ML20214V688

Radiological Controls Insp Rept 50-309/87-08 on 870427-30. Violations Noted:Failure to Post High Radiation Area,Adhere to Procedures,Control Access to High Radiation Area & Instruct Workers

ML20214V688
Person / Time
Site:	Maine Yankee
Issue date:	06/02/1987
From:	Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214V683	List: ML20214V681 ML20214V688
References
50-309-87-08, 50-309-87-8, NUDOCS 8706120247
Download: ML20214V688 (21)

See also: IR 05000309/1987008

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report;No. 50-309/87-08

Docket No. 50-309

License'No. DPR-36 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 27-30, % nd May 8-13, 1987

Inspecto s:

R. L. Nimi't

~ed de

iorpdiationSpecialist

S/L/87

'date

Approved by: # T

M. M. ShanbaTy, Chief Facilit'ies Radiation

N/2.[M

' date ,

Protection Section.

Areas Inspected: Routine (April 27-30,1987) and special (May 8-13,1987),

unannounced Radiological Controls Inspection during an outage. Areas reviewed

were: external exposure controls; internal exposure controls; radiation,.

contamination and airborne radioactivity surveys; personnel contamination

controls; exposure evaluations; and radioactive and contaminated material

control. The circumstances, and licensee evaluations.following identification

of a 1000 R/hr object and worker concerns were also reviewed. The inspection

was performed by one region based inspector.

Results: Five apparent violations were identified: (Failure to post a high

radiation area, paragraph 3; Failure to adhere to' procedures, paragraph 3;

Failure to control access to a high radiation area, paragraph 3; Failure to

instruct workers, paragraph 3; Failure to survey and identify the presence. of a

1000 R/hr object, paragraph 6). Programmatic weaknesses were identified in the

area of airborne radioactivity surveys, : personnel contamination control;

exposure evaluations; and effluent monitoring.

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PDR ADOCK 05000309

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DETAILS

1.0 Individuals Contacted

1.1 Maine Yankee Atomic Power Company

1) 2) J. Garrity, Plant Manager

1) 2) E. Boulette, Assistant Plant Manager / Technical Support Manager

1) 2) G. Pillsbury, Radiological Control Section Head

2) W. Riethle, Manager-Radiation Protection

Yankee Nuclear Service Division

2) D. Whittier, Manager, Nuclear Engineering and Licensing

2) P. Radsky, Chemistry Section Head

1.2 NRC

1) 2) C. Holden, Senior Resident Inspector, Maine Yankee

2) M. Shanbaky, Chief, Facilities Radiation Protection

Section, NRC Region I

1) Denotes those individuals attending the exit meeting on April 30,

1987.

2) Denotes those individuals attending the exit meeting on May 13,

1987.

The inspector contacted other licensee personnel.

2.0 Purpose of Inspection

The inspection was a combined routine and special unannounced.Radiologi-

cal Controls Inspection during the outage. The following matters were

reviewed:

external exposure controls

internal exposure controls

radiological surveys including:

- radiation

contamination

- airborne radioactivity

personnel contamination controls

radioactive and contaminated material control

personnel exposure evaluations

circumstances, licensee evaluations and corrective

actions associated with the identification of a

small object indicating 1000 R/hr on contact

worker concerns

3.0 Radiological Controls

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3.1 General

The inspector reviewed the adequacy, implementation and effectiveness

of radiological controls for the outage. The review was with respect

to criteria contained in applicable Technical Specifications and

licensee procedures.

The purpose of this review was to determine the following:

the adequacy of radiation, contamination and airborne radio-

activity surveys to support on going work

the adequacy of radiation work permit system

implementation of ALARA controls

the adequacy of high radiation area access controls

posting and labeling of radiological control areas and

radioactive material

use of personnel monitoring devices

radiation survey instrumentation and airborne radioactivity

sampling instrumentation checking and calibrations

use of engineering controls or respiratory protective equipment,

as appropriate, to minimize intake of radioactive material by

personnel,

instructions to workers on the radiological conditions at their

work location.

