ML19257A866
| ML19257A866 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/04/1980 |
| From: | Counsil W CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8001090303 | |
| Download: ML19257A866 (33) | |
Text
-
I.
POWER COMPANY YANKEE ATOMIC CONNECTICUT CON N ECTICUT B E R LI N.
N ARTFORD. CONNECTICUT o610t P. O. Box 270 Taterno=a January 4,1980 203 668-6911 Docket No. 50-213 Mr. Victor Stello, Jr.
Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Gentlemen:
V. Stello, Jr. letter to D. C. Switzer dated December 6, (1)
References:
1979 12, 1979.
W. G. Counsil to B. H. Grier dated AprilD. C. S (2)
(3)
W. G. Martin letter to W. G. Counsil dated December 13, 1979.
(4) 1979.
Haddam Neck Plant Radiation Protection Program informed In Reference (1), Connecticut Yankee Atomic Power Co of the apparent 14-16, 26-28 and March 5-conducted on February protection program at the Haddam Neck Plant.
d verbally The response to the preliminary findings of this audit was ma e 16, 1979 during the Management Meeting in King of Prussia on March (2).
In Reference (2),
This response was subsequently docketed via Referencenology of key events h
the background information, preoutage planning, c rot the time of the and the assessment of the health physics program aIn addition, a status report on the outage was provided to the Staff.
provided. These three instances of special exposure evaluations were t testing, exposures included exposures during steam generator eddy currenand RCA stay time or sures in during fuel sipping operations,All of these special exposure evalua of February-March excess of NRC regulations occurred during the outageSub h
of the NRC i
severity of the radiological concerns, the signif cance 1979.
findings notwithstanding.
(1) was provided CYAPCO's initial response to the requests of ReferenceAs we in Reference (3).
penalties proposed by the staff, Reference (3) in 303 8
2*
706 301
a It was response to the Reference (1) issues was under development.
further indicated that information demonstrative of the adequacy of the existing Haddam Neck Plant Accordingly, the following information is provided.
(2), an extensive program of corrective actions was identified.
30, 1979. These In Reference Implementation of this program was initiated on May actions supplemented other corporate programs in the health physics area Examples that were already either in effect or under development.the computerized health physics include the corporate ALARA program, The and the corporate personnel dosimetry laboratory.
corrective actions responding specifically to the Reference (1) concerns records system, include:
Reorganization and additional staffing of the 1.
Station management a.
Station health physics department b.
Corporate Radiological Assessment Branch c.
Modification of the radiation worker training program.
2.
Training and certification of all health physics technicians, 3.
foremen and supervisors.
Standardization of health physics procedures.
4.
Standardization of health physics equipment.
5.
Adoption of a single corporate contract for health physics technicians d
services for all Northeast Utilities nuclear stations for a perio 6.
of one to two years.
Improvements in the Haddam Neck Station layout.
7.
to obtain NRC concurrence in the respiratory protection 8.
An effort program.
Based upon the above extensive corrective measures, CYAPCO has concluded (1) have been thoroughly that the concerns identified in Reference In particular, each of the four items identified in the addressed.
follows:
forwarding letter of Reference (1) are addressed as Failure to recognize the significance of the radiological impact consequently, failure 1.
accompanying suspected fuel clad degradation; to plan and prepare accordingly; The organizational change in station management and the station The corporate Health Physics Department resolves this concern.
Radiological Assessment Branch will continue to perform routine audits of the station health physics program to ensure management Special audits awareness and the continued quality of the program.
of the preoutage planning will be conducted and assistance will be Audits provided to implement any corrective actions necessary.
will be conducted during outages at an increased frequency.
1706 302 Failure to provide sufficient leadership and direction in the implementation of the radiation protection program during the 1979 2.
refueling outage; The reorganization and staffing of station management and the The training station Health Physics Department resolves this issue.
and certification program for the health physics staff will provide assurance that the staff is prepared to exercise effective radiation The corporate Radiological Assessment Branch, safety controls.
Field Services Group will provide additional supervisory staff to supplement all shif ts and, as necessary, the station Health Physics Department supervision.
Failure to establish, maintain and implement procedures sufficient to provide guidance and direction in the performance of radiation 3
protection activities; Standardized health physics procedures and standardized health physics equipment programs ensure that a uniformly high level of Health physics quality is maintained in the station programs. staff training and certificat ilitate worker training program with workshop training sessions will fac achieving this objective.
Failure to provide suf ficient corporate assistance to the station's radiation protection program in the area of management and technical 4.
support in a timely manner.
The reorganization and increased staffing of the corporate Radiological Assessment Branch ensures that adequate personnel will be available to provide the necessary increased depth of technical and supervisory The Radiation resources to the station health physics programs.
Protection Field Service Group has been structured to alleviate the need for additional supervisory personnel during outage peak work and Regular meetings between station upper management Radiological Assessment Branch supervision will ensure implementation loads.
of the radiation protection pr eram.
In summary, the above delineated corrective actions have either beenC implemented or are in progress.A more detailed status report of the various for the calendar year 1980.
1.
corrective action programs is provided as Attachment The detailed response to each of the items of noncompliance is provided The response is intended to clarify the inspection Program details as Attachment 2.
details and provide specific explanations as necessary.
had previously been provided via Reference (2).
