ML19347A492
| ML19347A492 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 01/29/1979 |
| From: | Bores R, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19347A487 | List: |
| References | |
| 50-029-78-21, 50-29-78-21, NUDOCS 7904210020 | |
| Download: ML19347A492 (15) | |
Text
O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 2 port No.
50-29/78-21 Docket No'.
50-29 License No.
DPR-3 Priority Category C
Licensee:
Yankee Atomic Electric Company 20 Turnoike Road Westborough, Massachusetts 01581 Facility Name:
Yankee Nuclear Power Station Inspection at:
Rowe, Massachusetts Inspection conduc+ed:
November 27 - December 1, 1978 Inspectors:
/-R9-79 R. J. BdFes, Radiation Specialist date signed date signed
- cate signed Approved by:
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'74 J. P/ Sfohr, Thief. Environmental and date signed Spe61al Projects Section, FF&MS Branch Insoection Summary:
Insoection on November 27 - December 1,1978 (Recort No. 50-29/78-21)
Areas Insoected:
Routine, unannounced inspection of emergency planning and the environmental monitoring programs for operations.
For emergency planning, the areas inspected included:
licensee coordination with offsite support agencies; emergency facilities, equipment, instrumentation and supplies specified in the Emergency Plan and Implementing Procedures; training of emergency personnel; Emergency Plan and Implementing Procedures; 'icensee records relating to emer-gency drills; the licensee's management c:ricrols in the area of emergency planning; and licensee action on unresolved items noted in previous emergency planning in-spections.
For the environmental monitoring inspection, the areas inspected in-cluded:
the management controls for these programs; the licensee's program for quality control of analytical measurements; implementation of environmental moni-toring programs; nonradiological effluent release rates and limits; plant secondary releases; and a followup on licensee action on pr'evious environmental inspection - ~ -
'ndings. The inspection involved 35 onsite inspector-hours by one regionally
. sed inspector.
Region I Form 12 (Rev. April 77) 7904210Oao
t inspection Sumary:
Results: Of the 12 areas inspected,
..o items of noncompliance were found in nine areas.
Three apparent items of noncompliance (Infraction - failure to establish adequate procedures - Details, 4; Deficiency - failure to follow procedures /
training - Details, 6; Deficiency - failure to follow procedures / calibration -
Details, 5) were identified in three areas.
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DETAILS 1.
Individuals Contacted Yankee Nuclear Power Station (YNPS)
- H. Autio, Plant Superintendent
- N.
St. Laurent, Assistant Superintendent
- R. Aron, Technical Assistant
- W. Billings, Chemistry and HP Supervisor J. Trejo Health Physicist D. Rice, Environmental Supervisor
- G. Babineau, Engineering Assistant
- E. Miles, Health and Safety Supervisor W. Howe, Chief of Security J. Shippe I&C Supervisor W. Meyers, Engineering Assistant K. Jurentkuff, Shift Supervisor F. Hicks, Training Supervisor L. Laffond, Training Coordinator Yankee Atomic Electric Comoany - Corcorate
- D. Holsinger, Engineer - Emergency Plar.ning
- L. Reed, Operations Quality Assurance Department P. Littlefield, Manager, Radiological Engineering Department J. Jew, Engineer, Radiological Engineering Department Other Personnel G. Parker, Director, Radiation Control Programs, Massachusetts D. Scott, Health Physici.it, Division of Occupational Health, Ver=ont L. Corse, President, Whitingham (Vermont) Ambulance Service C. Roy, Supervisor of Nursing, North Adams (Massachusetts) Regional Hospital The inspector also interviewed several other licensee personnel of the operations, health physics and security staffs.
denotes those present at the exit interview on December 1,1978
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Bureau of Radiation Control Programs, Massachusetts Department of Public Health Division of Occupational Health, Vermont State Department of Health Whitingham (Vermont) Ambulance Service North Adams (Massachusetts) Regional Hospital These discussions verified that the existing agreements between the licensee and these agencies remain in effect, and that the licensee's contact and coordination were adequate for these agencies to maintain an effective response capability.
No items of noncompliance were identified in this area.
(See Details, 6, however, for a related matter.)
4.
