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U. S. NUCLEAR REGULATORY COMMISSION
 
==REGION I==
Report N /88-18 Docket No. 50-213 License No. DPR-6*  Priority - Category C Licensee: Connecticut Yankee Atomic Power Company Facility Name: Haddam Neck Power Station Inspection At: Haddam Neck, Connecticut Inspection Conducted: September 6-9, 1988
    '
  - >
Inspectors:  -
hAS A. Weadock, Radiation 3pecialist
    '0/W[!M8 date
#
Facilities Radiation Protection Sectien cm {3 D ,-) & G'
5. 5herbin1, Tentor Radiation Specialist I O /t9/I938 date'
Facilities Radiation Protection Section Approved by: -A*/ .5  M ChTef f
    /o////f[
      ' date DFacilities
  . 5hanbakylation Rad Protection Section  i
      .
l Inspection Summary: Inspection September 6-9, 1988 (Report No. 50-213/88-18) l Areas Inspected: Routine, unannounced inspection of the radiological controls incluling radiation surveys, respirator issue and maintenance, program, air samp ling equipment calibration, counting room operations, and the status of previously identified item Results: No vio'ations were identifie l 8910240509 G81017 PDR i
O ADOCK 05000213    i PDC    J l
 
'
.. .
DETAILS 1.0 Personnel Contacted 1.1 Licensee Personnel
  * H. Clow, Health Physics Supervisor
  * E. Debarba, Station Services Superintendent B. Groves, Assistant Radiation Protection Supervisor
  * D. Hiller, Jr., Station Superintendent
  * W. Nevelos, Radiation Protection Supervisor M. Sweeney, Radiation Protection Supervisor 1.2 NRC Personnel
  * T. Shadlosky, Senior Resident Inspector
  * A. Asars, Resident Inspector
* Denotes attendance at the exit meetin .0 Status of Previously Identified Items:
Inspection report 87-30 identified a number of concerns regarding the operation of the whole body counter and respirator fit facility. The following actions were taken by the licensee to resolve these issues:
I
- The manufacturer recommends that the detector electronics on the whole l body counter be adjusted before collecting data for calibration purpose l The licensee was not sure if the service contract with the vendor included '
'
such adjustment The licensee has added instructions in the procedure on gain adjustment 1 prior to calibration. However the electronic adjustments mentioned above includeadjustmentsofcontrolsthataffectpulseshapeandrequiresome technical expertise to perforn. It is still not clear whether these adjustments are part of the routine vendor services. This item will be reviewed during a future inspectio The procedures did not specify a minimum number of counts in each peak used for system calibratio The licensee has added a minimum count requirement to the procedure The required monthly QA tests were not formally specified, l
      ,
 
.
.. .
 
The licensee has specified all the required QA/QC tests for the whole body counters in the appropriate procedure Part of the OA program included a vendor supplying spiked samples periodically. However, procedures did provide details for conducting these tests and for accep Lnce criteri The licensee stated that these tests are not a formal part of the QA program for the whole body counter and should therefore not be included in the Procedures. The tests are performed only for added assurance to the  i program supervisors. The rest of the quality control program was inspected in a previous Report inspection and was found to be satisfactoryThis item is therefore considere 50-213/87-30).
 
- There was a conflict between procedures regarding the frequency of calibrations.
 
.
The licensee has rewritten the whole body counter procedures. The new procedures represent a considerable improvement and are consisten There were calibratio questions regarding the adequacy of the source used for The licensee has consulted with the vendor on this issue and the vendor stated that, although the source used by the licensee is adequate, a better source is available that provides a more satisfactory peak distribution. The licensee has made arrangements to replace their current source with the  ,
more satisfactory sourc *
- Although QA/QC checks were being performed, there were no clearly specified acceptance crite"ia for the results of these test The licensee stated that control charts will be established to plot the results of these tests. The charts will contain the acceptance criteria for each tes There were no checks on the values of the Minimum Detectable Activities  l MDA arinted by the whole body computer to ensure that these MDAs meet the
%o iaximum Permissible Body Burden criterio <
The licensee stated that procedure changes and training will emphasize the j need to verify that the MDAs meet the required limit The sampling tubes in the respirator fit booths were not positioned  >
properly to ensure that they sampled the breathing zone in the boot l The Itcensee stated that the tubes have been repositioned to' properly sample the air in the boot ..
. .-
.
 
