ML20214D343
| ML20214D343 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 05/11/1987 |
| From: | Lequia D, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214D273 | List: |
| References | |
| 50-309-87-07, 50-309-87-7, NUDOCS 8705210291 | |
| Download: ML20214D343 (12) | |
See also: IR 05000309/1987007
Text
. . .
'
.
J
'
..
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-309/87-07
Docket No.
50-309
License-No.
OPR-36
Priority
Category
C
--
Licensee:
Maine Yankee Atomic Power Company
83 Edison Drive
Augusta Maine 04336
Facility Name:
Maine Yankee Nuclear Generating Station
Inspection At:
Wiscasset, Maine
Inspection Conducted:
April 6-10, 1987
Inspectors:
M_y
6~'ll- 8 '7
. P. LeQuta, VWdiat46n~ Specialist
date
M. Shanbaky, Chief, Facilities Radiction
~ ////f7
Approved by:
M. 6A
d
<
date
,
Protection Section
Inspection Summary:
Areas Inspected:
Routine, unannounced inspection of the licensee's Radiation
Protection Program during a refueling outage. Areas inspected included:
ALARA; Audits; Internal Exposure Control; External Erposure Control; Control
of Radioactive Materials, Contamination, Surveys and Monitoring; and Records.
1
Results: One violation encompassing 3 examples of failure to adequately post
and barricade high radiation areas.
In addition, several weaknesses relative
to ALARA, external / internal exposure controls and control of radioactive
material were identified.
4
f
~3
0
- - .
-
-- ..
.- .
,
- , - .
- - . - - . . - . . -
__
. .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
__
.
Details
1.0 Persons Contacted
During the course of this inspection, the following personnel were
contacted or interviewed:
1.1 Licensee Personnel
- J. Randazza - Executive Vice President, Maine Yankee
[
J. Garrity - Plant Manager
- E. Boulette - Assistant Plant Manager / Technical Support Manager
- R. Lawton - Maine Yankee Manager Quality Assurance
- L. Lawson - Maine Yankee Quality Assurance Section Head
- A. Parker - Yankee Quality Assurance
- G. Pillsbury - Maine Yankee Radiological Controls Section Head,
Acting
J. Hummer - Radiological Protection Supervisor
'
- S. Evans - Licensing Engineer
G. Kapinos - ALARA Coordinator
J. Twickler - Respirator Protection Specialist
Other licensee or contractor personnel were also contacted or
interviewed during this inspection.
1.2 NRC Personnel
- C. Holden - Senior Resident Inspector
- Denotes attendance at the Exit Meeting held on April 10, 1987.
2.0 Purpose
The purpose of this routine inspection was to review implementation of the
licensee's Radiological Control Program relative to the current outage.
Areas inspected included the following:
- Audits
- ALARA
- Internal Exposure Control
- External Exposure Control
- Control of Radioactive Materials, Contamination, Surveys and Monitoring
- Records
..
-_
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _
n
.
.
3
3.0 Audits
The licensee's program for audits of the Radiological Control Program was
reviewed against criteria contained in:
- Technical Specification 5.5.B.9 " Audit Responsibilities";
- Regulatory Guide 1.146 " Qualification of Quality Assurance Program Audit
Personnel for Nuclear Power Plants"; and
,
- The Station Quality Assurance Manual
The licensee's performance in this area was determined by the following:
- Discussions with cognizant personnel;
- Review of the " Operational Quality Assurance Program" manual;
- Review of Auditor and Technical Specialist qualifications;
- Review of the 1987 " Maine Yankee Quality Assurance Evaluation Schedule";
- Review of the following audits:
-MY-84-3A, " Health Physics (Radiation Protection)"
-MY-85-03, " Radiological Controls"
-MY-86-03, " Radiological Controls"
-MY-86-05, " Training"
- Review of the following Evaluations:
-87E-014, (Rad. Controls) " Measuring and Test Equipment Controls";
-87E-016, " Instructions, Procedures for Establishing and Posting
Controlled Areas";
-87E-018, " General Employee Training For Contractors";
-87E-027, " Radiation and Contamination Controls";
-87E-029, " Source Calibration of the Radiation Monitoring System";
and
-87E-032, " Sludge Lancing of the #2 Steam Generator (S/G)".
