IR 05000309/1990009
| ML20055C882 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 06/13/1990 |
| From: | Nimitz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20055C881 | List: |
| References | |
| 50-309-90-09, 50-309-90-9, NUDOCS 9006250328 | |
| Download: ML20055C882 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.-
50-309/90-09
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' Docket No.
50-309 I
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License No, OPR-36 i
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Licensee: Maine' Yankee Atomic Power Company
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83 Edison Drive
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Augusta, Maine 04336 i
Facility Name: Maine Yankee Nuclear Generating Station Inspection At: Wiscasset,-Maine l
'i Inspection Conducted:
May 7-11, 1990
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Inspectors:
Q,l M M 6 l\\ 96 R. L. Nimitz, Senior Rad 1# tion Specialist date
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G G 9t Approved by:
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W.'J. Pas L k, CTiief datej
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.Facilitie Radiation Protection Section
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Inspection Summary:
This inspection was a routine unannounced inspection of-the Radiation Protection Program.
Areas reviewed were organization, staffing g
and communications; training and qualifications; ALARA; audits and assessments y
and performance monitoring; radioactive and contaminated material control;
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contamination control; external exposure controls; internal exposure
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' controls;.and worker concerns.
Results:
No violations were identified.
However, a need to improve radiological
controls for' steam generator work activities was identified.
The inspector
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identified a need to improve communications within the station organization to
ensure that worker concerns are resolved.
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DETAILS 1.0 Persons Contacted 1.1 Maine Yankee
- T. Boulette, Vice President, Operations
- R. Blackmore, Plant Manager
- J. Brinkler, Manager, Technical Support
- G. Pillsbury, Assistant to Manager, Technical Support
- S. Nichols, Licensing-Section Head
- J. Connell, Acting Radiological Controls Section Head
- R. Nelson, Technical Support Manager
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1.2 NRC
- C. Holden, Senior Resident Inspector
- R._Freudenberger, Resident Inspector
- E. Leeds, Project Manager
- R. Wessman, Project Director, Project Directorate 3
- Denotes attendance at the exit meeting, The inspector also contacted other licensee personnel.
2.0 Scope of Inspection The following areas were reviewed during the inspection:
organization, staffing and communication
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training and qualification
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audits and assessments and performance monitoring
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radioactive and contaminated material controls
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external exposure controls
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internal exposure controls
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worker concerns
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3.0 Organization. Staffing and Communications The inspector reviewed the organization a'nd staffing of the onsite radiological controls organization. The review was with respect to criteria contained in applicable Technical Specifications.
Within the scope of the review, no apparent violations were identified.
The'following positive observations were discussed with the liensee's representatives:
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The licensee significantly increased the staffing of contracted
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radiation protection personnel to support oucase radiological controls activities.
The licensee assigned dedicated craws to oversee radiologically significant work activities (e.g., reactor cavity diving activities).
The licensee's radiation protection personnel provided direct oversight to the contracted radiation protection personnel.
The licensee provided written instructions to radiation protection
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personnel manning satellite control points.
-The following matters were discussed with the licensee's representatives:
The span of control of one radiation protection supervisor was
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considered large.
The work activities the individual was responsible for overseeing were originally to be assigned to two different supervisors. The supervisor was now responsible for providing direction to radiation protection technician staff overseeing radiological work in the Containment Building, Spray Building, Primary Auxiliary Building, the Main Access Check Point and low level waste activities.
This was considered a large span of control for
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the outage.
The licensee indicated this matter would be reviewed.
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The inspector's discussions with the licensee's staff, including radiation protection personnel and other personnel (e.g., maintenance personnel), indicated a reluctance on the part of these people to bring problems or concerns to-the attention of radiation protection supervisors and management.
For example, personnel were reluctant to discuss personnel exposure problems with the licensee's radiation protection supervisors and management.
Attention to the area of communications appears warranted.
4.0 Training and Qualifications
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The inspector reviewed the qualifications and training of members of the radiological controls organization with respect to criteria contained in Technical Specification 5.3, Facility Staff Qualification.
Licensee performance in this area was evaluated by review of resumes and training records and discussions with cognizant personnel.
The inspector's review in this area focused on the qualification and training of contractor radiological controls personnel hired to augment the organization during the outage.
The inspector also reviewed the adequacy of the performance of these personnel during independent inspector review of on going work activities.