In addition to the above specific actions, the licensee stated that three members of the health physics supervision staff have enrolled in the vendor's training program on whole body counting. The vendor was also asked to review the whole body counting procedures to ensure that they were technically soun Bord on the above findings, all but one of the items previously identified in the inspection report have been satisfactorily resolved. The whole body counting pro ram will be reviewed during a future inspection to verify continued im lementation of the corrective action .0 Radiological Surveys j Review of the procedures for radiological surveys, as well as the surveys indicated that th records and tours of the plantimplementinganeffectiveroutinesurveyprogram.elicensee
,
Reviewed surveys were legible and completed at the required survey frequency. The procedures contained comprehensive instructions to the health physics technician concerning performance and evaluation of beta surveys. The inspector also noted the following licensee initiatives:
- A new program to reduce the volume of " M m etive waste has haan    '
initiated. The program is called "Green is Clean" and consists of providing green trash cans throughout the radiological controls area (RCA) for disposal of nonradioactive materials. The trash from these green cans is checked for radioactivity in a newly built monitoring facility before release as clean wast i
- The low radioactive waste facility has been upgraded by the installation of new equipment. This includes a waste shredder / compactor to reduce the volume of radioactive waste, and a sorting station to improve the
, efficiency of sorting radioactive waste. The station is equipped with
: radiation monitors and a ventilation system to protect the workers against the possibility of airborne radioactivit !
- The adhesive-backed "Radioactive Material" signs traditionally used to label metal radwaste containers have been replaced by magnetic label These labels are neater and are easy to remove, thus potentially reducing radiation exposure compared to removal of the stick-on labels.
 
j 4.0 Internal Exposure Control
, inspection of this part of the program included respirator issue, respirator maintenance and testing, air sampler calibration and a review of
-
the counting laboratory operation ,
,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
 
,
:
l
 
4.1 Respirator Issues end Maintenance Respirators are issued from a rooin within the RCA close to the control I point, Computer printouts are provided to the issue personnel detailing the respirator qualification status of personnel. Initial discussions with the licensee did not clearly indicate whether the list indicated the status of respirator fit or reflected all requirements, including medical and whole body count. Subsequent discussions showed that the list indicated only the status of respirator fit tests. The medical and whole body count requirements for respirator use are controlled at the dosimeter issue stage. A worker canr.ot be issued a dosimeter unless he has satisfied the medical and whole body count requirements, regardless of his resp (rator fit status. This practice is adequate to control respirator issu Storage of respirators in the issue room was found to acceptable. The respirators were sealed in plastic bags and individually stored in bin Each respirator was labeled with the last maintenance date. The licensee stated that the respirators available for issue are divided into two groups that are rotated at least once per quarter. This ensures that respirators will not remain in the issue room for a period of over a quarter without undergoing maintenance and inspectio After cleaning and inspecting the respirators in the respirator maintenance trailer, the rad waste technician who inspects the respirators puts on the respirator and performs a positive and negative fit test to check for leaks. The tested respirator is then sanitized by spraying with a disinfecting spray before packaging. This method is subjective and is not as sensitive as methods that employ a phantom head, an aeroscl generator, and readout meters. The licensee currently has this equipment in the respirator maintenance trailer but it has not yet been put in service. The ;
licensee stated that they will consider changing their current practices to use this equipmen I 4.2 Air Sample Analysis ector toured the countin Theinsgyzingairsamples.Recen for ana  room to reviewinthe im rovements thislicensee's capability area include the addition of a new automatic alpha / beta counter and the use of quality control charts to trend counting system performance data. The quality l control program is under the technical supervision of tha site health physicist. Review of the data and records showed that the counting room i operation was conducted in accordance with applicable station procedures and good practice. The following were observed:
-The current practice for counting air samples for alpha activity is to use ,
two trigger points. If the gross beta /gama counts show an activity of over I
 
.. .
.
 