Within the scope of.this inspection, no violations were observed. The
licensee is conducting annual audits of the Radiation Protection Program.
Review of these audits by the inspector found them to be of good quality,
with Certified Health Physicists being used as Technical Specialists
during the audits. This was considered, by the inspector, to be a program
strength.
.
.
4
In addition, periodic Quality Assurance Evaluations are being performed
to augment the annual audits.
These evaluations are conducted throughout
the year, by Quality Engineers, to evaluate the quality of the Radiation
Protection Program on a continuing basis.
One weakness of the audit program was identified by the inspector.
Specifically, audits performed to address the Technical Specification
requirement (5.5.B.9.b) to audit the performance, training and
qualification of the facility staff at least once per 12 months, did not
clearly address the qualifications portion of the require.nent.
The
inspector discussed this weakness with licensee Quality Assurance
personnel, who took timely and aggressive action to audit the
qualifications of Chemistry and Radiological Controls personnel during the
week of the inspection.
Preliminary results from this audit (87A-01)
indicated that some personnel in these departments may not have been fully
qualified (per ANSI N 18.1-1971) for a particular position at the time of
their appointment to it.
The licensee stated that any identified
deficiencies will be resolved as part of the audit corrective actions.
To strengthen controls in this area, the licensee stated they would take
the following actions (Referenced in Memorandums: MYQA-0207-87, and QAD
P2-312/1.1.3, April 9, 1987)
1.
They will revise the 1987 audit plan for Maine Yankee to include
" Qualifications" as a programmatic element on par with " Training'!
Hence, the new title of the audit will be " Training and
Qualifications" #MY-87-05.
2.
They will submit for consideration, a Technical Specification (TS)
interpretation of T.S. 5.5.9.b, per procedure 1-26-2, that will be
reviewed by PORC as to the applicability of using a " sample" to
perform this audit or , if appropriate, request from Maine Yankee
Licensing a determination in writing as to the applicability of using
a sample in fulfilling audits requirements pertinent to T.S. 5.5.9.b.
The results of audit 87A-01 and its associated corrective actions
will be evaluated in a future inspection.
4.0 ALARA
The licensee's ALARA program was evaluated against criteria contained in
the following:
10 CFR 20.1 " Purpose";
Regulatory Guide 8.8, "Information Relevant to Ensuring The
Occupational Radiation Exposures at Nuclear Power Stations Will Be
As Low As Is Reasonably Achievable" (ALARA);
.
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
.
.
5
Regulatory Guide 8.10, " Operating Philosophy for Maintaining
Occupational Radiation Exposures As Low As Is Reasonably Achievable";
and
Regulatory Guide 8.19, " Occupational Radiation Dose Assessment in
Light-Water Reactor Power Plants Design Stage Man-Rem Estimates."
Licensee performance relative to these criteria was evaluated by:
- Discussions with cognizant personnel;
- Tours of radiologically controlled areas;
- 0bservation of work in progress;
- Independent radiation surveys;
- Review of " Repair Orders for Lead Shielding";
- Review of exposure goals and status;
- Review of the following ALARA Reviews
-87-4, " Eddy Current Testing"
-87-16, " Steam Generator Manway and Nozzle Dam Installation and
Removal"
-87-35, " Remove RCP Motor and Replacement";
-85-35 " Replacing RCP Motor"; and
- Review of " Corporate Goals and Objectives 1987".
Within the scope of this inspection no violations were observed. The
licensee has implemented a basic ALARA program, which is administered by
a single ALARA Coordinator.
During 1986, the licensee established a goal of 200 man-rem.
This was
readily achieved, since only 92 man-rem was expended for the non-refueling
year.
For 1987, an exposure goal of 600 man-rem has been established and,
at the time of this inspection, a total of aporoximately 90 man-rem had
been expended. Most of this exposure has been as a direct result of the
work performed during the current refueling outage.