Facilities and Equipment The inspector examine 1 facilities, equipment and instrumentation to verify that items spec;fied in the licensee's Emergency Plan and Im-plementing Procedures were available for use and maintained in an operable state. The in;pection included examination of: a selection of four items of emergency communications equipment; radioactive re-lease monitoring instrumen":s - area and process monitors, and mete-orological instruments; medical treatment / decontamination facilities, both onsite and at the local hospital; three emergency equipment kits; and the primary emergency coordination center (ECC) and associated supplies and equipment.
The inspector's review cf this area indicated that the rcquired faci-11 ties, equipment and instrumentation were present and operable with h
the following exception. Two dosimeter chargers in the ECC emergency kit and one dosimeter charger in the Control Room emergency cabinet were inoperable at the time of inspection. The licensee stated that these instruments had been operable earlier in November,1978, during the monthly inventory and in October,1978, for use during the site emergency drill.
Prior to the completion of the inspection, these dosimeter chargers were sent to the I&C Department for repair. The inspector had no further questions regarding this item at this time.
The inspector noted that the licensee's instrumentation for emergency air sampling and analysis consisted of 301pm air samplers, particulate filters and charcoal cartridges, and G-M detector /ratemeter detection instruments. The inspector determined through the review of Procedure OP-3303, Revision 3, " Emergency Off-Site Radiation Monitoring"; evalu-ation of the available instrumentation with a Ba-133 check source; and
3 2.
Licensee Action on Previous Inscection Findings (0 pen) Unresolved Item (77-04-01): Meteorological Monitoring Procedures Review and Approval.
The inspector determined through discussions with the licensee and review of contractor cali-bration records, that the licensee's calibration procedures had not yet been finalized in the licensee's standard procedure for-mat, reviewed and approved. The licensee stated that since the last inspection, changes had been made in the instrumentation and in the meteorological contractor. Consequently, the procedures i
for the new equipment / contractor were not yet finalized / approved.
'The licensee stated that by January 1,1979 this would be ac-complished. The inspector stated that until the procedures are finalized, reviewed and approved by the licensee, and are sub-sequently reviewed by the NRC, this item remains unresolved.
(See also Details, 12.e)
(0 pen) Unresolved Item (77-04-02): Approval of Enviromental Ana-lytical Procedures. The inspector detennined through discussions with the licensee and review of the procedures, that the analytical procedures had not yet been reviewed and approved. The licensee stated that this would be dona in conjunction with the new 10 CFR 50 AppeMix I, Technical Specification requirements. The inspector stated that until the review and approval are performed, this item remains unresolved.
(See also Details, 12.d)
(Closed) Unresolved Item (77-25-01): Clartfication of Instituted Drill Program. The inspector determined through the review of the current procedures, AP-0503 " Fire Protection Training Procedures" and OP-3307 " Emergency Preparedness Exercises / Drills" and discus-
- sions with licensee personnel, that the frequency of emergency drills to be conducted and the degree of offsite agency participation have been clarified through procedural modifications.
The inspector had no further questions in this area at this time.
3.
Coordination with Offsite Agencies The inspector reviewed records, procedures and written agreements re-lating to the licensee's coordination of emergency planning with agencies listed in the Emergency Plan and Implementing Procedures.
The inspector discussed this subject with licensee representatives and persons of the following offsite-agencies:
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discussions with the licensee, that the above combination of pro-cedures and equipment was inadequate for the licensee to measure an air iodine concentration of 1 X 10-8 microcuries/cc or less (<100 MPC). Procedures OP-3300, OP-3301 and OP-3302 establish airborne activity levels of < 1 X 10-10 (MC); 1 X 10-10 to 1 X 10-9 (10 WC);
and > 1 X 10-9 (10 MPC) microcuries/cc, at the site boundary as respective parameters for defining local, site and general emergencies.
The Emergency Plan requires notification of authorities at levels of 1 X 10-9 microcuries/ce.
In addition, specific action reconnendations are to be made to civil authorities if levels exceed 1 X 10-8,1 X 10-7 or 5 X 10-7 microcuries/cc for specified anticipated durations.)