9.0E-9 uCi/m1, the sample is analyzed on the gamma spectrometer. If the analysis on the spectrometer shows a Co-60 activity of over 9.0E-9 uCi/ml, the sample is counted for alpha activity. The Co-60 trigger level is based on analysis results of dry active waste, which included analyses for alpha
<
emitting radionuclides. The analyses showed that the alpha activity may be coupled to the level of the Co-60 activity so that the presence of Co-60 at less than 9.0E-9 uCi present will be belo/mlw any indicates thatlimit allowable any alpha activity that may be The MDA for the alpha channel of the alpha / beta counter did not meet the
,
'
required MDA of 25% of the applicable maximum permissible air concentration (MPC). The MDA in this case should be below 7E-12 uti/cc alpha activity. The MPC is based on the known ratios of the alpha emitting radionuclides in the sacples analyzed b
 
during the inspection was 2.09E-11 uCi/y the licensee. The posted MDAcc for a 20 It did not reach the desired level until the sample volume reached 60 cubic feet, which is the largest air volume used routinely by the licensee. The MDA values are based on a background counting time of 10 minutes and a sample counting time of 0.5 minute. Discussions with the licensee showed ite that the MDA the high requirements values. Infor assigning cases where intakes the MDAwere still being is greater met desp/ml, than 7E-12 uCi and the activity is less than the MDA, the MPC fraction, on which intake is calculated at the MDA. Following discussions calculations betwaen are bssed, the inspector and the licensee, the counting procedure was modified to lower the HDA to below 7E-12 uCi/ml at 20 cubic feet. This was done by increasing the sample counting time from 0.5 minute to 3 minutes.
 
! -The acceptance criterion for the background on the alpha channel on the automatic alpha / beta counter was I cpm. Calculations by the inspector
'
showed that this count rate, for a counting time of 10 minutes, corresponded to an MDA for a 20 cubic foot sample that is substantially higher than the desired 7E-12 uCi daily QC background check therefo/ml. This acceptance criterion on there does not g The licensee ht: since changed that criterion to 0.5 cp .3 Calibration and Testing of Air Sampling Equipment The calibration and testing of air samplers and filters were reviewed during this inspection. The licensee stated that filters used on respirators are used only once and discarded. The air sampling pumps are calibrated for air flow using a flo*:t testing jig fabricated on site. The flow tester calibration was current and NBS traceable. Observation of a typical calibration showed that the flow tester is of sufficient accuracy for its intended purpos .0 Proposed Changes in Organization Durtwf the inspection, the itcensee explained to the inspector )roposed charges in the organization of the Health Physics department. T1e current org nization includes three supervisors who report directly to the Health Physics Supervisor. One of these positions, the Radioactive Materials
 
. . . ..-
. .
 
Handling Superviser position, is to be deleted. The person filling this
  )osition will become an assistant supervisor who reports to the Radiation f
report to that Radiation Protectio)n Supervisor (Operations .3rotection Supervisor The current organization chart show2 distinct groups of technicians reporting to each of these three individuals the Radioactive Materials HandlingSuervisorandtwoAssistantRadiatIonProtectionSupervisors joperations . The new organization chart shows all three su ervisors in one box" jointl with 11The the inspector technicians (health : physics and radwastereporting to them  expressed oncern that this kin of organization does not clearly show the lines of responsibility and may lead to less efficient supervision. It may also lead to conflicts of interest between the radwaste and decontamination functions and the health physics functions if both are supervised by the same individual. Finally, it may lead to errors in the area of radwaste handling because of the specialized nature and requirements of this function. The licensee stated that the proposed chart is preliminary and that these concerns will be taken into consideration before making a final decisio .0 Exit Meeting The inspector met with the licensee representatives at the end of the inspection on September 9,1988. The inspector summarized the scope of the inspection and the finding .
      '
,
i      ,
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Latest revision as of 12:56, 30 December 2020

Insp Rept 50-213/88-18 on 880906-09.No Violations Noted. Major Areas Inspected:Radiological Controls Program, Including Radiation Surveys,Respirator Issue & Maint,Air Sampling Equipment Calibr & Counting Room Operations
ML20204H968
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 10/14/1988
From: Shanbaky M, Sherbini S, Weadock A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204H915 List:
References
50-213-88-18, NUDOCS 8810240509
Download: ML20204H968 (7)


Text

.. .

