ML20235H237

Insp Rept 50-029/87-09 on 870518-22.Major Areas Inspected: Implementation of Radiation Protection Program During Refueling Outage,External Exposure Control & Control of Radiation Matl & Contamination.Listed Weaknesses Noted

ML20235H237
Person / Time
Site:	Yankee Rowe
Issue date:	07/02/1987
From:	Lequia D, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235H225	List: ML20235H223 ML20235H237
References
50-029-87-09, 50-29-87-9, NUDOCS 8707150066
Download: ML20235H237 (16)

See also: IR 05000029/1987009

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 87-09

Docket No. 50-29 j

License No. JPR-3 Priority --

Category C

Licensee: Yankee Atomic Electric Company i

1671 Worcester Road

Framingham, Massachusetts 01701

Facility Name: Yankee Nuclear Power Station

Inspection At: Rowe, Massachusetts

Inspection Conducted: May 18 - 22, 1987

Inspector

. LeQuia, R d io

M

p'ecialist

/, .h - 3 7

date

(LWeadock,

A~.

(& Radiation

x u

Specialist

L,hclq J

date

Approved by: # _hM

M. ShanbakyIChieT, Facilit{es Radiation

'//2. !77 ~ '

' ' d a t'e

'Jrotection Section

Inspection Summary: Inspection on May 18-22, 1987 (50-29/87-09)

A_reas Inspected: Routine, unannounced inspection of the licensee's implementa-

tion of their Radiation Protection Program during a refueling outage. Areas

reviewed included: Audits; ALARA; External Exposure Control; Control of

Radiation Materials and Contamination; Surveys and Monitoring; Facilities- and

Equipment; and Training.

Results: Within the areas inspected, no violations were identified. However,

several weaknesses relative to auditi, postings, control of radioactive

materials, and ALARA were observed. In addition, recurring weaknesses relative

to Operations and HP control of high radiation exclusion area keys were noted.

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G ADOCK 05000029

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Details

1.0 Persons Contacted

During the course of this inspection, the following personnel were

contacted or interviewed:

1.1 Licensee Personnel

• N. St. Laurent -

Plant Superintendent

• B. Drawbridge -

Assistant Plant Superintendent

• T. Henderson -

Technical Director

• R. Mellor -

Assistant Technical Director

• G. Babineau- -

Radiation Protection Manager

• C. Clark -

Training Manager

A. Parker -

Yankee Quality Assurance  !

P. Hollenbeck -

Radiation Protection Engineer

T. Shippee {

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Radiation Protection Engineer

• M. Vandale -

Radiation Protection Engineer i

J. Geyster' -

ALARA Coordinator

S. Wisla -

Assistant ALARA Coordinator

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1.2 NRC Personnel

• Harold Eichenholz -

Senior Resident Inspector

2.0 Purpose

The purpose of this routine inspection was to review implementation of the .

licensee's Radiological Controls Program relative to the current outage. {

Areas inspected included the following:

Audits  !

ALARA

• External Exposure Control i

Control of Radioactive Materials and Contamination, Surveys and

Monitoring

• Facilities and Equipment

• Training

3.0 Audits

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The licensee's program for audits of the Radiological Controls Program was  !

reviewed against criteria contained in: i

Technical Specification 6.5.2.9, " Audits"; and

Regulatory Guide 1.146, " Qualifications of Quality Assurance Program

Audit Personnel for Nuclear Power Plants".

The licensee's performance in this area was determined by the following.

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• - Discussions with cognizant personnel;

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Review of'the following audits:

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, Audit No. Y-85-3 " Radiation Protection"

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Audit No. Y-85-5 " Training"

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Audit No ~Y-86-3 " Radiation Protection"

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' Audit;No Y-86-5 " Training"

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• - Review'of " Plant Position Reports" Numbers Y-85-3 and-Y-86-3. These

reports address the applicable audit findings.

Within the. scope of this inspection, no violations were observed. The.

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licensee is. conducting annual audits of the Radiation Protection and

Training Programs. Review of these audits found them to be of acceptable

. quality, with timely resolution of audit findings. In addition,

experienced radiation protection personnel.from other affiliated Yankee

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Atomic Electric Company stations were used as Technical Specialists to

strengthen the audit process.

