ML20059E934
| ML20059E934 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 08/22/1990 |
| From: | Nichols S Maine Yankee |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| MN-90-80, SEN-90-240, NUDOCS 9009110018 | |
| Download: ML20059E934 (9) | |
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. EDISON DRIVE e AUGUSTA, MAINE 04330 * (207) 622 4868 i
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August 22, 1990-1 1
'MN-90-80 SEN-90-240' l
Region'I UNITED STATES NUCLEAR REGULATORY COMMISSION
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475 Allendale Road-
. King of Prussia, Pennsylvania 19406 l
Attention:
Mr.' Thomas T. Martin, Regional Administrator
References:
(a)
License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to Maine Yankee' dated June 20, 1990
. Inspection Report No. 50-309/90-11
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- (c) USNRC Letter to Maine Yankee dated July-13,1990 Inspection Report No. 50-309/90.
Subject:
1 Response to Notice-of Violation -
I Inspection Report: No. 50-309/90-II, Radiological Controls a
- Gentlemen
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1 A special radiological controls inspection was' conducted and documented with Reference (b)-.- Members of the Maine Yankee staff. met with members of your staff on:
June 27, 1990, to discuss the-r~esultshof.the: inspection.
Reference-(c) documented the-results of our meeting and also contained a Notice of Violation, as Appendix A; J
t This letter responds to the Notice of-Violation.- -In the ~ attachment to this letter,-
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we -have restated the violation and'provided our response.
In addition-to responding'to the NoticeLofL Violation, the cover, letter; off I
Reference (c), requested that our response " provide' specific details regarding the actions that will be or have been taken to improve the consistency of your planning-for and control of radiological work activities." The following actions have -been
.i implemented:
Work planning meetings are being held weekly.- Part of the job planning -
discussions is to assure pro)er radiological controls r. overage is.
available for'each job schedulec.
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Radiological controls supervision utilize a " Plan of the Week" to-assign-
'e radiological controls technicians to specific. jobs.
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9009110018 900822 PDR.ADOCK 05000309 Cl PDC e
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United States Nuclear Regulatory Commission Page Two.
' Attention: -' Mr. Thomas T. Martin-
-MN-90-80
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'e-A Radiation Work Pennit Request Form is required to Le initiated by the t
' requesting department supervisors. The form has been revised to require the work party to provide sufficient information-(in the form of answers to checklist questions) such.that radblogical. controls. personnel mayL l
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better understand the total scope of-coverage required.
In addition, a s
radiological controls supervisor specifies the details of radiological t-controls. support plans, on the Request Form.
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We have hired a new Radiological Controls Section Head' to L fill a previously vacant position.
Also, we have emphasized the need for radiological controls-supervision to spend more time in-the field.
7 observing radiological controls performance, e
We are in the process of; revising our radiological controls technician -
training program to address improvements in job coverage.
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'f Should you have any questions on this matter, please contact us.
Very truly yours, Sfddtbh S. E. Nichols Licensing Section Head s,
$e SEN:SJJ E.
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Attachment:
Response to Notice of Violation 4
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.Mr.:Eric J. Leeds Mr. Charles S. Marschall gg<
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ATTACHMENT i
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NOTICE DE VIOLATION 1 10 CFR 20.201(b) requires ~that each licensee make or.cause to be made such surveys 1
as (1) may be necessary to comply with the regulations in this part, and (2) are
-reasonable under the circumstances to evaluate the extent of radiation itazards that may be present. A survey,. as defined in 10 CFR 20.201(a), is an evaluation of the radiation hazards incident to the production, use, release, disposal or presence of radioactive materials or other sources of radiation under a specific set of conditions and when appropriate, includes a physical survey' of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive material present.
10 CFR 20.101 provides the allowable quarterly occupational radiation exposure values for individuals working in a restricted area.
