IR 05000309/1989015

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Insp Rept 50-309/89-15 on 890821-24.No Violations Noted. Major Areas Inspected:Radiation Protection Program,Including Radiological Controls Group Organization & Staffing. Weakness Noted Re Water in Radwaste Storage Bunker
ML20247M465
Person / Time
Site: Maine Yankee
Issue date: 09/14/1989
From: Nimitz R, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247M464 List:
References
50-309-89-15, NUDOCS 8909250230
Download: ML20247M465 (10)


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. U.S.. NUCLEAR REGULATORY COMMISSION

' REGION I Report No. 50-309/89-15'

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50-309

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Category C License No. :DPR-36 Priority

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Licensee: Maino Yankee Atomic Power Company

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83 Edison Drive:

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Augusta, Maine'04336

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. Facility' Name':'- Maine Yankee Nuclear Generating Station

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Inspection At: Wiscasset', Maine-InspectionfConducted:-' August 21-24, 1989-Inspectors:

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R. L. Nimitz,. Senior R&diation Specialist date.

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Approved by:

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'W. A Pasqjak, Chief

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Idatp Facilities Radiation Protection Section

Inspection Summary:- This inspection was a routine. announced inspection of the-Radiation Protection. Program. Areas reviewed were licensee action on previous findings, radiological controls group organization and staffing, routine radiation protection. activities and licensee radiation protection program improvements.

Results:. No violations were identified Two unresolved items were identified.

The TTrst. involved the adequacy of corrective actions for self-identified findings.

The second involved water in a radwaste storage bunker. Weaknesses were.also identified in the area of housekeeping.

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DETAILS 1.

Persons Contacted 1.1' Maine Yonkee C. T. Frizzle, President, Maine Yankee Atomic Power Company T. Boulette, Vice President, Operations

  • R. Blackmcre, Acting Plant Manager
  • J. Brinkler, flanager, Technical Support

'*G. Pillsbury, Assistant to Manager, Technical Support 1.2 NRC

  • C. Holden, Senior Resident Inspector R. Freudenberger, Resident Inspector 1.3 Others-
  • P, Dostie, Maine State Nuclear Safety Inspector
  • Denotes those individuals attending the exit meeting on August 24, 1989. The Inspector also contacted other personnel.

2.0 Purpose of Inspection This inspection was a routine, announced radiological controls i

inspection. The following matters were reviewed:

licensee action on previous inspection findings

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organization and staffing of the radiological controls group

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routine radiological controls practices licensee action on NRC concerns discussed in the Systematic

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Assessment of Licensee Performance (SALP) Report, dated January 5, 1989 (SALP Report No. 50-309/87-99)

audits

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3.0 Licensee Action on Previous' Inspection

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3.1 (Closed) Inspection Fr slow-up Item (50-309/86-09-02)

Licensee training or )ersonnel on use of survey meters needs improvement.

The licensee estat,iisied and implemented a separate specialty training lesson plan (GT-GET-II) on operation of survey meters.

The plan includes a description of instruments used and their limitations. This item is closed.

The inspector noted that the lesson plan did not specifically address saturation of GM tubes ir high radiation areas. The licensee indicated the lesson plan would be revised to address the matter.

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3.2l The licensee did not.have a'progra(m to select and) evaluate the experience (Open) Inspection Follow-up Item 50-309/86-19-01-level of contractor radiation protection technicians.

Inspection review.

. indicated the licensee has not formalized the criteria used.to evaluate

. experience levels of contractor radiation. protection technicians. This item remains open.1

he licensee s Radiation Area postin(g requirements d)id not reflect Closed). Inspection Follow-up Item 50-309/86-19-02 3.3

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guidance contained in.IE Information. Notice 84-92, Guidance for. Posting Radiation' Areas.. The licensee revised applicable procedures-(Procedure m,

. No. 9.1.6, Establishing and Posting Controlled Areas) to reflect guidance contained'in.IE Information Notice No. 84-92.

Inspector tours during

~this-inspection did not identify any discrepancies. This-item isiclosed.

3.4'.(0 pen) Inspection Follow-up Item (50-309/86-19-03)

Licensee to revise procedures.to ensure that personnel con'tamination-events are properly. documented and reviewed.

Inspector review indicated

.the licensee revised applicable procedures to allow personnel to stand

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around for up to one and one-half hours in' order to let short-lived radionuclides on their person decay prior to initiating a personnel contamination' report.