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f Within the scope of this review, no apparent violations were identified.
l The licensee's contractor personnel appeared to have received adequate
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training and qualification.
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5.0 ALARA
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L The inspector reviewed selected aspects of the licensee's ALARA Program.
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The review was with respect to criteria contained in the following:
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Regulatory Guide 8.8, Information Relevant to Ensuring that
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Occupational Radiation Exposure at Nuclear Power Stations Will Be As L
. Low As.Is Reasonably Achievable;
-Regulatory Guide 8.10, Operating Philosophy for Maintaining l
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Occupational Radiation Exposure As Low As Is Reasonably Achievable; NUREG/CR-3254, Licensee Programs for Maintaining Occupational Exposure
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to Radiation As low As Is Reasonably Achievable;
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NUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power r
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Plants; $tudy on High-Dose Jubs, Radw6ste Handling and ALARA
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Incentives.
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Within the scope of this review, no apparent violations were identified.
The inspector's observation of on going weik activities indicated good
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p overall ALARA controls to be in place for in-field work.
The following positive observations were made:
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The licensee used mock-ups for training personnel working on
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L radiologically significant work activities.
The mock-ups included a r
steam generator bowl and pressurizer.
The licensee also mocked-up
- the tools and area for performing underwater work on the thermal shield. The mock-up training was performed in a water filled tank, i
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The licensee used a special vacuuming system to minimize hot
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particle generation when performing drilling on the thermal shield.
The. licensee was using viewing cameras to monitor access points to
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High Radiation Areas to minimize unnecessary exposure of personnel
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checking the doors.
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The inspector estimated that the licensee performed extensive ALARA
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reviews for at least 86% of the planned outage expo:ure.
The licensee used television cameras where appropriate to monitor
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on going work, including constant monitoring of High Radiation Area
access doors.
The following matter was discussed with the licensee's representatives.
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The areas within the bio-shield exhibited high genera' area dose
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rates.
The licensee indicated that this matter was being reviewed.
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6.0 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 requirenents.
The inspector reviewed the licensee's audits and assessments of the radiological controls program.
The inspector reviewed QA evaluation reports, QA/QC surveillances, and recent QA audits of the radiological
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controls program.
The inspector also met with the licensee's QA personnel and discussed QA initiatives relative to oversight of the radiological controls program.
Within the scope of this review, no apparent violations were identified.
The inspector's review indicated the licensee was performing generally acceptable oversight of the radiological controls program.
The following positive observations were identified:
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Inspector review of QA audit MY 89-03, Radiation Protection, dated
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November 15, 1989 indicated that the audit was performance based and that the technical specialists that were used were appropriate.
Senior level radiction protection personnel from other stations were used as audit team members.
The licensee has obtained a contractor QA engineer to perform full
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time oversight of radiological control activities.
The individual works an average of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per week and spends at least two hours per day in actual oversight of work in contaminated areas.
The individual spends about 50'4 of his time in reviewing activities.
The licensee was providing a semi-annual trend report of
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radiological controls activities to plant station management.
The trend report focused on findings identified by QA and by the NRC.
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Radioactive and Contaminated Material Control and Contamination Control The inspector reviewed the licensee's posting, labeling and control program, as appropriate, for radioactive and contaminated material and contamination Control.
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The review was with respect to criteria contained in applicable procedures
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and 10 CFR 20, Standards for Protection Against Radiation.
The evaluation of the licensee's performance in this area was based on independent inspector observations of on going work, discussions with personnel and reviews of documentation.
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The following observations were made:
j Radioactive and contaminated material was properly posted, labeled
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and controlled, as appropriate.
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The licensee's Hot Particle Controls were generally acceptable.
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The licensee exercised generally good controls over material being
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removed from tFt flooded reactor cavity.
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The primary containment exhibited generally low levels of
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l Personnel were required to perform whole body frisking prior to
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exiting the facility to the back yard areas of the station.
8.0 External Exposure Controls The inspector reviewed selected aspects of the licensee's external exposuro control program.
