ML20059N463
| ML20059N463 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/02/1990 |
| From: | Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Frizzle C Maine Yankee |
| References | |
| NUDOCS 9010160012 | |
| Download: ML20059N463 (2) | |
See also: IR 05000309/1990011
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DCT 0 21993
Docket No. 50-309
Maine.Yaakee Atomic Power Company
ATTN: Mr. Charles D. Frizzle-
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President,
83 Edison Drive
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Augusta, Maine 04336
Gentlemen:
Subject:
Inspection No. 50-309/90-11
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This refers to your letter dated August 22, 1990, in response to our. letter
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dated July 13, 1990.
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Thank you for informing us of the corrective and preventive actions documented.
in your letter. These actions will be examined during'a_ future: inspection of
your licensed program.
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Based on a September 5,1990, telephone conversation between Mr. G.' Pillsbury
of your staff and Mr. R Nimitz of this office and a September 24, 1990 telephone
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conversation between Mr. Nimitz and Mr. R. Nelson ~ also of >your staff, we:under-
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stand that the revisions to the radiological controls technician training program
to address improvements in job coverage, referenced on page 2 of your. letter,
have been completed and the revised training program is being implemented. 'We
also understand that contractor radiological controls personnel brought onsite
to support outages will be provided training in what constitutes adequate job _-
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coverage.
Please inform us if our understanding of these matters'is incorrect.
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Your cooperation with us is appreciated.
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Sincerely,
Original signed By:
Richard R. Koimig
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-James H. Joyner, Chief.
Facilities Radiological Safety
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-and-Safeguards Branch
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Livision of Radiation Safety-
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and Safegsards
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0FFICIAL RECORD COPY
RL MY 90-11'- 0001.0.0
'9010160012 901002
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ADOCK 05000309
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Maine Yankee Atomic
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Power Company
Oc7 0 2 199g
cc w/ enc 1:
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J. Randazza, Assistant Chairman of the Board
J. H. Garrity, Executive Assistant to the President
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E. T. Boulette, Vice President, Operations
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P. L. Anderson, Project Manager.
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J. D. Firth, Vice President, Public and Governmental Affairs
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G. D. Whittier, Manager, Nuclear Engineering and Licensing
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R. W. Blackmcre, Plant Manager
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J. A. Ritsher, Attorney (Ropes and Gray)
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. Peter Brann, Assistant Attorney General
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U. Vanags, Maine State Planning Office
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Public Document Room (PDR)
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local Public Document Room (LPDR) .
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Nuclear Safety Information Center'(NSIC)
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NRC Resident Inspector
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bec w/ enc 1:
Region I Docket Room (with concurrences)
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Management Assistant, DRMA (w/o enc 1)
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R. Bellamy, DRSS
,
J. Johnson, DRP
E. McCabe, DRP
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H. Eichenholz, SRI - Vermont Yankee
M. Conner, SALP Reports Only
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K. Abraham, PA0 (20) SALP Report and (2) All Inspection Reports.
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J. Caldwell, EDO
E. Leeds, LPM, NRR
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09/lo/90
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OFFICIAL RECORD COPY
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MaineYankee
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EDISON ORIVE * AUGUSTA. MAINE 04336 * (207) 622 4868
August 22, 1990
MN-90-80
SEN-90-240
Region I
UNITED STATES NUCLEAR REGULATORY COMISSION
475 Allendale Road
King of Prussia, Pennsylvania 19406
' Attention:. Mr. Thomas T. Martin, Regional Administrator
References:
(a) License No. OPR-36-(Docket No. 50-309)
(b) USNRC. Letter _ to Maine Yankee dated June 20, 1990-
Inspection Report No. 50-309
(c) USHRC totter to Maine Yankee /90-11
dated July'13,'1990.
Inspection Report No.. 50-309/90-11
,
Subject: Response to Notice of Violation -
Inspection Report No..50-309/90-II, Radiological Controls-
Gentlemen:
A special radiological cunt'rols 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 results of the inspection. Reference' c documented
the results of our meeting and also contained a Notice of. Violation,-(as) Appendix A.
This letter responds to the Notice of Violation.
we have restated the violation and provided our response.In the attachment to.this-letter,
Reference (c), requested that our response " provide specific detailIn
4 regarding the
actions that will be or have been taken to improve the consistenc,' of your planning
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for and control of radiological work activities." The followint actions have'been
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implemented:
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Work planning meetings _are being hel.d weekly.
Part of.the' job' planning:
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discussions
is to
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available for each job schedulec. assure pro
>er radiological. controls : coverage -is
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Radiological controls supervision utilize a " Plan of the Week" to assign
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radiological controls technicians to specific jobs.
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United States Nuclear Regulatory Commission
Page Two
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Attention: Mr. Thomas T. Martin
NN-90-80
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A Radiation Work Permit Request Form is required to be-initiated by the.