It was not apparent that appropriate review of.the circumstances of the contamination would be undertaken and corrective actions taken, as appropriate, prior to-allowing the. individual to leave.

This was considered a poor practice. The licensee indicated the matter

.will be reviewed. This. item remains open.

The lice)nsee s respiratory protectio (50-309/86-19-06).n program did not include (Closed Inspection Follow-up Item 3.5 statement. prohibiting making allowance for the use of respiratory protection equipment when calculating airborne radioactivity intake estimates. The licensee revised the applicable procedure (Procedure No. 9.1.2, Respiratory Protection Program) to include this policy statement. -This item is closed.

3.6- (C'losed) Inspection Follow-u) Item (50-309/86-19-07)

.The position of Respiratory Protection Specialist was not staffed. The licensee staffed the position. This item is closed.

3.7 ' (Closed) Inspection Follow-up Item (50-309/87-07-01)iation Area.

The licensee failed to post and barricade a High Rad The licensee implemented the corrective actions outlined in his June 12, 1987 letter (MN-87-71) to the NRC. This item is closed.

'3.8; (Closed) Inspection Follow-up Item (50-309/87-08-10)

Licensee to review potential hazards and personnel dose consequences associated with exposure to radioactive particles found in containment.

The licensee evaluated the dose consequences and determined that no overexposure would have occurred. This conclusion was based on particle size, radiation levels exhibited by the particles and estimated work time limitations. This item is closed.

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-3.9 -(Closed)i tiUnresolved Item (50-309/87-28-01). NRC to review the lic

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High-Rad a on Area access control program. NRC reviews and licensee QA

. reviews identified a number of weaknesses in the program.

Inspector

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' review found that the licensee revised Procedure:No.:9.1.6,; Establishing E

land Posting Controlled Areas, to address the' weaknesses identified.

m These weaknesses included delineation of individuals. authorized to use keys,i key ' accountability, key transfer, and. actions for lost keys. and

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. entries to transient' and unusually High Radiation Areas. This item is closed.-

' Viol ation 150-309/87-28-02 Licensee did not post a 3.10.(Closed)ive.Materiais Storage Area.) The-licensee posted the Radioactive

'Radioact Materials-Storage Area and revised Procedure No. 9.1.6 ' Establishing and.

Posting Controlled Areas, to clearly describe Radioactive Material Storage Area posting' requirements.

Inspector tours did-not identify any.

posting concerns. This matter is closed.

' Inspection Follow-up Item (50-309/88-12-02) Licensee to review 3.11 (Closed)to ensure termination +eports were, properly sent to personnel.

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reports-detailing exposure received'at Maine Yankee were not transmitted to personnel as required. The licensee performed an extensive review of-personnel records. No other instances of failure to transmit termination reports were identified. This item is closed.

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3.12 (0penf Inspection Follow-up Item (50-309/88-03-05) NRC review indicated the incensee was not properly aligning the whole body counter when performing whole body counts of personnel. The-licensee revised procedures to require placing the detector in the scanning position when counting personnel.

Inspector discussions with licensee dosimetry

. personnel indicated the whole body counter detector was being aligned with a piece of tape stuck on the whole body counting chair. ~However, this was not discussed in procedures. The-licensee immediately initiated a review of this tratter. This item remains open.

Inspection Follow-up Item (50-309/88-12-03 Licensee to submit a 3.13 (0 pen) 20.302 request to seek permission to allow)slightly contaminated 10 CFR soil to remain onsite. The licensee submitted this report on November 2, 1988. The report will be reviewed with the licensee during a future inspection. This item remains open.

4.0 Radiological Controls Audits and Assessment The inspector reviewed selected audits, assessments and job observations made by the licensee. The review was with respect to applicable procedure and Technical Specification requirements.

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Within the scope of this review, the following was identified:

The licensee has initiated action to improve the overall quality'of

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audits.and make them more performance based. All members of the QA group attended a training course on performance based audit methods.

The licensee revised procedures to highlight the need to thoroughly

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review recurrent items and perform root cause determinations.

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The licensee is responding to SECY-87-220, Assurance of Quality, j

dated August 31, 1987.

Licensee audits will review management effectiveness to address this SECY document.

