IR 05000309/1990003

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Insp Rept 50-309/90-03 on 900306-09.No Violations Noted. Major Areas Inspected:Radiological Controls Organization, Staffing & Qualifications,Licensee Action on Previous Findings & Planning & Preparation for Upcoming Outage
ML20012F566
Person / Time
Site: Maine Yankee
Issue date: 04/02/1990
From: Nimitz R, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20012F565 List:
References
50-309-90-03, 50-309-90-3, NUDOCS 9004160161
Download: ML20012F566 (10)


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U. S. NUCLEAR REGULATORY COMMIS$10N

REGION I

Report No. 50-309/90-03 Docket No.

50-309 License No. DPR-36 Priority Category C

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Licensee: Maine Yankee Atomic Power Company Il Edison Drive Avousta, Maine 04336

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Facility Name: Maine Yankee Atomic Power Station Inspection At: Wiscasset, Maine Inspection f inducted: March 6-9, 1990 Inspector:

RLyJJ 3l% qD R. L, Nimitz, Senior RadiatteM Specialist

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Approved by: L0h O. \\Mb

'b og] y q q o W. Pasciak, Chief, Fac.ilities Radiation date

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Protection Section Inspection Summary:

Inspection conducted on March 6-9, 1990 (Inspection Report No. 50-309/90-D'3)

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Areas Inspected:

Routine, announced Radiological Controls Inspection of the i

following:

radiological controls organization, staffing and qualifications; licensee action on previous findings; planning and preparation for the

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upcoming outage; and implementation of the Radiological Controls Improvement Plan.

l Results: No violations were identified.

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DETAILS 1.0 Individualscontactec!

1.,. Maine Yankee

'E. T. Boulette Vice President, Operations

  • G. Pillsbury, Radiation Protection Manager
  • P. Radsky, Chemistry Supervisor
  • R. Blackmore, Plant Manager
  • R. Nelson, Technical Support Department Head 1.2 !iRC R. Fruedenberger, Resident Inspector, Maine Yankee W. Pasciak, Chief, Facilities Radiation Protection Section
  • Denotes those individuals 4ttending the exit meeting on March 9, 1990.

The inspector also contacted other licensee personnel.

2.0 Purpose and Scope l

The inspection was a routine, announced Radiological Controls inspection.

The following areas were reviewed:

-organization, stiffing and qualification-licenste action on previous inspection findings i

' planning and preparation for the upcoming outage

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-implementation of the Radiological Controls Improvement Plan 3.0 Licensee Action on Previous Findings 3.1 (Closed) Unresolved Item (50-309/88-12-01) Licensee to review the positioning of the whole body counter detectors.

The licensee had placed a tape marker on the whole body counter chair for alignment purposes, but it was unclear that all personnel had read or were aware of tape markers and what actions were to be taken if the marker did not align properly.

The licensee revised procedure No. 9.1.2.b on November 6, 1988, to require whole body counting in the scan mode

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versus the normal mode.

This allows for a wide angle view of the I

torso and minimizes effects due to detector mis positioning. The l

licensee also reviewed whole body counting date for 1987 and found no l

unusual data.

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The licensee placed one new detector in service in early January 1990.

A second detector was place in service in mid to late i

Februa ry, 1990.

However, procedures were not revised to reflect the new equipment.

The licensee immediately revised the procedures.

This item is closed.

3.2 (Closed)UnresolvedItem(50-309/88-12-02) The licensee bad identified some instances where exposure determination reports were not sent.

In May 1989, the licensee conducted an audit of all i

active exposure files for 1988 to verify generation and issuance of termination letter documentation.

No discrepancies were noted in the 1988 records.

Some pre 1988 records indic&ted some

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discrepancies that were corrected.

This item is closed.

i 3.3 (0 pen)UnresolvedItem(50-309/88-12-03) The licensee will make a 10 l

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CFR 20.302 submittal to address disposal in place of trace quantities of contaminated soil in the back yard areas of the station. The licensee submitted the request on October 18, 1988.

The request was reviewed by the NRC and approved.

The licensee will provide a second submittal to address other

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areas including the Radwaste Building roof and other soil.

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I 3.4 (0 pen) Unresolved Item (50-309/88-22-01) The NRC will review the licensee's evaluation and corrective actions for radiological

incident referral (RIR) No. 88 24.

The incident involved an apparent mis positioning of personnel dosimetry resulting in a worker

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exceedinghisallowableadministrativeexposurelimit. The

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licensee s initial review indicated the individual, authorized 1700

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millirem, may have received up to 2824 millirem. The initial dose value involved some confusion as to where the individual's dosinetry

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had been placed. The inspector was not able to understand the

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licensea's evaluation of the incident.