The following matters were reviewed:
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High Radiation Area access controls
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. posting and barricading of Radiation and High Radiation Areas
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worker adherence to radiation work permit (RWP) requirements and good
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radiologi:a1 control practices use of personnel contamination monitoring devices
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use of dosimetry
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completion and maintenance of dosimetry records
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adequacy of radiological surveys to support planning for work and
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on going work activities hot particle controls
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radiological controls for reactor cavity diving operations
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The evaluation of the licensee's performance in this area was based on z i
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observation of on-going work activities and discussions with cognizant personnel.
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Within the scope of this inspection, no apparent violations were identified.
The following matters were discussed with the licensee:
There is a need to improve the exposure control methods for personnel
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performing steam generator work activities.
Exposure records at the steam generator control points were noted to be out-of-date.
This made it difficult for radiation protection personnel to get up-to-date
exposure information.
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There was no well-defined, consistent method of tracking and controlling
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s accumulation of exposure for steam generator workers at the work location.
The licensee appeared to be relying solely on the digital integrating alarming dosimeters as the principal means of exposure control. The alarming dosimeters were not required to be worn. They were not specified
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on the RWP. The dosimeters were operability checked once per day.
The dosimeters were not periodically checked for operability throughout the day.
The licensee revised the RWP to require use of alarming dosimeters.
The licensee uses an RWP " Pink Form" to track accumulated personnel
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exposure.
Personnel carry a " Pink Form" into containment when
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working in the containment. The RWP procedure did not provide clear o
I guidance as to how a " Pink Form" is to be used when working on various elevations of containment.
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Inspector observations of work on the 46 foot elevation of containment
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indicated the satellite control points were not ensuring personnel entering onto the elevation had signed the appropriate radiation work permit and had been properly briefed.
r Observation of diving operations indicated no area monitors were placed
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on the work platform to monitcr the general area of the platform.
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The licensee's radiation protection personnel placed a radiation-monitor on the platform after it was brought to their attention by the inspector.
The inspector observed an individual suit up to perform work on the
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steam generator platform on May 8,.1990.
The individual suited up, with support from two other individuals, without any radiation protection personnel present.
Upon attempting to entering the work area, the workers were informed that radiation protection personnel were unaware of the worker's work task. As a result, the worker was required to wait. Although the suiting up and waiting was performed-in a general low dose rate area, the observations indicate a need to o
improve coordination and control of work activities to minimize exposure.
The following additional matter was discussed with the licensee's representatives:
i The inspector observed reactor coolant pump viewing ports (holes) cut
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through the bio-shield in containment.
The holes allow personnel to view the reactor coolant pumps from the annulus area of containment.
The holes appeared to allow for unauthorized personnel access into the loop areas, a locked High Radiation Area.
The inspector requested that the licensee review this matter.
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The licensee submitted a letter, dated May 16, 1990, to NRC Region I to
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provide additional information on the viewing holes.
The licensee's letter e
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stated it was possible to enter the loop areas via the viewing ports but l
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l that entry is difficult and could result in injury. The licensee's letter also stated that the viewing ports were not considered as entry points and
therefore, the viewing ports were not required to have locked doors.
This matter is considered unresolved.
(50-309/90-09-01)
9.0 Internal Exposure Controls The inspector reviewed selected aspects of the licensee's internal exposure controls program.
The following matters were reviewed:
posting of Airborne Radioactivity Areas
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proper selection and use of respiratory protection equipment
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c use of engineering controls in lieu of use of respiratory protection
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equipment internal exposure summaries a
adequacy of airborne radioactivity surveys to plan for.and support
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on going work activities maintenance of internal exposure records
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timeliness of analysis of airborne radioactivity samples
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supervisory review of air sample results
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The evaluation of the licensee's performance in the above areas was based on review of on going work activities, a review of documentation and
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discussions with cognizant personnel.
Within the scope of this review, no apparent violations were identified.
The following matters were discussed with the licensee's personnel:
Air samples were counted in a timely manner.
The results were
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reviewed by radiation protection supervisors No individuals exceeded 40 MPC-hours exposures
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The following matters were discussed with the licensee:
The inspector observed some lapel air sample filter analysis results
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indicating 1.17E-9 uCi/ml.
This represents about 39'i; of the 10 CFR 20, Appendix B value for Cobalt-60 (assuming Cobalt-60).
The licensee's gamma isotopic analysis did not show any identified radionuclides.
It was unclear as to the reason for this anomaly.
Several air sample results, which indicated the same general
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airborne radioactivity concentration values (10E-8 uCi/ml) showed different principal'radionuclide contaminants.