.

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-18 Docket No. 50-213 License No. DPR-6* Priority - Category C Licensee: Connecticut Yankee Atomic Power Company Facility Name: Haddam Neck Power Station Inspection At: Haddam Neck, Connecticut Inspection Conducted: September 6-9, 1988

'

- >

Inspectors: -

hAS A. Weadock, Radiation 3pecialist

'0/W[!M8 date

Facilities Radiation Protection Sectien cm {3 D ,-) & G'

5. 5herbin1, Tentor Radiation Specialist I O /t9/I938 date'

Facilities Radiation Protection Section Approved by: -A*/ .5 M ChTef f

/o////f[

' date DFacilities

. 5hanbakylation Rad Protection Section i

.

l Inspection Summary: Inspection September 6-9, 1988 (Report No. 50-213/88-18) l Areas Inspected: Routine, unannounced inspection of the radiological controls incluling radiation surveys, respirator issue and maintenance, program, air samp ling equipment calibration, counting room operations, and the status of previously identified item Results: No vio'ations were identifie l 8910240509 G81017 PDR i

O ADOCK 05000213 i PDC J l

'

.. .

DETAILS 1.0 Personnel Contacted 1.1 Licensee Personnel

  • H. Clow, Health Physics Supervisor
  • E. Debarba, Station Services Superintendent B. Groves, Assistant Radiation Protection Supervisor
  • D. Hiller, Jr., Station Superintendent
  • W. Nevelos, Radiation Protection Supervisor M. Sweeney, Radiation Protection Supervisor 1.2 NRC Personnel
  • T. Shadlosky, Senior Resident Inspector
  • A. Asars, Resident Inspector
  • Denotes attendance at the exit meetin .0 Status of Previously Identified Items:

Inspection report 87-30 identified a number of concerns regarding the operation of the whole body counter and respirator fit facility. The following actions were taken by the licensee to resolve these issues:

I

- The manufacturer recommends that the detector electronics on the whole l body counter be adjusted before collecting data for calibration purpose l The licensee was not sure if the service contract with the vendor included '

'

such adjustment The licensee has added instructions in the procedure on gain adjustment 1 prior to calibration. However the electronic adjustments mentioned above includeadjustmentsofcontrolsthataffectpulseshapeandrequiresome technical expertise to perforn. It is still not clear whether these adjustments are part of the routine vendor services. This item will be reviewed during a future inspectio The procedures did not specify a minimum number of counts in each peak used for system calibratio The licensee has added a minimum count requirement to the procedure The required monthly QA tests were not formally specified, l

,

.

.. .

The licensee has specified all the required QA/QC tests for the whole body counters in the appropriate procedure Part of the OA program included a vendor supplying spiked samples periodically. However, procedures did provide details for conducting these tests and for accep Lnce criteri The licensee stated that these tests are not a formal part of the QA program for the whole body counter and should therefore not be included in the Procedures. The tests are performed only for added assurance to the i program supervisors. The rest of the quality control program was inspected in a previous Report inspection and was found to be satisfactoryThis item is therefore considere 50-213/87-30).

- There was a conflict between procedures regarding the frequency of calibrations.

.

The licensee has rewritten the whole body counter procedures. The new procedures represent a considerable improvement and are consisten There were calibratio questions regarding the adequacy of the source used for The licensee has consulted with the vendor on this issue and the vendor stated that, although the source used by the licensee is adequate, a better source is available that provides a more satisfactory peak distribution. The licensee has made arrangements to replace their current source with the ,

more satisfactory sourc *

- Although QA/QC checks were being performed, there were no clearly specified acceptance crite"ia for the results of these test The licensee stated that control charts will be established to plot the results of these tests. The charts will contain the acceptance criteria for each tes There were no checks on the values of the Minimum Detectable Activities l MDA arinted by the whole body computer to ensure that these MDAs meet the

%o iaximum Permissible Body Burden criterio <

The licensee stated that procedure changes and training will emphasize the j need to verify that the MDAs meet the required limit The sampling tubes in the respirator fit booths were not positioned >

properly to ensure that they sampled the breathing zone in the boot l The Itcensee stated that the tubes have been repositioned to' properly sample the air in the boot ..