The evaluation of licensee performance in this area was based on:

discussions with personnel

review of documents

inspector performance of independent radiation surveys

inspector observations of work in the following areas:

- refueling activities

- Reactor Coolant Pump work

- Steam Generator secondary side work

3.2 Findings

Within the scope of this review, the following apparent violations

were identified:

Apparent Violation 1 (50-309/87-08-01)

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Technical Specification 5.11 requires that procedures for

personnel radiation protection be prepared and adhered to for

all operation involving personnel radiation exposure. Radiation

Protection Procedure 9.1.10, Radiation Work Permits, requires,

in part, in Section 7.4, that the method of high radiation area

control utilized and the surveillance frequency of checking work

be indicated on the radiation work permit.

Contrary to the above, on April 30, 1987, several radiation work

permits including 87-4-30, 87-4-47, 87-4-231, 87-4-232 and

87-4-281, used, in part, for entry into high radiation areas,

did not indicate the method of.high radiation area control or

the surveillance frequency of checking work.

The licensee immediately initiated action to review and revise

(as appropriate) the subject permits.

Apparent Violation 2 (50-309/87-08-02)

Technical 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

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receive in any one hour a dose in excess of 100 mrem be

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barricaded and conspicuously posted as a High Radiation

Area.

Contrary to the above, at about noon on April 27, 1987, a

high radiation area, located on the -2' elevation of the

Containment near the Reactor Head Stand, was neither

barricaded nor nosted as a High Radiation' Area. The area

exhibited dose rates which would result in an individual

receiving a dose to a major portion of the body in excess

of 120 mrem in an hour.

The area was immediately posted and properly barricaded.

Apparent Violation 3 (50-309/87-08-03)

Technical Specification 5.12.2 requires, in part, that

unauthorized access to high radiation areas, in which the

radiation intensity is such that a major portion of the

body could receive 1,000 mrem in any one hour, be prevented

by use of locked doors.

Contrary to the above, on May 10, 1987 neither locked doors

nor other compensatory measures were in place to prevent

unauthorized access to the waste storage area adjacent to

the RCA Storage Building. A scaffolding and ladder

arrangement provided for unauthorized access to locations

within the area that exhibited whole body dose rates up to

2,000 mrem /hr.

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When brought to the licensee's attention, the scaffolding

was immediately removed.

Apparent Violation 4 (50-309/87-08-04)

10 CFR 19.12 requires in part that all individuals working

in or frequenting any portion of a restricted area be kept

informed of the storage of radioactive material and

precautions to minimize exposure.

Contrary to the above, at about 11:00 p.m. on May 8, 1987,

workers, tensioning Reactor Head studs, were not informed

of radioactive material stored in a 55 gallon drum located

near the Reactor Head or precautions to minimize their

exposure to the radiation emanating from this material.

The workers were standing next to the drum which indicated

contact dose rates of up to 1200 mrem /hr.

The inspector noted that:

The drum was not marked or labelled in any manner.

The drum was not depicted on radiation survey records.

Inspector questioning of Radiological Controls (RC)

Technicians covering the tensioning work indicated they

were unaware of the drum's presence.

The Radiation work permit issued for the work specified

radiation protection " coverage" every 15 minutes.

The drum had been at the location for at least several

hours.

The following programmatic weaknesses in this area were

identified:

High Radiation Area Control

Licensee radiological controls supervisory personnel were

not providing effective instruction and/or guidance to

personnel controlling access to High Radiation Areas.

A Radiological Controls Supervisor informed the inspector

that security guards were responsible, in part, for High

Radiation Area Access Control. The superv+ sor informed the

inspector that security guards would prohibit inspector

access to a High Radiation Area unless certain criteria

were met. Inspector questioning of a guard controlling

access to Containment and the Spray Pump Areas indicated

that no High Radiation Area Access Control guidance had

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been provided to the guard. This indicates a lack of

understanding of responsibilities of personnel in the area

of high radiation area access control.

The licensee initiated action to clarify personnel

responsibilities in this area.

Licensee procedures require that the coverage frequency for

High Radiation Areas be specified on the radiation work

permit.

Radiological Controls technicians were not provided clear

guidance as to what constitutes " coverage".