CYAPCO has also conducted a review of the information provided in Reference Exceptions to several inspection findings are provided as Attachment (4).
3.
1706 303
. We trust you find the above information responsive to your requests, and sufficient to concur in CYAPCOs conclusion regarding compliance with regulations relating to the radiation protection program.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY v
2 M
W. G. Counsil Vice President Attachment 1706 304
DOCKET No. 50-213 ATTACHMEhT 1 HADDAM NECK PIANT STATUS REPORT ON THE CORRECTIVE ACTION PROGRAMS IDENTIFIED IN REFERENCE 2 January, 1980 1706 305
. 1.
Staffing and Organization The station management reorganization and staffing has been completed.
The station Health Physics Department reorganization is completed, Since April 1979, contractor supervisory staffing is in progress.
personnel and contractor technicians have been utilized to fill vacancies.
The corporate Radiological Assessment Branch reorganization has Additional engineering personnel have been hired been completed.
and are actively engaged in the implementation of the various The field services staff has been corrective action programs.
hired and have already been used in some of the recent outages and Additional for providing routine assistance in worker training, etc.as necessary, this personnel will be hired in 1980 to supplement, personnel dosimetry laborato The corporata field group.
Personnel have been hired and equipment installation constructec is proceedi.g.
2.
Training A.
Radiation Worker The radiation worker training program has been expanded in Textual material has been prepared, and slides and scope.
The program other video accessories are under development.
will include hands-on workshop sessions on protective clothing, etc.
The respirator usage, handling contaminated equipment, program is expected to be implemented by April 1980.
B.
Health Physics Staff The preparation of a phase one program lasting approximately 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> for technicians and foreman level personnel has been completed. The first class of nine began the program on classes for the remaining staff December 10, 1979. Additiona2 will be conducted in January-April 1980.
A phase two program for supervisory and engineering personnel is scheduled to be completed by late 1980.
3.
Standardized Procedures Approximately 60 percent of the standardized procedures have been drafted, and are in various stages of review.
All the procedures will be completed and in a manual format by These pro-April 1980 for inclusion in the station procedures.
cedures address in excess of 90 percent of the operation of the station health physics program.
1706 306
2-4.
Standardized Equipment laboratory equipment, and protective The lists of survey equipment, is being replaced and Some equipment clothing have been generated. additional equipment is being procured from Additional lists of other health physics equipment are being list.
prepared and will be completed by April 1980.
5.
HP Contractor Selection for both the Haddam Neck and Millstone Sites A two-year contract has been signed and will be effective this month.
6.
Station Layout (Haddam Neck)
The layout changes to the health physics areas have been conceptually Construction bids will be requested and a contractor completed.
Construction will not commence will be selected in early 1980.
until after the 1980 refueling outage in order to avoid disruptio of crucial areas.
for the outage.
7.
Respiratory Protection Program Station procedures and equipment are being upgraded with the It is expected that NRC addition of more quality control.
concurrence will be requested by May,1980.
1706 307
DOCKET NO. 50-213 ATTACHMENT 2 HADDAM NECK PLANT RESPONSE TO ITEMS OF NONCOMPLIANCE January, 1980 1706 308 INFRACTION A.
Technical Specification 6.13, "High Radiation Area", states in the first pa
,raph, "In lieu of the ' control device' or ' alarm signal' required by Paragraph 20.203(c)(2), each high radiation area in which the intensity of radiation is 1000 mrem /hr or less shall be barricaded and conspicuously posted as a high radiation area and extrance thereto shall be controlled by requiring issuance of a Radiation Exposure Authorization (Radiation Work Permit (RWP)). An individual or group of individuals permitted to enter such areas shall be provided with one or more of the following:
a.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
b.
A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.. Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them.
c.
A health physics qualified individual (i.e. qualified in radiation protection procedures) with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and who will perform periodic radiation surveillance at the frequency specified in the REA (RWP). The surveillance frequency will be est blished by the Health Physics Supervisor.
Contrary to the above, on February 15, 1979, two individuals performing hydro-lancing work on No. 2 Steam Generator in accordance with Radiation Work Permit (RWP) No. 791307 were working in high a
radiation area having dose rates between 100 and 30 H) mremit but were not provided with any of the specified contrc is.
RWP 791307 required the use of a continuous dose rate indicating instrument.
This is an infraction (Civil Ptnelty $4,000).
RESPONSE
Radiation surveys had been conducted in the work area adjacent to the #2 Steam Generator prior to the start of hydro-lancing werk, and the aorkers involved had been informed of these levels. A senior Health Physics technician was assigned to the job full time. As a result of the assigned Technician being absent from the high radiation are?,
Station Health Physics staff and vendor Health Physica technicians still on site have been reinstructed in the importance of p roper work practices in high radiation areas and compliance with RWP requi rements.
In the future, contractor Health Physics personnel w.11 receive more extensive instruction in plant technical specification requirements and 1706 309 plant procedures before being assigned to radiation protection duties.
Also additional technical and supervisory positions have been authorized both at the plant and at the corporate level to ensure future compliance.
Connecticut Yankee is therefore in full compliance with Technical Specification 6.13.
1706 310 INFRACTION Technical Specification 6.13, "High Radiation Area", states in the B.
that a high radiation area in excess of second paragraph, in part, 1000 mrem /hr shall be provided with locked doors to prevent unauthorized entry into such areas, and the keys shall be maintained under the administrative control of the shift supervisor on duty.
