IR 05000213/1987030

Safety Insp Rept 50-213/87-30 on 871116-20.No Violations Noted.Major Areas Inspected:Radiological Controls Program, Including outage-related Exposure Records & ALARA Measures, Whole Body Counting Program & Excreta Bioassay Program

ML20237E558
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	12/16/1987
From:	Shanbaky M, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237E534	List: IR 05000213/1987030 ML20237E531
References
50-213-87-30, NUDOCS 8712290057
Download: ML20237E558 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-213/87-30 Docket N License No. DPR-61 Priority -- Category. C Licensee: Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connecticut 06141 Facility Name: Haddam Neck Power Station Inspection At: Haddam Neck, Connecticut Inspection Conducted: November 16-20, 1987

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Inspector: e ap2 J 2. / 4 / $'7 S. Sherbini, Senior Radiation Specialist, Date Facilities Radiation Protection Section Approved by: .-f/f .

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'7 M. 'M.'S~hanbaky, ~ Chief, FjpWiities Radiation Protection Section Inspection Summary: Inspection November 16-20, 1987 (Report No. 50-213/87-30)

Areas Inspected: Routine, unannounced safety inspection by a region-based inspector of the licensee's radiological controls program. Areas inspected included outage-related exposure records and ALARA measures, the whole body counting program, the excreta bioassay prograt, and the respirator progra Results: No violations were identified during this inspectio PDR ADOCK 05000213 0 DCJ

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DETAILS 1.0 Personnel Contacted 1.1 Licensee Personnel

• J. Beauchamp, Quality Services Superintendent, NUSCO

• H. Clow, Health Physics Superviso * E. DeBarba, Station Services Superintendent R. Groves, Assistant Radiation' Protection Supervisor V. Harrison, Health Physics Technician -

• D. Miller, Station Superintendent

• W. Nevelos, Radiation Protection Supervisor

• R. Rogers, Manager, Radiological Assessment, NUSCO L. Silvia, Health Physicist M. Sweeney, Radiation Protection Supervisor NRC Personnel

• T. Shedlosky, Senior Resident Inspector A. Asars, Resident Inspector 2.0 Status of Previously Identified Items 2.1 Status of Open Items (Closed) Unresolved '(50-213/84-30-02) Develop' system for correcting self-identified deficiencie This item was reviewed and updated in NRC' Inspection Report (50-213/87-11). Although a system for correcting self-identified deficiencies had been developed since the item was, opened, review of the licensee's use of the system revealed that it was not being used effectively. The corrective actions following incidents identified and-investigated under this system's directives were found to be superficial and did not address the underlying cause Review of the item during this inspection showed that the licensee has corrected this programmatic weakness. Although no new incidents have been investigated under the.self-identification, system, other licensee actions indicate that corrective actions now address root'causes and produce programmatic changes designed to minimize the probability of recurrence of similar incident )

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2.2 Review of Previously Identified Weaknesses One of the areas that was identified as a weakness in previous inspection reports was that some of the procedures were not well written ard were sometimes ambiguous, incomplete, or inaccurate. Also, the audits performed by the corporate health physics group were found to be limited in frequency and dept Review of this item during this inspection indicated that the licensee has initiated corrective actions to address these weaknesses. The frequency of corporate audits has been increased and is in the process of being increased furthe The man-hours devoted to these audits has also been increased and will be increased further, indicating greater depth in the audit process. The emphasis of the audits is also being shifted to include more programmatic reviews rather than concentrating only on identifying violation The licensee has also established a committee of health physics personnel from the site and the corporate group to review station procedure Although these changes promise to improve the quality of the programs on site, this inspection indicated that the process still needs to be strengthened. This assessment is based on the fact that inspecti6n of the whole body counting and respirator programs identified important weaknesses in the program and the program procedures. These weaknesses had not been identified by the licensee despite the fact that the program and the procedures had been recently reviewed and audited. The licensee indicated that the process of establishing an ongoing audit program is not yet complete and that the complete program will address these weaknesse Another area of weakness that had been identified in a previous report was that the computer software in use on site had not been upgraded recently and that in many instances the software presented difficulties in performing daily tasks in an efficient and effective manner. Review of this area during this inspection indicated that some progress had been made. In particular, the software used by the ALARA group on site has been upgraded slightly to enable better tracking of exposures. However, it appears that a permanent solution to the problem has not been accomplished. .____-___ -____________ -

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3.0 Bioassay and Respirator Maintenance Programs The bioassay program on site, which includes the whole body counters and the excreta bioassay program were reviewed during this inspection. Also reviewed was the program for respirator maintenance and respirator fittin The whole body counter facility includes one chair type counter l and one bed counter. Both counters are operated using Canberra

electronics and data analysis software. Data analysis for both systeins is performed by a common computer. The facility is located in the Emergency Operations Facility (E0F), which is outside the site fence but within easy access by foot from the fenc The chair system is equipped with two sodium iodine (Nal)

detectors. The torso detector (lung plus gastrointestinal) is a 3"x3" crystal . The thyroid detector contains a 1.5"x0.5" crystal .