The licensee will clarify the evaluation and clearly document a final dose estimate for the l

individual.

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3.5 (Closed) Violation (50-309/88-22-03) The licenses did not control

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access to the 2-foot level of containment, a High Radiation Area, in accordance with Technical Specification 5.12.

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The inspector reviewed the implementation of the corrective actions outlined in the licensee's January 19, 1989, letter to the NRC.

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licensee implemented the corrective action outlined in the

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January 19, 1989 letter.

The licensee also submitted a Technical Specification change request to improve the effectiveness of

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controls. This violation is closed.

3.6 (Closed) Violation (50-309/88-80-01) The licensee's personnel did not

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adhere to radiation protection procedures as required by Technical

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Specification 5.11.

The inspector reviewed the adequacy and

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implementation of the corrective actions outlined in the licensee's February 21, 1989 letter to the NRC. The licensee implemented the corrective actions outlined in the February 21, 1989, letter. These

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included counseling of involved individuals, revision of procedures to reflect current practices, and review and revision of lesson

plans for outage training to stress compliance with radiation

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protection procedures and radiation work permits. The licensee also implemented a radiological work observation and performance j

improvement program.

This violation is closed.

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3.7 (Closed', Unresolved Item (50-309/86-19-01) The licensee will review and evaluate the practice of accepting non-commercial reactor

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experience (NAVY radiological controls experience) and the crediting

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of that experience to personnel for meeting experience requirements for commercial reactor positions.

The licensee reviewed the

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experience of each individual on staff with Navy background and found l

them to be qualified. The licensee revised applicable selection, j

qualification, and training program procedures for contractor

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technicians to ensure proper crediting of experience.

This item is

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closed.

The licensee has yet to incorporate the criteria into procedures for selection of permanent personnel.

The licensee piens to upcate

the selection criteria. This matter will be reviewed in conjunction with planned improvements to be implemented through the Radiological Controls Improvement Plan.

3.8 (0 pen) Unresolved Item (50-309/86-19-03) NRC to review the l

licensee's current methods of establishing and revising procedures.

The licensee's procedures did not reflect current practices for

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dealing with contaminated individuals.

The licenseo revised

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procedure No. 9.1.8, " Monitoring for Personnel Contamination " to reflect the current procedure.

The procedure permits individuals who

l are contaminated with noble gas decay products to wait at the health l

l physics check point and allow some decay time prior to completing a

contamination report. A report is issued if the contamination

remains after a maximum of cre and one-half hour decay time. This

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was considered a questionable practice. Also, a contractor performed i

a complete programmatic review of the radiological controls program including all procedures. The NRC will review the results.

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3.9 (Closed) Unresolved Item (50-309/86-19-04) The licensee will review I

and modify the record keeping system for radiation work permits

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(RWPs) to ensure that all paperwork (e.g., radiation survey) was

available and readily retrievable to support the RWPs.

The licensee

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revised Procedure No. 9.1.10, Radiation Work Permits, to improve

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record collection and maintenance. The licensee has established a

Technical file which contains all radiological records associated l

with radiation work permits. All appropriate documents for terminated RWPs are collected and placed in records retention.

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item is closed.

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3.10 (Closed) Unresolved Item (50-309/86-11-01) The licensee's personnel t

will verify the representativeness of the containment atmosphere

'i sampling system.

The licensee collected containment atmosphere samples inside containment at power in October 1986 and. compared the samples to those obtained by the normal containment sampling system.

The samples were found to be representative. This item is closed.

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3.11 (Closed) Unresolved Item (50-309/86-11-02) Licensee to conduct a more

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detailed time and motion study for the collection of post accident

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samples to ensure the allowed exposure values of General Design

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Criterion 19 are met during sample collection, transport and

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analysis. The licensee's results indicate the criteria of GDC-19

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would not be exceeded.

The post accident doses and dose rates were included in appropriate procedures.

The inspector noted the highest i

dose to the extremities was 61 rem.

This item is closed, t

3.12 (Closed) Unresolved Item (50-309/86-11-03) The licensee's personnel

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will improve the method of transporting syringes to the laboratory i

and include complete sample labeling instruction in procedures.

The licensee fabricated a special carrier to transport syringes from the sample location to the laboratory for analysis.

The licensee revised

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procedure No. 7.1 to provide for detailed labeling of samples.

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attachment was generated to track the location of the sample.

This item is closed.