Airborne Radioactivity Surveys

The licensee's program for airborte radioactivity sampling

and analysis would not ensure the quantification of

unidentified alpha airborne radioactivity (unidentified

nuclides) at the concentration value specified in 10 CFR 20

Appendix B. The program did not include a priori selected

air sample volumes and sample count times to ensure that

lower limits of detection were capable of identifying

concentrations at this Appendix B value. The program

appeared capable of detecting gross concentrations of

airborne alpha radioactivity at high concentration values.

The licensee immediately revised several procedures to

include methods to ensure identification and quantification

of unidentified alpha emitters.

The licensee is reviewing the need to revise other program

procedures in this area.

The licensee was using long duration air samples to

determine airborne radioactivity concentrations in water

boxes during Steam Generator Jumps. The samples, approxi-

mately 30 minutes in duration, do not appear to adequately

reflect peak concentrations which could be present during

the short duration of the jumps (about 2 minutes). In

addition, personnel are not exposed the entire 30 minutes

resulting in clean air being sampled and thus causing a

possible reduction of the peak concentration value. Peak

concentrations should be known to effectively control

personnel exposures.

The licensee initiated a review of this matter. I

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The licensee did not appear to have an effective program

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for real time airborne radioactivity monitoring of on going

work. With the exception of the Spent Fuel Pool area, no j

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continuous air monitors (CAMS) were set up and operable in

the station. About 4 other CAMS were out of service. In

addition, the licensee had not established quick sort

techniques for estimating airborne radioactivity by

counting of the samples in the field. A excessive back log

of~ air samples for counting was. identified in the count

room.

The licensee's action on the above airborne radioactivity

sampling concerns in the area of alpha monitoring, measur-

ing airborne radioactivity in a steam generator, and per-

forming real time air monitoring will be reviewed during a

subsequent inspection.

The above matters are considered an unresolved item.

(50-309/87-08-05)

ALARA Controls

Personnel were observed on the -2' elevation of Containment

standing in radiation fields up to 25 mrem /hr. The

individuals (3) were inspecting small hand tools to be used

on a job. A low dose rate area was located a short

distance away.

A Radiation Protection Technician in the area did not

recommend to the individuals that they work in the lower

dose rate area.

Radioactive and Contaminated Material Control

The licensee has posted and roped off the backyard area as

a Radiological Control Area. However,'the following were

noted:

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signs and ropes indicating Contaminated Areas were

down or poorly posted.

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bags of material labeled Radioactive Material extended

beyond the posted contaminated areas into the clean

area.

Sections of soil were posted " Contaminated - Shoe covers

required". The soil was in close proximity to storm

drains.

Two of the three storm drain outlets from the plant were

monitored for radioactivity. One of the drains not

monitored (Backbay) had at least one storm drain collection

point within the area posted as the Radiological Controls

Area.

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Note: Subsequent licensee sampling indicated that the storm

drain collection point (located near the Primary Water

Storage Tank) contained low levels of radioactive

material. It was also apparently not shown on plant

drawings.

The licensee initiated action to place the BackBay

storm drain outlet on their routine surveillance

schedule for periodic monitoring.

4.0 Exposure Evaluation

The licensee has inplace a procedure to be used to provide guidance to

personnel performing exposure evaluations. The procedure is used to

provide guidance for review of such matters as lost TLD badges, off-scale

dosimeters and lost dosimeters.

The review of this area indicated the following:

The procedure did not provide guidance as to the minimum evaluations

that should be performed for various dosimetry problem situations

(e.g. off-scale dosimetry).

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Inspector questioning of dosimetry personnel did not indicate a

uniform understanding of minimum evaluations which are to be per-

formed for various dosimetry problem situations (e.g. off-scale

dosimetry).

The inspector identified several individuals who had experienced

multiple off-scale pocket dosimeters within a period of a week.

However, the individuals' TLD dosimeters had not been read. It was

not apparent, based on review of documentation, that a thorough

review of the events had occurred.

NOTE: Licensee personnel indicated this area would be reviewed

and that the exposure evaluations for the individuals identified

with off-scale dosimeters would be re-examined.