One' weakness of the audit program was. identified by the inspector.

Specifically, audits performed to address the Technical Specification .

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requirement (6.5.2.9) to audit the performance, training and qualification

of the facility staff at least once per 12 monthr, did not clearly address

the qualifications portion of the requirement. This weakness had also a

been; identified.recently at another Yankee facility. Therefore, to l'

address- this concern on a system wide basis, the Yankee Quality Assurance

DepaVtment has revised the 1987 audit p?an to include " Qualifications" as

a programmatic element on par with " Training". Current audit schedules

identify that an audit of " Training and Qualifications" using this newly

revised and improved audit plan will be implemented at Yankee Rowe in

August of 1987. The results of this audit will be reviewed in a future (

inspection.

4.0 ALARA

The licensee's AL ARA program was evaluated against' criteria contained in

the following:

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10 CFR 20.1, " Purpose";

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Regulatory Guide 8.8, "Information Relevant to Ensuring That Occupa-

tions) Radiation Exposures at Nuclear Power Stations Will Be As Low

As Is Reasonably Achievable" (ALARA);

Regulatory Guide 8.10, " Operating Philosophy for Mainta' iing Occupa-

tional Radiation Exposures As Low As Is Reasonably Achievable"; and

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• . Regulatory Guide 8.19, " Occupational Radiation Dose Assessment in

Light-Water Reactor Power Plants Design Stage Man-Rem Estimates".

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[ Licensee performance ' relative to these criteria was evaluated by:

• Discussions with cognizant personnel;

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-Tours of radiologically-controlled areas; )

• - Inspection of ALARA Reviews;

a Review of Radiation Work Permits'(RWP);.

• Independent surveys; and

• - Observation of_ work in progress.

Within.the scope of this inspection, no violations were obsertied. The

-licensee has_ implemented an ALARA program, which is documented.and j

controlled by one procedure: .AP-8020, " Implementation and Documentation. 1

of ALARA' Job Reviews". An ALARA Coordinator and Assistant Coordinator l

provide management oversight of the program, although these management-

resources appeared to be excessively stressed in support of ALARA Review {

development and other work' assignments.

in 1986, a non refueling year, the-licensee expended approximately 45.3 1

person-rem. For 1987, a refueling year, a goal of 186 person-rem 'for the

outage and a total goal of 237 person-rem for the year has been

' established. As of the week of the inspection, the licensee had expended

approximately 24 person rem thus far into the outage, allowing toe. annual

goal to appear readily achievable. This level of person-rem expenditure

is comparatively low relative to an industry av'erage.of'397 person-rem in

1986, for all pressurized. water reactors (PWR). However, the low

exposures at the station appear attributable to initial design features,

such as using canned rotor coolant pumps, thereby eliminating the need to

rebuild reactor coolant pump seals on a routine basis.

Within the.. scope of this inspection, the following weaknesses were

identified:

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A steam generator (S/G) mock-up, constructed of plywood, is not built

to the same dimensions as the steam generator. This minimizes the

ability to pre-fit or test items prior to actual use. In addition,

full dress practice is not routinely used during mock-up training to

simulate actual working conditions.

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The licensee has the ability to track exposure for all tasks

involving an ALARA Review, but was only tracking -exposure for S/G

work due to a lack of sufficient manpower.

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The ALARA committee was dissolved due to a perceived lack of

accomplishment. A new, stronger committee has not been formed.

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ALARA status is not routinely addressed in daily outage meetings.

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Flagging limits have not been established to prompt an ALARA

reevaluation of the ongoing jobs (i.e. 50'4 of the estimated exposure

has already been received, yet only 10*4 of the job is done).

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Inspector evaluation of ALARA Reviews found them to be simplistic in

nature, recommending only basic health physics (HP) controls, such

as: use double gloves, frisk hands before touching face, and post

area appropriately. The inspector commented that these controls l

appeared to be consistent with standard health physics training, work

practices and Radiation Work Permit (RWP) requirements, rather than

constituting special or aggressive exposure reduction actions.