The inspector stated that the failure to have adequate procedures to l
measure established action levels of the Emergency Plan was in noncompliance with Technical Specification 6.8.1, which requires, in part, that procedures be established and followed for implementing the Emergency Plan - ANSI N18.7-1972, Section 5.3.8.3 (78-21-01).
(See Details, 5 for a related item.)
The inspector noted that instrtanentation was adecuate to measure the action levels based on direct radiation.
5.
Calibration, Inventory and Operational Checks of Emergency Ecuioment The inspector reviewed a sampling of calibration, inventory and opera-tional check records covering the period October 1977 thrc"gh November 1973 for the emergency response equipment listed in the Emergency Plan and Implementing Procedures. Records reviewed covered survey in-strument calibration, emergency equipment inventories / checks, emer-gency personnel dosimeter calibrations, emergency kit radio checks, and meteorological instrumentation calibration.
The inspecter discussed with the licensee the methodology and results of calibration of the emergency kit instruments for analyzing charcoal cartridges and particulate filters. Tne insoector noted that the methrd of " spiking" the charcoal cartridge with I-131 for use in cali-brating these instruments would have resulted in elemental iodide being collected on the surface of the charcoal.
This could result in an overestimate of the actual counting efficiencies.
The calibration of the instruments for particulate activity was.also discussed, in
' that, the source used was a plated source of smaller dia.eter than the particulate filters, and was " standardized" in tenas of " emissions /
second in 2r geometry" The licensee's practice was to assume tiat the actual source strength was then twice the 2r emission rate. The inspector noted that this would tend to underestimate the actual detector efficiency _since the 2r emission rate also includes back-scattered betz emissions. The_ licensee.s.tated that the calibration of _.
the instruments for both the particulate and iodine cartridges would be reevaluated. The inspector stated that this. item will be considered M
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l unresolved pending completion of this evaluation and subsequent review of the evaluation /results by the NRC (78-21-02).
The inspector's review of personnel dosimeter calibration records i
indicated that the last calibration of personnel dosimeters for 'use in the emergency kits was performed on June 2, 1977. Dosimeter records examined included those for 50 R dosimeter Nos. 50-292, 50-297, 50-299, 50-306, 50-210 and 50-305 and for 200 R dosimeters 200-131 and 200-138. The latter dosimeters, as indicated by the records were last calibrated on June 1,1977. The inspector noted that Procedures DP 85-50, Revision 3 and OP-480A require that dosimeters used in emergency kits be calibrated on an annual basis.
The inspector stated that the failure to calibrate the above dosimeters in accord with the procedures was in noncompliance with TS 6.8.1 and 6.11 (78-21-03). The inspector noted that prior to his leaving the site on December 1,1978, the licensee was in the process of recalibrating these dosimeters.
1 The review of this area indicated that with the exception of the items discussed..above, the licensee had maintained and checked emergency related equipment as required.
6.
Training The inspector reviewed training related documentation and procedures and interviewed six persons assigned to the licensee's emergency organization to verify that training required by the Emergency Plan and Implementing Procedures had been conducted. Training since October 1978 included sessions for general employees, emergency co-ordinators, emergency directors, fire brigades, offsite teams, emer-gency security personnel, medical first aid teams, hospital and ambulance personnel and fire department personnel.
The inspector noted that Section 8 of Procedure AP-0504 requires both formal and practical demonstration training programs for emergency organizations specified in Section A of AP-0504 on an annual basis.
The inspector noted that one of the specified organizations, Road 8arrier Teams, had received no formal or practical demonstration training during the previous year.
Team members were asked to review the applicable procedures / portions of the Emergency Plan and to sign their names to acknowledge that the review was perfonned. The inspector stated that the training received was not in accord with Procedure AP-0504, and consequently, wat in noncompliance with TS 6.8.1.
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7 The inspector also noted that Section E, Procedure AP-0504 requires that the Vermont and Massachusetts Departments of Health (Radio-logical Divisions) be invited to attend Emergency Coordinator re-fresher training on an annual basis. The inspector determined that the respective Departments of Health from Vermont and Massachusetts had not been invited to attend the Emergency Coordinator Training in 1978. The inspector stated that this also constituted an item of noncompliance with TS 6.8.1 (78-21-04).