The licensee's exposure evaluation program will be reviewed

during a subsequent inspection. (Inspector Followup Item

50-309/87-08-06). l

5.0 Personnel Contamination Control ,

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5.1 General

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The inspector reviewed the personnel contamination control program.

Because a number of instances of personnel contamination with hot

particles were identified by the licensee, emphasis was placed on

control of personnel exposure from hot particles.

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The review was with respect to applicable licensee procedures and

recommendations contained in IE Information Notice 86-23, " Control of

Exposure From Hot Particles" dated April 9, 1986.

The Information Notice provided information on problems identified at

other reactor sites in the areas of: personnel contamination with

hot particles; processing of laundry; and contamination control.

5.2 Findings

The following matters were identified and discussed with licensee

representatives. Licensee representatives indicated that the matters

will be reviewed. The licensee's action on these matters will be

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reviewed during a subsequent inspection: (Inspector Follow-up Item

j 50-309/87-08-07).

! 5.2.1 Frisking

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! The licensee allows personnel to leave a contaminated

l area (e.g. Containment) with protective clothing (e.g.

coveralls) and enter a clean area after removing

shoecovers and gloves. Personnel then frisk their

person, including the protective clothing, prior to

j performing activities in the clean area.

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! Some personnel were observed not to perform a frisk l

j for the length of time guidelires established by the  !

] licensee.

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Note: Frisking practices at several frisking locations ,

did not evidence aggressive oversight (e.g. l

Containment) by technicians monitoring access l

l control to ensure adequate frisking by workers.  ;

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Workers were observed performing poor frisking l

j (e.g. rapidly),

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j The licensee maintains a donut and coffee trailer '

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! within the Radiological Control Area. Personnel l

leaving the Containment with protective clothing,

excluding shoe covers and gloves, frisk themselves l

then obtain coffee and donuts. In consideration of '

! the poor frisking practice cbserved, this is

1 considered a questionable practice.

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The licensee has established guidelines for personnel

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frisking. These are: 25 seconds (total) for hand and

i feet to be performed by personnel who have not been in

j a contaminated area; and 90 seconds for a whole body

frisk to be performed by personnel who have been in a

! contaminated area.

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The licensee is experiencing some hot particles

l problems, consequently it was not apparent that the

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hot particles.

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The licensee does not possess high sensitivity portal

monitors. - Inspector challenging of the portal monitor

_ using small check sources at the Health Physics check point

indicated its detection and alarm capability was between

approximately 0.1 uCi (220,000 disintegrations per minute

(dpm)) and 0.2 uCi (440,000 dpm) of Cobalt 60.' Particle

activity less than-this detection capability would not be

detected. The detection' capability of the portal monitor

at the Main Guard Station was about I uCi (2.2*10' dpm) of

! Cobalt 60.

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.The licensee was performing tracking and trending of

personnel contamination events.

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Note: The licensee's Plant Manager met with all persons

, on May 9,1987 to reinforce the requirements for

proper frisking. In addition, person el were

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stationed at the frisking points to r...,nitor personnel

) frisking performance.

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The licensee also initiated action to obtain and

l install high sensitivity portal monitors at the Main

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Health Physics Control Point. These monitors were

installed and being calibrated by the end of the

l inspection. The licensee's action on the matter was

timely.

5.2.2 Laundry Monitoring / Processing

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3 The licensee had established informal guidelines (greater

than 500 counts per minute (cpm) above background) for

surveying laundry in the issue shelves.

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The licensee's closure package for the Information Notice,

j which was issued in April 1986, indicated no additional

! action need be taken.

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j However, inspector review indicated the following:

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The guidelines (500 cpm > background) were not being

adhered to. Personnel were using a criterialof imR/hr

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greater than background.

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The criteria used - ImR/hr> background was considered

j less than adequate for detection of hot particles.

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No procedures or instructions were in place for

quality assurance of processed laundry.

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The licensee is identifying particles with different

radionuclide composition. However, it was not clear

that the calculational methodology for estimating skin

dose establisned by the licensee was adequate for the

different nuclides.