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One outage ALARA Review for a specific job had a person-rem estimate  ;

of 379 person-rem. This estimate far exceeded the annual goal of 237 l

person-rem. Furthermore, there appeared to be little correlation

between ALARA Review exposure estimate totals and outage or annual

goals.

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There were numerous instances of poor mathematics on completed ALARA

exposure estimates, resulting in inflated exposure estimates.

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Neither the ALARA Coordinator nor Assistant Coordinator have any

formal training in ALARA practices or techniques.

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ALARA Reviews were not being closed-out in a timely manner following

job completion. This may result in lost data as key exposure saving

ideas / practices are forgotten.

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ALARA Reviews were not being written for all jobs requiring a review

in accordance with procedural guidance. Management personnel

responsible for this area stated that this occurred due to a lack of l

manpower and time. '

In Summary: While station exposure is low relative to other PWRs, this

appears to be due to low dose rates at the station and initial engineering

design features icther than a strong ALARA Program. Implementation

of AP-8020 procedural requirements was weak, specifically: ALARA Reviews

for all required jobs were not done; job task accumulative radiation

exposure was not being tracked for all ALARA Revicss; and in many

instances, there was no indication or documentation that personnel were

briefed on ALARA Review requirements. When these weaknesses were  !

discussed with the licensee, they stated that the paperwork had decreased i

in quality since they were focusing on getting the ALARA requirements set '

up at the work site. The inspector responded, stating that previous

weaknesses relative to ensuring that work practices closely correlated to

procedural requirements had precipitated a major Procedure Improvement

Program. Based on this, the inspector reemphasized the need for the

licensee to more closely align their ALARA activities to procedural

requirements.

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The inspector discussed the above weaknesses with the licensee, who stated

they would evaluate them and take action as necessary to strengthen the  ;

ALARA Program.

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5.0 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"; and

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Technical Specification 6.12, "High Radiation Area".

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Performance of the licensee relative to these criteria was determined  ;

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Discussion with supervisory and technician level personnel;

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Tours of radiological work areas and observation of work activities;

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Inspection of the control point and control room key lockers;

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Review of the following licensee procedures and documentation:

AP-0403, " Security Responsibilities of Plant Personnel";

AP-8010, "His' Radiation Area Control";

• OP-8415, "Radiatis7 Work Permit Issue, Update and Closecut";

RWP 87-1152, Detension #2 steam generator (S/G) manway,

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RWP 87-1300, Remove #2 S/G manway cover leaving diaphragm intact,

RWP 87-1312, Drop diaphragm #2 S/G,

RWP 87-1314, Install and maintain S/G eddy current equipment,

RWP 87-1327, Install eddy current equipment in channel head of S/G

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Radiological surveys associated with ongoing steam generator work.

Within the scope of the above review, no violations were identified.

Radiation protection technician staffing and level of coverage provided to

support work in the vapor container appeared adequate to satisfactorily

control worker exposure. However, weakresses were identified in the areas

of posting, content of RWPs, and High Radiation Area (HRA) key control. l

These are discussed below.  !

5.1 Posting of Radiological Areas

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Posting of radiation and high radiation areas (HRAs) was evaluated during ,

this inspection by tours of radiological areas and performance of '

independent survey measurements. During a tour performed on May 19, 1987, j

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the inspector noted recurring instances where the respective radiation

area or HRA boundary line was posted right at or slightly exceeding the i

applicable limit. Specifically;  !

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a survey at the radiation area signs and barrier rope surrounding the  ;

reactor head in the RCA yard identified dose rates of 5-6 mR/hr at i

the boundary.

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a survey at the HRA signs and barriers surrounding stacked fifty-five {

gallon drums in the radwaste building identified dose rates of

100-110 mR/hr at the boundary.

10 CFR 20 requires posting of radiation areas and HRAs at 5 mR/hr and 100

mR/hr, respectively. No violations were issued in the above instances,

however, as the observed deviations in dose rate over the applicable

limits were observed to be within the range of instrument error. However,

a potential trend was noted, in that posting appeared to be located right

at the applicable limit, rather than moving boundaries away from the

source to allow a larger margin for error.

The licensee took immediate corrective actions for the above concerns by

extending out the signs and barrier rope for the areas. Subsequent

inspector review of area postings during the week indicated radiological

boundaries were satisfactory.

