IR 05000213/1980006
| ML19337B491 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 07/23/1980 |
| From: | Baer R, Knapp P, Serabian J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19337B490 | List: |
| References | |
| 50-213-80-06, 50-213-80-6, NUDOCS 8010020636 | |
| Download: ML19337B491 (9) | |
Text
O-U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-213/80-06 Docket No.
50-213
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License No.
OPR-61 Priority Category C
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Licensee:
Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connecticut 06101
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Facility Name:
Haddam Neck Plant Inspection At:
Haddam Neck, Connecticut Inspection Conducted:
April 9-11, 1980 Inspectors:
d,67, dexN%eh 7-2 3-B o J/ A. Serabian, Radiation Specialist date hWkw 7-2 3 -so
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R.' E. Baer, Radiation Specialist date
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Approved by.
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O P.Ns Knapp, Chief, Radiation SupporDection, date
Fuel Facility and Materials Safety Branch Inspection Summary:
Inspection on April 9-11, 1980 (Report Number 50-213/80-06)
Areas Inspected:
Routine, unannounced inspection by two regional based inspectors
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of the radiation protection program as it relates to reft:eling outage activities including:
advanced planning and preparation and training.
In addition, licensee action on previous inspection findings was examined.
The inspection involved 46 inspector-hours onsite by two NRC regional based inspectors.
Results:
Of the three area inspected, no items of noncompliance were found.
Region I Form 12 (Rev. April 1977)
8010020(s30
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DETAILS 1.
Persons Contacted
- Mr. R. Graves, Station Superintendent, Connecticut Yankee Atomic Power Company (CYAPCo)
- Mr. J. Ferguson, Station Services Superintendent, CYAPCo
- Mr. H. Clow, Health Physics Supervisor, CYAPCo Dr. R. Rogers, Chief, Radiological Assessment, Northeast Utilities Service Company (NUSCo)
Mr. B. Renza, Project Engineer, NUSCo Mr. R. Brisco, Radiation Protection Scientist, NUSCo Mr. K. Chambliss, Outage Planning and Scheduling Engineer, CYAPCo Mr. B. Nevelos, Radwaste Foreman, CYAPCo Mr. M. Quinn, Chemistry Supervisor, CYAPCo Mr. S. Fleming, Training Supervisor, CYAPCo The inspectors also talked with and interviewed several other licensee employees including members of the health physics staff and maintenance personnel.
- denotes those present at the exit interview on April 11, 1980 2.
Licensee Action on Previous Inspection Findings References:
(a)
Inspection Report No. 50-213/79-06 (b) Enforcement Management Meeting Report No. 50-213/79-09 (c)
Letter from V. Stello, Jr., to D. C. Switzer, dated December 6, 1979 (d)
Letter from W. G. Counsil to V. Stello, Jr., dated
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January 4, 1980 As a result of previous inspection findings, Reference (a), a management meeting, Reference (b), was held at the NRC Region I (Philadelphia)
office to review concerns in the area of radiation protection and to discuss the corrective steps undertaken and planned to prevent recurrence and to strengthen the Haddam Neck Plant radiation protection program.
Further information was subsequently requested regarding the licensee's efforts to strengthen the radiation protection program, Reference (c).
The report of the management meeting and the licensee's response letter, Reference (d), identified the following items:
(a) to correct noncompliance
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and to prevent further recurrence, and (b) to initiate action items to generally upgrade the radiation protection program.
These items are listed below.
For items involving the program upgrade, the status of each item, as determined by the inspectors during the course of the inspection, is indicate _ _ _ _ _ _ _ _ _. _ _ _ _ _ _.
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a.
Previously Identified Items of Noncompliance and Inspector Followup Items (Closed) Noncompliance (50-213/79-06-03):
Failure to adhere to radiation protection procedures pursuant to Technical Specification 6.11.
The inspectors verified through discussion with licensee personnel and review of records that personnel were re-instructed in the importance of reading, initialing and understanding their responsi-bilities listed on the Radiation Work Permit (RWP) before beginning work.
