IR 05000309/1986019

Safety Insp Rept 50-309/86-19 on 861117-21.No Violations Noted.Major Areas Inspected:Radiation Protection Program, Including Status of Previously Identified Items,Alara, Organization & Staffing & Control of Radioactive Matls

ML20207P487
Person / Time
Site:	Maine Yankee
Issue date:	01/12/1987
From:	Cioffi J, Dragoun T, Kaminski M, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207P479	List: IR 05000309/1986019 ML20207P478
References
50-309-86-19, NUDOCS 8701160182
Download: ML20207P487 (12)

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U.S. NUCLEAR REGULATORY COMMISSION i

REGION I

Report No. 86-19 Docket No. 50-309 License No. DPR-36 Priority -

Category C Licensee: Maine Yankee Atomic Power Company 83 Edison Drive Augusta, Maine 04336 Facility Name: Maine Yankee Nuclear Generating Station Inspection At: Wiscasset, Maine Inspection Conducted: November 17-21, 1986 Inspectors: Cb '

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' d&te J. poff.1, Radiation Specfialist W. Ynswud$J ~~

l l9 N M. Ka'minsk1, Radiation Specialist ' date W $~ Y^ h ///date Zh7 T. Ofagoun, Senior Radiition Sppialist Approved by: 4t/. 5 Ndh M. Shanbaky, Chibf, Facilitifs Protection

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' dats Protection Section Inspection Summary: Inspection on November 17-21, 1986 (Report No 50-309/86-19)

Areas Inspected: Routine, unannounced safety inspection of the radiation protection program including: status of previously identified items; ALARA; organization and staffing; control of radioactive materials, surveys, posting and labeling; calibration and maintenance of survey meters; and the respiratory protection progra Results: No violations were observe ;

l 0701160182 870113 PDR ADOCK 05000309 O PDR ,

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

1.1 Licensee Personnel

• C. Frizzle, Vice President / Manager of Ops

• J. Garrity, Plant Manager

• E. Boulette, Assistant Plant Manager / Technical Support

• G. Pillsbury, Assistant to Technical Support Manager

• G. Cochrane, Rad. Controls Section Head

• D. Sturniolo, Principal Radiological Engineer

• L. Lawson, QA Section Head

• R. Lawson, QA Manager

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• S. E'ians, Licensing Engineer P. Dostie, Lead Rad. Controls Specialist J. Hummer, Rad. Protection Supervisor B. Wills, Hazardous Waste Coordinator G. Kapinos, Rad. Control Specialist D. Lewis, Personnel

• Attended the Exit Interview on November 21, 1986 1.2 NRC Personnel D. Limroth, Project Engineer 2.0 Purpose The purpose of this routine inspection was to review the licensee's radiation protection program with respect to the following elements:

• Status of Previously Identified Items

ALARA

• Organization and Staffing o External Exposure Control

• Calibration and Maintenance of Survey Meters

• Respiratory Protection Program 3.0 Status of Previously Identified Items 3.1 (Closed) Inspector Followup Item (50-309/86-09-01)

Supervisory review of surveys is not documented. All surveys and

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air samples are now initialed and dated by the Radiological Controls Supervisor or his designe .0 ALARA The licensee's ALARA program was reviewed with respect to criteria contained in:

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10 CFR 20.1 Purpose

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Regulatory Guide 8.8 "Information Relevant to Ensuring That Occupa-tional Radiation Exposures Will Be As Low As Is Reasonably Achievable"

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Regulatory Guide 8. 0 " Operating Philosophy for Maintaining Radiation Exposures As Low As Is Reasonably Achievable"

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Regulatory Guide 8.19 " Occupational Radiation Dose Assessment in Light-Water Reactor Power Plants - Design Stage Man-Rem Estimates"

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Maine Yankee ALARA Program (1982) (policy)

The licensee's performance relative to these criteria was determined from:

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Discussions with the Radiological Controls Section Head, Lead Ra Controls Specialist, and the ALARA Coordinato Review of ALARA training provided in September 1986 to plant supervision and engineering personne Review of ALARA committee meeting minute Review of corporate goals and objective Within the scope of the review, no violations were identifie The licensee's exposure goal for 1986, a non-outage year, is 200 man-rem. The plant collective exposure level has been historically worse than average for a PWR. However, management has estab'11shed a goal of 400 man-rem average per year by 1989 which will bring the plant into line with average industry performance. For 1987, an outage year, the goal is tentatively set at 600 man-re Although there is a part time ALARA coordinator, the program is controlled and directed by the ALARA Committee. This committee, reorganized in July 1986 to include most PORC members as well as radiation protection (RP) staff, provides input to the station manage At this point, most ALARA initiatives appear to originate from the RP department. To encourage wider participation by the plant technical staff, an ALARA training program for design engineers was conducted on site in July 198 .m-