The licensee has not evaluated the acceptability of

the calibration of the instruments used for measuring

the dose or counts per minute from a particle for the

various nuclides identified. Consequently, it was not

apparent that all dose estimates made were acceptable.

Note: Licensee personnel indicated that the adequacy of

previous dose estimates for personnel who had

received skin exposure due to contamination would

be reviewed and corrected, if necessary,

following evaluation of the skin dose estimation

methodology and instrument calibration factors.

The licensee's laundry vendor uses a wide area probe

to check laundry. The licensee has not verified the

acceptability of this probe.

6.0 Radioactive Object

Found on -2 Elevation of Containment

6.1 General

The inspector reviewed the circumstances, licensee evaluations, and

corrective actions associated with the identification of a small

object measuring about 1000 R/hr on contact. The object was found in

the Upender Drain Down Area located on the -2' elevation of the

Containment.

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The following matters were reviewed:

General Description

Licensee Actions

Origin of Object

Radiation Surveys

Personnel Exposures

6.2 General Description

At about 4:45 a.m. on May 7, 1987 an Auxiliary Operator contacted.the

Health Physics Technician located at the -2' elevation for guidance

regarding entry into the normally locked Upender Drain Down Area.

The purpose of the entry was to hook up a hose to the Upender Cavity

Drain line.

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Prior to allowing entry into the area, the technician performed a

general area survey and identified a small loose object (about 4

inches long and 1/4 inch in diameter) on the floor near the end of a

section of concrete blocks located on the floor (See Figure 1). An

initial survey of the object with an ion chamber (about 5:00 a.m.)

resulted in an off-scale reading (> 50 R/hr). Subsequent surveys

with a high range instrument also resulted in an off scale reading (>

1000 R/hr) on contact and 25 R/hr at approximately 1 foot. Four

layers of lead were placed over the object resulting in a contact

dose rate approximately 12 R/hr and a general area dose rate

approximately 1 R/hr at I foot from the lead.

Subsequent to the shielding, the auxiliary operator was permitted to

hook up the drain line. The hook up was performed about 5 feet away

from the shielded object.

The NRC Senior Resident Inspector was notified about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later.

(7:15 a.m. morning meeting)

An NRC Region I Senior Radiation Specialist was dispatched to the

site on May 8, 1987.

6.3 Corrective Actions

Short Term

The Upender Drain Down Area was secured. Access was prohibited

without specific Radiological Controls Oversight.

The object was transferred to a shielded container using long

handled tools to minimize personnel exposure.

An investigation into the origin of the object was initiated.

An investigation to determine the potential for significant

exposures of personnel who may have come in contact with the

object was initiated. Assistance with the dose evaluations was

requested from the Yankee Nuclear Service Division.

The licensee established an action plan matrix to track actions

to be performed.

The licensee surveyed the Containment for the purpose of

identifying any additional loose / uncontrolled radioactive

objects.

Note: The surveys identified several point (" speck") sources of

radioactive material. These specks read up to

approximately 1 R/hr on contact with an ion chamber. One

speck had been identified previously (approximately early

May, 1987), which indicated about 200 R/hr on contact with

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an ion chamber. ,

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The licensee was requested to review the hazards and

personnel dose consequences of these specks.

The licensee's action on this matter will be reviewed in a

subsequent inspection. (50-309/87-08-10)

Long Term

The licensee initiated a review of the Upender Cavity Drain Down

operation to identify improvements.

6.4 Origin of Object

The licensee examined the object and believes it, based on

preliminary review, to be a part of an incore instrument.

This is based on the object's size and the appearance of " cut" ends.

Note: These instruments are periodically replaced. Prior to

disposal they are cut up under water in the Reactor Cavity.

The licensee believes the cut piece was introduced into the

Upender Drain Down piping in September 1985 or possibly

earlier.

The licensee further believes that the piece fell to the floor area

(See Figure 1) when the drain down tubing was disconnected on

September 15, 1985.

Licensee review of personal exposure records and available survey

records prior to this time does not indicate the presence of a

significant localized source of radiation prior to this date.