Inspectors also verified through discussion with licensee representatives and review of the refueling outage health physics organization chart that an adequate number of health physics personnel were committed for coverage of refueling outage work. An inspector also verified that the licensee has implemented a computerized records program and hired two full time records clerks in order to strengthen control over the processing of increasing personnel exposure limits.
(Closed) Noncompliance (50-213/79-05-04):
Failure to adequately instruct workers of health protection problems pursuant to 10 CFR 19.12. The inspectors verified through discussion with licensee representatives, review of training lesson plans, and tour of the training facility that the corrective actions have been implemented.
Specifically, the radiation worker training program now addresses applied aspects in more depth (e.g., donning protective clothing), a training mock-up of radiologically controlled area scenarios has been set up, and a company booklet has been issue.d which addrasses occupational radiation exposure risks in perspective.
(Closed) Noncompliance (50-213/79-06-05):
Failure to adhere to occupational whole body exposure limits pursuant to 10 CFR 20.101.
The inspectors verified through discussion with licensee representa-tives that two full time records clerks have been hired and that the procedure governing personnel exposure has been modified to require that a member of the health physics records staff shall ensure that a Form NRC-4 has been completed prior to exceeding 1h rems.
(Closed) Noncompliance (50-213/79-06-07):
Failure to use precautionary procedures to limit the intake of radioactive materials.
An inspector verified through discussion with licensee representatives that the procedure governing MPC-hour accountability, in order to establish limitations on working times, is currently being implemented.
In addition, the following was verified. Procedure RAP 6.1-4, " Determining Airborne Radioactivity Concentrations to the Allowable Personnel Stay Time" has been amended to allow for easier MPC-hour tracking.
An operational whole body counter is on-site and, a respiratory protection program is under active development.
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(Closed) Noncompliance (50-213/79-06-09):
Failure to issue reports of personnel exposure pursuant to 10 CFR 20.408 and 10 CFR 20.409.
An inspector verified thrcugh review of selected licensee records, for the individuals involved, and through contact with the cognizant'
NRC headquarters office, that the reports required pursuant to 10 CFR 20.408 and 10 CFR 20.409 have been sent.
(Closed) Noncompliance (50-213/79-06-12):
Failure to label radioactive material containers pursuant to 10 CFR 20.203. The inspector verified through discussion with licensee representatives and review of general plant meeting minutes that personnel have been re-instructed in compliance associated with labeling radioactive material containers.
(Closed) Noncompliance (50-213/79-06-13):
Failure to post areas containing radioactive materials.
The inspectors verified, as above, that personnel have been re-instructed in the requirements in this area.
(Closed) Noncompliance (50-213/79-06-10):
Failure to provide a continuously indicating dose rate instrument pursuant to Technical Specification 6.13. An inspector verified the following through discussion with licensee representatives, examination of contractor health physics training lesson plans, and review of licensee health physics organization charts.
Health physics personnel have been re-instructed in proper work practices in High Radiation Areas and compliance with Radiation Work Permit (RWP) requirements.
Contractor health physics persoanel receive training in Technical Specifications and plant procedures prior to assuming work assignments on-site, and additional technical and supervisory positions have been created at the plant and at the corporate level.
(Closed) Noncompliance (50-213/79-06-16):
Failure to perform surveys pursuant to 10 CFR 20.201 to demonstrate compliance with 10 CFR 20.101.
Through discussion with licensee representatives and review of licensee health physics organization charts, the inspectors verified that the Health Physics Services Group has been formed and is functioning.
Through review of plant procedures and health physics equipment lists, an inspector verified the development of j
standardized procedures and a standardized health physics equipment list.
Also, a new procedure has been added entitled, " Malfunctioning I
Survey Equipment," effective June 12, 1979, to provide guidance for field personnel in identifying defective survey meters.
(Closed) Inspector Followup Item (50-213/79-06-01):
Interim Health Physics Supervisor qualifications.
Due to an illness, plant management
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had installed a health physics foreman as acting Health Physics I
Supervisor for the 1979 refueling outage; however, this individual did not meet the technical experience qualification requirement for
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the position.