It was unclear as to the reason for this anoma1y.
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Radioactive sample counter source check data and control charts were i
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not being consistently plotted.
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The daily radioactive sample counting performance check data sheet
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depicts incorrect units for total radioactivity of a check source, t
Some technicians are repeatedly calculating lower limits of detection
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of sample counters incorrectly. Other technicians are correcting the
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errors.
It appears additional training of technicians is warranted.
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It also appears additional supervisory oversight of counting activities may be warranted.
l The licensee indicated the above matters would be reviewed.
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10.0 Worker Concerns (RI-90-A-0054)
10.1 Background I
On April 25, 1990 a worker contacted the NRC to express concern that the Radiation Protection Manager had allowed personnel to enter High
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Radiation areas without providing those individuals the controls required
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by Technical Specification 5.12.
Specifically the worker indicated the
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following:
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Concern 1 i
Radiological.Controis Technicians were permitted to enter the Containment Building since April 6, 1990 without survey meters.
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The Containment Building was posted as a Technical Specification - 5.12 locked High Radiation Area and a High Radiation Area.
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The Radiation Work Permit for access to the Containment Building
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required radiation protection technicians to carry a survey meter during all entries to High Radiation Areas, i
Areas within the Containment Building were greater'than 1000
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millirem / hour.
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The Radiation Protection Manager was informed of the concern on
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or about April 11, 1990.
Concern 2
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On April 16, 1990 the Radiation Protection Manager authorized i
operations personnel to escort mi11 wrights into High Radiation Areas and provide coverage for these individuals.
This is in violation of Radiation Protection Procedure No. 9.1.6, Step 6.2.5.a.5.
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.10.2 NRC Review-10.2.1 General The licensee commenced the refuelin'g outage on April 6, 1990.
At that time, the licensee elected to control access to the High Radiation Areas (greater than 1000 mR/hr) inside.the Containment Building via controlling access at the personnel airlock.
Control at the airlock was maintained from April 6, 1990 to about. April 16, 1990. During this time, the licensee was constructing lockable caged doors to prevent general access to the loop areas located inside the bio-shield.
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Several areas within the loop exhibited general area dor,e'
L rates greater than 1000 millirem /hr. Until construction of i-the gates was complete (April 16, 1990) the licensee used
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personnel at satellite control points within the Containment
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Building to control access to the areas greater than 1000 millirem /hr. The general area dose rates within the
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Containment Building outsido the loop areas, between the satellite stations and the personnel air lock was less than 100 millirem /hr (a Radiation Area).
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To. enter a High Radiation Area, the licensee's Technical
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Specification 5.12 requires that an individual be. signed in
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on a Radiation Work Permit and one of the following
-monitoring requirements to be in effect:
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The individual is provided a continuously indicating
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dose rate meter or
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The individual is provided an integrating alarming I
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dosimeter after being instructed in the dose rates in
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the area to be entered or i
The individual is signed in on an RWP and an individual l
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qualified in radiation protection procedures performs
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surveys at a frequency specified on the RWP.
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10.2.2 Scope of Review i
The inspector reviewed the above concerns by the following methods:
The inspector reviewed radiation work permits for access i
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to'the Containment Building between the period,
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April 6, 1990 through April 16, 1990.
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Area Controls, use of survey meters, escort requirements and radiation work permits with contractor ario the t
licensee's radiation protection technicians on various shifts including backshifts, i
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compliance with Technical Specification 5.12, applicable
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radiation work permits and procedures.
10.3 NRC Findings
10.3.1 Concern 1 (Findings)
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The inspector's review indicated the following:
RadiationWorkPermits(RWPs)forradiationprotection
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technicians entering the containment required use of a-survey meters
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RWPs for workers specified one of the three monitoring
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h requirements discussed above. Typically this was a survey by a radiation protection technician at a frequency
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specified on the RWP.
The containment access (airlock) had been posted as a
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High Radiation Area - Technical Specification 5.12 locked door Radiation protection technicians were assigned or signed
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out survey meters to enter the containment and proceed
to their work location The concerns about entering containment without a meter
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was discussed with, but was not condoned by radiation protection management.
