ML20153C985
| ML20153C985 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 08/23/1988 |
| From: | Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20153C987 | List: |
| References | |
| 50-309-88-12, NUDOCS 8809010383 | |
| Download: ML20153C985 (10) | |
See also: IR 05000309/1988012
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-309/88-12
Docket No.
50-309
Category
C
License No.
Priority
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Licensee:
Maine Yankee Atomic Power Company
83 Edison Drive
Aucusta, Maine 04336
Facility Name:
Maine Yankee Atomic Power Station
Inspection At:
Wiscasset, Maine
Inspection Conducted:
July 18-22, 198_8
Inspector:
RL WM
8\\t3 lva
R. L. Nimitz, Senior Radiation Specialist
date
Approved by:
S/tT/ST
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M'~5fia7ibaky, chtet, tactlities Radiation
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Protection Section
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Inspection Summary:
Inspection canducted on July, 18-22, 1988 (Inspection
Report No. 50-309/88-12)
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radiological co,ntrols organization,gical Controls Inspection of the
Areas inspected:
Routine unannounced Radiolo staffing and qualifications;
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following:
audits; ALARA; corrective action system; external and internal exposure controls
and yard contamination,
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Results: No violations were identified.
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8809010363 880823ADOCK 05000309
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DETAILS
1.0 Individuals Contacted
1.1 Mt.ine Yankee
J. B. Randazza, President
J. N. Garrity, Vice President
E. T. Boulette, Plant Manager
J. Brinkler, Assistant Plant Manager
G. Cochrane, Radiological Controls Section Head
G. Pillsbury, Actirg Radiological Controls Section Head
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W. K. Peterson, Manager QA Audit Group
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J. C. Frothingham, Manager of Quality Programs
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S. D. Evans, Senior Licensing Coordinator
D. Sturniola, Principal Radiological Engineer
1.2 NRC
L. Tripp, Chief, Reactor Projects Section 3A, RI
P. Sears, Project Manager, NRR
R. Fruedenberger, Resident Inspector, Maine Yankee
The above individuals attended the exit meeting on July 22, 1988.
The inspector also contacted other licensee personnel during the course of
this inspection.
2.0 Purpose and Scope of Inspection
This inspection was a routine, unannounced Radiological Controls
Inspection. The following areas were reviewed:
- organization and staffing;
-qualifications lonsystem;
- corrective act
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- audits;
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- planning and preparation for the upcoming outage;
- ALARA;
- external exposure controls;
- internal exposure controls; and
- yard contamination.
3.0 Licensee Action on Previous Findings
(Closed) Inspector Follow up Item (The licensee's w) hole body counting
3.1
50-309/88-08-02 . Licensee to review and
evaluate the whole body counter.
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program did not provide administrative controls to ensure that the
detectors of the whole body counter were properly aligned prior to counting
of personnel.
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The licensee placed a tape marker on the whole body counting chair and
verbally instructed personnel to check that the detectors were properly
aligned prior to counting.
Inspector discussions with licensee personnel
indicated all individuals who may whole body count personnel may not have
been verbally instructed. The licensee immediately issued a memorandum to
all appropriate personnel regarding this matter. The licensee performed a
preliminary review of the potential for improperly counting personnel if
the detectors were not properly aligned . Licensee review indicated some
personnel could be improperly counted if the detectors were not properly
aligned prior to counting. The licensee indicated that an evaluation would
be performed to determine if personnel may have left the site with
undetected intakes of airborne radioactive material.
This Inspector Follow-up Item is closed for administrative purposes.
Further NRC review of this matter and review of licensee evaluations and
corrective actions for this matter will be made under Unresolved Item No.
50-309/88-12-01.
4.0 Organization and Staffing
The inspector reviewed the organization and staffing of the onsite
Radiation Protection Group with respect to criteria contained in the
following:
- Technical Specification 5.2, Organization; and
- Regulatory Guide 8.8, Information Relevant to Ensuring That
Occupational Radiation Exposure At Nuclear Power Stations Will Be As Low
As Is Reasonably Achievable.
Evaluation of licensee performance in this area was based on review of
resumes and discussions with personnel.
Within the scope of this review, no violations were identified.
The follvwing matters were discussed with licensee representatives:
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- The Radiological Controls Section Head who had been detailed to IHP0 for
the past year and a half has returned to the onsite organization. The
individual is currently in a turnover status with the individual who
filled the incumbent's position. The inspector observed an ap
orderly turnover of information and responsibility occurring. parent
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licensee's initiative to improve the background of Radiological Controls
Section management by detailing personnel to INP0 was considered good.
- The licensee is reorganizing the onsite Radiation Protection Group to
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provide for a superintendent level Radiation Protection Manager.