Contrary to the above:
On February 14 and 15, 1979, from 11:00 p.m. to 3:00 a.m.,
the 1.
following areas in the Primary Auxiliary Building were found by the NRC inspector to be as follows:
Accessible Status Dose Rate Area Residual Heat Removal 200-1500 mrem /hr Not Locked (RHR) Pit Access 1000 mrem /hr Not Locked Pipe Trench Access In Blowdown Room 1000 mrem /hr Not Posted as High Pipe Trench Access Radiation Area; in Valve Operating Not Locked Room 1000 mrem /hr Not Locked Pipe Trench Access in PAB Passageway 15, 1979, at approximately 2:30 a.m. the following On February 2.
areas in the Reactor Containment were found by the NRC inspector to be as follows:
Accessible Status Dose Rate Area Inner Annulus from 100 to 35000 mrem /hr Not Locked 3 Access Points in Lower Level Containment inner Annulus from 100 to 35000 mrem /hr Not Locked; Not Posted As 4 Circular Stairway High Radiation Access Points on Area the Charging Floor of Containment These instances of failure to lock and post high radiation areas constitute an infraction.
(Civil Penalty $3,000.)
1706 311
. RESPONSE B.1 Primary Auxiliary Building As indicated in Reference 2, there were a variety of reasons for a resource shortage in the Health Physics area which prevented the surveillance in the areas from being as complete as necessary.
Krys used to gain access to locked high radiation areas were also The necessary availability of these used to open locked valves.
keys for purposes other than gaining access to high radiation areas The following precluded absolute control over the locked areas.
steps have been taken to ensure the required control in high radiation areas in excess of 1000 mrem / hour:
All high radiation area locks have been changed.
a.
All high radiation areas greater than 1000 mrem /hr in the b.
Primary Auxiliary Building have been equipped with locked gates or doors in such a way that no individual will be prevented from leaving a high radiation area while at the same time the areas remain locked.
from control room Personnel requiring a key must obtain it c.
personnel who log these uses.
B.2 Containment The practice of " zone" Health Physics coverage in the reactor containment has long been established at Connecticut Yankee to reduce radiation exposure to control point monitors and Health This has been demonstrated to be adequate to Physics technicians.
More detailed preoutage maintain radiological controls in the past.
planning will be used to determine if more extensive H.P. coverage than the zone coverage approach is required for certain areas and In addition the following steps have been taken or certain jobs.
are planned to ensure c3ditional controls:
The entry ways to all four steam generator skirt areas have a.
been equipped with lockable gates.
The access doors from the containment lower level outer annulus b.
to the inner loop areas are equipped with lockable gates.
During the 1980 refueling outage, these will be modified so that no individual will be prevented from leaving a higa radiation area.
The circular staircases from the containment charging floor to the inner loop areas are equipped with waist high lockable c.
By the end of the 1980 refueling outage, more effective gates.
In the interim, health physical barriers will be installed.
physics qualified personnel (i.e., qualified in health physics procedures) will be assigned to each work party entering these areas as permitted in Connecticut Yankee Technical Specifications 6.13.1.c.
1706 512 in The expanded Radiation Worker Training Program will assist d.
delineating worker responsibilities.
Postings All required postings were in place prior to the start of the 1979 outage.
All station and contractor personnel on site have been reinstructed importance of maintaining high radiation areas greater than in the They have also 1000 mrem /hr locked or otherwise under control.
been reminded not to remove or modify radiological signs, ropes or wiher control or warning devices. The expanded Radiation Worker Training Program will facilitate understanding of the workers' responsibilities.
Posting requirements have been reviewed with station and vendor Two Health Physics Department Instructions health physics personnel.
have been issued addressing this subject.
Connecticut Yankee is therefore in full compliance with the locking requirements of Technical Specification 6.13 and the posting require-ments of 10CFR20.203(c).
1706 313
. INIRACTION 10 CFR 20,201, " Surveys" states in section (a) "As used in the C.
" survey" means an evaluation of the regulations in this part, release, disposal, radiation hazards incident to the production, use, or presence of radioactive materials or other sources of radiation When appropriate, such evaluation under a specific set of conditions.
includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive material present," and in section (b) "Each licensee shall make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part."
" Written Technical Specification 6.8, Procedures, states, in part, procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USAEC Regulatory Guide 1.33... USAEC Regulatory Guide 1.33, Quality Assurance Program Requirements Appendix "A", Section G.5.c specifies that the licensee have procedures for " Surveys and Monitoring".
Contrary to the above:
16, 1979, there were no written procedures As of February 1.
established, implemented or maintained that addressed detection, monitoring, survey and evaluation of alpha and beta radioactivity in regard to internal and external personnel exposure, even though individuals were subject to exposure from sources of these types of radiation. This lack of procedures contributed to the failures to survey described in items C.2 and C.3.
16, 1979, surveys sufficient to determine compliance On February 2.
with 10 CFR 20.101, " Exposure of individuals to radiation in restricted areas" were not performed when individuals in the Spent Fuel Building were performing fuel sipping operations with a contaminated fuel assembly hsndling tool in close Later measurements on proximity to the individual's face.
this tool indicated that the gamma dose rate was 25 mrem /hr at and the beta dose rate was 400 to 600 mrad /hr at
- contact, contact.