Consequently the object was most likely in this area from

September 15, 1985 until it was discovered on May 7, 1987.

The individual who disconnected the Upender Cavity Drain Down

Equipment on September 15, 1985, was interviewed by the

inspector. The individual was unable to positively indicate

whether he did or did not perform a radiation survey of the

drain line prior to disconnecting the drain down line at that

time or after disconnection.

Two radiation work permits (RWPs) were used by at least three

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individuals performing the September 1985 Upender Cavity Drain  ;

Down/ Disconnection (RWP Nos. 85-8-111,85-9-228). Neither RWP l

provided precautions or guidance relative to the need to perform  :

radiation surveys of the drain lines or piping prior to handling

or touching them.

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6.5 Radiation Surveys

.

The inspector reviewed the radiation surveys made to support the

, draining of the Opender Cavity. The review was with respect to 10

CFR 20.201, Surveys.

Within the scope of this review, the following was identified:

Prior to allowing hook-up of the drain line and drain down of

the Opender Cavity on May 7, 1987, a radiation protection

'

technician surveyed the area. The source was located at that

time.

The licensee was unable to provide specific survey records of

the area where the object was found. General area surveys

indicated 100-600 mR/hr.

. Note: Dirt and debris from the Upender Cavity may be highly

radioactive. This material is filtered prior to the liquid

being discharged to the Annulus sump.

Within the scope of this review, the inspector concluded that the

licensee's radiation surveys of the previous drain down operation

(September 1985) were inadequate to identify this highly radioactive

source.

The following apparent violation was identified. (50-309/87-08-08)

10 CFR 20.201b requires, in part, that each licensee make or cause to

be made such surveys as may be necessary to comply with the regula-

tions in Part 20 and are reasonable under the circumstances to

,

evaluate the extent of radiation hazards that may be present. 10 CFR

20.201a defines a survey as an evaluation of the radiation hazards

incident to the presence of radioactive material and requires that

when appropriate, such an evaluation is to include measurements of

levels of radiation present.

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Contrary to the above, on or before September 15, 1985, necessary and

reasonable surveys, sufficient to identify the presence of a small

object measuring approximately 1000 R/hr on contact were not

performed at the -2' elevation Upender Cavity Drain Down Area. These

surveys were necessary to ensure compliance with the occupational

personnel external exposure limits of 10 CFR 20.101.

,

6.6 Personnel Exposures

The inspector reviewed the potential exposures to personnel who may

have entered the Upender Cavity Drain Down Area on -2' elevation of

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the Containment.

Within the scope of this review the following was identified:

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The licensee initiated a review of the exposure of all

individuals who may have entered the Drain Down Area. The

individuals names were obtained from radiation work permits

which may have allowed access to the area. A total of 222

individuals were identified who may have entered the area since

the start of the 1985 outage (August 1985).

The licensee did not identify any significant whole body exposures.

The licensee indicated that, since there were no high whole body

exposures, it was reasonable to conclude that no high extremity

i exposures occurred.

The licensee pulled and read the active TLDs of those indi-

viduals who may have entered the area during this outage. No

<

unusual exposures were identified.

A dose evaluation was initiated for the individual who performed

the disconnect operation on September 15, 1985. Preliminary

! estimates by the licensee indicate a maximum extremity dose of

about 4 rem.

i

(Note: The quarterly exposure limit for the extremities is

18.25 rem.)

lt

The licensee's exposure evaluations were ongoing at the conclusion of

'

the inspection.

The inspector indicated that the lack of radiological surveys to

identify and control such a highly radioactive source, may have

created a substantial potential for personnel exposures in excess of

the applicable regulatory limits.

The area of personnel exposure to the radiation from the object and

resulting maximum personnel exposure is an unresolved item.

(50-309/87-08-09)

7.0 Worker Concerns

On May 6, 1987, an individual working at the Maine Yankee Nuclear Station

,

contacted NRC Region I to discuss some concerns. The workers concerns and

1

the inspector's findings relative to these concerns are as follows:

Worker Concern 1

The housekeeping in the Containment Building is poor, particularly in the

Loop Areas.