. The ALARA program is well documented and controlled at all ' levels within

.the organization. The program elements conform to the recommendations ,

provided in the Regulatory Guides and standard industry practic Although a basic program is in place, the progress, effectiveness, and

. achievements as the program develops will be reviewed in future inspection .0 Organization and Staffing The licensee's organization, staffing plan, and oversight of the Rad-Controls Program was reviewed with respect to criteria contained in:

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Technical Specification 5.2 Organization

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Technical Specification 5.3 Facility Staff Qualifications

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Technical Specification 5.4 Training

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Regulatory Guide 1.8 " Personnel Selection and Training"

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ANSI 18.1-19871, " Selection and Training of Nuclear Power Plant Personnel

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Te'chnical Specification 5.11 Radiation Protection Program

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Station Procedure # 25.300 " Technical Support Department Performance Assessment Program" rev. O dated 3/26/86

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Station Procedure # 0-16-1 " Corrective Action Procedure" rev. O dated 11/3/86 The licensee's performance relative to these criteria was determined from:

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Review of job description, personnel qualification resumes for incumbents, and Technical Support Department credentials summar Discussions with the Plant Manager, Tech Support Manager and selected personne Review of selected records, minutes of meeting and status report ,

i Within the scope of this review no violations were observe Inspector observations and conclusions are as follows:

5.1 Organizations

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The organization of the Rad Controls department meets the requirements provided by the Technical Specifications. Clear job descriptions are available for all positions detailing duties and responsibilities with clear lines of authorit ,

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Many of the positions are part-time such that one person may have several titles. For instance, the ALARA Coordinator is also one of the respiratory protection technicians. This approach has minimized the size of the staff, optimized the utilization of personnel resources, and provided for technical depth in the organizatio Whereas this provides good coverage of routine tasks, the staff is not able to support major program improvements / developments (see paragraph 8.0). Some limited technical support appears to be available from the Yankee Atomic Co.1pan .2 Staffing All positions are filled by qualified permanent employees. Staff turnover has been normal. Ongoing training and qualification programs for specialists and supervisors are provide The inspector noted that the licensee has routinely accepted Navy ELT experience in full satisfaction of the ANSI experience (crediting one year Navy for each year ANSI required) requirements for rad protection technicians. This practice may potentially lead to situations where a less than fully experienced / qualified technician would be assigned to control of radiologically significant operations. The acceptability of this practice will be reviewed in a future inspection. (86-19-01)

To develop a pool of qualified personnel to fill equipment operator, RC technician, and supervisory positions the licensee initiated the Nuclear Plant Trainee (NPT) Program in January 198 Local residents, preferably with college degrees, are provided with six months of technical training and then varying degrees of on-the-job training in various plant departments. This program indicates good preplanning by the license .3 Management Oversight of Rad Controls There is evidence of management involvement and very tight control at all levels from corporate down to first line supervision in the RC department. Decision making authority regarding RC programs occurs at the department manager level or higher. The RC section head and RC supervisors are responsible for implementation of the progra The licensee is in the midst of a long range improvement program called " Maine Yankee Quality Improvement Program 1982-1987". This program is directed towards all plant operations and departments including the RC department. The program is designed to identify quality problems or regulatory deficiencies at any site including Maine Yankee and to take effective action to prevent these problems from recurring at Maine Yanke _

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A " Radiological Controls Improvement Program" has been. introduced to identify, track, analyze and resolve radiological incident Monthly reports are issued. Management support of this program has been firm and severe disciplinary action has-been taken in a few instance A' major reconstruction and expansion of the control point and adjacent laboratories is underway. This will provide better access control of_ materials and workers entering and leaving the

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radiological areas during an outag In addition,.the inspector discussed in detail other licensee radiological improvement actions that_ were completed or initiated during the-year. A list of these items is as follows:

Maine Yankee Radiological Improvement Items The following programs, policies, and procedures have been initiated in the previous year to improve the Radiation program at Maine Yankee. Appropriate-documentation is indicated if applicabl . Upgrade of Radiological Control facilitie . Implemented a Radiological Controls Improvement progra . Goals and Objective progra ~ Rewrite of the Radiation Protection manua . Evaluation of the Pilgrim Nuclear station's Radiological Improvement progra . INPO Accreditation program for Radiological Control. technician . Radiological Controls Section Head loaned to INPO_for fifteen months to observe other plants' Radiation Protection program . Oversight of the Plant Radiation Protection program by the Nuclear-Engineering and Licensing Department principle Radiological Enginee . Reorganization of the ALARA Committee with the Assistant Plant Manager as Chairman. ALARA Committee now has the authority to make recommendations to the Plant Operating Review Committe . Departmental man-rem goals have been establishe . Implemented Nuclear Power Trainee program to staff department with college graduate . Implemented "0" leakage program to reduce plant contamination level . Dedicated supervisor for personnel monitoring record . Personnel changes - Hazardous Waste Coordinator, Radiological Controls Specialist, Radiological Controls Supervisor and Training Instructo . Improved Plant Decontamination program with established goal . Industry feedback system is used to inform personnel of noteworthy occurrences at other facilitie . Plant performance hints - memos from Plant Manager to Department Manager to include in their monthly department meetings or required reading program . Implemented a Performance Assessment program to evaluate department activitie .