Preliminary review indicates this will reduce the span of control of
some positions in the group and provide for enhanced oversight of day to
day program activities. The effectiveness of this reorganization and the
revision of applicable administrative documents will be reviewed during
subsequent inspections.
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- The licensee performed a job task analysis of the Radiation Protection
Group. The analysis indicated the need for at least two more radiation
protection technicians. The licensee is evaluating the analysis and
reviewing staffing levels of other facilities for areas of organizational
improvement at Maine Yankee. The licensee recently filled a number of
technician vacancies via qualification of a group of technician
candidates.
- The licensee recently filled the vacant positions of Respiratory
Protection Coordinator and Hazardous Waste Coordinator. With the
exception of the two technicians discussed above, the organization is
fully staffed.
- The licensee uses radiation protection technicians to perform some
limited chemistry functions. This was reviewed during Inspection No.
50-309/88-08 and found acceptable.
- Inspector review of job
Lead Radiological Contro$osition descriptions for some personnel (e.g.If
s Specialist) indicates the need to review an
update the descriptions to accurately reflect responsibilities and
authorities. The licensee recognized this need and is currently updating
the descriptions.
5.0 Qualifications
The inspector reviewed the qualifications of members of the Radiation
Protection Group with respect to criteria contained in Technical Specification 5.3 Facility Staff Qualifications.
Licensee performance in
thisareawasevaluatedbyreviewofresumesanddiscussionswithcognizant
personnel.
Within the scope of t'11s review no apparent violations were identified.
Inspector review of tne overall technical and experience level of personnel
in the Technical Support area of the Radiation Protection Group indicated a
need for enhancement in this area. The licensee has recognized the need
for this enhancement and is
personnel in selected areas (providinc
additional offsite training ofThe licensee has als,ra
e.g.
protection)ir capabilities.
o sent personnel
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enhance the
6.0 Audits
The inspector reviewed licensee audits of the Radiation Protection Program
with respect to criteria contained in Technical Specification 5.5, Review
and Audit.
Within the scope of this review, no violations were identified. Audit
quality appears to be improving. Technical Specialists from the Yankee
Nuclear Services Group continue to be used to perform audits. Audits
appeared to be more performance based. The licensee plans to audit the
area of radiation protection during the outage.
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7.0 Planning and Preparation for the Upcoming Outage
The inspector reviewed the licensee's planning and preparation in the area
of radiation protection for the upcoming outage.
Evaluation of licensee
performance in this area was based on discussions with personnel and review
of documentation. The following areas were reviewed and discussed with
licensee personnel:
- work scope;
- organization and augmentation of the staff to support outage activities;
- assignment of responsibilities and oversight of outage work activities;
- equipment and supplies (e.g., shielding and protective clothing);
- ALARA planning and preparation; and
- licensee actions to preclude recurrence of radiation protection problems
identified during the previous outage.
Within the scope of this review, no apparent violations were identified.
Overall licensee planning and preparation appeared to be adequate. The
licensee purchased additional supplies to support the outage.
Person-loading and organizational charts were under development. Identified
outage work was being pre-reviewed both from an ALARA stand point and from
an in-field radiological controls stand point. Specific procedures were
under development to specify radiological controls for the outage. Special
worker instructions were being developed to provide consistent radiological
controls for activities.
8.0 External Exposure Controls
The inspector reviewed licensee external exposure controls with respect to
criteria contained in applicable licensee procedures t.nd 10 CFR 20,
Standards for Protection Against Radiation.
The following matters were reviewed:
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- Sosting, barricading and access control, as appropriate, to radiation and
ligh radiation areas; and
- radiation exposure of personnel, including maintenance of appropriate
exposure history files.
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The licensee's program for controlling external exposure was reviewed by
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the following methods:
- discussion with personnel;
- review of selected personnel exposure records;
- review of licersee exposure investigations; and
- tours of plant areas and review of High Radiation Area controls.
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Within the scope of the above review, no violat',ons were identified.
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The inspector noted during plant tours that systems and piping exhibited a
considerable number of "hot spots" which tended to increase general area
background radiation levels. The licensee was aware of the concern
associated with the hot spots and was reviewing them.
The inspector noted that the licensee identified several instances where
termination reports detailing exposure received at Maine Yankee were not
transmitted to personnel as required.
The identification was made during
licensee efforts to computerize all exposure files. The licensee is further
reviewing this matter.
Licensee follow-up and resolution of this natter is
unresolved and will be reviewed during a subsequent inspection
(50-309/88-12-02).
9.0 Internal Evgosure Controls
The inspector reviewed selected aspects of the internal exposure controls
program. The review was with respect to criteria contained in applicable
licensee procedures and regulatory requirements.
The following matters
were reviewed:
- posting of airborne radioactivity areas; and
- bioassays and personnel airborne radioactivity intakes.