While ALARA administrative procedures have baen developed for most aspects
of the ALARA Program, implementation of ALARA in radiologically controlled
areas appears weak, as exemplified by the following observations made
during plant tours:
,
..
- _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _
.
6
1.
Workers, repairing piping on the -2' elevation of the containment,
were observed to be working in a 20-40 mR/hr field, when
approximately twenty-five feet away dose rates were less than
five mR/hr. When this was pointed out to the licensee, the ALARA
Coordinator directed the workers to move to the lower dose rate area,
which they subsequently did.
However, during a back-shift tour, the
inspector noted that the workers had returned to the higher dose rate
work area. When the inspector discussed this with the Radiation
Protection (RP) Technician providing coverage on that elevation, he
stated tSat he was not aware that they had moved.
The workers were
then redirected back to the low dose rate work area.
2.
The inspector observed five personnel standing around the cavity
rail.
Tnis area had dose rates from approximately 10-50 mR/hr.
The
inspector questioned the ALARA Coordinator on the need for these
personnel to be there. Upon questioning the workers, the ALARA
Coordinator found that their assigned tasks did not require them to
be present at the cavity rail.
He then directed the workers to a
lower dose rate area.
3.
During observation of work on #2 Reactor Coolant Pump (RCP), the
inspector observed a team of maintenance personnel enter the RCP work
area, a posted High Radiation Area.
However, frequently only two
members of the team were observed to be actually involved in the work
activity.
The RP Technician providing dedicated coverage, did not
require personnel not actively involved with the work to wait outside
the #2 RCP area, in a lower dose rate location.
In addition, the following weaknesses were identified:
-Low dose rate waiting areas had not been established in radiologically
controlled areas.
(The licensee has now taken steps to identify these
areas).
-The use of closed circuit TV, or other specialized equipment specifically
for ALARA purposes is very limited.
-There is no formal requirement or process to conduct pre-work and
on-the-job ALARA evaluations to ensure that work areas have been properly
set-up for exposure control, or that work is being accomplished in
accordance with ALARA Review requirements. However, pre-job planning and
post-work reviews were being conducted.
-There appears to be only limited use of mock-ups prior to actual work.
-The ALARA Coordinator has no formal training in ALARA practices or
techniques.
(The licensee stated that the ALARA Coordinator will attend
this tyre of training sometime in 1987).
l
._
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _.
._
1
.
.
7
The' inspector discussed these weaknesses with licensee management, who
stated they would evaluate them and take appropriate corrective actions
as necessary. This area will be reevaluated during a future inspection.
5.0 Internal Exposure Control and Assessment
The licensee's program for control of internal exposure was reviewed
against criteria contained in the following:
- 10 CFR 20.103, " Exposure of individuals to concentrations of radioactive
material in air in restricted areas";
- NUREG-0041, "Menual of Respiratory Protection Against Airborne
Radioactive Materials";
'
- NIOSH Certified Equipment List"; and
!
- Regulatory Guide 8.7, " Occupational Radiation Exposure Records System".
Evaluation of licensee performance in this area was based on the
following:
'
' Discussions with cognizant personnel;
1
- 0bservation of respirator fit' tests;
- 0bservation of Whole Body Counting;
- 0bservation of respirator usage in contaminated areas;
- 0bservation of respirator cleaning and inspection;
- Review of air sample analysis sheets and MPC-HR records; and
- Tours of the Radiologically Controlled Area.
Within the scope of this inspection no violations were observed. The
licensee has established a basic Internal Exposure Control Program, which
includes:
respiratory protection, bioassay, air sampling and engineering
controls. However, the following weaknesses were identified by the
inspector:
-The Respiratory Protection Specialist, has limited respiratory
protection experience.
-The Respiratory Protection Specialist has no formal respiratory
protection training.
-Respirator turn around time, following use, is hampered by poor drying
facilities and handling practices.
This has resulted in only a limited
number of respirators being available at times.
..
..
.
..- _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . . _ _
_ _
..
.