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requesting department supervisors. The form has been revised to require
the work party,to provide sufficient information (in the form of answers
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to checklist questions) such that radiological controls personnel may
better understand the. total scope of: coverage required.- Inl addition, a
radiological' controls supervisor! specifies the details of radiological-
controis-support plans, on the Request Form.
We have hired a new Radiological Controls Section!. Head to fill. ' a
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previously vacant position. .
Also, we have emphasized the need for
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radiological controls supervision to spend ;more time = in .the ' field
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observing radiological controls performance.
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We are in the process of revising our radiological l controls technician.
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training program to address improvements in , job coverage.
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Should you have any questions on this' matter; please contact us.
Very truly yours,
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SEMd6
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S. E. Nichols
Licensing Section Head
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SEN:SJJ-
Attachment:
Response to Noticeiof Violation-
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Mr Eric J. Leeds.
Mr. Charles. S. Marschall
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Document Control Desk
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ATTACIMDfT
10 CFR 20.201(b) requires that each licensee make or cause to be made such surveys
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as (1) may be necessary to comply with the regulations in this part, and (2) are
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reasonable under the circumstances to evaluate the extent of radiation hazards 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
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radioactive materials or other sources of radiation under a specific set of
conditions and when appropriate, includes a physical survey of the location of
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caterials and equipment, and measurements of levels of radiation or concentrations
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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 quarte.- in excess of 25% of the applicable value specified in
Contrary to the above, the licensee's surveys and evaluations performed to support
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work on valve PCC-A-216 during the period May 7-17, 1990, were inadequate to ensure
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
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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 unplanned,
unmonitored radiation exposures ranging from about 550 millires to about
1600 millires.
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
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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 determining their total whole body dose and their
remaining quarterly radiation exposure value.
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
appropriate personnel monitoring equipment.
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. Mig YANKEE RESP)NSE 1
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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
work could continue provided the workers did not lay across the floor trench.
In
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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,
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 / report)ng 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
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the workin<1 party and the assigned radiological controls technician. Specifically,
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the radio'ogical controls and - work permits (RWP) were established' with the
understanding that work would be performed above and beside the valve.
The work
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scope changed which necessitated valve disassembly. This change was not communicated
between the workers and the radiological controls technicians.
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Corrective steps which have been taken and the results achieved:
Imediate corrective measures included stopping the work, resurveying and
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posting
the
work
area,
and
processing
the
workers'
dosimetry,
Additionally, all parties involved were interviewed and a Radiological
Incident Report was prepared.
The workers' doses were calculated and
determined to be within 10 CFR 20 limits.
The event was subsequently discussed at shift turnover meetings and
included it, night orders.
The radiological hazards presented by floor
trenches was also discussed. Worker briefings were held concerning good
communications to ensure proper understanding of job scope and process.
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) logical controls for work activitiesreque
for use in establishing radio
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form requires the requestor indicate the planned job evolution before the
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start of work so that proper radiological control measures can . be
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established. Also, Procedure 9.1.1, " Plant Radiological Surveys," will be
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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 schieved:
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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Technical Specification 5.12.I' ,iates that in lieu of the controit device or alarm
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signal required by paragraph ?J.203 (c)(2) of 10 CFR Part 20, each High Radiation
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Area in which the intensity of radiation is at such levels that a major portion of
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the body could receive in any one hour a cose in excess of 100 millirem shall be
barricaded and conspicuously posted as a High Radiation Area and entrance'thereto
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shall 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
with or accompanied by one or more of the following:
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A radiation monitoring device which continucusly indicates the radiation
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dose rate in the area.
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A radiation monitoring device which continuously integrates the radiation
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dose rate in the area and alarms when a preset integrated dose is
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received.
Entry into such areas with this monitoring device may be made
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after the dose rate levels in the area have been established and personnel
have been made knowledgeable of them.
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A radiological controls qualified individual (i.e., qualified in radiation
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protection procedures) with a radiation dose rate monitoring device who is
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responsible for providing positive control over the activities within the
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area atid who will perform periodic radiation surveillance at a frequency
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specified in the RWP.
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RWP No. 90-1144 specified, in Section IV, High Radiation Area Controis-Technical
Spe:ification 5.12, that radiation protection coverage was to be performed every 60
ainJtes.
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Cont *ary to the above, three workers, working under fae provisions of RWP No. 90-1144
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during the period May 7-17, 1990, for repair of ',alve PCC-A-216~ worked in- a High
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Radiation Area and the three workers did not have a continuously indicating dose rate
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meter, did not have an integrating alarming dc.imeter or radiation surveillance was
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not performed every 60 minutes by a radiological controls. qualified individual with
a radiation dose rate monitoring device.
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.MAINEYANKEERESPdNSE2
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. 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
remain in low dose areas and check hourly dose levels by calling to the workers.