On February 3, 1979, surveys sufficient to determine compliance 3.
with 10 CFR 20.101, " Exposure of individuals to radiation in restricted areas" were not performed prior to allowing personnel 1 Steam Generator (Primary Side, Channel to enter the No.
790599, in that no surveys to Head), in accordance with RWP determine beta dose rates were performed prior to subjecting personnel to exposure; and no evaluation was performed to estimate beta exposure to the individual. Subsequent meanurements of the beta dose rate in the steam generator indicated that levels may have been as high as 370 rad /hr in the general area within the channel head.
1706 314 4.
On March 7, 1979, surveys sufficient to determine compliance with 10 CFR 20.101, " Exposure of individuals to radiation in restricted areas," were not made while personnel were performing work in the Reactor Containment in accordance with RWP 792396,
" Clean out flux thimbles," in that the portable instrument (Teletector No. 11068) used to monitor that operation was found to produce inaccurate and unreliable information when used to measure various radiation intensities; the instrument significantly underestimated the actual exposure rate.
In addition, two other portable radiation survey instruments (Teletector Serial 34198 and PIC-6 Serial 1499) were found to be inoperable or inaccurate.
These instances of failure to have a procedure and failure to perform surveys constitutes an infraction (Civil Penalty $3,500.)
RESPONSE
C.1 Connecticut Yankee Surveillance Procedure No. SUR 5.6-8 " Health Physics Surveys" dated 10/14/77, section 5.1 directs the health physics technician to obtain an area survey form. Each survey form has check blocks at the top where the technician indicates the type of survey performed (i.e., beta gamma or alpha).
In addition, check-off lists A-2, A-4, B-3 and B-6 in this procedure require specific beta measurements.
Long standing practice in the health physics department has been to check a percentage of all smears for alpha contamination. Therefore, CYAPCO reiterates its position that a procedure for detection, monitoring, survey and evaluation of alpha and beta radioactivity was in effect at the time of the inspection. Adequate instrumentation was available to perform these evaluations. However, as indicated in Reference (2) there was a need for greater health physics resources to ensure that surveillance was being done in all areas.
C.2
& 3. Trained health physics technicians must be relied upon to perform appropriate surveys to ensure adequate protection for the personnel they are assigned to cover. Survey forms indicated a need for beta, gamma and alpha contamination evaluations. The fact that in two instances these surveys were not performed resulted from inadequate training and/or experience on the part of some of the vendor technicians and a temporary shortage of health physics supervisory personnel to maintain surveillance of vendor technicians.
When these items were identified all health physics technicians were instructed to take particular care assessing the radiological conditions in their assigned areas. Dose evaluations were performed and exposures assigned to all workers involved in these jobs.
In the future, vendor technicians will be scrutinized more carefully in regard to their qualifications and experience. Some form of evaluation will be conducted before vendor technicians are permitted to provide on job health physics coverage.
Increased supervisory 1706 315 staf f will allow for more field supervision of work in progress and A
allow for closer review of survey data to ensure completeness.
(2).
Health Physics Staff training program is described in Reference The use of a 2 year contract for HP vendors will help to obtain a better quality and enhance continuity regarding station procedures The Corporate Field Service Group will provide additional and policy.
supervisory personnel as necessary.
The three inoperable or inaccurate instruments were found at the C.4 end of an extended and arduous period of very heavy instrument It is emphasized that the teletector being used to cover usage.
the cleaning of the flux thimble was indicating on scale and indicating the presence of radiation. The workers involved all received less Good work than 15% of their allowable exposure listed on the RWP.
practices require workers to check their pocket dosimeters frequently.
Unusual or high exposure rates were not detected using this met, hod.
Radiation surveys had been performed in the area in question and the results of that survey were available.
When this situation was brought to the attention of Connecticut Jobs Yankee, all work in the radiation control area was stopped.
restarted only when the meter to be used to cover that job had were been verified to be accurate.
The formation cf a Health Physics Service Group in the plant will ensure that the required amount of portable radiation survey instruments are calibrated and in good repair. The standardized procedures and standardized equipment corrective action programs will also assist in alleviating the problem.
In addition, the station procedure used for determining alpha and beta exposure has been rewritten to provide additional specific information to the technician.
Connecticut Yankee is therefore in full compliance with 10CFR20.101, 10CFR20.201 and Technical Specification 6.8.
1706 316 INFRACTION 10 CFR 20.102, " Exposure of individuals to concentrations of radio-D.
active materials in air in restricted areas," states in section (A)(1),
"No licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a quantity of radioactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in Appendix B, Table 1, In this regard Section (a)(3) stipulates, "For purposes Column 1..."
of determining compliance with the requirements of this section the licensee shall use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas..."
Section (b)2 of 10 CFR 20.13 states "..., other precautionary procedures, such as increased surveillance, limitation of working times, or provision of respiratory shall be used to maintain intake of radioactive protective equipment, material by any individual within any period of seven consecutive days as far below that intake of radioactive material which would from inhalation of such material for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform result concentrations specified in Appendix B, Table 1, Column 1 as is reasonably achievable."
Contrary to the above:
Between January 29 and March 1, 1979, suitable measurements of 1.
concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity were not made in the Reactor Containment in that the air samples were collected in the general area of the Reactor Containment at various locations that were not directly representative of the concentrations of airborne radioactivity in the breathing zone of the workers.