A concern was also noted with the licensee's posting of HRAs inside the

Vapor Container (VC). Prior to a tour of the RCA on May 19, 1987, the

inspector questioned the Radiation Protection Manager (RPM) as to the

method of posting and controlling the VC access. The RPM was unsure as to

the exact posting of the VC at this time, but indicated that the VC has

been routinely posted as a High Radiation Exclusion Area during previous

outages.

NRC tours of the VC on May 19, 1987, identified that the access hatch was

posted as a radiation area. Access to the charging / refueling floor area

was posted as a HRA. The following concerns were noted:

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Accesses to the loops and steam generator blockhouses were

redundantly posted as HRAs, even though these were located inside the

HRA posting at the charging refueling floor access;

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Posting at the access to one steam generator blockhouse was

conflicting and identified it as both a radiation area and a HRA,

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Ladders leading to the upper levels of the steam generator

blockhouses were posted as HRAs, but did not include a barrier as

required by the Technical Specifications. Instead, the sign was

merely hung on the ladder, or, in one instance, on a nearby conduit.

The inspector determined from review of licensee surveys that the licensee

had over posted the accesses to the charging / refueling floor and the steam

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generator blockhouses, in that radiation dose rates did not warrant HRA

posting. Consequently, potential Technical Specification citations

involving the lack of barricades or appropriate controls in HRAs were not

warranted. However, the inspector stated that the redundancy and  !

excessive conservativeness evident in the containment posting reflected an

inattention to radiological conditions and Technical Specification

requirements by the licensee.

In response, the licensee stated that:

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The HRA posting located at the charging / refueling floor access was

inappropriate.

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Drain and fill operations had recently been completed for the

secondary side of the steam generators. Variable dose rates had

resulted, requiring the ongoing modification of steam generator

blockhouse porting. Subsequent to these operations, final posting

had not been evaluated, resulting in the conflicting radiation

area /HRA posting and the general over posting of the blockhouses.

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The licensee had considered the ladder itself to constitute the

required barrier when the ladder acted as the access to a HRA.

Consequently, no additional steps had been taken to construct a

barrier. The inspector indicated that, as the ladder was the normal

means of access to the area, some additional restriction or

requirement on the use of the ladder was required to constitute the

barrier.

The licensee immediately made the following changes:  !

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The unnecessary HRA posting at the accesses to the steam generator

blockhouses and the charging / refueling floor was taken down. HRA

posting was limited to those areas inside the containment actually

requiring them.

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The licensee indicated that a more positive barrier would be provided

for future posting of ladders which function as accesses to HRAs.

' Licensee posting and control of HRAs will continue to be reviewed during

subsequent inspections.

5.2 Radiation Work Permits

The inspector reviewed the licensee's implementation of a Radiation Work

Permit (RWP) system to control exposure by discussion with cognizant

personnel and by reviewing selected RWe's and associated radiological

surveys.

Within the scope of the above review, no violations were identified.

However, several concerns with the station's use of RWPs were noted,

including the following:

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RWPs and their associated radiological surveys are physically

separated at the control point (see Section 7.0), potentially

hampering worker pre planning and review.

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Limited radiological survey information is.actually contained on the

RWP form itself; survey information may be limited to one general {

area dose rate. f

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Inconsistent general area dose rates are sometimes given on RWPs l

covering work in the same area. For example, general area dose rates 4

of 100 mR/hr and 250 mR/hr were given respectively in two different

RWPs covering work in the steam generator (S/G) #2 tent.

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RWPs with nearly identical job descriptions were noted to control

work activities with varying workscopes, particularly in association ,

with work involving the #2 S/G and the S/G access tent.

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Computer problems were noted to cause delays in worker log-in to the

RCA (see Section 7.0).

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Several RWPs were noted to require "RP coverage"; however, no

guidance was given as to whether this was to be constant coverage, or

periodic coverage at some predetermined frequency. NRC interview of

several contractor technicians indicated that technicians were

individually interpreting the extent of coverage required for these

RWPs.

