ML20236H878

Suppls Response to NRC Re Violations Noted in NRC .Corrective Actions:Radiation Work Permits Corrected by Specific Survey Meter Required or Technician Job Coverage Barricade Ajusted to Less than 100 M/H

ML20236H878
Person / Time
Site:	Maine Yankee
Issue date:	10/26/1987
From:	Whittier G Maine Yankee
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
9032L-SDE, 9259L-GDW, GDW-87-246, MN-87-119, NUDOCS 8711050011
Download: ML20236H878 (7)

Text

,

, j MaineYankee AELIABLE ELECTRICITY FOR MAINE SIPCE 1972 EDISON DRIVE . AUGUSTA. MAINE 04330 .(207) 622 4868 l i

i October 26, 1987 l MN-87-119 GDH-87-246 I i

l a

United States Nuclear Regulatory Commission )

Attention: Document Control Desk 1 Washington, D. C. 20555

References:

(a) License No. DPR-36 (Docket No. 50-309)

(b) USNRC Letter to MYAPCo dated July 14, 1987  ;

(c) MYAPCo Letter to USNRC dated August 13, 1987 (MN-87-91) '

(d) USNRC Letter to MYAPCo dated September 15, 1987

Subject:

Maine Yankee Radiological Controls Gentlemen:

In your letter dated September 15, 1987, Reference (d), you requested additional information concerning our corrective actions taken to address the violations identified in Reference (b). As discussed with Dr. Shanbaky of your staff on October 16, 1987, Maine Yankee required additional time to respond to your request. Our responses to the violations in reference (b) were forwarded to you in Reference (c) and are attached (Attachment A) for completeness. He believe the root cause of the problems that we experienced in radiation controls during the last outage was a mismatch between the amount ,

of work planned requiring radiological controls and the resources available to cover the work. As a result, we plan to place much greater emphasis on radiological controls resources when planning and scheduling the work to be performed during future refueling cutages. He believe this improvement in our planning of outage activities should prevent recurrence of the radiological controls problems experienced during the past outage. ,

Maine Yankee has implemented several changes to increase the effectiveness ,

of our radiological controls program. These improvements are summarized below.

Plannina for and Staffhu for Outagesi Maine Yankee will -develop an outage radiological plan prior to the next )

refueling outage. The deficiencies noted during the past refueling outage I will be factored into this plan. As noted above, we will place greater emphasis on radiological control resource limitations when planning and scheduling jobs to be performed during future refueling outages. l 8711050011 871026 ph PDR ADOCK 05000309 G PDR l 9259L-GDH -

l j 4

J

1 MaineYankee United States Nuclear Regulatory Commission .Page Two Attention: Document Control Desk MN-87-119 l

)

1 1

Radiological Oversite of Station Hork Activities

• l l

Maine Yankee has improved the radiological oversite of work activities. l The improvements include observations of jobs in progress, noting deficiencies j in performance, and correcting improper work practices. Heekly inspection tours within the Radiation Control Area are being made on a rotating basis by ,

the Technical Support Department Section Heads. In addition, Radiological '

Controls management has directed the Rad Controls supervisors to spend a major portion of their time inspecting and directing radiological work in the plant.

l General Housekeeoina and Radiological Controls Practices: j q

The plant has been decontaminated to approximately the levels that existed prior to the outage. Technicians have been assigned specific plant areas for ]

which they are responsible for housekeeping, radiation area postings, surveys, and job control.

Identifying Problems and Takina Corrective Action:

Maine Yankee's " Management By Walking Around Program", requires weekly inspections of designated plant areas by plant based department managers, and semiannual inspections by other department managers. This program will be improved by placing greater emphasis on observing radiation controls practices.

Cavity Drain Modj fications:

Although the discovery of the highly radioactive object referred to in Reference (b) did not constitute a violation of NRC requirements, we believe it is important to prevent recurrence of this event. Therefore, we are implementing two design changes in the cavity drain system which would prevent the passage of large objects such as the one discovered during the last refueling.