An inspector verified through interviews with the Health Physics Supervisor that this substitution was only temporary and that he had returned to his former (and current) position as Health Physics Supervisor after the 1979 refueling outage.
(0 pen) Noncompliance (50-213/79-06-06):
Failure to make suitable (e.g., breathing zone) measurements of concentrations of radioactive materials in air for detecting and evaluating personnel exposure pursuant to 10 CFR 20.103.
An inspector verified through observation that lapel and high volume air samplers have been purchased and are
on-site. An inspector examined procedures entitled " Air Particulate Sampling" and " Determining Airborne Radioactivity Concentrations and the Allowable Personnel Stay Time", and noted that they incorporated instructions that air samples be taken in the breathing zone.
(0 pen) Noncompliance (50-213/79-06-11):
Failure to control High Radiation Areas greater than 1,000 mrem /hr pursuant to Technical Specification 6.13. Through discussion with licensee representatives, an inspector verified that personnel have been re-instructed in High Radhtion Area control.
An inspector verified through examination of procedures that two Health Physics Instructions (HPI) have been written on the subject of High Radiation Area posting.
These are HPI No. 4, " Posting Contaminated Areas", (which includes precautionary statements that only health physics personnel are to modify or remove High Radiation Area Posting), and HPI No. 5, "Rediation Posting Policy".
(0 pen) Noncompliance (50-213/79-06-17):
Failure to perform surveys pursuant to 10 CFR 20.201 to determine compliance with 10 CFR 20.103 (Refer to Item No. 50-213/79-06-06).
b.
Radiation Protection Program Upgrade (1) Reorganization and additional staffing of the station management, the station health physics department and Corporate Radiological Assessment Branch.
Status:
Current organization charts and job descriptions (where applicable) have been developed in accordance with the above. These changes have been implemented.
All three groups are currently functioning in accordance with these changes.
(2) A special program to present general background information and a perspective on radiation and health effects will be initiated during working hours.
In addition, on-the-job training programs will be modified to increase worker's awareness of good radiation work practice,
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Status:
The radiation worker training program was improved through development of additional audio-visual materials.
The program has been modified to include practical sessions (e.g.,
in protective clothing use and handling contaminated equipment).
A facility has been setup for this purpose, which includes radiologically controlled area mock-ups for demonstration and practice sessions.
Implementation began on April 9, 1980.
(3) A corporate training program for all technicians and foremen will be initiated.
This will be a combination of classroom training and on-the-job training.
All technicians and foremen will be required to attain certification by NU [ Northeast Utilities].
Status:
A phase one program for health physics technicians and foremen level personnel has been developed.
As of May 2, 1980, most (approximately 35-40) health physics technicians within the Northeast Utilities organization have completed the program.
The program consists of about 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of training.
Although on-the-job training is conducted for these individuals, it has not been formally coupled with the 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of training and certification.
An inspector conveyed this finding to the cognizant licensee representative.
A phase two program for supervisory and engineering personnel is currently under develop-ment.
The program will involve one to two week training sessions presented by either universities cr private industry.
Implementa-tion is expected by late 1980.
(4) Certain procedures will be made consistent for all nuclear stations where NUSCo has responsibility.
i Status:
As of May 4, 1980, the standardized health physics procedures had been approved.
(5) Survey and laboratory equipment will be made as consistent as possible for both nuclear stations.
Status:
A Corporate Health Physics Program Standardized Equipment List has been developed.
Final approval of the list was expected by the end of May.
(6) Additional specialized equipment for contamination control will be obtained for Haddam Neck Station.
Status:
Decontamination of radiologically controlled areas had commenced prior to the start of the refueling outage.
A portable air treatment system and blast bag has been obtained for use during steam generator tube plugging operation.
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(7) A corporate contract for health physics technician services...will be negotiated to cover periods longer than 6 to 10 weeks (possibly 1 to 2 years).
Staus:
A two year contract has been signed and went into effect in January 1980.
(8) The layout of the station will be evaluated to determine the possibility for improving... space and logistics....
