ML20155A077

Insp Rept 50-213/86-02 on 860210-14.Violation Noted:Failure to Make Temporary Mod to Procedure Controlling Special Compacting Operation

ML20155A077
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/31/1986
From:	Shanbaky M, Sherbini S, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20155A060	List: ML20155A057 ML20155A061 ML20155A077
References
50-213-86-02, 50-213-86-2, NUDOCS 8604080208
Download: ML20155A077 (7)

See also: IR 05000213/1986002

Text

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 86-02

Docket No. 50-213

License No. DPR-61 Priority --

Category C

Licensee: Connecticut Yankee Atomic Power Company

P.O. Box 270

Hartford, Connecticut 06101

Facility Name: Haddam Neck

Inspection At: Haddam Neck - Connecticut

Inspection Condu d: , FAbr;// 10 - February 14, 1986

Inspectors:

J

.

. iilhhe ,' SenWr

N

diatto Specialist,

h#

"date

i n.we a la ' n Prote ion Section

M OT '// IM

Sami She'rbi'ni', Ra'diation Specialist, dath

o

FacilitiesRadiapi'nProtectionSection

Approved by: ~#% /, b

Mohamed 3fi'anbaEy,~ Chief, Facilities

3 3/

date

[

Radiation Protection Section

Inspection Summary: Inspection on February 10 - February 14, 1986 (Report No.

50-213/86-02).

Areas Inspected: Unannounced, routine inspection of refueling outage activi-

ties, including: qualification and training of licensee and contractor per-

sonnel, personnel exposure control, contamination control, ALARA, and dosimetry

records. The inspection involved 70 inspector hours onsite by two NRC region-

based inspectors.

Results: One violation was identified (failure to make temporary modification

to procedure controlling special compacting operation, as required by Technical

Specification 6.8).

860400020s

ADOCK

86 $13

PDR PDR

O

_

- ..

-

_

.

DETAILS

1.0 Personnel Contacted '

Licensee Personnel

• Mr.-G. Bouchard, Station Service Superintendent

• Mr. H. Clow, Health Physic's Manager

Mr. W. Nevelus, Radiation Protection Supervisor

M.-Sweeney, Radiation Protection Supervisor

• denotes attendance at-the exit interview.

Other, personnel were also contacted or interviewed during this inspection.

2.0 - Purpose

The purpose of this routine inspection was to review the implementation

of radiological control relative to the current refueling outage; and

evaluate previously identified items'. Areas inspected included:

qualification and training of contractor HP personnel

a exposure control

• contamination control _

• ALARA program implementation

a status of previously identified items

3.0 Outage Related Activities

During the course of this inspection, the licensee radiological control

program was reviewed relative to the following activities:

Steam Generator Eddy Current Testing

Steam Generator Sludge Lancing

Refueling Preparation

Area Decontamination

In order to enhance radiological control, the licensee introduced the

following innovations:

1. Extensive use is made of closed circuit television (CCTV) monitoring.

Eleven individual remote control cameras have been situated to pro-

, vide direct surveillance of steam generator and refueling activities.

The devices are used by the on-watch technicians to control work in

,

high radiation areas; and by management personnel to observe the

status of jobs and areas.

[

I' r.

l

!

I-

I

I

t

>

,

.

'

3

The expected result from this extensive use of CCTV is reduced expo-

sure to personnel providing continuous coverage and increased direct

work surveillance; and increased management attention to work site

status, high radiation area control, and general productivity.

2. Specific plant areas have been designated as zones in an effort to

enhance communications and awareness among workers relative to rad-

iological controls. In this concept, 6 zones have been designated.

Each zone functions as a satellite control point from which RWPs are

developed and controlled, surveys are performed, job surveillance is

assigned, and decontamination and clean-up services are arranged.

Dedicated senior personnel are assigned as zone controllers and are

responsible to implement and manage the radiological controls for all

work in the zone. Sufficient support is provided in terms of per-

sonnel and material, and management oversight.

The concept appears to be effectively implemented and has resulted

in better maintenance of areas since decontamination services are

usually readily available; and increased worker awareness since the

radiological control personnel are dedicated and in close

proximity. Additionally, there is more rapid identification and

resolution of problems since workers are more aware of who is

responsible for radiological control implementation.

The licensee's ccntrol and accountability of outage related work

appeared to be well done. Support Contractor Health Physics (HP)

personnel were carefully selected and subjected to 9 training and

qualification programs designed to assure capability in the areas for

which the individuals were responsible. Very discreet functional

statements of responsibility and authority were implemented to pre-

clude any advertent misassignment of personnel.

Personnel dosimetry and records management was found to be performed

in accord with site procedures. Sufficient personnel were available

to manage the increased man-loading to support the outage.

4.0 Status of Previously Identified Items

(Closed) Violations (50-213/84-24-01)

(Closed) Violations (50-213/84-24-02)

(Closed) Violations (50-213/84-24-03)

(Closed) Inspector Follow-up Item (50-213/84-24-05)

All of these items pertain to the failure to qualify, train and control

the activities of a junior level technician commensurate with the require-

ments of Technical Specification 6.3.1, 6.41 and 6.13(c), respectively.

- _ _

.

. 4

The licensee has effected corrective measures for each of these violations

as stated in correspondence to the NRC dated November 13, 1984 and

February 20, 1985. The procedural anu administration controls specified

in LER 84-020-00 were verified to be implemented. Current control of

contractor personnel, observed in this inspection, appears sufficient to

prevent recurrence.

(Closed) Unresolved (50-213/84-30-01)

Develop procedures to subject changes in facility design to a safety

evaluation pursuant to 10 CFR 50.59.

Administrative procedures have been amended and require safety analysis

review of changes in the facility, including temporary structures and

mobile facilities.