10 CFR 20.202(a) requires that each licensee supply appropriate personnel monitoring.
equipment to and' require the use of such equipment by each individual who enters a restricted area under such circumstances that he receives or is likely to receive, a dose in any calendar quarter in excess of 25% of the applicable value specified in 10 CFR 20.101(a).
Contrary to the above, the licensee's surveys and evaluations performed to support work on valve PCC-A-216 during the period May 7-17, 1990, were inadequate to ensu m compliance with 10 CFR 20.101 and 10 CFR 20.202 in that:
1.
Three workers, working on valve PCC-A-216 repositioned their bodies during the work activity and the licensee did not make or cause to be made radiation surveys in all locations where the workers repositioned their bodies. As a result, three workers unknowingly lay across a grating with measured contact radiation levels up to 180 mR/hr and received unplar.ned, unmonitored radiation exposures ranging from about 550 millirem to about 1600 millirem.
2.
On the evening of May 17, 1990, at about-9:00 p.m.,
a contractor ALARA technician was informed that workers, repairing valve PCC-A-216 may have been unknowingly exposed to radiation fields in excess of 100 mR/hr, however the individuals were permitted to return to work on valve PCC-A-216 without first deterr..ining their total whole body dose and their remaining quarterly radiation exposure value.
L 3.
Three workers, working on valve PCC-A-216, received unmonitored radiation exposures to the lower portions of their whole bodies in excess of 25% of the applicable value in 10 CFR 20.101 because they were not provided L
appropriate personnel monitoring equipment.
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' MAINE YANKEE RESPONSE 1
-Upon identification of the elevated radiation levels coming from the floor trench,.
a contract ALARA technician investigated the matter. He discussed the work scope and duration with the workers and surveyed the area.
At that time, he concluded that
,e work could continue provided the workers did not lay across the floor trench.
In i
subsequent discussions with the ALARA technician, it was determined that he based this decision on the short amount of time needed to complete repairs on PCC-A-216,.
1 the low dose area away from the trench, and his view that less, exposure would be received by the current workers than would be received if a new crew were assigned to complete the job.
The workers' dosimetry.was processed following completion of their shift. The work area was resurveyed and posted.
Maine Yankee initiated a Radiological incident Report, the highest investigation / reporting mechanism in the radiological controls area.
The results of this investigation and our short and long term corrective actions have been discussed with the NRC.
The root cause of this event was determined to be inadequate communication between the working party and the assigned radiological controls technic 6 Specifically, hed with the.
the radiological controls and work permits (RWP) were understanding that work would be performed above and besidt The work scope changed which necessitated valve disassembly. This chan, municated between the workers and the radiological controls techniciano p
1.
Corrective steps which have been taken and the results achieved:
Immediate corrective measures included stopping the uork, resurveying and posting the work
- area, and. processing tne workers' dosimetry.
Additionally, all parties involved were iderviewed and.n Radiological Incident Report was prepared.
The workers' doses were calculated and determined to be witP ' 10 CFR 20 limits.
The event was subauently discassed at shift turnover meetings and included in night orders.
Tne radiological hazr.eds presented by floor trenches was also discussed. Worker briefings tere held concerning good communications to ensure proper understanding of job scope and process.
l The - Radiological Incident Report has been forwarded to Training for inclusion in general and radiological controls technician training.
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2.
Corrective steps which will be taken to avoid further violations:
A radiation work permit (RWP) request form checklist has been developed for use in establishing' radiological controls for work activities. This.
form requires the requestor indicate the planned job evolutian before the start of work so that proper radiological control measures can be established. Also, Procedure 9.1.1, " Plant Radiological Surveys," will be revised, by September 15, 1990, to include surveying floor trenches-adjacent to work areas when performing RWP surveys.
Finally, we will train lead valve workers in use of survey meters, for the next refueling outage (Fall 1991).
3.