Other Proaram Improvements:

In addition, Maine Yankee has initiated several other changes to improve the effectiveness of our radiological controls program. These changes include procedure changes to improve clarity and specificity, improved tracking and trending of contamination events, improved practices for contamination control, and revised procedural controls for RWPs. ,

y l

~ ~""

L

r M a. lrme ank.ee

. ;. , 1- ,

-United States Nuclear. Regulatory Commission Page Three?

Attention: : Document Control. Desk- MN-87-I l 9

1 4 He believe the improvements should resolve your~ concerns surroun' ding our ~l Radiological Controls.' program. If you should have any further questions, i

please feel free to. contact me.

]

Very truly yours,

, MAINE YANKEE .

7 N/AV G. D. Whittier, Manager Nuclear Engineering and' Licensing

GDH/bjp'

' Attachment cc: Mr.LCecil 0. Thomas Mr.'Hilliam T. Russell.

Mr. Pat' Sears:

Mr. Cornelius F.-Holden .

'I 4

m -!

4 l

i

' 9259L-GDH

MaineYankee 1 ATTACHMENT A HAINE YANKEE RESPONSE TO NOTICE OF VIOLATION .

I VIOLATI0fLA Technical Specification 5.11 requires that procedures for personnel radiation protection be prepared and adhered to for all operations involving personnel radiation exposure. Radiation Protection Procedure 9.1.10, Radiation " k Permits, requires, in part, in Section 7.4, that the method of hign radiation area control utilized and the surveillance frequency of checking work in such high radiation area be indicated on the radiation work permit. '

Contrary to the above, Radiation Work Permit Nos. 87-4-231, 87-4-232, and 87-4-281, used for entries into high radiation areas on April 30, 1987, did not indicate the method of high radiation area control or the surveillance frequency of checking the work performed in those areas.

MAINE YANKEE RESPONSE TO VIOLATION A

a. Reason for the Violation:

This violation resulted from insufficient procedural guidance on the t development of_RHPs. In trying to write general radiation work )

permits (RHPs) to allow access to the Containment Building for inspection activities, sometimes involving more than one job, non-specific High Radiation Area controls (such as " consistent with t job being inspected") were specified. Since the RHP procedure did not explicitly prohibit writing such RHPs, the Radiological Controls personnel assumed it was an acceptable practice.

b. Corrective Steos Taken and Results Achieved:

All RHPs written for such inspection activities were reviewed and immediately corrected, by specifying on the RHP ' survey meter j required' or ' technician job coverage', when this issue was identified by the inspector. Radiological Controls personnel were instructed not to write RHPs with non-specific High Radiation Area

-(HRA) controls,

c. Corrective Steos that will be Taken to Avoid Further Violationn L

1. The RHP procedure will be revised to explicitly require the identification of specific methods of High Radiation Area I

controls on the RHPs. The circumstances surrounding this violation and the associated corrective actions will be reviewed a by all Radiological Controls personnel. These actions will be completed by September 1, 1987.

I d. Date when Full Comoliance will be Achieved:

Full compliance was achieved on April 30, 1987.

l l

.9032L-SDE

l I

MaineYankee I VIOLATION B Technical Specification 5.12.1 requires, in part, that each high radiation i area in which the intensity of radiation is at such levels that a major- l portion of the body could receive in any one hour a dose in excess of 100.

mrem be barricaded and conspicuously posted as a high radiation area.

Contrary to the above, at approximately 12:00 p.m. on April 27, 1987, a high radiation area existed on the -2' elevation of the containment near the Reactor Head Stand, and the barricade and postings for this high radiation area were inside the 100 mR/hr boundary and thus were not serving as a warning to any one approaching the area. As a result, an individual in the area could have received a dose to the major portion of the body of 120 m em in an hour.

MAINE YANKEE RESPONSE TO VIOLATION 8 a '. Reason for the Violation:

This violation appears to have been caused by the relocation of hoses which, when moved, pushed the barricade toward the radiation source.

