IR 05000029/1991002

Insp Rept 50-029/91-02 on 910204-08.No Violations Noted. Major Areas Inspected:Radiological Controls Program, Including & Staffing,External Exposure Controls,Internal Exposure Controls,Audits & Appraisals & ALARA

ML20029B442
Person / Time
Site:	Yankee Rowe
Issue date:	02/22/1991
From:	Mann D, Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20029B441	List: IR 05000029/1991002 ML20029B440
References
50-029-91-02, 50-29-91-2, NUDOCS 9103080009
Download: ML20029B442 (8)

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U.

S.- NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

30-029/91-02 Docket No.50-029 Licenso No.

DPR-03 Licenseo Yankee._ Atomic Electric ComnaQY igp_Hain Stroot Bolton, Massachusetts 01740-139Q Facility Hamos yankee Nuclear Peter Station inspection Att Rown. Massachunotts Inspection Conducted:

Februa ry 4-8.

1991 Inspectors:

[M.A 2 / 9'/ '

P. O'Connell, Radiation Specialist, dato Facilities I diation Protection Section h thg*

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D. Mann, Radiation Special[st, date Facills_lps' Radiation Protection Section Approved byF dever 3 eV-9/

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W.

Pusciak, Chief, Facilities dato

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Radiation Protection Section, DRSS Insnection Summary: Inspection on February 4-8, 1991 (Report No.

50-029/91-02).

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hrgng_Insnected: A routino, unannounced inspection of the radiological controls program at your facility was conducted by D. Hann and P. O'Connell on February 4-8, 1991.

Areas covered in this inspection included a review of:

organization and staffing, external exposure controls, internal exposure controls, audits and appraisals, and ALARA.

Results: Within the scope of this inspection, no violations were identified.

9103080009 910225 PDR ADOCK 05000029

PDR

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DETAILS 1.0 Personnel Contacted 1.1 Lkensee Personnel

• 0.11abineau, Radiation Protection Manager D. Calys.n, Quality Assurance Engineer

• J. Geyster, Radiation Protection Engineer J. Giard Engineering Assistant M. liedges, Chemistry Manager

• P. Hollenbeck, Radiation Protection Engineer J. Kay, Technical Services Manager M. Kralian, Manager Analytleal Services Group

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E. Moreno, Nuclear instrumentation Supervisor J. Murray, Nuclear Instrumentation Supervisor

• G. Mairt, Technical Director D. McCurdy, Director Environmental 1.aboratory N. Panzarino, Manager Dosimetry Services

M. Scannell, Dosimetry Engineer

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• N. St.1.aurent, Plant Superintendent T. Treat, Engineering / Technical Assistant S. Wisla, Radiation Protection Engineer 1,2 NRC Personnel

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• T. Koshy, Senior Resident inspector

• M. Miller, Resident inspector 2.0 Drganization and Staffing The replacement of two Radiation Protection (RP) technicians in mid 1990 provided the licensee with a fully staffed radiation protection organization. The two technicians began the qualification process in mid 1990 and recently completed qualifying as shift technicians. The inspectors noted an organizational change had been implemented for positions above the Radiation Protection Manager ( PM) level. The changes included creating an Assistant Plant Superintendent position w. 4ch provides an additional level of management between the RPM and the Plant Superintendent. The impact of the organization changes will be reviewed during future inspections.

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On February 6,1991, the inspectors met with several individuals at the Yankee Atomic Environmental Laboratory (YAEL). The inspectors toured the YAEL and reviewed the radiation protection support YAEL provides the Yankee Rowe plant.

YAEL routinely provides technical and equipment support to the plant in sescral areas including, dosimetry processing, extrapolation chamber measurements of plant radiological environments, alpha spectroscopy of air samples and waste streams, electrometer measurements of calibration sources, quarterly blind spike analysis of the plant whole body counter (WBC) and, during outages, providing an additional WilC to support outage activities. The technical support available to plant personnel from the corporate office was scry good. The corporate staff were well qualified and very knowledgeable of technical issues concerning the plant.

The inspectors discussed the current and longer term programs for augmenting the RP staff during non routine outages. Currently, personnel from other departments onsite attend a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> training session to learn the access control procedure. Upon completion of this training, these individuals could replace RP technicians at the control point (s) during non routine outages; thereby, allowing one or two RP technicians to perform other duties such as radiation and contamination survey s, or job coverage.

The licensee is giving preliminary consideration to forming a corporate radiation protection support group, The RP support group, consisting of RP technicians and supervisors, would be dedicated to supporting those plants affiliated with the Yankee Atomic Electric Company during routine and non routine outages. Progress in this arca will be reviewed during future inspections.

3,0 htternal Exoosure Controls The inspectors reviewed the operation and calibration of the WBC located at the plant and a portable WBC located in the YAEL. Typically, the portable WBC is transported to the site to support refueling outage activities.