3.13 (Closed) Unresolved Item (50-309/86-11-04) Licensee to review the methodology for isotope analysis of dissolved gases in reactor

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coolant, and revise the methodology as necessary to assure results

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are within recommended tolerance ranges. The licensee modified the i

sample panel to preclude condensation of moisture in the sample line l

and provide for a more representative sample. The licensee collected

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a series of gas samples, using the post accident sampling system after the modification, and compared the sample results to those l

obtained by analyzing a sample from the normal loop sample location.

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The samples, collected in October 1987, indicate the sampling system provided for representative samples meeting NUREG-0737 accuracy

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specifications.

This item is closed.

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3,14 (Closed) Unresolved Item (50-309/86-11-05) Licensee to formalize and document the preventative maintenance and calibration program for the post accident sampling system. The licensee established and

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implemented Procedure No. 7.210, Post Accident Sample Equipment Preventive Maintenance Program.

The procedure formalizes and

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documents the program for the Yankee Atomic designed post accident

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sampling system.

The procedure was most recently performed in

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I February 15, 1990. This item is closed.

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3.15 (0 pen) Unresolved Item (50-309/86-11-06) The licensee's personnel r

will complete the training of all chemistry personnel in post

accident sampling and analysis. The licensee has two laboratory i

assistants and four chemists.

Only one lab assistant (technician) is

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fully certified to do the sampling, while two chemists are fully

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certified.

The licensee will retrain personnel on the sampling by t

performing hands on sample collection once per year. No individual i

has received self-contained breathing apparatus training. The

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inspector questioned whether an adequate number of personnel were

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trained to do sampling and analysis considering the high extremity doses that could be obtained.

(See Section 3.11).

The licensee

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indicated this matter would be reviewed.

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r 3.16 (0 pen) Unresolved Item (50-309/86-11-07) NRC to review effluent flow

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rates to determine if flows are appropriate for release calcula-

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tions. The inspector reviewed the licensee's evaluation of both

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effluent flow rates and effluent sampler pump flow rates to determine if 1) appropriate flows are used for post accident effluent release calculations and 2) flows for effluent samples are set to ensure

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isokinetic sampling. The licensee currently uses the fan capacity l

values for effluent release calculations.

These values are with 10%

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of the actual flows which consists one or two exhaust fans to be on-line. The inspector could not determine if the flows were proper.

3.17 (Closed) Unresolved Item (50-309/86-11-08) The procedure for f

operating the by pass valve in the post accident iodine / particulate

system did not include limitations for operating modes.

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remeasured ventilation flow rates for the reactor building and the primary auxiliary building have not been incorporated into appro-

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priate procedures.

The licensee revised, on September 22, 1986,

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procedure No. 7.1.3 to provide proper guidance for use of the by pass

valves. The licensee also revised procedure No. 7.1.3 to incorporate

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remeasured flow rates. This item is closed, i

4.0 Oroanization. Staffino and Qualifications The inspector reviewed the organization, staffing, and the qualifications

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of the onsite Radiation Protection Group with respect to criteria l

contained in the following:

-Technical Specificav >n 5.2, Organization; and-Regulator Guide 8.8, Information Relevant to Ensuring That Occupational Radiation Exposure At Nuclear Power Stations Will Be As

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t.ow As Is Reasonably Achievable.

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Evaluation of licensee performance in this area was based on discussions

with personnel and review of organization charts.

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

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-The licensee has reor0anized the Technical Support Department to create the position of Assistant Manager Technical Support.

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position will provide oversight and management of the radiological j

controls organization.

The individual filling this position is

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qualified to NRC Regulatory Guide 1.8 requirements.

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-The position of Radiological Controls Section Head has not been l

permanently filled. An individual is temporarily filling the

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position. The individual does not meet the qualification requirements of ANSI-N18.1, 1971.

The individual's responsibilities

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have been administrative 1y limited.

5.0 Planning and preparation for the Upcomina Outace

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The inspector reviewed the licensee's planning and preparation, in the area of radiation protection, for the upcoming outage.

Evaluation of

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licensee performance in this area was based on discussions with personnel

and review of documentation. The following areas were reviewed and i

discussed with licensee personnel:

t-work scope;

-organization and augmentation of the staff to support outage activities;

-assignment of responsibilities and oversight of outage work activities;

-equipment and supplies (e.g., shielding and protective closing); and

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-ALARA planning and preparation.

l Within the scope of this review, no violations or unacceptable conditions

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were noted.

The following matters were identified and discussed with the l

licensee's personnel.

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-The licensee established and implemented an Outage Radiological Controls Planning and Preparation document.

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-The licensee has established a draft 1990 Refueling Radiological Controls Organization.

The organization is substantially expanded

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as compared to previous outages.

The structure of the organization

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was selected to enhance supervisory oversight of in-field work.