Surveys taken prior to the inspector's measurements showed that the High Radiation Area was properly barricaded (and posted), complying with the requirements of 10CFR20 and Technical Specification 5.12.1.

b. Corrective Steos Taken and Results Achieved:

The barricade was immediately adjusted to establish a boundary of less than 100 mrem / hour. Other High Radiation Area barricades were also promptly surveyed and all were in compliance with the requirements of Technical Specification 5.12.1.

c. Corrective Steos that will be Taken to Avoid Further Violations:

2. New barricades, which have spring-mounted uprights that spring back to the original position if contacted by workers or equipment, are being fabricated and placed into service. The barricade stanchions have heavy base plates. The location of i the base plate will be marked to denote any movement. Procedure 9.1.6 " Establishing and Posting Controlled Areas" will be revised to require that survey maps of HRAs indicate barricades and the dose rates at the barricades. These actions will be

) fully implemented by September 1, 1987.

d. Date when Full Como11ance will be Achieved 1 Full compliance was achieved on April 27, 1987.

i l

l 9032L-SDE t - - - - - _ - - - - - - - - _ _

Mainehkee l- 1 VIOLATION C 10 CFR 20.203(c)(iii) requires that each entrance or access point to a high radiation area be maintained locked with positive access control over each individual entry.

Contrary to the above, on May 10, 1987, access to the Haste Storage Area adjacent to the Radiation Control Area (RCA) Storage Building was not maintained under positive access control. Specifically, scaffolding and a ladder were located adjacent to a wall of this area which would allow an individual to reach the top of the wall and gain access to the inside where radiation dose rates were as high as 2000 mrem /hr.

l

. MAINE YANKEE RESPONSE TO VIOLATION C a.- ReAion for the Violation:

A scaffolding, which had been used during the inspection of the reactor coolant pump rotating assembly, was inadvertently placed near the'15 foot high radwaste storage area wall. Since a ladder at another location is the normal method of access to the area, the scaffolding was not recognized as a means of access when it was t placed against the wall.

b. Corrective Steos Taken and Results Achieved:

The scaffolding was immediately moved away from the wall to prevent unauthorized access to the hign radiation area as soon as this matter ,

was brought to our attention by the inspector,

c. Corrective Steos that will be Taken to Avoid Further Violations:

The wall has been posted to prohibit objects, which could be used for access, being placed against the wall. Heekly supervisory itapection tours of the area have shown no further instances of unauthorized means of access being placed against the wall.

d. Date when Full Compliance will be Achieved 1 Full compliance was achieved by Julv 31, 1987.

j 9032L-SDE 9

~

MaineYankee l

VIOLATION D 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 approximately 11:00 p.m. on May 8, 1987, certain workers were standing in a restricted area next to a 55-gallon drum which had contact dose rates of 1200 mrem /hr, and these workers were not informed that radioactive material was stored in the 55 gallon drum, nor were they provided precautions to minimize their exposure to the radiation emanating from the material in this drum.

MINE YANKEE RESPONSE TO VIOLATION D

a. Reason for the Violation: 1 The workers were not informed of the radiation source because the technician failed to check the work area as required by the RHP.

b. Co r r e c t i y.fLSiep_LJAkfto_aaOnu i t s A c h i e v e d :

The drum was moved away from the workers and barricaded and posted as a High Radiation Area when the inspector brought the matter to our attention. As soon as the crane was available, the drum was removed from the refueling cavity. No other high radiation drums were introduced into the work area during the reactor head installation.

c. Corrective Stens that will be Taken to Avoid Further Violatiom i Specific, written instructions for providing RWF job coverage were provided to all technicians in the Containment Building. The instructions included requirements for checking workers' dosimeters, verifying area dose rates, and keeping radioactive material containers properly labeled. Supervisor inspections conducted during the outage verified that the technicians were complying with these instructions.

4. In addition, procedure 9.1.6 will be revised by September 1, j 1987 to require proper labeling of all radioactive material '

containers.

5. In order to address a concern raised during the Enforcement {

Conference, the removal of reactor head stud hole plugs will be  !

reviewed by the ALARA Committee. This will be completed prior 4 to the next refueling outage,

d. De1L_when FulLCompliance will be Achieved:

l Full compliance was achieved by May 9, 1987, 1 i i'

l 9032L-SDE L_.__.___ a