Date when full compliance was achieved:
e Full compliance was achieved upon stopping the work, resurveying and reposting the work area, and completing discussions of conditions with the l
workers involved on May 18, 1990, h
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NOTICE OF VIOLATION 2 Technical Specification 5.12.1 states that in lieu of the control device or alarm:
signal required by paragraph 20.203. (c)(2) of =10 CFR Part 20, each High Radiation-Area in which the intensity of radiation is at such levels that-a major portion of-
'the body could receive in any one hour a dose in excess of 100 millirem shall be barricaded and conspicuously posted as a High Radiation Area and entrance thereto 1
shell' be. controlled by requiring issuance of a radiation work permit (RWP).
Any individual' or group of individuals permitted to enter such areas shall be provided -
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with or accompanied.by one or more of the following:
t A radiation monitoring device which continuously indicates the raciation-dose rate in the area.
a A radiation monitoring device which contin"ously integraMs the radiation dose rate in the area and alarms wher, a preset inurated dosu is received.
Entry into such areas with this monitoring device may be made
. l after tbs dose rate levels in the area have been established and, personnel have been made knowledgeable of them.
A radiological controls qualified individual (i.e., qualified in radiation 1
l 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 a frequency specified in the RWP.
L RWP.No. 90-1144 specified, in Section IV, High Radiation Area Controis-Technical Specification 5.12, that radiation protection coverage was to be performed every 60-minutes.
. Contrary to the above, three workers, working under the provisions of RWP No.' 90-Il44' during the period May 7-17, 1990, for repair.of valve PCC-A-216 worked in_ a High -
Radiation Area and the three workers did not have a continuously indicating dose rate-meter, did not have an integrating alarming dosimeter or radiation surveillance was not performed every 60 minutes by a radiological controls. qualified individual with a radiation dose rate monitoring device.
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MAINE YANKEE RESPONSE 2
' At the time the RWP was prepared, the technicians responsible for covering work on
' PCC-A-216 understood the radiation fields around the valve were less than 50 mR/hr.-
Start of shift surveys.and hourly: checks of dosimetry confirmed these dose levels.-
In order to keep his dose ALARA, the contract technician covering the job elected to rescin in low dose areas and check hourly dose levels by calling to the workers.<
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. This practice is no longer used at Maine Yankee.
b 1.
Correctiva steps which have been taken and the results achieved:
Immediate corrective measures were as discucsed in response to Notice of r
L Violation 1.
The event was discussed at shift turnover meetings and included in night orders.
We also revised Procedure 9.1.10, " Radiation Work. Permits", to define. " radiation surveillance" and-to require radiological' controls-technicians to enter work areas to check workers' dosimeters and' verify survey results.
L 2.
Corrective ~ steps which will be taken to avoid further violations:
7 We will evaluate dedicated technician coverage by October 1991 and train-leac' valve workers, per response to Notice of Violation 1.
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Date when full compliance was achieved:
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. Full compliance was achieved upon stopping the work, resurveying and reposting the work area', and completing discussions of conditions with the workers involved on May 18, 1990.
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y N0TICE OF VIOLATION 3 10 CFR '19.12 states, in part, that all individuals working in or frequenting any portion of a restricted area shall-be kept informed of the storage, transfer, or use of radioactive materials or radiation in such portions of the restricted area and in precautions or procedures to minimize exposure.
Contrary to the above, three workers, working in a restricted area on valve PCC-A-216 during the period May 7-17, 1990, were not-adequately informed of precautions or procedures to minimize their exposure. During the work activity, the three workers unknowingly moved out of the immediate vicinity of their work location, _ whose radiation levels were well known, and lay across an area (a grating) that had not been surveyed and as a result received unplanned, unmonitored radiation exposures-ranging from about 550 millirem to about 1600 millirem.
MAINE YANKEE RESPONSE 3 The root cause of this event is similar to that of item 1.
Also, a work party leader was not identified for the PCC-A-216 repair.
The work party leader is responsible
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for communicating changes in job scope.
1.
Corrective steps which have been taken and the results achieved:
Immediate corrective measures were as discussed in response to Notice of Violation 1.
l 2.