This practice is no longer used at Maine Yankee.
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Corrective steps which have been taken and the results achieved:
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Immediate corrective measures were as discussed in response to Notice of
Violation 1.
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'The event was discussed at shift turnover meetings and included in night
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orders.. We also revised Procedure 9.1.10. " Radiation Work Permits", to
define " radiation surveillance" ,and to require- radiological controls
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technicians to enter work areas to check workers' dosimeters and verify
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survey results.
2.
Corrective steps which will be taken to avoid further violations:-
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We will evaluate dedicated technician coverage by October 1991 and train
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lead valve workers, per response to Notice of Violation 1.
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3.
Date when full compliance was achieved:
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Full corpliance was achieved upon stopping the work, . resurveying and
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repostirg the work area, and completing discussions of conditions with the
workers involved on May 18,~1990.
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NOTICE OF VIOLARON 3
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10 CFR 19.l?, 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
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of radirective materials or radiation in such portions of the restricted area and in
pree:otions or procedures to minimize exposure.
Contrary to the above, three workers, working in a restricted area on valve PCC-A-216
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during the period May 7-17, 1990, were not adequately informed of precautions or
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procedures to minimize their exposure. During the work activity, the three workers
unknowingly moved out of the immediate vicinity of their work location, whose
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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
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ranging from about 550 millirem to about 1600 millirem.
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MAINE YANKEE RESPONSE 3
The root cause of this event is similar to that of item 1.
Also, a work party leader
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was not identified for the PCC-A-216 repair.
The work party leader is responsible
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.
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 require identification of
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the Work Party Leader.
A Radiation Work Permit Request Form has been
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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
scope as a " change in position, location, method - of work, system
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
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reposting the work area, and completing discussions of conditions with the
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workers involved on May 18, 1990.
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Technical . Specification 15.ll.1 requires that procedures for. personnel radiation
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protection be prepared consistent with the requirements of 10 CFR 20 and be approved,
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 -
6.1.8 that stay times shall be specified under Section- V (of the RWP).
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Contrary to the above,Section V of RWP No.' 90-Il44, used for repair. of
valve PCC-A-216, did not' include stay times..
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Radiation Protection Procedure No. 9.1.10, Revision 26, statesiin Section
' 6.7.1 that workers must read, understand, and comply with the radiation
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work permit exactly as written. . Radiation work permit No. 90-1206, Vent-
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and Drain Penetrations in the Letdown Area, stated that a respirator is
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required if in the area of venting and draining;
-In addition. . the
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radiation work permit (90-1206)c stated that an air; sample was' required-
during opening of a system and while venting and draining.
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Contrary to the above, an operator,~ draining valve PR-42, located in the:
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letdown area, on Nay 15, 1990, during.the period 4:40 a.m. to 5:30'a.m.,
did not wear a respirator when in the arealoffthe. venting and. draining.
The operator spent at least 5 minutes in the: area uncapping the vent and
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drain lines, performing radiation measurements of the trench in which the.
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liquid was released directly under the drain line, and. recapping.the vent'
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and drain line.
In addition, no airJ sample.was collected during the
venting and draining.
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MAINE YANKEE RESPONSE 4
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- Procedure 9.1.10 Section 6.1.8 specifies that stay times be entered under Section V.
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The procedure further indicates that stay timestare established so that workers do
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not exceed allowable exposure limits.
When- RWPi No' .< 90-1144 - was prepared,; the
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technicians had not identified the-elevated dose coming- from:the floor trench and.
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therefore did not believe the work activity;would challenge the workers': exposure
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limits, and a stay time was not prescribed.
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With regard to the venting and draining operation, theLoperator entered the work area
on a general Operations Department RWP. At the time he read the RWP.he understood
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that a respirator was required if he were: present.in the = area during venting and
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draining. The operator has stated that once he opened PR-42 and began draining the
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line, he imediately left the' area.'
-The operator" believed he. met the RWP-
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requirements because he was not-in the area of venting and draining.a In retrospect
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we recognize the unique hazards associated:with venting and' draining potentially-
contaminated. lines, and we do not believe that general'RWPs are appropriate.for these
activities,
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Corrective steps which have been taken and the;results achieved:
The event was discussed at shift turnover meetings;and. included.in night.
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orders. The Radiological Controls and Operations departments issued night.
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orders concerning Radiation Work Permit compliance.- Procedure 3 9.1.10,-
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" Radiation Work Permits," was revised to elarify - the; requirement ' for
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- 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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Correctivesteps.whichwillbe_t' ken'toav'oid'furtherviolations:.
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- RWP. compliance will continue. to bei stressed during -training. . Generic.
guidance- for . venting and draining systems' will
be developed by'
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November 30, 1990,
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3.
Date when full compliance will be achieved:.
Full compliance was achieved with the worker briefings and the procedure-
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change on July 31, 1990.
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