IR 05000213/1987011

Health Physics Insp Rept 50-213/87-11 on 870420-24.No Violations Noted.Major Areas Inspected:Health Physics & Status of Previously Identified Items

ML20214J269
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/15/1987
From:	Shanbaky M, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214J260	List: IR 05000213/1987011 ML20214J258
References
50-213-87-11, NUDOCS 8705270717
Download: ML20214J269 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-213/87-11 Docket N License No. DPR-61 Priority -

Category C Licensee: Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Haddam Neck Nuclear Power Plant Inspection At: Haddam Neck, Connecticut Inspection Conducted: April 20-24, 1987 Inspector: b^ E- I b / 9 8-7-S. Sherbini, Radiation Specialist date

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Approved by: M. t 4 f//rIf/7

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M. Shanbaky, Chief ~ 'date FacilitiesRadiationProte[ctionSection Inspection Summary: Irspection on April 20-24, 1987 (Report No. 50-213/87-11)

Areas Inspected: Routine health physics and review of the status-of previously identified item ,

Results: Within the scope of this inspection no violations were identifie '

8705270717 870518 PDR ADOCK 05000213 G PDR. G:

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DETAILS 1.0 Persons Contacted During the course of this inspection, the following personnel were contacted or interviewed:

1.1 Licensee Personnel

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• Bellman, NUSCO Radiation Protection Specialist

• H. Clow,' Health Physics Superviso * Collins, NUSCO Radiation Protection-Asco. Scientist

• E. Debarba, Station Services Superintenden D. Miller, CYAPC0 Station Superintendent

• Nevelos, Radiological Protection Supervisor, Operations R._ Roger, Manager, Radiological Assessment Branch, NU '

L. Silvia,' Health Physicist

• M. Sweeney, Radiological Protection Supervisor,- Services 1.2 NRC Personnel

• A. Asars, Resident Inspector

• P. Swetland, Senior Resident Inspector, 2.0 Status of Previously Identified Items 2.1 (0 pen) Unresolved (50-213/84-30-02). Develop system for correcting self-identified deficiencie Drum compactor incident not fully correcte Review of.the status of this item indicated that steps have been taken to correct the previously identified weaknesses in this are A system of self identification has been established. The system is designed to identify and document 1any deviations from proper procedures. - Actions takenito achieve this goal include procedure-changes to accommodate this system, as well as methods to disseminate information on incidents and methods to prevent repeating of errors. These methods include periodic newsletters discussing ,

issues of interest to radiological safety, discussion of radiological deviations in weekly station meetings, and reports to-management discussing these deviation Reports to the head of the department involved in the deviation are also used, with a response from the department head expected. These responses are meant to '

ensure that the deviation is understood and that corrective action will be taken. Incidents of a more significant nature are elevated to upper management attention by issue of Radiological Incident Reports (RIR) I l

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[ 3 A review of selected RIRs issued during 1986, however, indicated a continuing program weakness with regard to analysis of radiological deficiencies and their root causes and lack of comprehensive corrective actions to prevent recurrence. The licensee's corrective actions were usually confined to a specific problem and narrow in scop Recently, there have been significant changes in personnel, organization, and operating philosophy at the site since this item was first identified as a weakness. It is also realized that these changes have taken place only a relatively short time before this inspection was conducted, and that the newly instituted changes may not have had sufficient time to manifest significant improvements in this area. However, since there is no evidence to date of a change, this issue will remain ope .2 (Closed) Violation (50-213/86-02-01). Failure to have procedures for compacting operation which resulted in personnel contaminatio Weaknesses in this area have been corrected by the licensee as indicated in the licensee's response to this violation, dated May 5, 1986. Current procedural controls on the safe use of the compactor in question appear to be adequate for this purpose. The problem of the tendency not to follow procedural requirements, however, which was one of the main contributing factors to this incident, has not been adequately addressed to date. This issue is discussed in

, connection with item 84-30-02 in this repor .3 (Closed) Violation (50-213/86-22-01) (Closed) Violation (50-213/

86-22-02) (Closed) Violation (50-213/86-22-03). These items pertain to the exposure of a worker to a whole body dose in excess of the regulatory quarterly limit of 3 rems. These violations were the subject of escalated enforcement action by the NRC. The weaknesses that were identified have been corrected by the licensee, as described in the response to the violations dated January 9,198 The corrective measures were extensive and appear to be sufficient to preclude similar incident In addition to the corrective actions described in the licensee's response to the violations, other measures have been instituted or are planned to be in effect by the upcoming outage. These measures are designed to remove ambiguous instructions to workers, eliminate poor communications during job execution, and ensure proper worker dose monitoring while working in high radiation field Some specific items designed to accomplish the above include changes to the RWP cover sheet, particularly the elimination of ambiguous instructions such as the requirement to perform intermittent surveys. A Radiation Protection Guidelines sheet has also been added as an addendum to the RWP cover sheet. The guidelines is a