The licensee performed two audits of the radiological controls

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program in 1988.

In order to continue to monitor the performance of the radiological controls program, the licensee plans to again-perform two audits of the radiological controls program in 1989.

The following was discussed with licensee management:

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The licensee has in place a program entitled " Job Observation Program." This program provides for personnel to observe on-going activities and document positive observations or poor practices needing improvement. This program is a good initiative.for self-identifying and initiating corrective actions for performance deficiencies.

Inspector review, however, indicates continued problems with documentation and resolution of identified problems (e.g., procedure violations.).

For example, a job observation made on May 31, 1989, identified problems with personnel not adhering to a radiation work permit. Personnel were observed cutting contaminated material in apparent violation of the applicable radiation work permit.

At the time of this inspection, job observation or what, if any,the licensee was u any information regarding this short and long term corrective actions had been taken. The inspector noted that the job observation had been signed by a radiological controls supervisor and that the observation was to be i

routed to the department manager. No information was presented to

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indicate that this matter was resolved by management.

t The inspector noted that previous job observations had identified

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personnel not adhering to radiation protection procedures. Also, the matter of the licensee not being able to provide corrective actions for self-identified problems was discussed with the licensee in July 1988 Reference NRC Inspection Report No. 50-309/88-12 and in Novem er 1988 (Reference NRC Inspection Report No. 50- 09/88-80).

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' Since the licensee was unable to provide any information on the apparent procedure violations identified, the inspector was unable to determine if the licensee met all criteria for non-issuance of a

. Notice of Violation as described in Appendix B of 10 CFR Part 2. The

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licensee indicated information would be gathered to address the inspector's concern. The inspector indicated that recent job observations were considered unresolved pending review of licensee t

information (50-309/89-15-01).

5.0 Organiza' tion and Staffing

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i The-inspector. reviewed the organization and staffing of the radiological controls group. The review was with respect to criteria contained in applicable Technical Specifications.

Within the. scope of the review, no violations were identified. The following matters were discussed with the licensee's representatives:

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The licensee is attempting to strengthen the technical capabilities.

and industry experience levels of the radiological controls group by hiring personnel from outside the licensee's organization. As an example, a dosimetry supervisor was recently hired with considerable experience from outside the licensee's organization.

The licensee's Radiation Protection Manager has indicated a desire

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to resign. A replacement has not yet been selected.

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The licensee's Radiological Support Supervisor responsible for managing the ALARA 3rogram, the Internal Dosimetry Program, the External Dosimetry )rogram, the Respiratory Protection Program and the Hazardous Waste Program recently resigned. The individual selected to fill the position has limited pract cal experience in reactor radiological controls programs.

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The licensee recently upgraded a radiation protection technician to fill the. position of ALARA coordinator. The technician has limited experience in the area of ALARA and limited formal training in ALARA Programs. An individual previously in this position was rotated into another position.

The licensee's representatives indicated a review was currently underway to reorganize the Radiological Controls Group. The licensee is considering reorganizing the Radiological Controls Group to improve its management and overall effectiveness.

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6.0- Radiological Controls Program Improvements 6.1 Background The NRC's Systematic Assessment of Licensee Performance (SALP), dated January 5, 1989 (SALP Report No. 50-309/87-99) for the Maine Yankee Atomic Power Company, identified a number of programmatic weaknesses needing licensee attention.

During this inspection, the inspector reviewed the licensee's actions on the identified weaknesses. The inspector also reviewed the-licensee's plans for improving the overall Radiological Controls Program.

6.2 Findings The inspector's review and discussion with licensee management indicate actions are planned or underway to improve the overall quality of the Radiological Controls Program at the Maine Yankee Nuclear Station.

Support for the improvement was clearly indicated by inspector discussions with the licensee's senior management.

The following initiatives to improve the quality and effectiveness of the Radiological Controls Program were noted:

The licensee has developed a draft Radiological Controls Improvement

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Program. The draft plan includes 48 major programmatic items selected, in part, to improve performance relative to the seven assessment criteria considered in NRC SALP assessments.

The plan also includes 16 ALARA initiatives to improve performance in the area of ALARA. The plan has been distributed for review and comment. The plan is scheduled for approval around the end of September 1989.

Plan elements include reorganization of the Radiological Controls Group and performance of a review of the entire Radiological Controls Program by an outside consultant.