The inspector also discussed with the licensee the lack of clarity in documenting emergency training conducted; specifically, for emergency directors, whose Emergency Plan Training is included in the operator requalification training, but without documented lesson plans; and for ambulance and hospital personnel, whose training records are not maintained onsite. The licensee stated that the documentation of training would be reviewed.
The inspector determined that except as identified above, the required training had been provided.
7.
Emergency Orills The inspector reviewed the records of the radiation emergency and medical emergency drills conducted since the previous emergency plan-ning inspection. The inspector determined that the required drills had been conducted and involved the coordination with and participation by the North Adams Regional Hospital and the Whitingham Ambulance Ser-vice.
The inspector determined that the licensee used qualified personnel to evaluate the organization's response; critiques were held during which discussions highlighted' improvement possibilities; and appropri-ate actions had been initiated or completed to correct any areas needing improvement.
The inspector also reviewed the licensee's followup of any items identified during the 1977 radiation emergency and medical drills. The inspector verified that appropriate evaluation and re-solution of drill identified improvement items had been initiated or completed.
No items of noncompliance were identified.
8 8.
Emergency Plan and Implementing Procedures
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l The inspector reviewed and evaluated any changes to the Emergency l
Plan and Implementing Procedures and detennined that the revised j
l Plan and procedures provided the same or/ higher degree of pre-l paredness than the previous ones and that the changes had been l
reviewed and approved as required. The inspector noted that the revised procedures more clearly defined the frequencies for con-i ducting emergency drills and defined the required training programs.
l No items of noncompliance were identified.
l 9.
Management Control - Emergency Planning a.
Established / Documented Procram The inspector reviewed procedures, applicable technical speci-fications and held discussions with responsible licensee personnel l
and verified that a clearly defined program of management control over emergency planning activities had been established. This program consists of: the delineation of planning responsibilities and authorities; provisions for periodic review, audits and updates l
of Emergency Plan implementation; and delineation of responsibility l
for overall conduct of reviews, audits and updates.
b.
Reviews and Audits The inspector reviewed a report of an internal licensee audit covering the Emergency Plan and Implementing Procedures conducted August 29-31, 1978. This review indicated that the licensee had identified several items requiring action.
Further review in-dicated that all licensee audit findings for 1977 and 1978 relative to emergency planning had been evaluated and resolution was either complete or in progress.
No item. of noncompliance were identified in this area.
- 10. Management Controls - Environmental Monitoring a.
Changes Through discussion with licensee personnel, the inspector reviewed the licensee's organization responsible for managing the environmental programs, applicable procedures, and any changes made in the following areas since the last environmental inspection:
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(1) Assignment of responsibility and authority; (2) Provisions for audits and inspections of environmental activities; (3) Provisions for identifying, documenting and reporting, correcting and following up on program deficiencies and inspection / audit results; and l
(4) Review of program results.
The following changes were identified and reviewed by the inspector:
(1) Mr. J. Jow, Engineer, Yankee Atomic Electric Company has assumed the responsibility for review of the en-vironmental programs and preparation of environmental radiological reports, replacing Dr. Desrosiers.
(2) All radiological environmental analyses were perfonned by the Yankee Environmental Services (YES) Laboratory beginning in October 1977. Prior to this time, these analyses were perfonned by Teledyne Isotopes, Incorporated.
l (3) Meteorological instrumentation calibrations and data evaluations are performed by TRC (The Research Corpora-tion of New England) beginning with the second half of 1978. The services were formerly performed by Environ-mental Research and Technology, Incorporated (ERT).
No changes were identified which would result in a decrease in the overall effectiveness of the management controls.
b.
Licensee Audits / Inspections The inspector determined that no formal audits / inspections were perfonned by the licensee of the Yankee (Rowe) environ-mental programs. The' inspector noted that the licensee had no specific requirements in this area at this time.
I The licensee stated that a contractor had just completed an l
audit of the YES Laboratory, but had not yet submitted the i
findings to the licensee. The licensee also stated that audits j
of the entire environmental program would be evaluated for im-i plementation in the near future.
The inspector had no further questions in this area at this time.