8
,
-Respirator fit testing has had to be postponed on occasion due to an
insufficient number of staff personnel trained to use the fit booth, even
,
when allowing a maximum 60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> work week.
L
-199 air sample sheets for April 4-8, 1987, were unreviewed by licensee
management as of 0900 April 9, 1987. This indicates a lack of management
attention to detail. When the inspector discussed this with the
cognizant licensee person, he stated that he was too busy with other,
more pressing matters such as Radiation Work Permits.
(The licensee has
since implemented an air sample log book to more easily review and trend
air sample data). The inspector noted that the pace of the outage
appeared to overload licensee first-line Radiation Protection (RP)
supervisory resources. This was also evident during inspector tours of
the restricted area, when licensee RP Supervisory presence was noted to
be very limited during the week of the inspection.
-The breathing air compressors were rebuilt in March of 1987. However
the licensee used the compressors to supply breathing air to steam
!
generator (S/G) personnel installing nozzle dams on April 6,1987,
without first certifying the air as grade
"D" quality or better. When
this was identified to the licensee, they took prompt corrective action
tu sample and analyze the air for grade "D" during the inspection on
April 9, 1987. To strengthen controls in this area, the licensee stated
that the following procedures would be revised:
9.330 " Operation of the Robbins 'RAF' Compressed Breathing Air
Purification System," Rev. 5, and
9.1.2 " Respiratory Protection Program", Rev. 11.
The procedures would be upgraded, as necessary, to include the frequency
i
for sampling breathing air and to specify the limits for grade "0"
quality breathing air.
The inspector discussed the above weaknesses with the licensee, who
stated they would take action to improve this area. This area will be
reevaluated in a future inspection.
6.0 External Exposure Control
The licensee's program for external radiation exposure control was
reviewed against criteria contained in:
- 10 CFR 20.201, " Surveys";
- 10 CFR 20.203, " Caution signs, labels, signals and controls";
- 10 CFR 20.401, " Records of surveys, radiation monitoring and disposals";
_
,. . .
. .
. .
.. -
-.
_ _ _ - - - _ - - - - - -
.
l-
i
.
l
9
.
,
t
- Regulatory Guide 8.2, " Administrative Practices and Radiation
Monitoring"'
l
- Regulatory Guide 8.4, " Direct Reading and Indirect Reading Pocket
-
Dosimeters";
- Regulatory Guide 8.7 " Occupational Radiation Exposure Record Systems";
- IE Informatior. Notice No. 81-26, Part 2, " Placement of Personnel
Monitoring Devices for External Radiation Exposure," August 2, 1981 and
Supplement 1, July 19,1982;
- IE Information Notice No. 83-59, " Dose Assignment for Workers in
Non-Uniform Radiation Fields," September 15, 1983.
Licensee procedures:
-9.1.1, " Plant Radiological Surveys";
-9.1.6, " Establishing and Posting Areas"; and
-9.1.10, " Radiation Work Permits." (RWP)
Performance of the licensee relative to these criteria was determined
from;
- Discussions with cognizant personnel;
- Tours of the Radiologically Control Area;
- Independent Surveys;
=0bser,ations of work in progress;
- Review of RWP's;
,
- Review of survey records; and
- Checking locked High Radiation Area gates.
Within the scope of this inspection the following violations were
observed:
TecF11 cal Specification 5.12.1, requires, in part, that 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 mrem shall be barricaded and conspicuously posted as a high
radiation area.
l
l
'
,
..
.
_ _ _ _ _ _ _ _ _ _ _
.
'
10
However, on April 7,1987, whole body dose rates in excess of 100 mR/hr
were present on the -2 foot elevation adjacent to the access area to
loop #1 in the Containment Building and were inadequately posted and
barricaded. Specifically, radiation dose rates ranged between 100-130
mR/hr at approximately 6 feet from the posting sign and barrier rope.
When informed of this situation, licensee personnel took action to
reposition the barrier ropes and posting signs.
Furthermore, on April 8, 1987, between 1230 and 1410, access to Reactor
Coolant Pump #2, an area with radiation intensities in excess of
,
100 mR/hr, was not barricaded nor conspicuously posted.