For example, during the work activities described by RWP 792066 which involved opening the primary system (disassembly of RHR-MOV-781), the only sample taken was at least 10 feet behind the work area.
On February 3, 1979, no measurements of radioactive materials 2.
in air were made in the area in which personnel were working in No. 1 Steam Generator (Primary Side, Channel Head) in accordance with RWP 790599, an area having loose surface contaminationashighas250 mrem /hrjgamma),and3,000 mrad /hr (nonpenetrating radiation) per 100 cm Between February 11 and March 9, 1979, precautionary procedures 3.
such as increased surveillance, limitation of working times, or provisions of respiratory protective equipment were not used in that the provided precautionary procedure developed to address limitation of working times (Procedere RAP 6.1-4, Revision 3, " Determining Airborne Radioactive Concentrations and the Allowable Stay Time") was not implemented.
As a result, at least 11 persons were subject to intake of radioactive material in excess of that which would result from inhalation 1706 317 of such material for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform concentrations specified in Appendix B, Table 1, Column 1.
These instances of failure to make suitable measurements and to implement precautionary procedures constitute an infraction.
(Civil Penalty $3,000.)
RESPONSE
& 2. All vendor health physics technicians were instructed prior to the D.1 outage to take air samples in the immediate work area to ensure that the samples were representative of the air the workers were The lack of suf ficient numbers of health physics supervisors breathing.
prevented enforcement of this policy in some instances.
the following steps have been taken:
To prevent recurrence, High volume air samplers are now in use to allow for more expeditious evaluation of airborne radioactive material.
a.
Lapel air samples have been purchased and are now on site.
b.
They will be utilized as conditions warrant.
Health Physics personnel have been reinstructed in the importance of taking air samples in the breathing zone of workers.
c.
An improved method for obtaining air samples inside the channel head and in the reactor cavity are being developed and will be d.
available for use during the 1980 refueling outage.
Although the stay time log was not maintained according to procedure RAP 6.1-4, several attempts were made to comply with this requirement.
D.3 The reasons that these attempts fell short were lack of sufficient knowledgeable and trained personnel to do this work, changing effective airborne limits during the course of the outage and weakness in the procedure format which made tracking of an individual's MPC hours difficult and cumbersome.
The following items should be noted:
All work inside the steam generator skirts and in the steam generator channel heads was accomplished in supplied air.
a.
From the time that alpha emitting airborne contaminants were detected, all personnel in these work areas were required to b.
wear full face respiratory protection.
Subsequent whole body counts of all departing workers and calculations of MPC hours showed no internal contamination in c.
excess of reportable limits.
17106 318 Four individuals, selected on the basis of high exposure time inside the containment building, were sent to the New York d.
University Medical Center for evaluation by a sophisticated whole body cotnter capable of measuring plutonium deposition.
No significac:. detectable plutonium was detected.
Procedure RAP 6.1-4 has been amended to allow for easier and more A respiratory accurate tracking of MFC hours for individual workers.
protection program is being developed to comply with Reg Connecticut Yankee's whole body counter is now fully operational to allow prompt evaluation of any suspected refueling outage.
internal contamination situation.
(2), unidentified alpha MPC hours were As indicated in Reference Later on when the alpha activity initially used to be conservative.
was identified, the correct MFC hours were used, resulting in moreThe standardized flexibility regarding access to the contaminated areas.
procedures, standardized equipment and health physics staff training corrective action programs address these items.
Connecticut Yankee is therefore in full compliance with 10 CFR 20.103(a)
(a)(3) and (b)(2).
1706 319 INFRACTION 10 CFR 19.12, " Instructions to workers," states, "All individualsbe working in or f requenting any portion of a restricted area shall E.
transfer, or use of radioactive kept informed of the storage, materials or of radiation in such portions of the restricted area; shall be instructed in the health protection problems associated tions with exposure to such radioactive materials or radiation, in precauand in the p or procedures to minimize exposure, of protective devices employed... The extent of these instructions shall be commensurate with potential radiological health protection problems in the restricted area."
individuals working in the restricted area between February 5 and March 1,1979, (particularly those individuals Contrary to the above, ddy working in the Reactor Containment to support steam generator e current testing, reactor cavity and inner annulus decontamination, and steam generator hydrolasing) were not adequately instructed in the health protection problems associated with exposure to radio-active materials or radiation and in precautions or procedures to minimize exposure in that the extent of these instructions were not commensurate with the radiological health protection problems that Workers were not adequately were encountered by these individuals.
instructed at the job sites in the precautionary procedures that they need to take in order to prevent exposure to significantly This high levels of radioactive loose surface contamination.result performance of work. some of which could have been avoided.
This is an infraction (Civil Penalty $3,000).
RESPONSE
The high levels of contamination encountered when the primary system was be opened required that workers be reinstructed in extra precautions to Since there were too few health physics taken in doing their jobs.
supervisors available to accomplish this task, key job supervisors were contacted, informed of the situation and asked to pass the informationThis met wit on to their first line supervisors and workers.
success.
result of these changed radiological conditions, the existingi f
worker training program has been modified to incorporate a discuss on o As a Also, a the potential radiological health hazards they might encounter.
has stricter and more effective method of wearing protective clothing been developed and a demonstration of this method is now a part of the worker training program.