(0 pen) U? resolved (50-213/84-30-02)

Establish, implement and maintain a system for self-identification and

resolution of discrepant radiological controls.

While the licensee has established a system to identify and correct dis-

crepent radiological controls, review of this area revealed less than

adequate performance of event analysis and subsequent corrective action

implementation as detailed in Section 5.0 of this report.

(Closed) Inspector Follow-Up Item (50-213/84-30-03)

Review ALARA Program and last outage report.

This item is considered closed based on details contained in Section 6.0

of this report.

5.0 Licensee Identified Discrepancies in Radiological Control Implementation

In reviewing the licensee's Radiological Incident Reporting (RIR) System,

RIR-0285 was reviewed to determine the adequacy of the analysis, causal

factor determination, and the appropriateness and ef fectiveness

of subsequent corrective measures.

The event occurred September 5, 1985, when two radioactive waste tech-

nicians compressed a 55 gallon drum of unknown identity, measuring 60

R/hr at contact, with the LSA box compactor. The purpose of the job was

to reduce the dimensions of the drum to allow disposal in a spent resin

liner.

Compacting operations are performed in accordance with Radiation Protec-

tion Procedure (RPP) 6.3-5 " Radioactive Material Management". A safety

evaluation of compacting operation and the compacting facility was per-

formed September 30, 1985. In this instance the procedural specification

.

.

5

of RPP 6.3-5 was not applicable since.the compaction in a LSA box was not

performed. Rather the compactor was being used as a press on the 55

gallon drum, without the containment of a box. Also the operation was

done beyond the constraints of the safety evaluation, since the evaluation

was predicated on the fact that applicable procedures would be followed.

No temporary procedural modification or change was established, nor were

the constraints of the safety evaluation considered.

.

,

As a result.the facility was subjected to extensive contamination, i.e.,

8 to 300 mrad /100 cm2 loose surface activity. The two individuals per-

forming the work with respiratory protective equipment in accordance with

RWP 8502118, were subject to internal deposition of about 19 and 15 MPC-

hrs respectively, which is 1 sss than 4% of the quarterly quantity limits

specified in 10CFR20.103.

The HP technician controlling the job outside of the area without respi-

ratory protective equipment received about 30 MPC-hrs, or about 6% of the

quarterly quantity limit specified in 10CFR20.103.

While RIR-0285 demonstrated that the licensee attempted to self identify

this problem, the event analysis does not adequately identify all of the

causal factors sufficient to effect corrective measures and prevent re-

currence. For example, the licensee analysis:

1. does not address that the compactor was being operated in a

manner for which it was not designed ar.d as such would not

develop sufficient capture velocity via the ventilation system

to control resulting airborne activity;

2. does not address that there was no procedure or procedure change

developed for this mode of operation;

3. does not address that the licensee's safety evaluation required

that a general area monitor / recorder be in service prior to

compacting activities, nor does it identify that use of such

monitoring system is not incorporated in RPP 6.3-5.

The licensee's RIR does identify other contributing causes such as the

fact that not all of the personnel assigned to RWP 8502118 were wearing

all of the protective clothing or respirators specified by the RWP; and

that containment was not maintained during compactor operation. However,

due to incompleteness of analysis and an inadequate review by management,

the licensee concluded that the personnel exposures were only attributable

to inadequate removal of protective clothing by the individuals involved.

Except for reprimands for the subject individuals no other recognition of

a problem is evident from the licensee's evaluation. Consequently no

other corrective measures were established to prevent recurrence.

p

.

6

The licensee evaluation focused only on the narrow aspect of the occur-

ance of personnel internal deposition and essentially ignored a series of

extremely poor practices that led to the personnel exposures. Even when

some of the factors were identified by the licensee's own staff, licensee

management essentially ignored the critique and formed a conclusion that

is not justifiable in view of the data.

Since the licensee did not recognize the procedural inadequacies asso-

ciated with this event, and consequently failed to implement effective

corrective action, this event constitutes a violation of Technical Speci-

fication 6.8, " Procedures". In this case, the intent of the original

procedure was altered without a changed or modified procedure being

established, implemented and maintained that addressed control and

mitigation of the potential radiological hazards from the changes in

operation. (50-213/86-02-01)

Follow-up on monitoring of the three personnel involved in this event indi-

cated that the deposited activity was essentially eliminated within 10

days of the event. Personnel exposures have been assigned to the indi-

viduals in accordance with 10 CFR 20.103.

6.0 ALARA Program

The licensee's ALARA program has developed since the last review in this

area, and is now a more sophisticated exposure tracking system that has

the capability of providing management personnel with timely information

on personnel exposure expenditures and highlights problem areas.

Actual implementation of dose reduction efforts are largely the respon-

sibility of individual job supervisors in terms of engineering controls,

planning and personnel training. While the concept is not flawed, com-

plete success is not yet evident. For example, the 1986 Outage man-rem

expenditures indicates that goals and estimates have been exceeded for

several planned tasks with less than 40?s completion of the outage. While

some overruns may be explain.?d, this type of performance does not indicate

that the licensee has been generally effective in exposure reduction, when

compared with previous outaces.

This item will be reviewed in a subsequent inspection. (50-213/86-0'2-02)

Man Wkly Man Wkly

Refueling Outage Weeks Rem Avg. Hours Avg.

1983 12 1260 105 72,665 6,055

1984 14 1108 72 46,067 3,290

1986* 6 607 100 45,814 7,635

• about 40?; complete

.-

7

7. Exit Interview

The inspector met with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on February 14, 1986. The inspector

summarized the scope of the inspection and the findings.

At no time during this inspection was written material provided to the

licensee by the inspector.

.