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- 11. Licensee Program for Quality Control of Analytical Measurements The inspector determined through discussions with licensee personnel, review of appropriate procedures, and review of program results since the end of 1976, that the program had provisions for the:
a.
Assignment of responsibility to manage and conduct the program; b.
Type and minimum number of quality checks; c.
Acceptance criteria for measurement results; and d.
Followup on identified program inadequacies.
The inspector determined that the program had been operated in ac-cordance with Procedure OP-8600, Revision 3.
The results of the program indicated that samples of media, including water, milk, food, sediment and aquatic plants, were split and sent as blind duplicate samples to the YES contractor for such analyses as, gy:ma nuclides, tritium, Sr-89, Sr-90 and I-131.
The results of this program were reviewed by the licensee with respect to established acceptance criteria. With few exceptions, the laboratory results met the acceptance criteria. When exceptions were identified, appropriate actions were taken by the licensee to resolve the discrepancies.
The inspector noted that the YES Laboratory also had an internal quality check program which included appropriate standards, spikes and blind duplicate samples.
YES also provided acceptance based on documented criteria and provided for actions to resolve discrepancies.
The inspector had no further questions in this area.
12.
Implementation of the Environmental Monitoring Program a.
Direct Observation The inspector examined selected air sampling and TLD monitoring stations during a portion of the routine weekly air filter change and collection route. The inspector noted that the selected stations were located as required by the Technical Specifications (TS) and were operating at the time of inspection.
11 b.
Review of Reports (Annual)
The inspector reviewed the Yankee Rowe Radiological Environ-mental Surveillance Report - January 1,1977 to December 31, 1977. The inspector determined that the licensee had complied with the requirements of the TS in terms of environmental sampling frequencies and locations, measurements, evaluations and reporting schedules for this time interval.
c.
Other Records (1) Thermoluminescent Dosimeters (TLDs)
The inspector-reviewed the results of the 1978 environ-mental TLD measurements to the date of inspection.
The inspector discussed the TLD calibration, deployment and read-out procedures with the licensees The inspector also examined the results of the. licensee's study conducted to determine whether the air sampler shelters prnvide significant radiation shielding to TLDs kept inside them.
The study indicates that there was no significant difference between the environmentally exposed TLDs inside and outside the air sampler shelters, based on a paired
't-test' analysis at the 95% confidence level.
9 No items of noncompliance were identified in this area.
(2) Air Sampling The inspector reviewed the records of the air monitoring program for 1978 to the date of inspection and identified no items of noncompliance in this area.
In discussions with the licensee, the inspector determined that air filters are no longer counted inplant prior to sending them to the YES Laboratory for analysis.
This eliminates one potential source of cross-contamination of samples.
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The inspector also determined that the licensee has an j
established program for calibration of dry gas meters and maintenance of sampler systems.
The inspector had no further questions in this area.
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12 (3) Other Media The inspector reviewed the records of data analyses for other environmental media including: milk, water, vege-tation, fish, soil and river sediments since the beginning of 1978. The inspector found no instances in which required samples were not collected or analyzed as per the TS.
The licensee stated that the use of more specific sample medium identification, such as, fish species, type of v'.getation, kind of food crop, etc., in order to establish some specific radiological levels to which previous or future measurements can be compared, would be evaluated.
The inspector had no further questions in this area at this time.
d.
Environmental Sampling and Analytical Procedures The inspector reviewed the current environmental sampling pro-cedures and noted that all required sample media were included.
With respect to the environmental radioanalytical procedures, the licensee provided the inspector with copies for review.
The inspector determined through discussions with the licensee that procedures had not been formally reviewed and approved by the licensee. The inspector noted that this had been identified as an unresolved item during the last inspection of this area (77-04-02), ed that this item remains unresolved. The licensee stated that ti e mechanics of reviewing / approving these procedures would be evaluated and appropriate actions will be taken.
e.
Meteorological Surveillance The inspector examined the meteorological instrumentation read-out panel in the control room and noted that all of the required meteorological parameters were being collected at the time of in-spection. The inspector noted that several of the recorder strip charts were not adjusted to reflect the correct time of day.
(One of the charts was approximately four hours out of sequence.) The inspector also observed that a notice had been posted at the panel,
t 13 cautioning the operators to properly adjust the chart times.
