IR 05000029/1996003

Insp Rept 50-029/96-03 on 960827-29.No Violations Noted. Major Areas Inspected:Operations,Rp Program,Including Operations,Staffing,Mgt & Licensee Experience in Identifying & Correcting Weaknesses Re Control of Radioactive Matls

ML20129C963
Person / Time
Site:	Yankee Rowe
Issue date:	10/16/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129C923	List: IR 05000029/1996003 ML20129C921
References
50-029-96-03, 50-29-96-3, NUDOCS 9610240165
Download: ML20129C963 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket N License N DPR-03 Report N /96-03 Licensee: Yankee Atomic Electric Company 580 Main Street Bolton, Massachusetts 01740-1398 Facility Name: Yankee Nuclear Power Station Location: Rowe, Massachusetts Dates: August 27-29,1996 Inspector: J. Nick, Radiation Specialist Approved By: J. White, Chief Radiation Safety Branch, Division of Reactor Safety 9610240165 961016

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I Report Details 01 Summary of Facility Operations On October 12,1995, the Commission served Memorandum and Order CLl-95-14 to Yankee Atomic Electric Company (YAEC) concerning activities at the Yankee Nuclear )

Power Station (NPS) in Rowe, Massachusetts. The Order states, in part, that "the l NRC's approval of the Yankee NPS Decommissioning Plan cannot be accorded further I legal effect, pending an [ adjudicatory] hearing opportunity," and, that in accordance with the pre-1993 interpretation of the decommissioning regulations, "the Commission expects YAEC not to conduct any further ' major' dismantling or decommissioning activities until final approval of its [ decommissioning] plan after completion of the hearing process." Based upon issuance of this Order, the inspector observed YAEC's activities during routine inspections on August 27 through 29,1996 to ascertain what work activities were in progress and if these activities were in compliance with the Orde Technical guidance and established written criteria for what constituted " major" facility dismantling or decommissioning activities were previously provided to YAEC in a letter dated November 2,1995. The letter stated, that "YAEC could proceed with activities (such as additional decontamination, component disassembly, and shipment and I storage of spent fuel), if these activities: (1) are permitted by the POL and l 10 CFR 50.59, and (2) do not materially and demonstrably affect the methods or options available for decommissioning or substantially increase the cost of decommissioning." Consequently, the inspector determined that all the work activities observed on August 27 through 29,1996, were in accord with this guidance and consequently satisfied compliance with the October 12,1995 Orde The inspector verified by observation, documentation review, and/or discussions with responsible or involved plant staff, that the activities on the current work schedule were the only jobs working. No safety concerns were identified by the inspector and appropriate radiological and industrial safety practices were observed for those jobs in- I progres O2 Operations O2.1 Facility Tours l The inspector toured radiological controlled areas (RCAs) within the vapor containmen The inspector noted operating air sampling equipment in various areas. Personnel dosimetry was worn by all workers in the area. Workers were in the vapor containment, outsido the bioshield, removing mechanical and electrical components (duct-work, conduit, cables, and fan units). The inspector observed that high radiation area (HRA) and locked high radiation area (LHRA) controls were satisfactory. All areas were posted, barricaded, and locked as required by NRC regulations and Technical l Specifications. The posting and labelling of radioactive material were satisfactor Very good radiological controls were provided by health physics technician coverage for jobs / activities in RCA _ _ _ _ _ _

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The inspector toured most of the RCAs outside the vapor containment including the primary auxiliary building (PAB), the service building, the radioactive waste processing (compactor) building, the potentially contaminated area (PCA) storage building (a storage / staging area for potentially contaminated equipment and materials), and the PCA warehouse attached to the radwaste processing buildin Workers were observed assembling a temporary waste processing system near the ion exchange pit. The temporary waste processing system included holding tanks and an evaporator which were planned to replace the existing waste evaporator syste Other electrical and mechanical systems removal was continuing in the Primary Auxiliary Building (PAB). All radiation areas (ras) and HRAs were posted and barricaded as required. Locked HRAs were maintained locked with appropriate warning signs. Housekeeping in contaminated areas was good, and contamination control was evident by the use of " step-off pads", personnel monitoring equipment (friskers), and contaminated area postings at the boundaries. No safety or NRC regulatory concerns were noted by the inspecto .2 Current Activities Asbestos abatement work was continuing on the secondary side in the turbine buildin Some secondary and support systems removal had been started. The water treatment system had been dismantled and the space was being reconfigured for use by the site survey team. A temporary gatehouse had been established to allow renovation of the main gatehouse. The licensee plans to move the control room functions to the gatehouse to consolidate activities with the security organization. The engineering design change request for moving the control room functions had not been finalized as of the period of this inspectio Other work planned for 1996 included completion of the jobs mentioned above. At the time of this inspection, no new activities were planned pending the approval of the Decommissioning Plan by the NRC or later submittal in writing to the NRC regarding new planned activitie Planning was continuing for the reactor vessel removal project. Actual removal, packaging, and shipment of the reactor vessel was planned to begin after approval of the Decommissioning Plan by the NR R1 Plant Support - Radiological Controls Program R1.1 Oraanization Inspection Scooe (83722)