Evaluation of licensee performance in this area was based on discussions
with personnel, tours of the facilities and review of documentation. Within
the scope of this review, no violations were identified. No apparent
intakes of airborne radioactivity by personnel in excess of 40 mpc-hrs.
were identified for 1987. The licensee is currently in the process of
upgrading his whole body counting capabilities with state of the art Geli
systems. The following areas for improvement were identified:
- The licensee's procedure guidance for whole body counting of personnel
specifies that whole body counts are to be given when an individual was
exposed to an airborne radioactivity concentration of 10 x MPC.
Consideration should be given to counting of selected workers on jobs
with a high potential of generating airborne radioactivity. This would
provide some oversight of the quality of the respiratory protection
program and the adequacy of the licensee's airborne radioactivity
sampling program. Licensee personnel indicated this would be reviewed.
- Although the licensee is taking action to install drip collectors on
leaking valves to limit the spread of contamination and thus the
potential for personnel contamination and intakes of airborne
radioactivity, ding containment. Additional action
the station exhibits a total contaminated area of about
15% not inclu
as appropriate, should
be Initiated to further reduce the extent of station contamination.
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10.0 ALARA
The inspector reviewed selected aspects of the licensee's ALARA Program.
Emphasis was placed on licensee performance during the past outage and
planning and goal setting for the upcoming outage. The review was with
respect to criteria contained in the following:
- Maine Yankee Radiation Protection Manual
- Procedure 9.1.28, Implementation of the Maine Yankee ALARA Program
- Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational
Ex)osure at Nuclear Power Stations Will Be As Low As Is Reasonably
Ac11evable
- Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational
Radiation a Lou As is Reasonably Achievable
- NUREG/CR-3254(ow As Is Reasonably AchievableLicensee Programs for Maintai
Radiation As
- NUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power
Stations; Study on High-Dose Jobs, Radwaste Handling and ALARA
Incentives.
Within the scope of this review no violations were identified. The
following matters were discussed with licensee personnel:
1987 ALARA Performance
The licensee sustained 7 total exposure for 1987 of 690 person .em. Of
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this 597 person-rem was sustained during the outage. About 409 person-rem
oft $e597wasreviewedbytheALARACommittee.Reviewofseveralmajor
tasks (lworkandsteamgeneratorinspectIcnreactor coolant pump impeller
steam generator dryer replacement
and sea
indicated generally adequate
ALARA preplanning. Licensee exposure totals r)eflect an aggressive effort to
maintain plant availability and sr.fety through considerable preventive
maintenance. Licensee exposure totals for ma;or tasks (such as reactor
coolant pump seal replacement comoare favorably with industry averages.
Although licensee performance) compared favorably,h the lice
several areas for
improved performance were noted and discussed wit
- There is a need to better understand the principal contributors of
personnel accumulated radiation exposure sustained during "routine"
outage work. Inspector review of 1987 exposure data indicated that about
200 person rem of exposure was sustained from routine outage wot k. This
exposure received little if any ALARA review. Since this exposure
represents about 30% of the total accumulated exposure for 1987, efforts
to identify the sources and limit this exposure should be initiated.
- The licensee's ALARA Program does not require a job to receive an ALARA
review unless 1.5 person-rem of exposure will be received. This action
point for ALARA reviews should be considered for reduction. The licensee
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is in the process of reviewing his ALARA Program for improvement.
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- Review of some work tasks indicated the following:
- There is a need to improve coordination of work groups. Multiple work
groups were noted working in one area. Multiple work groups hampered
effective use of shielding.
- Some work crews were switched from one job to others resulting in the
need for familiarization of different work crews to a particular job.
- In light of significant reactor ecolant pump work, consideration should
be given to purchase of a pump mock-up.
- Some exposure goals for tasks were not challenging (e.g., steam generator
dryer replacement)
Licensee personnel were aware of these areas and were reviewing them to
prepare for the upcoming outage.
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1988A1ARAG0ALS
The licensee is taking action to enhance his understanding of expenditure
and accumulation of exposure during the outage.
With in the scope of this review, the following matters ware discussed with
licensae personnel as areas for imprcvement:
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- The licensee has selected an 19% occupational exposure goal of 600
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person-rem.
Inspector review M vork scope and discussions wnh
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personnel at the time of this i..spection indicated an apparent evosure
total (by years end of considerably less than this value.
Licensee
personnel indicated)that additional work may be performed.
The inspector
indicated an effort should be made to identify additional outage work in
a timely fashion in crder to provide sufficient time to perform ALARA
pre-planning of this work.