Specifically, the
high radiation area posting and barricade were found down and unattended
three times during approximately ninety minutes.
Relative to this event, the inspector informed licensee management and
RP technicians located on the Charging Floor immediately upon first
observing the rope barricade and posting down.
Licensee personnel took
action to rehang the posting and rope barricade.
However, during the next
ninety minute tour of the Containment Building, the inspector found this
barricade and posting down on two more occasions. The two RP technicians
assigned to provide cnverage for the Charging Floor failed to observe that
the barricade and posting were down even though it was clearly visible
approximately 30 feet from their control desk.
To strengthen controls in this area, the Radiological Controls Section
Head, Acting, issued two memos relative to "High Radiation Area work
controls / measures". One memo, dated April 8,1987, was addressed to
Radiological Controls Personnel on all shifts, and the other was issued
on April 9, 1987, to "All Maine Yankee Employees & Contractor Personnel".
However, these upgraded controls did not prevent a similar occurrence on
April 10, 1987, as follows:
On April 10, 1987, at approximately 1005, access to the refueling cavity,
an area with radiation intensities in excess of 100 mR/hr, was not
barricaded nor conspicuously posted.
Specifically, the barrier rope and
sign at the access were down and unattended.
These 3 examples constitute an arparent violation of Technical Specification 5.12.1 (50-309/87-07-01).
7.0 Control of Radioactive Materials ano Contamination, Surveys, and
Monitoring
The licensee's program to ensure effective control of radioactive material
and contamination, as well as performing adequate surveys and monitoring,
was reviewed against criteria in:
- 10 CFR 20.201, " Surveys";
.
_
_
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
.
11
- 10 CFR 20.202, " Personnel Monitoring";
- 10 CFR 20.203, " Caution signs, labels, signals and controls";
- 10 CFR 20.401, " Records of surveys, radiation monitoring, and disposal."
Licensee performance relative to these criteria was determined by:
- 0bservation of frisking practices;
- Tours of the Radiologically Controlled Area;
- Review of survey documents and air sample sheets;
- Independent surveys;
- 0bservation of work in progress; and
-
(
- Review of procedure 9.1.6, " Establishing & Posting AREAS, "Rev. 13.
Within the scope of this inspection no violations were observed.
The
licensee has instituted an adequate program for the control of radiosctive
material and contamination.
Within the scope of this inspection, the following weaknesses were
identified:
1.
During tours ofsthe Auxiliary Building and Containment Building, the
inspector noted numerous instances where drums for radioactive waste
and protective clothing were not labelied " Caution - Radicactive
Material".
Independent surveys made by the inspector determined that
10 CFR 20, Appendix C limits had not been exceeded. However, the
licensee took prompt precautionary measures to appropriately label
the containers.
2.
The contamination control area around Auxiliary Charging Pump P-7, on
the 11 foot eleva. ion of the Primary Auxiliary Building, had enlarged
so that it extended beyond the posted boundaries. This was corrected
by the licensee in a timely manner.
3.
Inspector review of procedure 9.1.6, " Establishing & Posting Areas"
identified a weakness in that the procedure did not provided guidance
for control of containers of radioactive material. The inspector
discussed this with the licensee, who stated they will upgrada the
applicable procedure.
This will be reviewed in a future inspection.
.
..
-__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ .
_ _ _ _ - _ _ _ _
_______ ____
7
.
_,
12
8.0 Records
The inspector noted during the course of the inspection that the
licensee's system for the handling of radiological records associa'.ed with
the outage appeared to be only marginally adequate. Specific examples
include the 199 unreviewed air samples as identified in Section 5.0 and
the fact that it took nearly seven hours for the licensee to produce two
RWP's and their associated air sample sheets and radiation surveys
requested by the inspector for a recent outage task. This weakness was
discussed with licensee management, who stated they would make efforts to
improve this area.
)
9.0 Exit Meeting
The inspector met with licensee management denoted in Section 1.0 on
April 10, 1987, at the conclusion of the inspection. The scope and
findings of the inspection were discussed at that time.
-
1
l
l
.