ML20155A077
| 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: |
| References | |
| 50-213-86-02, 50-213-86-2, NUDOCS 8604080208 | |
| Download: ML20155A077 (7) | |
See also: IR 05000213/1986002
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
86-02
Docket No.
50-213
License No.
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
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Inspectors:
.
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J
. iilhhe ,' SenWr
diatto Specialist,
"date
i n.we a la ' n Prote ion Section
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IM
Sami She'rbi'ni', Ra'diation Specialist,
dath
FacilitiesRadiapi'nProtectionSection
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Approved by: ~#% /,
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Mohamed 3fi'anbaEy,~ Chief, Facilities
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 86
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DETAILS
1.0 Personnel Contacted
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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:
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qualification and training of contractor HP personnel
exposure control
a
contamination control _
ALARA program implementation
status of previously identified items
a
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
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status of jobs and areas.
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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.
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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
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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.
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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.
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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
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
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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.
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