The inspector discussed with the licensee the importance of having correct times on the charts, especially for those instances in which the computer is inoperable and the charts must be read and correlated manually. The licensee stated that further instructions will be given to the operators in this area.
The inspector reviewed the meteorological instrumentation cali-brations performed since 1978. The inspector also noted that formal calibration procedures had not yet been established and that the last calibration was performed using draft procedures by TRC. The licens.ee stated that the reason for lack of formal procedures at this time was due to the changes in instrumentation and contractor in June 1978. The licensee further stated that these procedures would be formalized and approved by January 1, 1979. The inspector noted that this had been left unresolved during the last inspection of this area (77-04-01). The in-spector stated that this item would remain unresolved pending completion of the above actions and subsequent review by the NRC.
The inspector examined meteorological data for selected time intervals during 1977 and 1978 to assure that all operating /re-porting requirements were met. The inspector determined through the correlations between the analon recorder data and comouter
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listings, that for those intervals examined, all of the require-ments were met.
13.
Nonradiological Effluent Release Rates and Limits The licensee conducts chemical and thermal monitoring of effluents in accord with the requirements of their NPDES (federal) and state discharge permits. The inspector examined selected discharge records for 1977 and 1978 with respect to frequency of measurement, types and measurement and limits imposed on the licensee.
For those records examined, no instances of nonconformance with the requirements were found.
14.
Plant Secondary Leakage During the course of the environmental inspection, the inspector noted that the H-3 levels in the West Stonn Drain were elevated relative to the other storm drains. The licensee stated that this was due to the steam jet air ejector (SJAE) condensate releated via this pathway. The licensee also stated that during the current outage, the SJAE condensate line was rerouted to the circulating cooling water seal pit. Further r
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i 14 examination in this area also indicated other secondary system drains / leaks also drained to the West Storm Drain.
In order to establish the quantity and concentration of this leakage to the storm drain system, the inspector examined available analyses of the secondary cooling system water and discussed system water balance.
(No direct measurements were made of the SJAE blowdown or other secondary side losses other than steam generator blowdown.)
The licensee stated that the secondary cooling water is routinely analyzed (typical H-3 levels are lE-4 vCi/ce) and the discharges of H-3 are accounted for by assuming that the total volume of the daily makeup to that system (about 15,000 gallons) is discharged.
More than one-third of the loss is accounted for by the steam generator blowdown which is monitored. The inspector determined through discussions with the licensee and review of available records, that the current record system at Yankee Rowe does not account for H-3 discharges from the secondary side, other than from steam generator blowdown. The licensee stated that this was an oversight and that the effluent records program would be modified to include the balance of secondary H-3 discharges. The inspector noted that the current TS were not specific in this area; that the concentrations of H-3 in the West Storm Drain were well within the NRC limits; and the total H-3 releases from the secondary system were only a couple of percent of the total Yankee Rowe releases.
The inspector stated that until the effluent records program was modified to account for all the secondary system losses, this item is considered unresolved (78-21-05).
- 15. Unresolved Items Unresolved items are matters about which more inform 6 tion is re-quired in order to ascertain whether' they are acceptable items or items of noncompliance. Unresolved items disclosed during this inspection are described in Details, 2, 5, 12.d, 12.e and 14.
- 16. Management Interview On December 1,1978, the inspector met with licensee representa-tives (denoted in Detail,1) at the conclusion of the inspection.
On December 15, 1978, a telephone discussion was held between Dr.
Bores and Mr. J. MacDonald of Yankee Atomic Electric Company.
On January 9,1979, a telephone discussion was conducted between Dr.
Bores and Mr. Autio.
15 During these meetings / discussions, the purpose and scope of the inspection were sumarized and the inspection findings, including each item of noncompliance and unresolved item was discussed.
With respect to the item of noncompliance (78-21-01) - failure to have adequate procedures / equipment to implement a portion of the Emergency Plan, the licensee stated that the Emergency Plan and Implementing Procedures would be revised along the lines of the EPA Protective Action Guides.
In the interim, procedures would be modified to enable air samples to be analyzed in plant (if accessible) or at Vermont Yankee Nuclear Power Plant to insure required sensitivities are met.
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