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l-The licensee has obtained experienced ALARA personnel to assist in

I the planning and review of outage work. An ALARA coordinator and

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three engineers have been assigned to the Maintenance Group.

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-The licensee has added an ALARA engineer to the engineering department to assistant in outage planning.

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-The licensee will be undertaking some in-vessel radiological work.

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The licensee will use extensive mock-ups to plan for the work.

-The licensee has obtained a state-of-the-art information system to assist in tracking, trending, and reporting of personnel radiation exposure information.

-The licensee has established a special team of personnel to review emergent work from a dose savings stand point.

-The licensee plans to implement a primary loop flush program to flush crud out of the primary system, i-The licensee collected lessons learned comments from other departments for the 1988 refueling outage.

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Based on the above observations, the inspector concluded the licensee was performing good planning for the outage.

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6.0 plant Tours The inspector toured the plant during the inspection.

The following matters were reviewed:

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-personnel contamination control-radioactive and contaminated material control

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-posting, barricading, and access control, as appropriate, to l

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radiation and high radiation areas-house keeping

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-industrial safety-issuance and use of personnel radiation monitoring devices i

Within the scope of this review, no violations were identified.

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following observation was made:

L-The licensee has performed extensive clean-up of the back yard

areas of the facility. Quantities of material that were temporarily stored in the back-areas (e.g., drums and lumber) have been

removed. A large walled-in enclosure has also been removed.

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i licensee's efforts are on going,

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The following matters were brought to the licensee's attention as areas

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for review:

-The inspector observed several individuals not wearing dosimetry in accordance with the licensee's standards.

The dosimetry was worn inside clothing or worn on locations other than the front chest areas.

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-The inspector noted some radiological postings on the floor of the spent fuel storage building and the outside back yard areas.

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-The licensee uses special outdoor coats, called chore coats, when working outside.

The coats were hung in the radiological controlled i

area and reused.

It was not clear that the coats were frisked for i

contamination after use.

-The licensee established a second sample counting laboratory near the main health physics access control point. The inspector observed unsecured gas bottles, with one of the bottles exhibiting a pressure

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reading of 1400 pounds per square inch (psi), in the laboratory. The

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licensee immediately secured the bottle.

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-The inspector observed several out-of-date NRC-Form 3's.

This form provides information to workers regarding contacting the NRC.

l-The licensee maintains a combination Radiation Work Permit and Survey Records office area at the Main Health Physics Access Control

Point. This office area adjoins the. radiological controlled area

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(RCA).

The inspector noted that the contamination control barriers

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separating the office area from the RCA were not well identified.

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File cabinets actually extended from the non-RCA into the RCA.

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-The inspector observed several visitors touring the facility. The licensee routinely allows properly escorted visitors to tour the

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facility.

The inspector noted that individuals receive indoctrina-

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tion and training prior to the tour. The inspector reviewed the

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training and indoctrination outline and noted that the outline did

not identify specific training to be given relative to radiation protection.

Inspector discussions with the licensee's personnel i

indicated the topic of radiation protection is discussed. The

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discussions apparently included such items as adherence to posting

and barricades, expected radiological conditions, and contamination controls.

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-The inspector noted that different individuals apparently give the i

training and indoctrination and questioned how consistently radiation protection subject matter is maintained. The licensee's personnel

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stated that the outline would be revised to indicate what aspects of radiation protection are discussed.

This would also ensure consistency of presentations.

The licensee's representatives indicate the above matters would be reviewed, t

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l-7.0 Radiological Controls Improvement Plan i

The inspector met with the licensee's personnel to review the implementation of

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the Radiological Controls Improvement Plan. The plan was initiated in

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July 1989 and included a number of items to improve overall performance t

in the area of radiological controls.

The improvements completed or

planned included i-reorganization of the radiological controls section l-improvement in the training and qualification of radiation workers and radiological control technicians

-conduct of a comprehensive radiological controls program assessment i-enhancement of pre-job planning

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-development of a 1990 outage plan

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-improvement of contamination control I

i-development and implementation of a three year ALARA Plan.

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The inspector found that the licensee implemented the improvement plan milestones that were due.

The licensee's senior management was closely

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monitoring the status of the improvement plan milestones. The inspector noted that a contracted assessment team had performed a comprehensive assessment of the radiological controls program consistent with the improvement plan.

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The implementation of the Radiological Controls Improvement Plan will be reviewed during subsequent inspection.

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8.0 Exit Meetino

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The inspectors met with licensee representatives denoted in section 1 of this report on March 9, 1990.

The inspector summarized the purpose, scope and findings of the inspection.

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