The bed system contains a 8"x4" crystal detector. A' review of the whole body counter procedures and program showed that the systems I are well maintained and well operated by a health physics technician. The system is periodically tested using vendor-supplied spiked samples. The NRC had also recently performed a confirmatory measurements test on the system using the NRC phantom and reference standard sources. During this inspection the inspector found that the whole body counter operation may need additional technical improvements. The i procedure ~. governing the operation and quality assurance of the j system were also found to be lacking in important details. Some i of the items identified as weak points are listed below as examples to illustrate these weaknesse According to the manufacturer's recommendations, the i

detector electronics must be properly adjusted before collecting data for calibration purposes. The procedures do-not mention this requirement. The licensee stated that the vendor comes in once a month as part of the service contract

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to perform maintenance on the counters. The licensee was not l

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sure, however, if the service work included the required adjustments, nor of the recommended frequency for such adjustment ;

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According to the manufacturer's recommendations, and also ;

based on accepted good practice, spectrum peaks used for l calibrations must contain a sufficient number of counts to l ensure good statistics. The licensee's procedure specifies a !

minimum counting time for calibration measurements. However, i a source strength is not specified, nor is there a ;

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requirement to check the counts under the peaks used in the calibration i I

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Although the procedures call for monthly QA tests, these tests are not specifded in the procedures. The monthly tests ,

are, however, being performed in accordance with tables designed for accepting monthly test dat As part of the QA program for the whole body counters, the licensee has contracted with a vendor to periodically supply )

spiked samples for analysis on the counters. However, the a procedures do not mention these tests which may require l necessary information such as activity ranges, frequency of testing, testing protocol, acceptance criteria, personnel to review the results, and other technical informatio The whole body counter operation is governed by two <

procedures. However, one of these procedures specifies )

annual system calibration and the other requires it )

semi-annually. The licensee stated that the calibration is now to be performed annually and that the conflict arose because one of the procedures has been revised and the other )

is still in the process of revisio J i

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The manufacturer specifies that the source used for 'i efficiency calibrations must produce a minimum of five peaks in the energy spectrum. Furthermore, those peaks should have energies such that at least two are below the crossover point and two above that point. The crossover point is an energy that separates the high end from the low end of the efficiency curve. The source used by the licensee does not satisfy this requirement. Discussions with the licensee indicated that the concept of crossover was not understood clearly by those in charge of producing the efficiency curves. Also, the effects of an improper choice of crossover on system performance was also not clearly understoo The QA/QC program for the counters requires that tests be performed and that the results of these tests be evaluated 4 to determine if "significant" differences or changes are noted. In many instances, however, the criteria for significance are not specified, either in qualitative or in quantitative term The computer system prints out the values of the minimum detectable activities (MDA) of the isotopes that were not identified in an analysis. However, there is little review of the magnitudes of these values to ensure that the systems continue to have the required sensitivity, which is normally 5% of the maximum permissible organ burde The above weaknesses were discussed with the licensee's health physics staff. The licensee indicated that these issues will be examined and action will be taken as appropriat _ _ _ _ _ _ - ___ ____ _ _ _ _ _ _ _ _

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i The respirator maintenance and fitting facilities were reviewed during this inspection. The maintenance and cleaning facility is

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located in a trailer in the yard inside the plant fence. A review l of this facility indicated that it is well equipped. There was no activity in the trailer during the inspection, but discussions 3 with the licensee 'ndicated that the cleaning and maintenance procedures are adequate and up to accepted industry standard The respirator fit facility is located in the'E0F, adjacent to the whole body counter facility. It consists of two fitting booths, each with its own aerosol . supply and detection system Mineral oil is used in the generator. The machines were originally used with corn oil. However, the licensee stated that .