The inspector reviewed the radiation protection program organization through interviews with personnel and a review of licensee documents.

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3 Observations and Findinas The radiation protection department had a direct reporting relationship to the plant manager. This change was made effective in the past 2 years and provided clear direction and accountability from the plant manager. The licensee's organization was not large and complex, and the radiation protection manager previously had access to the plant manager; however, the change was symbolic in elevating the radiation protection program and worker protection to a higher management level. This change had ensured management attention and support for the radiation protection progra The Radiation Protection / Chemistry Manager maintained six areas of responsibility, including operational radiation protection, radwaste, technical, final status survey, ALARA, and chemistry / environmental. The personnel supervising these areas were well qualified and experienced for their position Conclusions The licensee had no significant changes to the organization that could affect the ability to control radiation and radioactive materials. Mirior decreases in the number of contractor personnel were noted. No safety concerns were note R1.2 Staffino Inspection Scope (83722) -

The inspector reviewed the staffing of the radiation protection program through interviews with personnel and a review of licensee document Observations and Findinas The majority of workers on the Rowe site were contractor employees. Yankee Atomic Energy Corporation (YAEC) provided oversight and supervision of the contractor employees for radiological work activities. Eight YAEC employees provided this oversight for approximately 60 contract radiation protection technicians. Many of the contract employees were long term employees or had worked at the site in the pas The YAEC staff's control of work activities was very good, and staff involvement was continuous. This control ensured proper direction to the contractor employee The inspector reviewed the records of initial and continuing periodic refresher training for the radiation protection technicians. With the exception of one individual, all technicians were listed as attendees at the required training. The licensee's staff determined that the one individual had been missed due to an isolated error in the attendance system. The staff was considering actions to prevent recurrence of this erro .. . . . . -

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l The inspector also reviewed the lesson plans for the training sessions. The quality of the training was very good and included important program changes, industry events, and basic information refresher Conclusions Plant management ensured proper staffing, training, and direction of personnel for the l effective control of radiation and radioactive materials. Personnel were qualified for the l positions and no safety concerns were note R1.3 Radiation Protection Manaaement insoection Scope (83722)

The inspector reviewed the management of the radiation protection program through examination of procedures, memorandum, and other licensee documentation, and interviews with personne Observations and Findinas

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As stated in section R1.2 of this Report, the Radiation Protection / Chemistry Manager had six areas of responsibility. Control of work activities was well coordinate Effective management controls and oversight were implemented through the use of procedures, internal memoranda, staff meetings, and facility tours. The management team was effective in planning, organizing, and directing radiological controls and associated program Conclusions The inspector determined that the radiation protection management had adequate responsibility, authority, and support to ensure effective control of radiation and radioactive material. No violations or significant safety concerns were identifie R1.4 Identification and Correction of Weaknesses Insoection Scope (8372 The inspector reviewed the licensee's experience in identifying and correcting weaknesses related to the control of radiation and radioactive materials through examination of records and interviews with licensee personne !

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, The licensee provided several methods for identification and correction of program

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weaknesses including the radiological occurrence reporting system, internal reviews, and oversight committee The licensee's radiation protection staff had written several radiological occurrence i reports (RORs) during 1996. Four RORs were written earlier in the year and had been rev'ewed during previous NRC inspections. All RORs documented minor procedure i violations. The inspector reviewed the corrective actions and noted that timely and

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technbally acceptable corrective actions were implemented for these deficiencies to ,

prevent recurrenc j l Internal reviews were performed on a periodic basis to probe specific areas of the radiation protection program for weaknesses. The inspgetor had previously reviewed I internal assessments of the occupational safety program, the ALARA program, and the '

technical program. Periodic reviews were also performed on radiological occurrence 1 reports to identify common trends or root causes. These reviews resulted in  ;

recommendations to prevent recurrenc i l Conclusions  :

i The inspector concluded that the licensee had effectively identified and corrected areas of weakness within the radiation protection program. No significant safety items or violations were identified in this are R1.5 Audits and Aooraisals insoection Scooe (83722)