.

Findings

During the inspection, the licensee was in the process of storing material

in preparation for its removal from Containment. Therefore some of the

.

16

.

housekeeping concerns appear to be related to accumulation of material

in the process of being removed, particularly from the Containment Annulus

Areas.

i

The inspector tours in the Loop Areas, however, did indicate an apparent

lack of aggressive housekeeping. Material observed included rubber boots,

paper and trash.

J

The licensee was informed of this concern.

i

Worker Concern 2

Very high radiation areas in the loop area are not marked such that

-

workers can avoid " hot spots".

Findings

The inspector toured the Loop Areas and made independent radiation

surveys. Generally, Hot Spots indicated on licensee surveys were found to

be marked. One Hot Spot originally indicating 300 R/hr on contact was

j found not to be marked. However, this spot had been shielded, but the

sign indicating the hot spot was not reattached after shielding. The hot

spot sign was reposted. The inspector did identify some examples of poor

posting. (See Section 3.0)

i

Worker Concern 3

l

4

Station rules change frequently and are contrary to training provided.

Workers were required to stand in 35 F weather in bare feet and underwear

due to a change in frisking policy.

Findings

>

The physical arrangement of buildings at the facility requires workers to

suit up in Protective Clothing inside the locker room near the Main Health

Physics Access Control Point and pass outside in the weather to enter the

Containment Building. Those workers who remove all outer Protective

Clothing upon exiting the Containment must pass outside in the weather in

i order to return to the locker room. Some workers were observed passing

i between the two locations in under clothing. In addition, during

Containment evacuations, personnel were required to " frisk out" in the

weather.

Regarding frisking practices, due to concerns identified in the area of

frisking (discussed in Section 5 of the report), the licensee initiated

action to strictly enforce his current frisking policy. Instructions to

personnel in training regarding frisking, were consistent with in-field 1

practice. No rule changes that were contrary to training were identified.  ;

!

I

. . _ _ - -.

.

17

.

Worker Concern 4

The licensee did not provide protection against radiofodine while cutting

into a coolant pipe even though it is known that high radiotodine levels

are present due to failed fuel.

Finding

The inspector reviewed numerous airborne radioiodine samples collected

since the start of the outage including those collected during initial

pulling of the Reactor Vessel 1:ead, a task which could introduce radio-

iodine into the air. No signiiicant airborne radiofodine was identified

(normally less than 10% MPC).

The licensee took a number of steps prior to opening of its primary system

to clean up residual radiciodine.

These included:

running of the Primary Containment Atmosphere Cleanup System

Maintenance of primary water cleanup and

Venting of the primary system to the Containment Ventilation System

prior to opening.

Exposure to radiotodine was maintained well below the regulatory limits.

Worker Concern 5

Twelve workers became til after exposure to hydrazine and morpholine

inside the steam generator secondary side.

Findings

The inspector discussed the matter with the two station nurses and the

station Industrial Safety Director.

The incident in question occurred April 8, 1987. Circumstances, causes

and corrective actions were discussed in an April 13, 1987 meeting with

all appropriate personnel. The meeting minutes were documented in an

April 15, 1987 licensee memorandum.

Exposure to hydrazine and morpholine was not identified as a casual factor

based on sampling inside the generator.

No exposure to chemicals was identified. i

Worker Concern 6 i

Chemical drums are improperly disposed.

.. . _ _ _

-

.

18

.

i

Finding

This matter was discussed with the Waste Coordinator. The Coordinator was

unaware of individuals improperly disposing of drums. The Waste

Coordinator indicated that the principal chemicals in use were morpholine

and hydrazine. Morpholine drums are sent back to the manufacturer.

Hydrazine drums (plastic) are rinsed out to clean out residual hydrazine,

cut in half and disposed of as normal trash.

Worker Concern 7

Training is poor. Instructors are inexperienced and not knowledgeable.

!

Findings

.

This concern relates to General Employee Training.

The inspector reviewed the training, certification and qualification of

General Employee Training Instructors. The instructors were found to be

certified and/or qualified (as appropriate) by the approved program.

