IR 05000213/1989008

Insp Rept 50-213/89-08 on 890614-16.No Violations Noted. Major Areas Inspected:Radiological Controls Program on Site, Including Changes in Organization,Personnel,Procedures & Review of Preparations for Refueling Outage

ML20246H584
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	07/07/1989
From:	Pasciak W, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20246H573	List: IR 05000213/1989008 ML20246H569
References
50-213-89-08, 50-213-89-8, IEIN-81-26, IEIN-88-087, IEIN-88-87, NUDOCS 8907170144
Download: ML20246H584 (9)

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. U. S. NUCIFAR REGUIA'IORY 00WlSSICN REGICH 'I Report N /89-08 Docket N License No.' DPR-61 Licensee: ' Liumscticut C Yankee Atcznic Ibwer Cbnpany,.

. Facility Name: Haddam Neck Ibwer Station Inspection At: Haddam Neck, Cbum3cticut Inspection Conducted: June 14-16, 1989

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. Inapar+0r: .

Of S. Sherbini, Senior Radiation Wialis:t date Facilities Radiation Protectlon Section Approved by: SL Md b W. Pasciak, Chief, FMilities Radiation l 7l %9 c ate '

Protection Section Inspection Summary: Inspection conducted June 14-16, 1989 (Inspection Report N /89-08).

Areas Inspected: Routine, unannounced inspection of the radiological controls program on site, including changes in organization, pumumal, and procedures, as well as review of preparations for the trevn%g refueling outag Results: No violations were identified.

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F DETAILS 1.0 Personnel Contacted

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1.1 Licensee Persorinel

• J. Beauchamp, Quality Services, NUSCD

• H. Clow, Health Physics Supervisor W

• E. IbBarba, Station Services Superintendent, CY W. Gates, Assistant Radiation Protection Supervisor (Operations), CY

• D. Miller, Station Superintendent, CY

• W. Nevelos, Radiation Protection Supervisor (Operations), CY J. Powell, AIARA Coordinator, CY 1.2 NRC Personnel

• T. Shedlosky, Senior Resident Inspector

• Indicates attendance at the exit meetir .'O organization Some changes in the Health Physics organir,ation on site were being instituted at the time of this inspection. The licensee stated that the changes are interded to improve ] performance in some areas and also to bring the ratios of supervised technicians per supervisor more in line with company practices. The changes are not expected to have any substantial effect on the manner in which the program is currently being operated, and the.re are to be no changes in staffirg level as a result of the change 'Ihe current organization includes three supervisors reporting to the Health Physics Supervisor: the Radiation Protection Supervisor (Operations), the ard the Radioactive Materials Radiation Protection'Ihe Hardling Superviso Supervisor (Services),ill new organization w have only two supervisors:

Operations and Services; the Radioactive Materials Handling Supervisor position will be eliminated and the persori currently fillirg that position will be reclassified as Assistant Radiation Protection Supervisor reporting to the Radiation Protection Supervisor (Operations). He will be overseeing the same group of technicians involved in radwaste operations, but he will be assisted by a secord Assistant Radiation Protection Supervisor who is being moved laterally from a similar position that he held in the Operations group and that is to be abolished.

l Two Assistant Radiation Protection Supervisors, Services ard Dosimetry, i currently report to the Radiation Protection Supervisor (Services). Both

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these pn=itions ara beirg abolished and the persons fillirq them are to be reclassified as Radiation Protection Specialist and Senior Station Technician, respectively. S ey will both report to their original supervisor and will perform roughly the same functions; the main difference is that their positions in the organization are no longer classified as supervisory positions. We charge was made because the number of personnel they supervised was low (four and two, r=rw+1vely).

