supplement the whole body friskers.
Protective measures have been established for high risk hot particle evolutions. Additionally, a radiological laundry monitor will be in service prior to the outage.
The licensee has been effective in establishing a comprehensive hot particle program. The inspector will continue to evaluate this program and its implementation during a future outage.
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8.3 Radiological Work Activities On August 16,1988, individuals went to work without the correctthe inspector observe planning where the equipment to perform the task. A water hose needed to move material at the bottom of the Spent Fuel Sol (SFP? was equipped with the wrong fittings. A radiation protectio., technicnan was sent to get the correct equipment after the job had started. Also, operations departrent coordination was war unavailable when needed. poor in that the necessary water supply Later, the water was provided and the job was completed. The inspector noted that much time was wasted in the radiological area due 10 poor planning and coordination.
These weaknesses were also observed by 4 licensee radiological engineer implementing the licensee's observation and inspection program, immediate corrective actions were initiated.
Inspector observation of continuing work activities the next day indicated improved performance.
8.4 Posting and Labeling Inspector observation of radiological posting and labeling indicated that 10 CFR 20 rt.autrements were met. No weaknesses were identified.
The licensee was noted to make improvements in posting during the course of the inspection.
8.5 Dosimetry Workers were observed to be correctly wearing personnel radiation monitoring dosimetry.
Examination of in use dosimetry indicated that all self reading dosimeters had valid calibration stickers.
ror the outage, the licensee plans to use alarming dosimeters for work groups entering the containment.
9.0 Control of Radioactive _ Material and Contamination
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Inspector review of this area was based on:
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observation of worker frisking practices;
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review of station procedures; and
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discussions with licensee personnel.
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Within the scope of this review, no violati.
.re identified.
Perscnnel
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were observed to be properly frisking there
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Inspector evaluation of the licensee s fri s instrumentation indicated good performance (section 6.0).
The licensee is also considering the use of strippable coatings for improved decontamination and contamination control.
10.0 ALARA The licensee's ALARA program was evalt.ated against criteria contained in the following:
Regulatory Guide 8.8, "Information Relevant to Ensuring that
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Occupational Radiation Exposure at Nuclear Power Stations Will Be As low As Is Reasonably Achievable";
Regulatory Guide 8.10, "Operating Philosophy for Maintairing
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Occupational Radiation Exposures As Low As Is Reasonably Achievable".
Licensee performance relative to these criteria was evaluated by:
discussions with cognizant personnel;
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tours of radiologically controlled areas;
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review of station ALARA goals;
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review of station procedures; and
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- review of ALARA Review Tracking Status Report.
The licensee has maintained consistent ALARA goals through the 1988 calendar year.
The annual exposure projection is 193 person-rem (156 outage and 37 non-outage). At the time of inspection actual annual exposure was 26 person-rem.
Thesegoalsarereasonableandimproved when compared to the 1987 outage year actual exposure of 204 person-rem.
Review of outage planning indicated that some ALARA briefing package preparation has slipped tiehind schedule.
Specifically the onsite ALARAstaffwaswaitingforinputfromtheYankeeAtomicGroupfor review packages involving Engineering Design Change Requests (EDCRs)
and input from the onsite outage planning group.
When brought to licensee management's attention, positive effort was made to address the delay for each item.
The licensee stated that these packages would be complete prior to the start of the outage.
Although procedures were revised in ar effort to improve the completeness of ALARA briefings, the licensee is trying to improve implementation by adding three contractors to the outage staff. Other licensee initiatives for the outage include: the implementation of an ALARA logbook to improve ongoing job evaluation and post-Job reviews, expanded use of audio visual equipment, and the acquisition of the steam generator mockup.
The licenses has demonstrated good initiative in ALARA.
Programatic changes and equipment acquisitions represent a strong licensee commitment to maintain exposures as low as is reasonably achievable, n
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11.0 Exit Meeting.
The in;pector met with licensee management listed in section 1.0 on
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a August'18, 1988 at the conclusion of the inspection.
The findings of the inspection were discussed at that time.
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