However, the following was noted:

Certification documentation for one of the three instructors was not

available. The documentation was subsequently completed.

.

The three instructors did not possess any significant health physics

experience. However, this was acceptable under the licensee's

current program.

The instructors were " certified" as able to effectively instruct a

class.

Individuals with little or no health physics experience were

l certifying the instructors as acceptable to instruct General Employee

Training.

The training, certification and qualification program for General

'

l Employee Training Instructors did not clearly describe the

l certification and qualification methodology.

The above matters were brought to the licensee's attention.

,

Worker Concern 8

The station is issuing " hot" protective clothing.

Finding

"

The area of monitoring of protective clothing for issuance is discussed in

i

Section 5.2.2 of this report.

The inspector surveyed 10 pairs of coveralls, 5 hoods and 5 pairs of

rubber gloves ready for issuance. One pair of coveralls was found to have

- -_ _ _ - _ - . . -- - - _ _ - _ - - - _ - __ . - . _ _ _ - _ _ _ . - - -

_ _ _

et.

19

.

a " speck" of contamination indicating about 15 mR/hr (open window GM

Tube). All other protective clothing indicated less than about 200 counts

per minute (cpa) above background (100 cpm). The contaminated coveralls

were identified to the licensee.

The licensee is aware of this concern and has initiated a review of it.

(See Section 5.2.2)

Worker Concern 9

Respirators are not properly cleaned and maintained. Workers are not

allowed to inspect respirators after issuance.

Findings

Cleaning of respirators was reviewed during inspection 50-309/87-07. Some

weaknesses were identified in the area of respirator washing. The

licensee is aware of this matter.

Regarding maintenance, the inspector selected 12 full face respirators

(Scott and MSA) from the issue shelf. The inspector inspected the masks

and checked them for contamination. No deficiencies were identified.

Regarding worker checking of respirators, the inspector questioned several

workers thcut their ability to "self-check" their respirators and how it

would be performed. The workers had been trained to perform self-checks

in the iespirator

t Training Program and were permitted to do so. The

inspector observed workers performing "self-checks".

Worker Concern 10

Work was performed on a pump reading 50 R/hr on contact without health

physics technician coverage.

Finding

The work referred to appears to be Reactor Coolant Pump impeller work.

The coverage of the pump work was reviewed during inspection 50-309/87-07.

No violations were identified. The work coverage was consistent with

radiation work permit requirements.

The inspector reviewed work associated with impeller work in the Primary

Auxiliary Building Decontamination Room (RWP No. 87-4-414). The RWP

specified continuous radiation protection coverage. When the inspector

checked the work area, a technician was providing continuous coverage.

No violations were identified.

.

20

.

Worker Concern 11

The crane operator receives high exposure when he passes over the

"Wiscasset Wall".

Findings

The Wiscasset Wall encloses a radioactive waste storage area. Dose. rates

in the area range are up to 2R/hr whole body.

Inspector surveys at the top of the wall indicated dose rates about 120

mR/hr. Inspector discussion with several radiation protection technicians

indicated that dose rates in the crane cab were on the order of 10 to 15

mrem /hr.

No high exposure situation was identified.

Worker Concern 12

The roof of the Primary Auxiliary Building and the yard areas are

contaminated.

Findings

The roof of the Spent Fuel Building indicated contamination levels of

about 10,000 dpm/100cm2 based on discussions with health physics

supervisory personnel. The roof is posted as a Contaminated Area.

Several areas in the back yard areas are posted as contaminated areas (See

Section 3.2).

Worker Concern 13

Health physics technicians are inexperienced and do not perform well in

protecting workers.

Findings

The inspector selected five technicians providing responsible oversight of

radiological activities inside the Containment on different shifts. The

training. qualification and experience of each individual was reviewed.

No violations or deficiencies were identified.

Regarding technician performance, weaknesses in this area were identified

and are discussed in Section 3.0

8.0 Exit Meeting

The inspector met with those individuals denoted in Section 1 on April 30,

1987 and May 13, 1987. The-inspector summarized the purpose, scope and

findings of the inspection.

No written material was provided to the licensee.

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