ML20235H237
| 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: |
| 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
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REGION I
Report No.
87-09
Docket No.
50-29
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License No.
JPR-3
Priority
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Category
C
Licensee:
Yankee Atomic Electric Company
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1671 Worcester Road
Framingham, Massachusetts 01701
Facility Name:
Yankee Nuclear Power Station
Inspection At:
Rowe, Massachusetts
Inspection Conducted: May 18 - 22, 1987
Inspector
M
/,
.h - 3 7
. LeQuia, R d
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p'ecialist
date
(L (&
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L,hclq J
A~. Weadock, Radiation Specialist
date
Approved by:
_hM
'//2. !77
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M. ShanbakyIChieT, Facilit{es Radiation
' ' d a t'e
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'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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8707150066 070706~
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:
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Licensee Personnel
- N. St. Laurent
Plant Superintendent
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- B. Drawbridge
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Assistant Plant Superintendent
- T.
Henderson
Technical Director
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- R. Mellor
Assistant Technical Director
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- G. Babineau-
Radiation Protection Manager
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- C. Clark
Training Manager
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A. Parker
Yankee Quality Assurance
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P. Hollenbeck
Radiation Protection Engineer
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T. Shippee
Radiation Protection Engineer
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- M. Vandale
Radiation Protection Engineer
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J. Geyster'
ALARA Coordinator
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S. Wisla
Assistant ALARA Coordinator
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1.2 NRC Personnel
- Harold Eichenholz
Senior Resident Inspector
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2.0 Purpose
The purpose of this routine inspection was to review implementation of the
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licensee's Radiological Controls Program relative to the current outage.
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Areas inspected included the following:
Audits
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External Exposure Control
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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
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reviewed against criteria contained in:
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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.
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reports address the applicable audit findings.
Within the. scope of this inspection, no violations were observed.
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licensee is. conducting annual audits of the Radiation Protection and
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Training Programs.
Review of these audits found them to be of acceptable
quality, with timely resolution of audit findings.
In addition,
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experienced radiation protection personnel.from other affiliated Yankee
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
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been; identified.recently at another Yankee facility. Therefore, to
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address- this concern on a system wide basis, the Yankee Quality Assurance
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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
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inspection.
4.0 ALARA
The licensee's AL ARA program was evaluated against' criteria contained in
the following:
10 CFR 20.1, " Purpose";
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Regulatory Guide 8.8, "Information Relevant to Ensuring That Occupa-
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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:
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Discussions with cognizant personnel;
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-Tours of radiologically-controlled areas;
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Inspection of ALARA Reviews;
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Review of Radiation Work Permits'(RWP);.
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Independent surveys; and
Observation of_ work in progress.
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Within.the scope of this inspection, no violations were obsertied.
The
-licensee has_ implemented an ALARA program, which is documented.and
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controlled by one procedure: .AP-8020, " Implementation and Documentation.
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of ALARA' Job Reviews". An ALARA Coordinator and Assistant Coordinator
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provide management oversight of the program, although these management-
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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
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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.
The licensee has the ability to track exposure for all tasks
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involving an ALARA Review, but was only tracking -exposure for S/G
work due to a lack of sufficient manpower.
The ALARA committee was dissolved due to a perceived lack of
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accomplishment. A new, stronger committee has not been formed.
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
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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
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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
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of 379 person-rem. This estimate far exceeded the annual goal of 237
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person-rem.
Furthermore, there appeared to be little correlation
between ALARA Review exposure estimate totals and outage or annual
goals.
There were numerous instances of poor mathematics on completed ALARA
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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.
ALARA Reviews were not being closed-out in a timely manner following
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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
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manpower and time.
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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
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in quality since they were focusing on getting the ALARA requirements set
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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
Technical Specification 6.12, "High Radiation Area".
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Performance of the licensee relative to these criteria was determined
from:
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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;
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,
RWP 87-1300, Remove #2 S/G manway cover leaving diaphragm intact,
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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.
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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.
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These are discussed below.
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5.1 Posting of Radiological Areas
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Posting of radiation and high radiation areas (HRAs) was evaluated during
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this inspection by tours of radiological areas and performance of
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independent survey measurements.
During a tour performed on May 19, 1987,
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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
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applicable limit.
Specifically;
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a survey at the radiation area signs and barrier rope surrounding the
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reactor head in the RCA yard identified dose rates of 5-6 mR/hr at
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the boundary.
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a survey at the HRA signs and barriers surrounding stacked fifty-five
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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;
Posting at the access to one steam generator blockhouse was
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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
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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:
The HRA posting located at the charging / refueling floor access was
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inappropriate.
Drain and fill operations had recently been completed for the
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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
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separated at the control point (see Section 7.0), potentially
hampering worker pre planning and review.
Limited radiological survey information is.actually contained on the
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RWP form itself; survey information may be limited to one general
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area dose rate.
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Inconsistent general area dose rates are sometimes given on RWPs
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covering work in the same area.
For example, general area dose rates
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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.
RWPs with nearly identical job descriptions were noted to control
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work activities with varying workscopes, particularly in association
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with work involving the #2 S/G and the S/G access tent.
Computer problems were noted to cause delays in worker log-in to the
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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.
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Station HREA keys are maintained in the control room and at the RCA
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control point.
Issue of the keys is documented in key logs.
Procedure
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AP-8010 specifies HREA key control requirements for taese HREA keys under
the administrative control of the radiation protection group.
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procedure requires:
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HREA' key issuers to be designated by the RPM,
undocumented shiftly accountability of all HREA keys,
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weekly, documented inventory of the HREA key locker by radiation
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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,
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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.
The list of authorized key issuers maintained in the key locker
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had expired on December 31, 1986.
HREA key issuers were initialing, rather than signing the key
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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
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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.
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In addition, the licensee stated they would reinstitute the
requirement for shiftly, documented accountability of the HREA key-
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locker.
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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.
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The inspector audited the contents of the control room key lockers,
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reviewed key issue logs and key inventory data, and reviewed
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procedure AP-0403. The 'ollowing concerns were identified.
Procedure AP-0403 does not specifically identify the shift
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supervisor's administrative responsibilities for HREA keys or
indicate how HREA keys are controlled or issued by the control
room.
The duty shift supervisor interviewed during thir inspection was
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not aware of any HREA keys maintained in the key locker.
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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
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operator's key ring.
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HREA keys were not specially designated or identified as such in
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the key locker.
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Shif t to shift turnover of the key ring from one auxiliary
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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.
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was no key count made to ensure all keys were present.
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The inspector was able to verify that inventories of the key locker
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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:
OP-8430, " Personnel Contamination Monitoring and
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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
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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
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without regard for the radiological health and safety difference between
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fixed (i.e. laundered coveralls) and loose contamination.
Following this
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discussion, the licensee stated they would reevaluate this number. This
will be reinspected in the future.
7.0 Facilities and Equipment
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Several new facilities have recently been established and were being
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utilized to support radiation protection activities during the outage.
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These include:
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A redesigned access control point to the Radiologically Controlled
Area (RCA),
An additional whole-body counting facility, supplied by the Yankee
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Atomic Environmental Laboratory,
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Vendor-supplied laundry, respiratory equipment fit-booth and
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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
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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
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efficiency could be expected to improve.
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Radiation Work Permits (RWPs) for work to be performed in the RCA are
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posted for review on the unrestricted side of the control point.
The
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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.
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The inspector observed the operation of the licensee's whole body counting
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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
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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",
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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
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Personnel", and
AP-8001, " Radiation Protection Department Organization and Training".
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Licensee performance in this area was determined by the following methods:
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".
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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
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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.