Corrective steps which will be taken to avoid further violations:
The event was discussed at shift turnover meetings and included in night orders.
Worker briefings were held concerning good communications to ensure proper understanding of job scope and process.
Procedure 9.1.10
" Radiation Work Permits," has been revised to rcquire identification of ~
the Work Party Leader.
A Radiation. Work Permit Request Form has been revised to include the radiological controls support plan for the job.
The Pre-Job Briefing form has been-revised to define a change in work
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scope. as a " change in-position, location, method of work, system l
barrier / breach, time to complete work."
Finally, the Radiological-Incident Report has been forwarded to Training for inclusion in training programs.
3.-
Date when full compliance was achieved:
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Full compliance was achieved upon stopping the work, resurveying and L
reposting the work area, and completing discussions of conditions with the I
workers involved on May 18, 1990.
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-N0TICE OF VIOLATION 4 L
' Technical Specification 5.ll.1-requires that procedures for personnel radiation-protection be prepared consistent with the requirements of 10 CFR 20 and be approved, q
maintained and adhered to for all operations involving personnel radiation exposure. -
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Radiation Protection Procedure No. 9.1.10, Revision 26, states in Section y'
- 6,1.8 that stay times shall be specified under Section V (of the RWP).
Contrary to the above,Section V of RWP No. 90-1144,. used for repair of' valve PCC-A-216, did not include stay times.
2.
Radiation Protection Procedure No. 9.1.10, Revision 26, states in Section 6.7.1-that workers must read, understand, and comply with the radiation-work permit exactly as written. Radiation work permit No.. 90-1206, Vent' "j
and Drain Penetrations in the Letdown Area', stated that a respirator is required if in the area of venting and. draining.
In addition, the radiation work permit-(90-1206) stated that an air sample was required during opening of a system.and while venting and draining.
Contrary to the above, an operator, draining valve PR-42,-located in the letdown area, on May 15, 1990, during the period 4:40 a.m. to 5:30 a.m.,
did-not wear a respirator when in the area of=the venting and draining.
The operator spent at least 5 minutes in the area uncapping the vent and drain lines, performing radiation measurements of the trench in which the Lliquid was released directly under the drain line, and recapping the vent 1
and drain line.
In addition, no air sample was collected during the venting and draining.
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MAINE' YANKEE RESPONSE 4 Proceduro 9.1.10 Section 6.1.8 specifies that stay. nes be entered under Section V.
'The procedure further' indicates that stay tipes a established so that workers do
-not exceed allowable ' exposure limits.
When RWF No. 90-1144-was prepared, the technicians had not--identified the elevated dose coming from the floor trench and J
therefore did-not believe the work activity would challenge the workers' exposure
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limits, and a stay time was not prescribed.
With regard to the venting and draining operation, the operator entered the work area.
on a general Operations Department RWP. At the time he read the RWP he understood 1
that azrespirator was required if he were present in the area during' venting.and draining. The operator has stated that once he opened PR-42 and began draining the line, -he immediately left the area.
The operator believed he met - the RWP requirements because he was not in the area of venting and draining. In retrospect we recognize the unique hazards associated with venting and= draining potentially a
contaminated lines, and we do not believe that general RWPs are approprtate for these activities.
1.
Corrective steps which have been taken and the results achieved:
The event was discussed at shift turnover meetings and included in night orders. The Radiological Corf rols and Operations departments issued night orders concerning Radiation Work Permit compliance.
Procedure 9.1.10,
" Radiation Work Permits," was revised to clarify the requirement-for specifying stay times when required. Procedure 9.1.10 was further revised to require a separate Radiation Work Permit for each venting and draining evolution.
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M' RWP^ compliance will continue. to be-stressed 'during training.- - Generic
- guidance-for
- venting. and draining systems. will' be. developed by
' November 30,.1990.
3.
D' ate when full compliance will be achieved:
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Full = compliance was achieved with the worker briefings and;the procedure
. change -on July 31,.1990.'
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