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Conclusion for Concern 1 The inspector was unable to substantiate that radiation protection technicians had entered containment in' violation of their radiation work permit and. Technical Specification-requirements. -This concern appeared to be a rumor circulating-
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among the radiation protection technicians.
No apparent violations of procedures or licensee requirements was identified.
This concern is not substantiated.
10.3.2 Concern 2 (Findings)
The inspector's review indicated the following:
The licensee's Radiation Protection Procedure 9.1.6,
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Step 6.2.5.a.5 prohibited operators from escorting-
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personnel into High Radiation Areas.
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The licensee's radiation protection management took an
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initiative on or about April 16, 1990 to allow
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operators to escort workers (mi11 wrights) into High
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Radiation Areas. This was done in order to reduce the h
exposure received by radiation protection personnel in L
escorting workers into High Radiation Areas.
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The licensee's radiation protection management issued
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a Night Order, dated April 16,1990(RCO-90-022).
The Night Order, to all " Rad Controls Personnel" stated, in part, under the heading High Radiation
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Area Coverage that the Operations Department now has some mi11 wrights working with them on shift. The RPM (Radiation Protection Manager) has authorized that the mi11 wrights may enter high radiation areas with an operator (who will have a meter) on the operation radiation work permit.
The licensee's radiation protective management issued
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a memorandum dated April 21, 1990, to "All Rad Con Personnel, subject Controls for Special Operations
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Department Support Personnel" which. discussed this t-planned initiative.
This memorandum stated..in part, that in the interest of ALARA, operators will be allowed to provide locked area access to mi11 wrights
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or ALARA technicians.
These latter individuals (ALARA technician and millwrights) were those assigned to the t
operating shift crew. The memorandum specifically-stated that satellite station radiation protection technicians must assure that the entries are made with i
a survey meter or alarming dosimetry and that adequate
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dose controls are in place.
The licensee's operations management issued a memo-
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randum dated May 2, 1990, to Plant Shift Supervisors,
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subject-M111 wright usage. 'This memorandum stated that millwrights should be accompanied anytime they are on the " hot side" until they are comfortable with radiological controls procedures.
If a Technical Specification 5.12 area is to be entered, the millwright must have radiation protection technician
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coverage or be with an auxiliary operator who has the
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proper survey meter.
- The licensee-initiated a change to radiation protection
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Procedure 9.1.6 on May 2, 1990.
This change was to
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allow operators to escort individuals into a locked
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The procedure was changed to l
allow operators to escort the shift millwright and ALARA technician into locked High Radiation Areas.
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Conclusion for Concern 2
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The inspector's review indicated that the licensee's
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initiative to allow operators to escort the shift
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millwrights and ALARA technicians into locked High Radiation
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Areas was not in violation of Technical Specification 5.12 requirements. The licensee's memorandum stated, and the inspector's review verified, that entries into Technical Specification 5.12 locked High Radiation Areas were made
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personnel were in compliance with Technical 5.12 requirements. The personnel were required to have in their i.
possession integrating alarming dosimeters or have in their
possession a continunusly indicating dose rate meter.
However, although the practice was considered by the inspector to be in compliance with the Technical
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Specification, the licensee's procedures prohibited the practice, it appeared that the licensee's April 16, 1990 memorandum authorized the entry although the procedure was not revised until May 2, 1990 to permit this practice.
Regarding the potential violation of Radiation Protection
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Procedure 9.1.6, the licensee recognized that the procedure needed to be revised to allow operators to escort individuals into locked High Radiation Areas. At the time
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of the inspection, the inspector was unable to verify that
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between April 16, 1990 and May 2, 1990, the date the procedure was revised, operators escorted individuals into
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locked High Radiation Areas in violation of the procedure requirements.
The inspector did not have sufficient time
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to search documents to determine if operators had escorted millwrights into locked High Radiation Areas in violation E
of approved procedures.
This matter is unresolved and will be. reviewed during a subsequent inspection (50-309/90-09-02).
The inspector's discussion with radiation protection personnel indicated that the use of operators to escort i
personnel was not effectively communicated to the radiation protection staff in that the plant personnel did not believe it was in accordance with Technical Specifications.
11.
Exit Meetino
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The inspector met with the licensee representatives, denoted in Section 1
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of this report, at the conclusion of the inspection on May 11, 1990 'The inspector summarized the purpose, scope and findings of the inspection.
No written material was provided to the licensee, t-u t