The inspector reviewed the licensee's programs and systems for auditing and appraising the program for control of radiation and radioactive materials through examination of records and interviews with licensee personne Observations and Findinas There had been no new audits of the radiation protection program since the last inspection; however, the inspector noted recent audits of the special nuclear materials control program, the training program, the industrial safety program, the environmental program, the REMP/RETS/ODCM programs, and the corrective action syste Appropriate and timely corrective actions had been taken by the licensee's staff for the minor deficiencies and weaknesses that were identified during the audits performed by the quality assurance grou The quality assurance group was continuing to perform surveillance of radiological work activities and waste shipments. The inspector reviewed surveillance report regarding various radiological work activities. The surveillance reports indicated that the implementation of the radiation protection program was satisfactory.

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I 6 Conclusions The inspector concluded that the audit, self-assessment, and corrective action programs were continuing to identify problem areas and improve the quality of the radiation protection program. No violations were identified in this are R1.6 Maintainina Occupational Radiation Exoosures ALARA Inspection Scope (83100)

i Through interviews with personnel and review of several documents, the inspector ;

examined the program to maintain personnel exposures ALAR Observations ad Findinas )

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The personnel working at the Rowe site received a total radiation exposure of

approximately 81 person-rem during the period from January 1,1996 through

August 26,1996, as measured by thermoluminescent dosimeters (TLDs) and pocket '

ion chambers (PICS). The projected total exposure during 1996 was 91 person-rem for routine work and support of decontamination and decommissioning activities.

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Additional exposure was projected for dismantlement of the reactor vessel, the main j coolant system, various other systems in the vapor containment, balance of plant systems, and other structures. Some additional exposure was projected for asbestos abatement end radioactive waste shipments. The total dose to personnel working on i

all activities at the Rowe site for the period from 1993 through August 1996 was approximately 486 person-rem. The total dose for decommissioning and dismantlement

) activities, including support work, was approximately 440 person-re i Conclusione

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The licensee continued to maintain ALARA reports for exposure tracking and trending.

l Total occupational radiation exposure for the year to date was less than the projected total for the yea R2.0 Radioactive Material Shioments Insoection Scoce (86750)

The inspector reviewed licensee records and interviewed personnel to determine the scope of radioactive material shipments from the Rowe sit Observations and Findinas Many radioactive waste and radioactive material shipments were sent from the Rowe site to waste processing or disposal facilities during the period from May 15,1996 through August 15,1996. The licensee was continuing to use various vendors for volume reduction, incineration, reclamation, and decontamination of radioactive materials. Various other radioactive material shipments were made from the facility including contaminated protective  !

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7 Conclusions The licensee continued to ship radioactive materials to various vendors and disposal facilities. Licensee records were well maintained and no safety concerns or violations of regulations were note X1 Exit Meeting Sumn'ary The inspector met wi*h the licensee representatives denoted below at the conclusion of the on-site inspection w August 29,1996. The inspector summarived the purpose, scope, and findings of the inspection. The licensee representatives acknowledged the inspection finding i i

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l PARTIAL LIST OF PERSONS CONTACTED i

Licensee i

! *G. Babineau, Radiation Protection and Chemistry Manager

• W. Blackadar, Radiation Protection Engineer

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• H. Breite, YNSD, Lead Engineer j 'W. Cox, YNSD, Radiation Protection Engineer l l *N. Fetherston, Maintenance and Construction Manager l 2 J. Gedutis, Chemistry i *R. Greenfeld, Radiation Protection Engineer

'R. Grippardi, YAEC, Quality Assurance Supervisor

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"K. Heider, Site Manager l *S. Litchfield, Health and Safety Supervisor

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• R. Mellor, YNSD Decommissioning Manager (via telephone)

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S. Mullet, Radiation Protection Technician ,

• J. Pelletier, Yankee Atomic j *S. Racz, Training Coordinator j 'A. Trudeau, Quality Services Group Senior Engineer i e

'M. Vandale, Radiation Protection Senior Engineer ,

] F. Williams, Operations Manager  :

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• Denotes those individuals participating in the exit briefing held on August 29,199 I INSPECTION PROCEDURE USED

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IP 83722: Radiation Protection, Plant Chemistry, and Radwaste: Organization and Management Controls

ITEMS OPENED, CLOSED, AND DISCUSSED Opened I NONE Closed NONE l Discussed

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NONE