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19. Implemented a Corrective Action Reporting procedure to assure timely corrective actions to internal audit finding . A review of INP0 guidelines for radiological protection at nuclear power stations is in progres . Monthly Radiological Control report to management is used to trend key section activitie . Implemented a weekly meeting of Radiological Control technicians and department supervisors to discuss procedure changes, plant policy, et . High priority has been given to completing scheduled training program . Timers have been placed on frisker to assure that adequate frisking is performe . Implemented a daily tour of the Radiation Control area by department specialist to observe work activities and report problem . Company wide compilation of Performance Indicator, including man-rem, effluent releasas, dose to the public, and radwaste volume . Significant improvements in radwaste volume reduction activities in 1986 including 47% volume decrease, construction and use of new waste storage facility, and development of a plan to dispose of the radwaste backlo Based on observations during the inspection, the inspector concluded that management oversight of the radiological controls program at Maine Yankee is excellen .0 External Exposure Control The licensee's program for external exposure control was reviewed against criteria contained in applicable regulatory requirements and the licensee's technical specification The licensee's performance related to the above criteria was determined by:

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review of the following procedures:

• 9.1.1, " Plant Radiological Surveys," revision 12.

l * 9.1.3, " Neutron Surveys," revision * 9.1.6, " Establishing and Posting Controlled Areas," revision 1 * 9.1.7, " Area and Equipment Decontamination," revision * 9.1.8, " Monitoring for Personnel Contamination," revision 1 * 9.1.10, " Radiation Work Permits," revision 1 review of 25 radiation work permits;

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review of routine and special smear, dose rate, and airborne surveys;

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review of calculation for assigning personnel skin doses from noble gas activity;

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observation and measurements made during tours of plant areas; and

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discussions with licensee personne Within the scope of this review, no violations or deviations were ident.i fi ed. However the inspector identified several areas in need of improvemen .1 Posting and Controlling Radiation and High Radiation Areas During plant tours, the inspector identified a section in the Waste Gas Decay Tank cubicle with a dose ' rate of 30 to 40 milliroentgens (mR) per hour. This section was not identified in the cubicle as having a higher dose rate than the adjacent areas, nor was this section identified on the survey map posted on the outside of the cubicle. The general area dose rate was less than 2 mR per hou The licensee stated that the door to the cubicle was posted as a high radiation area and an RWP was required to enter the cubicl The licensee stated that although the section was not posted, personnel were required to carry a dose rate instrument into the cubicle and would become aware of the higher dose rate because of instrument reading. The inspector stated that this practice may fail to properly inform the worker of radiological hazards, and provided a copy of and discussed IE Information Notice 84-82: " Guidance for Posting Radiation Areas" with licensee personnel for clarification of the NRC position for posting rz.diation area The licensee stated that this posting practice had been questioned during an internal audit performed in July 1986, and was being evaluated due to the audit finding. This area will remain open and be re-examined in a future inspection (50-309/86-19-02).

6.2 Procedures for Control of Radioactive Materials NRC inspection report number 86-13 identified a concern over the quality of surveys performed on contaminated dirt and sand as a result of excavation of piping during the previous outage. A survey technique was developed to measure the radioactivity in the soil and quantify the presence and type of contamination. This survey technique was reviewed in NRC inspection report 86-09. During the current inspection, the inspector reviewed the methodology developed for handling potentially contaminated soil and requested to review the procedure for controlling this work. The specific methodology developed was not incorporated into a procedure, nor was it referenced for future use. The licensee stated that this methodology will be indexed in an appendix to the applicable procedure for future referenc _ _ _ _ _ _ _ _ _ - - _ - _ _ _ - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _

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During the inspection, the inspector witnessed two contaminated-individuals for which no report was issued, and no decontamination was performed. The individuals were contaminated with short lived particulate activity resulting from immersion in a noble gas cloud, and were instructed to wait at the Health Physics Control point until the particulate activity decayed away. Although this incident did not have the potential for significant personnel exposure, the procedure indicated that decontamination would be performed and the incident documented and evaluated. The inspector discussed this ,

finding with the licensee. The licensee immediately issued a draft '

revision to formalized the current practice for handling this particular type of contaminatio Although these two examples did not result in a compromise of health and safety, they suggest a lack of licensee attention and effort in establishing and adhering to formal procedure The status of the above mentioned procedure changes and a review of the licensee's mechanism for establishing and revising procedures will be performed in a future inspection (50-309/86-19-03).