A new radiation worker training program is being developed which will provide information commensurate with the radiological health protection The training will also include " hands on" problems they will encounter. training in the use of protective clothing, respira d
1706 320 The health physics staff training program will ensure that more adequate dialog is maintained with worker crews on job / task and friskers.
A company booklet has been issued specific radiological conditions.
explaining in great detail and putting the risks of occupational exposure In addition the Corporate Psdiological Assessment in perspective. instituted a program of regular meetings with the different company and vendor radiation worker groups to discuss worker risks from Branch has A
radiological controls and radiation area work practices.
in alleviating problems such radiation, more informed radiation worker will assist as those encountered during the outage.
Connecticut Yankee is therefore in full compliance with 10 CFR 19.12.
1706 321 INFRACTION 10 CFR 20.101, " Exposure of individuals to radiation in restricted F.
"Except as provided in paragraph (b) of this section, areas," states, no licensee shall possess, use, or transfer licensed material in to such a manner as to cause any individual in a restricted area in any period of one calendar quarter from radioactive receive material and other sources or radiation in the licensee's possession in excess of...(the following limit):
a dose lens Whole body; head and trunk; active blood-forming organs; of eyes; or gonads.................... 1-1/4 (rems) not to Paragraph (b) permits exposure in excess of this limit, the licensee has exceed 3 rems per calendar quarter provided that determined the individual's accumulated occupational dose to the whole body on Form NRC-4, or on a clear and legible record containing all the information required in that form; and has otherwise complied with the requirements of 10 CFR 20.102, " Determination of accumulated dose."
as of February 15, 1979, three individuals Contrary to the above, received a cumulative whole body exposure in excess of 1-1/4 rems first quarter of 1979, without first having their accumulated during the occupational dose to the whole body determined on Form NRC-4, or on a clear and legible record containing all the information required in that form or otherwise complied with the requirements of 10 CFR 20.102.
This is an infraction (Civil Penalty $3,000).
RESPONSE
large volume of records being processed and a less The combination of a than optimum number of personnel properly trained in radiation records Immediately upon discovery of requirements contributed to this problem.
this situation, additional personnel were assigned and a complete radiation From this record review for all personnel still on site was undertaken.
review it was determined tha no person exceeded the lifetime whole body accumulated dose limit.
The computerized radiation records system will assist HP records personnel to have a more timely control over personnel exposure and it will be The procedure used more extensively to maintain a current NRC-4 form.
for obtaining permission for a person to exceed 1-1/4 rems in a calendar quarter has been modified to require a member of the Health Physics records staff to ensure that the person has a completed Form-4 before additional exposure is authorized.
The Health Physics records staff has added two full time clerks to the coordinator with the administration of the records program.
assist 1706 322 The health physics staff training programs and the use of a select IIP vendor under a 2 year contract will ensure a higher degree of quality control in the lip records area.
Connecticut Yankee is therefore in full compliance with 10 CFR 20,101 and 10 CFR 20.102.
1706 323 INFRACTION 10 CFR 20.203, " Caution signs, labels, signals and controls,"
G.
in Paragraph (f)... "each container of licensed material
- states, clearly visible label identifying the radioactive shall bear a durable, contents...[the} 1abel shall bear the radiation caution symbol and the words " CAUTION, RADIOACTIVE MATERIAL" or " DANGER, RADIOACTIVE It shall also provide sufficient information to permit MATERIAL."
individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures...
the information will include radiation levels, (As appropriate, kiads of material, estimate of activity, date for which activity is estimated, mass enrichment, etc.)."
Paragraph (e) of 10 CFR 20.203 Each area or room in which staces... " Additional requirements.
licensed material is used or stored and which contains any radioactive material (other than natural uranium or thorium) in an amount exceeding 10 times the quantity of such material specified in Appendix C of this part shall be conspicuously posted with a sign or signs bearing the radiation symbol and the words:
CAUTION RADI0 ACTIVE MATERIAL (S)"
Contrary to the above:
15, 1979, three open 55-gallon drums containing On February 1.
pressurizer code safety valves from which radiation was measured to be as high as 400 mrem per hour at contact, and having loose surface contamination as high as 300,000 dpm/100cm, did not bear any label or other information sufficient to permit individuals handling or using the containers or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
2.
On February 15, 1979, the Spent Fuel Building and areas or rooms within that building, in which licensed material was used or stored containing radioactive material in excess of 10 times the quantity of such material specified in Appendix C of this part was not conspicuously posted with a sign or signs CAUTION -
bearing the radiation caution symbol and the words:
RADI0 ACTIVE MATERIAL. Radioactive material stored in that location consisted of 1) three pressurizer code safety valves having radiation levels as high as 400 mrem per hour.
These instances of failure to sufficiently label containers (Civil Penalty -$3000).
and post areas constitute an infraction.
RESPONSE
A delay in communications between the job supervisors and the Health Physics Department allowed the pressurizer code safety valves to be moved from the containment to the Spent Fuel Building without proper labeling and posting precautions being taken.
1706 324 All plant personnel have been reinstructed in the importance of complying with radiological practices and timely notification of Health Physics before moving radioactive material. We have re-emphasized to all station personnel the need to properly label radioactive material and properly post the areas in which it is stored.