11.0 Corrective Action System and Performance Monitoring
The inspector reviewed selected aspects of the licensee's corrective action
and performance monitoring program. The review was with respect to criteria
contained in the following:
- Procedure 9.203
- Procedure 9.1.25,Radiolc,gical Controls Performance Assessment
Radiological Incident Reports.
Licensee radiation protection supervisors perform weekly plant tours as
part of the performance monitoring program. Action is initiated to correct
observed deficiencies. A quarterly review of job observations is made and
transmitted for station management review. Radiological incident reports
are sumarized on a yearly basis.
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Inspector review of data indicated a reduction in the frequency and
severity of findings. However, pro *ulems continue to be identified in
selected areas indicating a need for more aggressive corrective action by
management and accountability on the part of all station groups and
personnel.
Repeat problems continue in areas such as adherence to and
adequacy of radiation work permits, lack of radiological surveys and
personnel contamination control. Some recurrent observations -in high
radiation control were identified and are discussed later. In addition come
radiological inc6' ant r6 ports were not transmitted to plant management as
required by procedure. The inspactor considered the corrective action
program to be in need of improvement.
Licensee personnel indicated the
program would be reviewed.
The follow ig weaknesses in High Radiation Area access control were
discussed
eth licensee personnel:
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- There were four sepi' ate findings in 1987 dealing wit' failure to control
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access to High Radiation Areas. On June 17, 1987 an dRC 1-'pector found
the posi3d High Radiation Area access door of the upper elevation of the
Sen. The licensee was notified immediatrly and corrective
spray building , ken to prevent t'ecurrer.ee.
actions were ta
The correct::e actions were
completed on June 24, 1997. On June 25, 1987 an NRC inspector again
t'aund tne same door open. A Notice of Violation was issued on July 30
1987. The licensee's August 28, 1987 responsetotheviolationspecifIed
that all plant personnel had been reminded of the need to verify that
doors are locked upon exiting such areas and that all locks had been
checked for propar optration.
This was verified during a subsequent NRC
review.
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1:Jwever during review this inspection the inspector noted that the
licensee,throughhisHighRadiationkreaaccessdoorsurveillance
program, had identified the above discussed door sgain open on November
24, 1987. In addition, the High Iadiation Area access door to t;.t
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Auxiliary Drain Tank was found open on December 2,1937. Licensee review
ind: cates that the doors were apparently left open by unknown
individuals. Inspector review of limited available radiation surveys for
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areas entered did not indicate that radiation levels at that time were
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such that a majcr portion of the body could be exposed to a dose rate l'
ex:ess of 1000 mR/hr. How:ver, the inspector conc 1Lued that the two
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High Radiation Area access control program.g weaknesses in the licensee'.
additional examples indicate some con'.inuin
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The two dears identified
were to ta controlled in accordance with Technb.a1 Specification 5.12.2.
The licensee i
- stracted operations personnel following the incidents.
As of the date
'c' inst f* ion no additional examples were identified.
High Radiatic nisc
, cess co.h ils will be reviewed during future
inspections.
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22.0 Yard Contamination
The inspector reviewed licensee follow up of radioactive contamination of
the soil areas in the back yard areas of the station. The soil
contamination apparently or10insted from poor contamination control
practices during work on contaminated equipment in the back yard area this
past outage and as a result of unplanned leaks associated with tanks. The
contamination ranged from several thousand disintegrations removabic to
about 30 mr/hr. on samples of soil associated with a leaking lir.e
essociated with a tank.
1he licensee has excavated significant quantities
of soil for disposal and is working on a plan to fully decontaminate,as
appropriate, the back yard areas.
Some apparent trace quantities of cont aination remain in excavated areas.
The licensee has performed a preliminary safety analysis wh!ch shows off
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site consequences to be minimal. The licensee has comritted to submit an
evaluation in accordance with 10 CFR 20.302 to discuss the contaminated
areas. This submittal will be made in about 90 days Licensee follow-up
and disposition of the contaminated areas is considered an unresolved item
and will be reviewed during a subsequent inspection ( 50 309/P8-12-03 ).
Within the scope of this review the following area for improvement was
identified:
- Although the licensee does require frisking prior to exiting the
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radiological controlled area, the licensee does not provice friskers or
require their use by all personnel wiio exit the Reactor Building. The
inspector observed personnel leave tne Reactor Containment a
contaminated area removetheirprotectivec1cthincandexItoutsideinto
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theenvironmentwIthoutperforriinganyfrisking.Thisisconsidereda
poor practice considering the potential for personnel contamination when
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in containment and er tracking of contamination into the envirnnment.
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Licensee personno)
ndicated some one he,d apparently removed the frisker
from the con hinment exit without replacing it.
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13.0 Exit Meeting
The inspectors meet with licensee representatives denoted in section 1 of
this report on July 22, 1988. The inspector summarized the purpose, scope
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and findings of the inspection.
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