The plant WBC and the portable WBC are similar in design, with both WBCs consisting of a single germanium detector. Both counting systems are calibrated on a two year frequency and undergo a quarterly quality control (QC) test. YAEL provides the samples for the quarterly QC tests. The tests consist of several blind spike samples using a humanoid phantom with internally dispersed radioactive material. The inspectors reviewed records of recent quarterly QC tests and noted that both WBCs obtained acceptable results.

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Daily QC counts are also taken for the W11Cs. hicasurements are taken immediately following calibration for both WilCs, to establish a mean, standard deviation, and a three standard deviation value. The inspectors noted that the YAEL use these values to establish a control chart. Plant personnel track the daily QC checks for 20 days following calibration. Plant personnel generate a control chart based on data from the past 20 daily QC checks. This practice allows for increased variability due to source positioning, temperature, and humidity changes. The 20 day tracking method prior to establishing a control chart was a good licensee initiative.

Both WilC's are calibrated using an "Amr"Eu mixture that is uniformly distributed throughout the appropriate phantom organs. The inspectors noted that this practice allows a photon energy gap of > 200 kev across the 340-780 kev energy range. This practice was not consistent with American National Standards Institute (ANSI)

N42.141978, ' Calibration and 1Aage of Germanium Detectors for hicasurement of Gamma Ray Emission of Radionuclides", which recommends, in section 6.5, that calibrations be made at least every 0.1 hieV from 0.06 to 0.30 McV. about every 0.2

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hieV from 0.3 MeV to 1.4 MeV, and at least at one energy between 1.4 MeV and 2 MeV. The standard also recommends that a calibration with the same rac%nuclides that are to be measured should be made whenever possible.

The licensec stated that the nuclides that are expected to be measured and would fill the > 200 kev energy gap are relatively short lived compared to the calibration frequency and the licensee would therefore be required to obtain new sources for the phantom organs for every calibration. The licensee provided the inspectors with a study which compared the energy vs. efficiency curves for the short lived and longer-lived isotopes. The curves were essentially the same over the 300-800 kev energy range. The inspectors concluded that the licensee program was meeting the intent of the ANSI standard regarding this issue.

To ensure that the WBC is properly calibrated, YAEL personnel perform a calibration verification using cobalt and cesium. The inspectors felt that this was a good practice.

The inspectors noted that the plant procedures were not as detailed in that they did not require a calibration verification. However, at the time of the inspection, the cognizant engineer on his own initiative had performed a calibration verification for the counting geometry routinely used with the plant WBC.

The inspectors reviewed licensee records of WBCs. WBC records indicated that the

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licensec had an effective program for minimizing personnel exposures to atrborne radioactive material. In 1990 only one positive WBC, resulting from a July 20,1990

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facial contamination incident, required follow-up WBCs and evaluation of intake of radioactive material. The inspectors reviewed the evaluation of the July 1990 facial contamination. The licensee had in place, and effectively implemented, comprehensive procedures for evaluating in vivo bioassay results. The licensee's bioassay evaluation was consistent with air sample data. The evaluation concluded that the intake was well below any regulatory or administrative limit. The inspectors had no further questions on this matter.

The inspectors reviewed selected areas of the licensee's respiratory protection program. The licensee has an adequate program for ensuring that only individuals with current training, medical evaluations, and fit testing are issued respiratory protection devices. The inspectors did note one area of the licensee's respiratory protection program which was not consistent with NUREO 0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials". Section 10.2 of NUREG-0041, * Inspection and Tests After Cleaning and Maintenance" recommends that a leak test shall be performed on all cleaned or repaired devices. This leak check may vary from a simple field test using irritant smo' c to a very sophisticated leak check employing test heads on which the device is mounted and probe tested using a specially generated acrosol or gas with the appropriate readous equipment.

The licensee currently performs a negative pressure test on respirators prior to use; instead of performing a leak test following maintenance. The licensee stated that they are in the process of developing a program to leak test respirators following maintenance. Once implemented, the leak test program will make the respiratory protection program consistent with Section 10.2 of NUREG-0041. This item will be reviewed during future inspections.

4.0 External Esponge Controh The inspectors reviewed the YAEL verifications of exposure rates of the on site gamma calibration sources. Thesc veriGeations were performed using a Keithley 617 electrometer, maintained within a biannual calibration cycle, and Exradin air equivalent ion chambers, traceable to the National Institute of Standards and Technology (NIST). No deficiencies were noted in this area.

The licensee recently purchased a rotating chamber to replace the woodca disc holder used during pxket ion chamber calibration. On the wooden disc holder, the ion chambers are positioned around the perimeter of the holder and an encapsulated source is manually placed in the center of the disc. This method results in unnecessary

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exposure to the technician and exposes the ion chambers to dose rate gradients while the source is phpically removed from the storage cabinet and placed in the source holder located in the center of the dise. The rotating table using the 'J.L. Shepherd

'"Cs irradiator' will reduce the technician exposure and climint a exposure gradients to the ion chambers. The inspectors felt that the addition of the rotation table was a gocxl lleensee initiative.