Additional staffing and training of HP personnel described in Reference 2 will allow for a more positive control of labeling and posting in the In addition the expanded Radiation Worker training program will future.
alleviate this concern with a better definition of worker responsibilities.
Connecticut Yankee is therefore in full compliance with 10 CFR 20.
203(e) and (f).
1706 325 INFRACTION
- states, Technical Specification 6.11, Radiation Protection Program,
" Procedures for personnel radiation protection shall be prepared H.
consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."
Administrative Procedure No. ADM 1.1-37, Revision 7, approved 1.
December 4, 1978, " Radiation Work Permit Completion and Flow in paragraph 20 of Part 1 of section 5.6.1, Control", states,
" Personnel listed on the RWP initials and acknowledges requirements, complies with instructions on the form."
the following RWPs were not adhered to Contrary to the above, in that the individuals did not initial the respective RWPs to No other indicate acknowledgement of the RWP requirements.
method was used to assure that personnel were aware of the radiological conditions or associated protective requirements for each of the areas.
Number of individuals failing to acknowledge the RWP RWP#
Title 791389
" Eddy Current" 2 Individuals
- 2 S.G.
791385
" Fuel Shuffle" 1 Individual 791401 "RCP Oil Switches" 1 Individual 791397
" Sludge Lance" 3 Individuals
- 4 S.G.
Administrative Procedure No. ADM 1.1-37, Revision 7, approved 2.
December 4, 1978, " Radiation Work Permit Completion and Flow Control," states in paragraph 2.0, "This procedure applies to all personnel who are assigned to work in the CY Radiation Control Area (RCA)."
Radiation Work Permit 792066, issued for work in the RCA to replace the bonnet gasket on RHR-MOV-781, required continuous coverage by health physics technicians.
Contrary to the above, health physics technicians were present only intermittently during the performance of the work.
Administrative Procedure No. ADM 1.1-40, Revision 2, approved 3.
13, 1978, " Radiation Exposure Control," describes the November method used to control and limit personnel exposure at the licensee's facility. The procedure requires:
In section 5.3, that planned exposures in excess of 1000 mrem require the written approval of the Health a.
Physics Supervisor and the Station Superintendent; and i706 326
- b.
In section 5.5, that personnel exposures greater than 2250 mrem per quarter will only be granted in exceptional and unusual circumstances; and c.
In section 5.6, that personnel exposure greater than 2750 mrem shall not be granted.
Contrary to the above, between February 21 and 23, 1979, an individual who had previously been approved for an exposure of up to 2500 mrem, and who already had received an exposure of 2705 mrem for the quarter (based on three film badges already processed plus the Pocket Ionization Chamber value for the most recent time interval) ws3 allowed to enter a high radiation area and received an additional exposure of 160 mrem.
While no regulatory limits were exceedcd, this failure to follow procedure ADM 1.1-40 demonstrates a breakdown in the licensee's program for controlling personnel exposure.
These instances of failure to follow procedures constitute an infraction.
(Civil Penalty $4,000.)
RESPONSE
H.1 All personnel have been reinstructed in the importance of reading, initialing and understanding their responsibilities listed on the RWP before they begin work. Job Supervisors were reminded to check RWPs periodically to ensure compliance. The new Radiation Worker training program will address in more depth these items of worker responsibilities.
H.2 In the future, sufficient numbers of Health Physics technicians will be available to provide continuous coverage where required.
HP staff assigned to completing RWPs have been instructed to ensure that adequate Health Physics coverage is available before allowing a job which requires continuous coverage to start.
H.3 This procedural breakdown was caused by a less than optimum number of trained personnel to process the large amount of exposure information required.
The fully implemented computerized radiation records program and the tightened control over the process of increasing personnel exposure limits will enable us to comply with our administratively imposed limits. The addition of two full time records clerks will help prevent future occurrence of this kind. The standardized procedures and HP staff training program will alleviate this problem.
Connecticut Yankee is therefore in full compliance with Procedure ADMIN 1.1-37, Revision 7 " Radiation Work Permit Completion and Flow Control."
1706 327 DEFICIENCY 10 CFR 20.408, " Reports of personnel monitoring on termination of I.
in Paragraph (b)"... When an individual employment or work", states licensee... or an individual assigned terminates employment with a to work in such a licensee's facility but not employed by the completes work assignment in the licensee's facility, the
- licensee, licensee shall furnish to the Director of Management and Program Analysis, U.S. Nuclear Regulatory Commission, Washington, D.C.
report of the individual's exposures to radiation and 20555, a radioactive material, incurred during the period of employment or work assignment in the licensee's facility, containing information 20.401(a)... [which]
recorded by the licensee pursuant to requires the licensee to maintain records of exposures to radiation for whom personnel monitoring was required; and that such records will be kept on Form NRC-5 in accordance with the instructions contained on that form, including the recording of external exposure (2) skin of the whole body; (3) hands and (1) the whole body; to or (4) feet and ankles... Such information is also required forearms; to be submitted to the individual in accordance with 10 CFR 20.409."
Contrary to the above, as of March 8, 1979, the licensee failed to report to the Commission and to at least five individuals, all of the exposure information that had been determined for inclusion on the individuals' Form NRC-5, in that only whole body exposure was reported for these individuals when in fact the individuals were determined to have received extremity exposure to the hands.