The AIARA Coordinator and his assistant currently report to the Radiation Protection Supervisor (operations), but in the new organization tiley will report directly to the Health mysics Supervisor. Beir functions remain essentially unanange Wo other changes were made in the existing organization. Rese involve two persons who were assigned to the site frcan the corporate group on a basis but are now permanently assigned. One of them is a Senior Ra olog cal Engineer who currently reports to the Radioactive Materials Handling Supervisor but who will be reporting directly to the Health mysics Supervisor. His title remains Senior Engineer and he will be working on a variety of Sw ial projects assigned to him by the Health Physics Supervisor. W e second person is a Senior Radiation P1 M ion technician who currently reports to the Assistant Radiation Protection Supervisor (Services) but will now report to the Radiation Protection Supervisor (operations). The title of the person remains unchange .0 Containment Entries At Power Two sets of entries into containment were made recently with the reactor operating at reduced power. Both sets of entries were made to perform maintenance work on the Containment Air Recirculation (CAR) system. his system consists of four cooling units located inside containment. Each unit includes coolire coils, a cooling fan, and ducts to distribute the air, as well as other canpanents for use under accident conditions. Se unit cooling coils are cooled by filtered river water supplied by the Service Water System. We fan ircturs are cooled by small motor coolers also supplied by the Service Water Syste W e first set of entries were made to clean the CAR fan coolers, and took place between March 1 - 22, 1989. S e second set of entries were made to clean or replace the CAR fan motor coolers, ard took place during May 30 -

June 6, 198 Se AIARA review for the CAR fan cooler job included comparisons of estimated man-rems at different power levels as well as differences between work with and without neutron shielding. Se results of these comparisons are shown in the table belo _ __ -_ _ _ _ - - _ _ _ - _ _ _ _ _ - _ _ - _ _ _ _ - _ _ _ - _ - _ _ - _ _ _ _ _ _ _ -

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Ruer Invel, % Dose Estimate, man-rems 100 100 17.023 16.085 -(with (no shieldirxy)

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30 6.383 (no shiel )

30 5.697 (with shield )

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'Ihe choice of power level was influenced by reactor fuel considerations:

operation at irthiate power levels (about 40-80%) is apparentl detrimental to the integrity of the stainless steel fuel cladding.ySurveys '

of the work areas and the man-rem estimates showed that there was a ~

significant reduction in dose rates and dose estimates at 30% power ocmpared with 100% power. On that basis, the decision was made to reduce power to 30% prior to start of work. 'Ihe March entries were made at 30%

power and neutron shieldirxy was used. 'Ibe cooler units were cleaned and put back in service one at a time. 'Ibe estimates and actual values for the job were:

Man-hours Man-rems Estimate 1216 5.697 Actual 1433 6.802

'Ihe estimated was eW. by approximately .19%, which is roughly the extent by ch the actual man-hours exceeded the estimat 'Ibe second job, which involved cleaning or replacing the motor coolers, was also performed at 30% power. Neutrun shielding was not used because it was found to be unjustified due to the smaller dose savings in this case.- 'Ihe estimated dose without shielding was 2.196 man-rems, and was 2.096 man-rems with shielding, for a saving of 0.1 man-rem. 'Ibe net saving would be less than that value after accounting for doses received during installation and l removal of the shields, which was estimated to be roughly equal to the I savings resulting frem using the shield. 'Ihe estimates and actual values for the job were:

Man-hours Man-rems Estimate 576 2.196 Actual 195 1.351 l

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he substantially lower actual dose was due to the fact that the coolers 3 were replaced instead of cleaned, a less avmmare intensive job, whereas j the estimate was based on cleaning the cooler A rreview of the am=antation generated during preparations for these jobs showed that the radiological consequences were carefully considered and that at least a qualitative cost-benefit analysis was do ;e to decide on the appropriate power level to use. Se decision to perfon both jcibs at power {

rather than after shutting down the reactor was apparv ,tly motivated by considerations of fuel integrity and fuel cycle consir'tration .0 Procedures me licensee is continuing the project of re-writing all the site health physics procedures. We licensee stated that the project-is approximately 40% ocmplete. S e new p u alares are being written to conform to a new procedure organization that is substantially different from that used in the old p m alares. "Ihe new suculare set is being organized into a four-volume manual called the Radiation Protection Manual. Each volume addresses a specified area of station health physics. Se Manual titles are Administrative Controls, Radiation Area Cbntrols, Radioactive Materials controls, and Instrumentation. Each volume is organized by subject, much as a technical text is organized. Fach subject area within a volume is called a chapter. For example, in Volume II, " Radiation Area Control", the chapters are: Radiation Work Permit, A%"d of Radiological Carditions, Health Physics Technician Duties, Respiratory Protection Prupam, and Control of Work in Radiation Areas. Each chapter is subdivided into sections, each section being devoted to a particular area of the subject covered by the chapter. S e section is the smallest unit of the Manual, and each section represents an individual sucuiure. For exanple, Chapter III of Volume II, " Health Physics Technician Duties" includes the sections:

PostingofRadiologicalControlsAreas,IockedH1ghRadiationArea Controls, Protective Clothing Guides, Respiratory Protection Guides, Count Roam Duties, Rotating Shift Responsibilities, Control Point Duties, and Personnel m Wuunination. A glossary is added at the end of each volume to define some of the important terms used in that volum A procedure writer's marmal was developed at the beginning of this project to describe how the procedure should be written and validated and the format for each procedure. All suculares are written to the same format, and they all include the same section headings numbered in the same wa S e format includes both the o .'zation of the sections as well as the page format, margin sizes, spac s, and so on. Each procedure is written by the person who works in the area covered by the procedure and who is considered the rest expert in the subject of the procedure. All procedures are validated by technicians by actually performing the steps described by the procedure while being observed by one or more members of the health physics staff. The procedures are kept on a camputer system and are

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6 regularly updated as needed. We last section of each procedure is called the Basis section. Bis section describes the basis for any required action in the procedures, and describes the dr~nts or references fram which the requitamuis were drawn. he actual documents are kept in the health physics library on site. Another section of each pmx ture includes copies of all data sheets, sign-off sheets, and other tables or charts mentioned in the procedure. W e scope of each g vcedure is limited to the activities of the person to wham the procedure is addressed. Ibr example, generation of a Radiation Work Permit (RWP) is covered by several procedurcs, one for the person who requests the IMP, another for the health physics technician I who issues the RWP, and so on. The licensee stated that this method results in simpler, shorter procedures and each individual will have to execute only one complete procedure to accamplish the desired actio A ruview of a few randamly selected procedures frca the Manual showed that the new procedures represent a substantial improvement over the old procedures. me improvements are in the appearance and quality of the suculares, the carqpleteness of the logical prugmssian of actions to be followed, ard in the clarity of the descriptions of the steps to be followe .0 Housekeeping

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Tours of the plant during this inspection showed that most areas of the plant were clean and portable equipnent was kept in an orderly and safe manner. h e licensee stated that they have recently started a new program

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I l to help maintain good housekeeping. High level members of station l management belong to a cammittee called the Fire and HousekeepixJ Canmittee. Members of the cammittee make quarterly inspections of various areas of the plant to look at housekeeping. All areas of the site are l

inspected in one year, and the process is pras-bly repeated. Ecse inspections are in addition to the inspections conducted by the department heads of their own areas of responsibility on site.

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6.0 Definition of Dctremity he extremity is defined in the licensee's Radiation Protection Manual, l Volume I as "The area of the body consistiry of the forearms, including I the elbows, the hands, knees and below". 'Hus definition was based on the licensee's interpretation of IGC Information Notice NO. 81-26, Part 3, Supplement 1: Clarification of Placement of Personnel Manitoring Devices for D:ternal Radiation. We inspector stated that the licensee's definition of extremity appears to be at variance with 10 CFR Part 20, section 20.101, in that the licensee includes the sldn below the knee as part of the extremity and therefore subject to a dose limit of 18.75 rem per quarte !

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That part of the skin, accordire to 10 CFR 20.101, is subject to a dose limit of 7.5 rem per quarter. The inspector statal that this item will be left open pendiro resolution of this matter by the NR

7.0 Changes in Technical Specifications Se detailedlicensee, in a letter s mosed dated charges AprilStation's to the 25, 1989Technical and addressed to the NRC, Specification, Sect ion 6.13, "High Radiation Area". These changes are to be incorporated into an amended openting license. One of the changes is the addition of a distance frm the source of radiation for measuring the avmmire rate to be used in classifying a high radiation area. The current Technical Specifications do I not specify a distance, and this amission has been assuned to imply a contact measutuumit. The proposed distance is 18 inches. This practice has been approved by the NRC for use at the utility's Millstone Unit 3 Reacto In addition to this change, the sentence introducing the requirements for entry into a high radiation area is to be changed from "An individual or group of individuals permitted to enter such areas shall be provided with one or more of the follwing" to " individual or grotp of individuals permitted to enter such areas shal provided with or aemmmnied by one or more of the follwing". 7he erfay requirements remain unchange The inspector stated that the peed revision still cantains a requimusit that may be misinterpreted. This is the requirement that  !

persons entering a high radiation area "shall be armmmnied by ...." "An individual qualified in radiation protection pucstares....who is 1espuisible for providing positive control over activities within the area...". The licensee stated that they interpret this requirement to mean that the qualified person is to keep all Euhas of the group * entering the

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high radiation area urxler visual observation at all times during their stay in the area. The inspector stated that the revised sucelares will be reviewed in a future inspection to ensure that this interpretation is reflected in the !