The licensee _ acknowledged that RWP titles may require additional

description clarifying the scope of work to be performed. The licensee

also indicated that additional survey information will be added as

required by specific RWPs to insure consistency of information and

nighlight areas of concern. The licensee stated additional guidance in

these areas will be provided to technicians writing RWPs; in addition,

these items will receive increased attention during management review.

This area will be reviewed during a subsequent inspection.

5.3 High Radiation Exclusion Area Key Control

Technical Specifications Section 6.12 requires that locked doors shall be

provided to prevent unauthorized entry into HRAs with dose rates greater

than 1000 mrem /br. Such areas have been designatec as High Radiation

Exclusion Areas (HREAs) by the licensee. The Technical Specifications

also require that keys to locked HREAs be maintained under the

administrative control of the on-duty Shift Supervisor and/or the plant

Health Physicist. j

Station HREA keys are maintained in the control room and at the RCA

control point. Issue of the keys is documented in key logs. Procedure I

1. AP-8010 specifies HREA key control requirements for taese HREA keys under

the administrative control of the radiation protection group. This I

procedure requires:

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HREA' key issuers to be designated by the RPM,

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undocumented shiftly accountability of all HREA keys,

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weekly, documented inventory of the HREA key locker by radiation

protection supervision.

5.3.1 Radiation Protection Group

The inspector audited the contents of the HREA key locker at the RCA

control point, along with the associated key issue log and results of

weekly inventories. The following deficiencies were noted.

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HREA key No. 24 was not present in the key locker, although it

was included on the key locker inventory list. Key issue

logsheets indicated it was issued and not returned on May 12,  !

1987. A weekly supervisory inventory on May 17, 1987 failed to

note or give explanation for the discrepancy.

The inspector subsequently determined by interview and review of

radiation protection logbooks that key No. 24 nated with a lock

that had been destroyed. No loss of control over a HREA access

occurred; however, no documentation of the lock and key status

was made in the key issue logsheets.

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The list of authorized key issuers maintained in the key locker

had expired on December 31, 1986.

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HREA key issuers were initialing, rather than signing the key

issue form.

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Several HREA key tags had two duplicates on one ring, such that

one key could be taken from the locker without being missed.

NRC inspection report No. 85-11 previously identified a concern with

the radiation protection group's control of HREA keys. During that

report, the inspector questioned the adequacy of the licensee's once

per week inventory of the HREA key locker. Licensee response was to

require a shiftly, documented accountability of the key locker as

part of the technician shift relief routine. This requirement was '

included in procedure OP-8042, " Radiation Protection Shift Personnel

Duties and Surveillance". This shiftly accountability was not being

performed in support of the current outape, however, as the procedure

itself is only required during modes 1-4l The inspector stated that

removal of the shiftly key inventory requirement during outage

conditions was not well planned, in that peak use of HREA keys and

locks generally occur during outage conditions.

Once the above concerns were identified, the Radiation Protection

Group took the following corrective actions:

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a new list of authorized key issuers was generated,

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duplicate keys were removed from HREA key tags.

In addition, the licensee stated they would reinstitute the

requirement for shiftly, documented accountability of the HREA key- (

locker. 1

5.3.2 Operations Group

Procedure AP-0403 requires bi-weekly inventory of the control room

key lockers and also requires key issue to be documented on t key

issue log. Several HREA keys are maintained in the control room key

locker; in addition,1 HREA key (to the PAB cubicle corridor) is

maintained on the auxiliary operator key ring. 1

The inspector audited the contents of the control room key lockers, )

, reviewed key issue logs and key inventory data, and reviewed

/ procedure AP-0403. The 'ollowing concerns were identified. ]

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Procedure AP-0403 does not specifically identify the shift

supervisor's administrative responsibilities for HREA keys or

indicate how HREA keys are controlled or issued by the control

room.

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The duty shift supervisor interviewed during thir inspection was

not aware of any HREA keys maintained in the key locker. The

radiation protection group subsequently identified seven HREA

keys in the key locker. The shift supervisor was aware,

however, that a HREA key was included on the auxiliary i

operator's key ring. j

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HREA keys were not specially designated or identified as such in

the key locker.