The YAEL processes the dosimeters for the licensee. The YAEL holds current accreditation in all eight National Voluntary Laboratory Accreditation Program (NVLAP) caty'ories. The licensee routinely uses Panasonic UD 808 thermoluminescent dosimeters (TLDs), which are depleted in 'Li and "'B and therefore neutron insensitive, to monitor the seven categories that do not include a neutron response. The neutron response, NVLAP category number eight, is measured using a liarshaw dosimeter.

The inspectors reviewed the extrapolation chamber and TLD analysis done to support plant outages. The licensee takes radiation measurements using the extrapolation chamber and TLD s, in a phantom under varying depth s of mylar, in the same geometry. This allows the licensee to correlate the extrapolation chamber data with the TLD data. The TLD data provides exposure rate and exposure gradient information inside the steam generators.

The inspectors reviewed the YAEL quality control (QC) program for dosimetry processing. New dosimeters undergo four QC checks before they are used at the plant site. The dosimeters are visually inspected to verify that the dosimeter has the proper identification number and no obvious physical deformities. The dosimeters are then irradhted to verify that only one calcium sulfate (CaSO) element is present and that it is Heated in the appropriate position. The filtration depth is tested by irradiating the dosimeter using a "'Cs beam with a large secondary electron component and companng the element responses to the expected element response. Finally, the dosimeters are irradiated in a neutron / photon environment to test for neutron sensitivity. The inspectors also noted that the dosimeters undergo a quarterly QC check by an independent laboratory.

The YAEL inserts one control dosimeter, irradiated to a known dose (400 mR), with every ten dosimeters. If a dosimeter is analyzed and a high dose is determined, a control dosimeter, irradiated to a known high dose (2500 mR) is processed to demonstrate that the TLD reader is functioning properly.

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O The inspector reviewed recent chemistry analysis of primary coolant. The analysis indleated a slight increme of lodine concentration in the primary coolant during the end of January 1991. The inspector reviewed relevant sample data and discussed the

matter with individuals from the chemistry department. At the time of the inspection the licensee was operating well below applicable Technical Specincation limits. The

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j licensee did not anticipate any further increase in the primary coolant lodine concentration. This item will be reviewed during future inspections.

I 5.0 Mant Tours i

Tours of the licensee's facilities were conducted during the inspection. Areas toured

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included the fuel handling building, the instrument calibration trailer, and the Auxiliary building. The tours showed housekeeping within these areas to be good.

Postings and access control to the controlled areas were found to be good.

j 6.0 Stdits and Aparabah The inspectors reviewed the most recent audit of the radiation protection program,

i Audit Report Number Y 90-03. The 1990 audit had been conducted during the months of June and July. Inspector review of the audit report ineated that a comprehensive audit had been conducted by well qualified individuale The licensee

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had been responsive to audit findings.

l The inspectors reviewed the licensee's summary of Radiological Occurrence Reports j

(RORs) for 1990. There were a total of 10 RORs written in 1990. There were no i

significant ROR findings and the. !!censee's corrective actions for the self identified occurrences was good.

Three QC surveillances were performed for radiation protection practices during 1990.

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Two of the surysillances were conducted during periods of routine operations and one surveillance was conducted during the refuelling outage. The QC auditors also incorporate RP practices into surveillances of all plant departments. The inspectors felt that this was a good practice.

The inspectors noted that the 1990 refuel outage QC surveillance identified instances where the RP contamination controls were reactionary instead of preventive. For cxample, although the system had been drained, a horizontal piping nm was breached

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prior to installing a catch containment. Some residual contaminated fluid spilled onto the floor, requiring the RP technician to immediately establish contamination area

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controls. The auditors noted that the RP technician's response was appropriate; however, they recommended that more consideration be given to preventing instead of reacting to such an occurrence. The inspectors considered the licensec QC surveillances to be a program strength, 7.0 ALARA The 1990 ALARA dose projection was 218 person rem. This projection was increased to 245 person rem when the refuel outage was extended. During the outage ext ( asion, a main coolant pump was replaced, a control rod latching problem was corrected, and a leaking instrument seal on the reactor head was repaired. The dose

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expended during 1990 was 256 person-tem.

The dose projections for 1991 were reviewed during the inspection. The licensee projected that 53 person rem will be expendei in 1991. This estimate allows for 5 person-rem for main coolant pump maintenanca,10 person rem for the Old Potentially Contaminated Storage Area decontamination and clean up, and 3 person rem for work on the Activity Decay and Dilution Tank. The 1991 ALARA goal appeared challenging.

8.0 Exit Meeting The inspectors met with licensee representative at the conclusion of this inspection, on February 8,1991. The inspector reviewed the purpose and scope of the inspection and discussed the inspection findings.

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