Status:
A blueprint for station layout changes has been completed and approved.
Construction will commence after the 1980 refueling outage.
(9) Station procedures and equipment [regarding respiratory protection]
are being upgraded with the addition of more quality control.
It is expected that NRC concurrence will be requested by May 1980.
Status:
By letter dated April 1, 1980, from W. G. Counsil to B. H. Grier, the licensee notified the Nuclear Regulatory Commission, Region I office, pursuant to 10 CFR 20.103(e), of the intention to make allowance for the use of respiratory protective equipment. The licensee sent an approved set of respiratory protection procedures and respiratory protection equipment list to the Region I office on April 25, 1980.
3.
Advanced Planning and Preparations a.
Increased Health Physics Staff To augment its staff for the refueling outage, the licensee requested supplemental health physics personnel from a contractor firm.
Approximately 75 to 85 technicians were requested.
A licensee representative stated that these individuals would receive training in plant procedures prior to assuming work assignments in the field.
An inspector reviewed lesson plans, tests and sign-off sheets and verified that the licensee's screening method for contractor health physics technicians appears adequate.
The screening method includes review of previous related experience, formal and practical training,
testing and check-off sheets.
b.
Special Training One of the most radiologically significant activities during the refueling outage involves steam generator entries (incident to eddy current testing and tube plugging operations).
A licensee representa-
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tive stated that vendor personnel, involved with steam generator activities, are specially training for these entries (e.g., through mock-up exercises).
Prior to allowing steam generator entries, the licensee intends to verify, through review of the vendor's special training documentation, that the training has been conducted and provides instruction commensurate to the hazard, as required by 10 CFR 19.12.
c.
Contamination Controls Prior to the start of the outage, the licensee contracted for the services of a decontamination firm.
Approximately 80 individuals were assigned to decontaminate or to significantly reduce contamination in controlled area (e.g., the Vapor Containment).
Also, certain areas, such as the refueling cavity deck, will be subject to pre-job set-ups using plastic drop cloths for contamination control.
d.
Instrumentation, Equipment and Protective Clothing The inspectors reviewed matsriel inventory lists, made observations in the field, and interviewed licensee representatives to verify that adequate quantities would be available during the outage.
The inspectors noted that approximately 300 survey instruments (which included survey meters with alpha and beta radiation measurement capability) would be available for the outage. Also, the formation of the Health Physics Service Group would ensure that instrument maintenance was provided throughout the outage.
The inspectors
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concluded that the licensee had acquired survey instruments of sufficient numbers and capabilit'.es as to support maintenance / refueling activities throughout the outaqe.
An inspector learned the following regarding other matsriel.
A licensee representative stated that a respiratory mask cleaning trailer would be obtained for use during the outage and would be capable of cleaning from 1,200 to 1,800 respirator masks per day.
Also, regarding protective clothing, on-site cleaning was anticipated to clean from 1,800 to 2,000 coveralls per day.
Moreover, an additional whole body counter would be obtained for use during the outage.
The inspectors concluded that the licensee had (or planned to have)
sufficient matsriel as to support maintenance / refueling activities throughout the outage.
e.
Special Audits The inspectors learned through discussion with licensee representatives that sevo al special pre-outaga audits had been conducted by the licensee's corporate Radiological Assessment Group.
The inspectors i
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subsequently reviewed these audits and noted that instrument inventories and the status of the developing respiratory protection program were examined.
The inspectors verified through review of licensee memoranda and station / corporate meeting minutes that review and followup of audit findings and recommendations are conducted.
No items of noncompliance were identified in this area.
4.
Radioactive Waste Shipping At the inspectors' request, two of twenty radioactive waste drums, which had been packaged and made ready for shipment, were randomly selected for inspection. The lid of each drum, containing solidified evaporator bottoms, was removed.
Inspectors observed no free standing water and no evidence of moisture.
No items of noncompliance were identified in this area.
5.
Exit Interview The inspectors met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on April 11, 1980.
An inspector sucmarized the scope and findings of the inspection as presented in this report.
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