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Shif t to shift turnover of the key ring from one auxiliary

operator to another was not always documented in the key issue

log. Furthermore, where documentation was complete, it

identified only that the key ring had changed possession. There

was no key count made to ensure all keys were present.

l The inspector was able to verify that inventories of the key locker

I were performed on a weekly basis. Audit of the locker and review of

key inventory data indicated that all HREA keys were accounted for.

5.3.3. HREA Key Control Summary

Several problems were noted with the administrative control of HREA

keys by both the Operations and Radiation Protection (RP) groups.

Procedure AP-0403 did not identify Operations responsibility for HREA

key control and personnel were not aware of HREA keys in their

custody. HREA keys in the control room key locker were not

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specifically identified.

Several concerns indicate a lack of management attention to detail.

Specifically: 1) the list of authorized RP key issuers was allowed

to expire for nearly five months without notice, 2) a HREA key was

not returned, yet was not specifically flagged by either informal

shiftly accountability or weekly supervisory inventory, 3) poor

documentation was noted in the Operations key issue logbook, and 4)

discrepancies among procedures in how to perform HREA key

accountability.

In addition to the corrective actions identified in paragraph 5.3.1,

the licensee indicated they would be taking additional actions to

strengthen administrative controls and address the above noted

deficiencies associated with those HREA keys under the administrative

control of the Shift Superintendent. These actions will be reviewed

during a subsequent inspection.

6.0 Control of Radioactive Materials and 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";

10 CFR 20.202, " Personnel manitoring";

10 CFR 20.203, " Caution signs, labels, signals and controls";

10 CFR 20.207, " Storage and control of licensed material in

unrestricted areas";

10 CFR 20.401, " Records of surveys, radiation monitoring, and

disposal"; and

• Licensee procedures:

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OP-8430, " Personnel Contamination Monitoring and

Decontamination".

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OP-8100, " Establishing and Posting Controlled Areas".

Licensee performance relative to these criteria was determined by:

• Tours of the radiologically controlled area;

• Discussions with cognizant personnel;

• Independent surveys;

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• Review of Radiation Work Permits;

• Review of radiological survey records;

Observation of personnel contamination control practices;

Observation of personnel monitoring practices; and

• Inspection of radwaste containers

Within the scope of this inspection, no violations were observed. The

licensee has implemented an effective program for the control of most

radioactive materials. To support their efforts in this area, the

licensee has made substantial improvements at the control point to provide

effective, positive control for personnel access to and egress from the

radiologically controlled area. In addition, whole body frisking units

have been purchased to expedite personnel egress from this area, while I

maintaining a high degree of quality relative to personnel contamination

control practices.

Inspector review of selected air sample surveys found them to contain

multiple errors and administrative weaknesses. In some cases, it was

difficult to determine how the actual MPC-HR value was derived without a

detailed explanation by the Radiation protection Manager (RPM). These

weaknesses indicate a lack of management attention to detail relative to

air sample record keeping practices.

Through discussions with the RPM, the inspector determined that a

formalized program, plan or methodology to identify " hot particles" has

not been established. However, cognizant licensee personnel stated they

were aware of the health and safety concerns relative to hot particles,

and further indicated that they had noted the presence of hot particles in

the refueling cavity following cutting of control rod blades. Although

the licensee is aware of the potential for hot particles in the refuel

cavity, the use of sticky smears or rollers to quantify other areas of the

station has not been implemented. Following this discussion, the licensee

stated that they would implement a hot particle control program in the

near future. This will be evaluated in a future inspection.

The licensee recently deleted the requirement to wear labcoats for general

entry into the radiologically controlled area. This now allows the mixing

of personnel, some wearing full protective clothing, and some with just

street clothing, in the same area. To control the potential for cross

contamination of personnel and equipment, the licensee has staged a

frisker for personnel to frisk their protective coveralls upon exiting the

Vapor Container (VC). Inspector review of associated frisking practices

and posted frisking instructions, revealed that protective clothing with

up to 30,000 cpm (approximately 300,000 dpm) of loose radioactive

contamination may be worn while mixing with personnel in street clothing.

This was considered to be a program weakness by the insoector. Subsequent

discussion with the RPM revealed that the 30,000 cpm value was previously

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used as a limit for reuse of laundered protective clothing. This value

was arbitrarily chosen to be used for coveralls with loose contamination ,

without regard for the radiological health and safety difference between i

fixed (i.e. laundered coveralls) and loose contamination. Following this l

discussion, the licensee stated they would reevaluate this number. This

will be reinspected in the future.