6.3 Radiation Work Permits During records review of 25 radiation work permits (RWPs), the inspector identified 4 RWPs with erroneous or missing air sample information, 2 RWPs for which the surveys were not immediately available or retrievable, 1 RWP which had incorrect survey informa-tion, and 1 RWP for which the air sample and resultant skin dose was not recorded even though the air sample information was availabl Additionally, the licensee stated that the method for filing the supporting information made it difficult sometimes to thoroughly review and oversee work packages as they were completed. The inspector discussed this finding with licensee management, who stated that the recordkeeping system would be reviewed and modified if necessary to ensure that all paperwork was available and easily retrievable to support the RWPs. This area will be reviewed by the NRC in a future inspection (50-309/86-19-04).

7.0 Calibration and Maintenance of Portable Radiation Instrumentation The licensee's program for the calibration and maintenance of portable radiation instrumentation was reviewed with respect to criteria contained in regulatory requirements, technical specifications, and appropriate industry standards for instrument maintenanca, use, and calibratio The licensee performance related to the above criteria was determined by:

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review of selected calibration procedures;

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observations made during plant tours of instruments in the field, and of the calibration facility; and

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discussions with-licensee personne Within the scope of this review, no violations or deviations were identified. The licensee's procedures for instrument calibration were '

concise and well-written. All instruments observed in the field had been calibrated within an acceptable time-frame. However, the inspector noted that the licensee's calibration facility may need upgrading and improvemen For. free-air calibration, the source-to-detector distance was unacceptably close due to lack of adequate source strength. Also, the licensee had no calibration assemblies for free-air calibration to provide mechanically-precise positioning of detectors in the radiation fiel The licensee stated that they were in the process of reviewing and updating their calibration facility, and that they were already aware of these short comings. The inspector stated that this area will be reviewed in a future inspection (50-309/86-19-05). ,

8.0 Respiratory Protection Program (Internal Exposure Control)

The licensee's Respiratory Protection Program was evaluated against ,

criteria contained in:

• 10 CFR 20.103 " Exposure of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas",

Procedure 9.1.1 " Plant Radiological Surveys",

• Procedure 9.1.2 " Respiratory Protection Program",

• Procedure 9.1.20 " Bioassay Program",

• Procedure 9.1.23 " Remote Sampling of Containment for Radioactive Analysis",

• Procedure 9.1.26 "Whole Body Counting",

Radiation Protection Manual.

l l The licensee's performance relative to these criteria was determined

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' * Tour of facilities and observation of ongoing work practices j Discussions with licensee personnel, I

• Randomly selected air samples for 1984-1986,

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MPC hour tracking sheets, t

[ Whole body count records, l

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Respirator use logs for 1984-1985,

• Current personnel respirator cards, Routine and emergency respirator protection equipment,

Randomly selected Radiation Work Permits for 1984-1986,

Respirator qualification of randomly selected personnel

Respirator inspection log sheet,

Maine Yankee Radiological Controls Audits MY-85-03 and MY-86-03,

General employee training lesson plan on respiratory protection,

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Job posting for " Respiratory Protection Specialist".

In areas where airborne radioactivity is present, the licensee uses

engineering controls, increased surveillance, and limited stay times to

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maintain the intake of radioactive material by any individual below the

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limits of 10 CFR 20.103(b)(2). The licensee has, in some instances,

, issued respirators to personnel as an additional safety measur However, in calculating MPC-hours the licensee's policy is not to take credit for the protection factor associated with respirator use. This policy is not documented in the licensee's procedures. The inspector discussed this matter with appropriate licensee personnel who stated that this policy will be documented in Procedure 9.1.2 " Respiratory Protection Program". This documentation will be reviewed during a subsequent inspection (86-19-06).

Examination of the licensee's Respiratory Protection Program indicated that individuals using respirators had been physically examined, adequately qualified, and properly fit tested for respirator use. Air samples used in respirator selection were adequate. All respirators examined were NIOSH/MSHA certified. Procedures governing respirator selection, fit, use, training, and bioassay are adequate. The licensee is also tracking MPC-hours and performing whole body counts as necessary to adequately assess individual intakes of radioactivity by exposed individual The inspector noted an area of concern in the staffing of the Respiratory Protection Program. The position of Respiratory Protection Specialist is not staffed thus placing an additional burden on personnel assigned to other areas. Licensee management is aware of this co,cern and is taking appropriate action to fill this position before the end of the yea This area will be reviewed during a subsequent inspection (86-19-07).

During the course of this review, no violations were identifie . . . - . _ _ _ _ _ _ _ - -

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9.0 Exit Interview The . inspector met with licensee management denoted in section 1.1 at .the conclusion'of the inspection on November 21, 1986 and discussed the scope ard findings as detailed in this repor .