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The licensee is planning to reorganize the Radiological Controls Group to improve Radiological Control Program management and effectiveness. The reorganization is scheduled for October 1, 1989.

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The licensee has completed significant clean-up of the backyard areas. More work is on-going.

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In order to reduce general area radiation levels, the licensee has initiatu a flushing program to flush localized crud deposits from piping.

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The licensee is developing a loop flush procedure to flush primary loops during cool down for the 1990 outage.

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.-c The licensee' plans on installing sub-micron filters on portions of -

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<the primary loop to enhance primary water clean-up.

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The licensee has increased the budget for ALARA purposes.

The licensee established a program to monitor'the. rounds of R

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-auxiliary operttors during.their plant tours. ' Standardized rounds,

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which minimize personnel exposure,.will be developed.

7.0: Plant Tours Th'e inspector toured the plant periodically during the inspec' ion. The t

following areas were reviewed:

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qualifications of radiation protection personnel

_ posting,c barricading and. access control to radiation, high. radiation

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and airborne' radioactive. areas, as appropriate radioactive:and contaminated material control

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radwaste storage

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issuance and proper use of dosimetry

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-The reviews in this area were with respect to criteria contained in 10 CFR-

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20,' Standards ~ for Protection Against Radiation, applicable licensee

. procedures and standard industry practices.

Within the scope of the review, no violations were identified. However, the following matters were brought to the licensee's attention:

Housekeeping in portions of the radiological controlled area was

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considered poor.. Observation _identifiec: dirty and dusty conditions, balls of tape discarded on electrical trays and plastic trash bags stuck behind piping.

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The licensee has a radwaste storage bunker in the backyard area of the facility.

Inspector reviews noted water inside the bunker. The sump pump-for the bunker was broken. Tne licensee's personnel could not )rovide the inspector information regarding radioactivity levels of tie water or-information on the acceptability of allowing the water to remain in'the bunker. The acceptability of this matter is i

unresolved.

(50-309/89-15-02).

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The licensee maintains an interim low level waste storage facility on site. The facility is used to. store radioactive material prepared for transport.

Ins)ector review indicated that there was limited radwaste stored in tie facility and dose rates on the outside of the facility were negligible.

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However, it was not apparent that adequate procedural ' controls.were established to ensure compliance with 40 CFR 190 offsite dose limits. The licensee indicated this matter would be reviewed. The inspector indicated this matter would be reviewed during'a subsequent inspection..

A sign warning personnel not to remove material from the spent fuel

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storage pool due to radiation hazards was stuck behind'some piping and obscured. There were no other signs around the pool warning of this hazard.

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Tours throughout the radiological controlled area identified numerous examples of hoses and lines running from clean areas into contaminated areas. The hoses and lines were not secured to prevent them from being' inadvertently pulled from the contaminated areas into the clean areas.

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Numerous 55 gallon drums of slightly contaminated oil were^ stored.

outside the facility under a small roofed structure. The drums were showing some rusting and were in close proximity to storm drains.

The licensee plans to burn the oil in boilers and has apparently.

received authorization for the burning. The drums, however, have been in the area for an extended period of time.

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A locked High Radiation Area' Door in the lower elevation of the auxiliary building, leading to the letdown area, exhibited about a 6 inch to 12 inch gap from the floor.

It was not apparent that the door would preclude unauthorized entry into the letdo::n area.

A contractor individual (one of three) dosimetry properly. working at the excav

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the backyard area was not wearing his The TLD badge was worn at the neck level while the pocket dosimetry was worn on the hip pocket. The devices are to be worn together.

The licensee indicated the above matters would be reviewed and corrective actions, as appropriate, taken.

The folicwing additional matter was noted:

The licensee's hot ) article exposure control program continues to

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need improvement.

)otential Hot. Particle Exposure Areas are not posted (e.g iso,ent Fuel Storage Pool Area), a standard industry Sp practice. k certain programmatic weaknesses associated with personnel working in areas with hot particles (excavation in alleyway area) were discussed in NRC Inspection Report 50-309/89-11.

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8;0LExitMeeting.

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~The: inspector met'with. licensee representatives,- denoted in Section?liof

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this report,.at the conclusion of the inspection on August 24, 1989.' The.

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? inspector summarized'the-purpose, scope and findings:of the inspection.

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s No written material was provided.to'- the licensee.-

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