The amended Technical Specifications are also to include more specific )

requirements for entry into locked high radiation areas. These include specification of the mvimm allwable stay time in the area, and direct or remote (7V monitor) continuous surveillance, by a person qualified in radiation protection promeinres, to provide positive control in the are l This is currently standard practice at the sit The amended Technical Specifications are also to allw for the use of barricades and flashing lights in lieu of using locked enclosures for areas with owire rates above 1000 mR/hr. According to the proposed Technical Specifications, this method is to be used only when locked enclosures cannot be reasonably cubiancted around the. area. This exemption is contained in Standard Technical Specifications 6.12. However, as rH==M in NRC Information Notice 88-87, same licensees have interpreted this l

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exemption to mean that flashiry lights may b6used in place of locked doors under any circumstances. Wese included situations in which existing doors were tot being locked because they were in need of repair.- A review of dmanants provided by the licensee and also discussions with the licensee indicated that they are aware of the misinterpretations or miantaa of this exenption that have occurred in the irdustry and that are detailed in the NRC Information Notdo ' 8.0 Outage Preparations te cycle 15 refueling outage is scheduled to start on September 2,1989 and erd October 30,1989. Se 1989 annual avrmare goal was previously set at 759 man-rem, which includes 10 months of power operation as well as the outage. Se licensee estimated that the power operations for the year will reach 71.5 man-rem, leaving 687.5 man-rem for non power operations wor Se goal as of June 5,1989 for the outage was set at 625 man-rem, but charges in work scope or details may change this goal. he goal is fixed 30 days prior to the start of the outage. Se licensee stated that all steam generator work will be performed under contract by RaWk and Wilcox and that refueling will be performed by Westinghouse with participation by licensee personnel. We licensee stated that they plan to do all refueling work in-house starting with the next outag me cumulative aptre for the outage has been projected by the licensee to be as follows:

Repetitive work 326 man-rem Steam Generator work 108 man-rem Non-repetitive work 191 man-rem Total 625 man-rem Repetitive work includes testing and inspections, valve repairs and

. repacking, insulation renoval and installation, refueling, health physics work, and radwaste. Se most dose-intensive jobs in this category are projected to be as follows:

Refueling 80 ma t rem (25%)

Valve work 55 man-rem (17%)

ISI/ Inspections / Testing 37 man-rum (11%)

HP/Radwaste 80 man-rem (25%)

Operations 40 ran-rem (12%)

Total 292 man-rem (90%)

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Steam Generator LSG) work incitries plugging an estimated 110 tubes,  !

repairing an est 2nated 600 plugs, and sludge lancing. @e licensee stated that most of the work will be done using robotics with only a minimal rumber of jtmps into the channel hea Non-repetitive werk is work not included in the other two categories. We -

rest dose intensive jobs in this category include:

Cavity paint removal / application 10 man-rem (5%)

RHR heat exchanger gaskets 17 man-rem (9%)

Core barrel inspection 10 man-run (5%)

Safety related piping work 21 ran-run (11%)

Appendix R work 60 man-rem (31%)

Modernization of the reactor protection system 10 man-rem (5%)

Nuclear instrumentation replacement 20 man-rem (10%)

Fire detection system upgrade 10 man-rem (5%)

ECCS modifications 10 man-rem (5%)

Split pin repair work 10 man-rem (S%)

Total 178 man-rem (91%)

On November 9, 1988, each department head on site was officially assigned the department's exposure goals for 1989, including power operations and outage goals. A series of meetings was held on February 6,1989 ard on later dates between the health physics and other personnel and the project engineers responsible for the outage jobs. 2e project engineers presented detailed descriptions of their projects, justified the methods used, the numbers of onnel involved, and described actions taken to minimize exposure. D ions followed these presentations in which the projects and methods were evaluated ard dose reduction methods were further explored. As a result of this and other studies performed by the AIARA coordinator on

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site, the initial outage estimate of 1100 man-rems was r d M to the current goal of 625 man-re .0 Exit Meetirn l

me inspector met with licensee representatives at the end of the l irspection on June 16, 1989. We inspector reviewed the purpose ard scope I

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