This is a deficiency (Civil Penalty $1,000).
RESPONSE
the time of this inspection, the transition from hard copy to computerized At The task of manually entering skin and records system was in process.
data had not yet been completed for a number of extremity exposure Due to the greatly increased work load during the refueling, individuals.
readings was overlooked on the termination letters.
the absence of thesc All exposure information has now been entered into the computerized increased health physics records staf f will now be records system. The Amended termination able to better adminiater the radiation rerords program.
letters have been sen; to the individuals identified and to the NRC.
Connecticut Yankee is therefore in full compliance with 10 CFR 20.408(b) and 10 CFR 20.409.
1706 328
DOCKET NO. 50-213 ATTACH?ENT 3 HADDAM NECK PIANT EXCEPTIONS TO INSPECTION FINDINGS OF REFERENCE (4)
January, 1980 1706 329
.t.
DETAIL 3.
Advance Planning and Preparation The inspector identified the following in regard to pre-outage licenser's efforts in planning and preparations upon review of the this area:
The station's Health Physics (HP) supervisor was unable to provide sufficient direction regarding planning and preparation a.
due to illness; and was alsc unavailable for the duration of As an interim solution Connecticut the outage for the same reason.
Yankee Atomic Power Company (CYAPCO) Management installed the HP foreman as acting Health Physics Supervisor for the outage.
The inspector reviewed the qualifications of the HP foreman against the qualification requirements identified in Technical Specification 6.3.1.1 which states:
"The position of Health Physics Supervisor shall meet the following minimum qualifications:
Academic degree in an engineering or science field a.
or equivalent as per Section 6.3.1.1.c.
Minimum of five years professional technical experience b.
in the area of radiological safety, three years of which shall be in applied radiation work in a nuclear facility dealing with problems similar to these encountered in a nuclear power reactor, Technical experience in the area of radiological c.
safety beyond the five year minimum may be substituted on a one-for-one basis towards the academic degree requirment (four years of technical experience being equivalent to a four year academic degree),
d.
Academic and technical experience must total a minimum of nine years."
Contrary to part "b" of this requirement, the inspector learned from reviewing the individual's resume and from interviews that the person had three years and one month professional technical experience in the area of radiological safety as of March 1, 1979.
Upon notification, the licensee's representative indicated that the HP foreman was filling this pcsition only until the Health Physics Supervisor returned to duty.
The inspector noted that this area would be reviewed in a subsequent inspection to assure that the situation does not exist for an unreasonable length of time; and that the intent of the requirement is not superseded by unresolved organizational problems (50-213/79-06-01).
- 1706, 330
. Response The HP Foreman, who was acting as HP Supervisor during the outage, had been employed continuously in positions dealing with radiological safety at nuclear power reactor facilities from June 1974 to the date of the inspection (March 1979), a total of four and three quarter calendar However, in evaluating Health Physics technician conformance to ANSI N18.1, the guideline years.
the two year experience requirement to meet used is one " year" equivalent to 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> experience.
This allows for the overtime worked by these individuals and permits fulfillment credit of experience requirement in less than two calendar years.
(February 1975 through While a technician at the Haddam Neck Plant December 1975), the HP Foreman worked 640 hours0.00741 days <br />0.178 hours <br />0.00106 weeks <br />2.4352e-4 months <br /> overtime (nearly four As Health Physics Foreman (January 1976 through March 1979)
" months").
he worked 2,292 hours0.00338 days <br />0.0811 hours <br />4.828042e-4 weeks <br />1.11106e-4 months <br /> overtime, more than one additional " year".
Based on the above information, CYAPCO respectfully requests revision (4) to reflect the facts presented.
cf this aspect of Reference 1706 331 DETAIL No special training was utilized by the licensee to familiarize personnel with the radiological hazards associated with steami 3c.
generator entries, As a result the licensee experienced utilized for such operations.
problems with personnel monitoring and contamination during the duration of steam generator eddy-current testing.
RESPONSE
All ten individuals utilized during steam generator entries had been l d d mock-up given a minimum of four hours of special training, which i t
t r.
Nine of the ten individuals involved had previous experience in steam generator entries at other facilities.
Based on the above information, CYAPCO respectfully requests revision of (4) to reflect the facts presented.
this aspect of Reference 1706 332 DETAIL 5, paragraph 8, page 12.
One worker was contaminated to 90 mrem /hr on his skin and had to undergo He was not given instructions 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> of continuous decontamination.
by any Health Physics technician as to how to remove protective clothing lie was also observed smoking or how to minimize contamination spread.
in the controlled area while his hands were contaminated to 12 mrem /hr, in full view of several Health Physics technicians.
RESPONSE
The worker involved became contaminated because he entered a steam generator before the channel head had been allowed to dry after cleaning.
This was contrary to specific guidelines established for him by his This individual had the special mock up and health physics supervisor.
training described above and had performed steam generator eddy current CYAPCO therefore concludes that he had work on four previous jobs.
proper and adequate training and experience but at the time in question This resulted in the contamination.
chose to disregard that training.
The individual was permitted to smoke only after several decontamination Subsequent whole body counts showed no ingestion of radioactive showers.
material in excess of reportable limits.
Based on the above information, CYAPCO respectfully requests revision of this aspect of Reference (4) to reflect the facts presented.
1706 333