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' 4 check list for the health physics technician and is intended to be used for all jobs in high radiation area Personnel monitoring requirements are also being augmented to require integrating dosimeters for all personnel whose jobs require movement in different areas with substantial field gradients within or between areas. The licensee stated that although these and other masures not detailed here are designed to minimize the risk of errors due to misunderstanding of requirements, they recognize that they are not a substitute for effective and forceful management and control by the station supervisory staf .4 (Closed) Inspector Followup Item (50-213/86-11-01). ALARA program followup (includes item 86-02-02). An ALARA program appraisal has recently been conducted by the corporate staff of Northeast Utilities (NU) of the Millstone and Connecticut Yankee sites, as well as of the corporate staff involved with ALARA. The report describing the findings is dated December 18, 1986. The audit identified many weaknesses in the ALARA operation within the NU organization, both at the sites (Connecticut Yankee and Millstone Point) and at the corporate level. The findings indicate that substantial changes are needed in order to improve the effectiveness of the ALARA measure The heads of the departments involved in the various audit findings were asked to respond to the findings and suggestions in the audit, either by concurring or by suggesting alternatives. The licensee indicated that the official responses to the audit are in the process of being assembled in preparation for review and implementatio Discussions with the licensee and a review of the goal setting process for the upcoming outage indicated that some of the proposed recommendations in the audit have already been informally implemente The goal setting process is now tied in closely with the actual scope of the outage work, and procedures for making more accurate exposure estimates are being developed. The site health physics organization has also had considerable input in the goal setting process, and has participated in the reviews that were held to examine the scope of outage work, the need to perform each of the proposed jobs, and better ways to perform certain parts of the work. As a result of this effort, the initial rough estimate for the outage of approximately 1800 man-rems was reduced to the current estimate of approximately 830 man-rem Other positive efforts toward improving ALARA performance include a system established by site management to track the progress of all outage jobs in order to ensure that the job packages are completed and sent to the site for review in a timely manner. Job supervisors are also being assigned man-rem budgets for the jobs under their supervisio The dosimetry issue system for contractor personnel is also to be modified, i

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The new system will. out contractor workers through all the necessary training and screening but dosimetry will not be issued unless the worker is actually required to enter the Radiological Controls Area (RCA)~for a task assignment. This measure is hoped to prevent the tendency observed in the past to have workers wait in the RCA for job assignments rather than in the contractor trailer areas outside the RCA. Consideration is also being given to incorporate exposure reduction incentives or exposure overrun penalties in work contracts. Other ALARA initiatives include upgrading ALARA training, particularly for job supervisors, and an Exposure Reduction Initiatives (ERI) program. Short term measures in this program include use of known skilled and. trained workers for repetitive jobs and greater reliance on house workers, minimize numbers of people in the RCA, and use of shielded assembly areas for workers inside the RCA. Long term measures include use of alternate materials in the system and full system decontaminatio The exposure tracking system for non-outage operation has been improved, and accountability for exposures incurred has been made explicit. A Goals and Performance sheet is published weekly to track these exposures. The sheet lists the monthly goal for each department, the month and year to date-exposures, and the percentages of the goals these exposures represent. Department heads are expected to justify any exposure overruns to site managemen The licensee stated that the above measures are expected to result in substantial improvement in ALARA performance both during normal operation periods and also during outages. Some areas of weakness remain however. These include the following:

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Measures to control exposures incurred by contractor personnel during outage work is still not well define Training in radiological controls procedures and ALARA measures remain weak, and for many workers is limited to the material presented during the 8-hour General Employee Training (GET).

Review of Radiological Incident Reports (RIR) and discussions with licensee representatives indicate that many workers appear to be unfamiliar with some basic radiological control practices and procedural requirement Pre-job briefings and preparations for entry into the RCA appear to be weak, and job supervisors in some cases appear to neglect to fully brief their workers and to ensure that preparation for the job has been thorough and complet . .

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The audits conducted by the corporate staff of the site health physics program have identified many instances of poor practices observed during the audit tours. However, the. scope of the audits appears to be limited, with. insufficient attention or time being devoted to identifying programatic weaknesses that lead to the' observed deficiencies. This reduces the effectiveness of the corporate audit functio .0 Exit Interview The inspector met with licensee representatives at the conclusion-of the inspection on April 24, 1987. The inspector summarized the scope of the

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inspection and the finding ,

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