corn oil tended to foul the internals of the generators and I tubes, and made maintenance and cleaning very difficult. The j inspector inquired whether the change from corn oil to mineral 1 oil may have required different machine settings. The licensee explained that no change was require Inspection of the respirator fit facility indicated that it was properly operated in accordance with accepted industry standard The inspector noted~ one weakness, however. The flexible plastic pipe in each of the booths that is used to draw a sample of .

aerosol from the booth did not appear to be in the breathing zone of the person being fit tested. The licensee stated that the tube inlets will be repositioned to ensure that proper breathing zone aerosol samples are obtained during testin The inspector noted that, in general, the whole body counter and respirator fitting operations were well organized and well run on a day to day basis. The technicians in charge of operating the systems were found to be competent in performing their duties, and the systems appeared to be well maintained. However, the inspector found that technical support and oversight was-weak. The technicians were in effect making decisions regarding technical matters that were outside their areas of expertise, and -

there was little review of these decisions. The procedures governing the operation were found to be somewhat weak in that'

they did not explicitly specify the QA/QC tests to be performed, the frequencies of such tests, and the acceptance criteria to be use The inspector discussed these findings with the licensee. The licensee stated that these findings will be examined and the weaknesses in the program will be correcte _ _ . _ _ _ _ _ .

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4.0 Integrated Exposures During the Outage and ALARA The inspector reviewed the scope of the work performed during the current outage and the records of exposure accumulated during that work. The inspector also reviewed the efforts expended by

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the licensee to minimize exposur The first man-rem projected for the outage was published September-1986 and was about 1870 man-rem. It was realized at the time that this was a large exposure figure and that efforts must be expended to reduce it. As a result of re-evaluation of the work scope and the details of each job to be performed, a new estimate of 990 man-rem was published by the ALARA coordinator on October 1986. The reductions resulted from eliminating some jobs deemed to be unnecessary, reduction in the scope of others, and changes in the manner some of the jobs were to be performe ALARA measures were incorporated into this reevaluation. Further ALARA reviews and meetings between the project engineers and site and corporate health physics staff resulted in a final goal for the outage of about 830 man-re Review of the outage cumulative exposure to the date of the inspection showed an exposure of approximately 630 man-rem. Major work performed included repetitive maintenance jobs, welding and inspections of systems, and major system modifications. The outage is still ongoing but most of the work has been complete The main outstanding items are work on the thermal shield and refueling. The work is expected to be completed during the first I quarter of 1988. The licensee estimates that the final outage I exposure will be within the established goal of 830 man-re ALARA performance during the current outage marks a significant l improvement over performance during the previous outage. Although  !

the initial exposure estimate for this outage of 1870 was close to the cumulative exposure for the previous outage, the process of job scope and goal setting was changed during preparations for the current outage. This change was directly responsible for j reducing the estimate by a factor of over 2. Some of the factors that led to an improvement in ALARA performance compared to that in previous outages are listed belo j i

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More timely planning of outage work. This permitted more )

extensive discussions regarding the scope of the work and '

methods to reduce exposur '

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Closer cooperation between the engineering staff in charge of projects and the health physics staff, particularly the site staff. This led to important modifications in the manner some jobs were performe __ - _ - _ _ _ . _ _ _ _ _ _ _ _ _ _ - . __ -. . _ -

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Early involvement of the site health physics staff in the goal setting process. This allowed the site staff to use their detailed knowledge of the radiation fields in the plant in changing the job details with a view to reducing exposure. It also gave the ALARA personnel sufficient time to implement ALARA method Establishment of a new facility devoted to steam generator work. This facility was used as the control point for. access into containment for steam generator work. The facility included tee.hnicians to review RWPs, check dosimetry, and maintain constant monitoring of work on all generators at all times by way of closed circuit T Greater presence of supervisory staff at job locations to review job progres Adoptions of important ideas submitted by station staff to improve job efficiency and reduce exposur Commitment of station upper management to ALARA and their insistence on accountability of section heads for the exposures of personnel they supervis Commitment of corporate management to improving ALARA performanc The outage exposure to date of 630 man-rem is higher than the national annual average for pressurized water reactors of about 400 man-rems. However, this should not detract from the fact that there has been a significant initial improvement in performanc This improvement is the result of important changes in management philosophy as well as in the manner in which outages are planned and controlled. The licensee stated that further improvements in performance with significant reduction in total exposures is expected for future outage .0 Exit Meeting The inspector met with licensee representatives at the conclusion of the inspection on November 19, 1987. The inspector summarized-the scope of the inspection and the findings.

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