7.0 Facilities and Equipment i

Several new facilities have recently been established and were being I

utilized to support radiation protection activities during the outage. 1

These include:

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A redesigned access control point to the Radiologically Controlled

Area (RCA),

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An additional whole-body counting facility, supplied by the Yankee

Atomic Environmental Laboratory,

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Vendor-supplied laundry, respiratory equipment fit-booth and

respirator maintenance and cleaning facilities.

The RCA access control point was recently redesigned to improve

contamination control and enhance the separation between the clean and

controlled areas. Three Nuclear Enterprises IPM-7 whole body friskers

have been stationed at the RCA exit. Workers appeared familiar with their i

operation and were using the friskers correctly.

The licensee is also utilizing a new Health Physics computer system to log

personnel access into the controlled area. Despite the use of this

system, the inspector noted long lines and delay times for personnel

access during shift changes. The licensee indicated that work was ongoing

to break in and familiarize personnel with the new system and that ,

efficiency could be expected to improve. '

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Radiation Work Permits (RWPs) for work to be performed in the RCA are i

posted for review on the unrestricted side of the control point. The '

inspector noted, however, that asseciated radiological surveys are posted

inside the controlled area, at the personnel dressing station. Physical

separation of RWPs and their associated surveys may reduce both the

frequency and effectiveness of pre-job briefing. The licensee indicated

methods would be evaluated to increase worker access to radiological

survey information.

I

The inspector observed the operation of the licensee's whole body counting i

and contaminated laundry facility. The inspector also toured the

licensee's vendor-supplied respirator cleaning and maintenance facilities.

The respirator and laundry facilities were posted as required and ,

individuals performing these tasks appeared familiar with their operation.

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8.0 Training

The licensee's program for the selection, qualification and training of

contractor radiation protection personnel was reviewed against the

following criteria:

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10 CFR 19.12, " Instructions to Workers", j

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Technical Specifications, Section 6, " Administrative Controls", '

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ANSI N18.1, 1971, " Selection and Training of Nuclear Power Plant

Personnel", and

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AP-8001, " Radiation Protection Department Organization and Training".

Licensee performance in this area was determined by the following methods:

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Discussion with supervisory radiation protection personnel,

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Review of selected contractor technician resumes, and

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Review of selected " contractor personnel procedure review sheets".

Within the scope of the above review, no violations were identified.

Approximately 26 senior and 11 junior technician positions were filled by

contractors to augment the licensee's radiation protection technician

staff.

Inspector review of selected technician resumes indicated that contractors

brought in as senior technicians met the two year experienct requirements

of ANSI N18.1. The inspector noted, however, that no documentation was

available in technician files to indicate that the licensee had either i)

called previous sites where the contractors had worked to evaluate

performance, or ii) reviewed the quality of previous technician

experience, giving only partial credit for work such as control point

monitor or respirator maintenance.

The licensee indicated that the above techniques are in fact used to

evaluate previous contractor experience or performance; however, there are

not documented or included in the file. The licensee indicated they would

evaluate whether efforts should be taken to improve documentation in this

area.

Procedure AP-8001 requires that contractor technicians review and sign-off

on selected radiation protection department procedures. Each procedure

review and sign-off sheet is then reviewed by a radiation protection

supervisor. The inspector verified by review of randomly selected

procedure sign-off sheets that the licensee is complying with the

l,- procedure requirements. It was noted, however, that the list of

procedures actually reviewed was not consistent among the technicians.

Newly written procedures were not reflected on all sign-off sheets; in

addition, several procedure review sheets showed sign-offs for procedures

that had been cancelled and superseded by new procedures. Supervisory

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review of these sheets had not been effective in identifying these

inconsistencies.

The licensee indicated that additional attention would be directed towards

assuring consistency in technician review and sign-off of procedures.

9.0 Exit Meeting

The inspector met with licensee management denoted in Section 1.0 on May

22, 1987, at the conclusion of the inspection. The scope and findings of

the inspection were discussed at that time.