. .-

.

In addition to the above specific actions, the licensee stated that three members of the health physics supervision staff have enrolled in the vendor's training program on whole body counting. The vendor was also asked to review the whole body counting procedures to ensure that they were technically soun Bord on the above findings, all but one of the items previously identified in the inspection report have been satisfactorily resolved. The whole body counting pro ram will be reviewed during a future inspection to verify continued im lementation of the corrective action .0 Radiological Surveys j Review of the procedures for radiological surveys, as well as the surveys indicated that th records and tours of the plantimplementinganeffectiveroutinesurveyprogram.elicensee

,

Reviewed surveys were legible and completed at the required survey frequency. The procedures contained comprehensive instructions to the health physics technician concerning performance and evaluation of beta surveys. The inspector also noted the following licensee initiatives:

- A new program to reduce the volume of " M m etive waste has haan '

initiated. The program is called "Green is Clean" and consists of providing green trash cans throughout the radiological controls area (RCA) for disposal of nonradioactive materials. The trash from these green cans is checked for radioactivity in a newly built monitoring facility before release as clean wast i

- The low radioactive waste facility has been upgraded by the installation of new equipment. This includes a waste shredder / compactor to reduce the volume of radioactive waste, and a sorting station to improve the

, efficiency of sorting radioactive waste. The station is equipped with

radiation monitors and a ventilation system to protect the workers against the possibility of airborne radioactivit !

- The adhesive-backed "Radioactive Material" signs traditionally used to label metal radwaste containers have been replaced by magnetic label These labels are neater and are easy to remove, thus potentially reducing radiation exposure compared to removal of the stick-on labels.

j 4.0 Internal Exposure Control

, inspection of this part of the program included respirator issue, respirator maintenance and testing, air sampler calibration and a review of

-

the counting laboratory operation ,

,

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

,

l

4.1 Respirator Issues end Maintenance Respirators are issued from a rooin within the RCA close to the control I point, Computer printouts are provided to the issue personnel detailing the respirator qualification status of personnel. Initial discussions with the licensee did not clearly indicate whether the list indicated the status of respirator fit or reflected all requirements, including medical and whole body count. Subsequent discussions showed that the list indicated only the status of respirator fit tests. The medical and whole body count requirements for respirator use are controlled at the dosimeter issue stage. A worker canr.ot be issued a dosimeter unless he has satisfied the medical and whole body count requirements, regardless of his resp (rator fit status. This practice is adequate to control respirator issu Storage of respirators in the issue room was found to acceptable. The respirators were sealed in plastic bags and individually stored in bin Each respirator was labeled with the last maintenance date. The licensee stated that the respirators available for issue are divided into two groups that are rotated at least once per quarter. This ensures that respirators will not remain in the issue room for a period of over a quarter without undergoing maintenance and inspectio After cleaning and inspecting the respirators in the respirator maintenance trailer, the rad waste technician who inspects the respirators puts on the respirator and performs a positive and negative fit test to check for leaks. The tested respirator is then sanitized by spraying with a disinfecting spray before packaging. This method is subjective and is not as sensitive as methods that employ a phantom head, an aeroscl generator, and readout meters. The licensee currently has this equipment in the respirator maintenance trailer but it has not yet been put in service. The ;

licensee stated that they will consider changing their current practices to use this equipmen I 4.2 Air Sample Analysis ector toured the countin Theinsgyzingairsamples.Recen for ana room to reviewinthe im rovements thislicensee's capability area include the addition of a new automatic alpha / beta counter and the use of quality control charts to trend counting system performance data. The quality l control program is under the technical supervision of tha site health physicist. Review of the data and records showed that the counting room i operation was conducted in accordance with applicable station procedures and good practice. The following were observed:

-The current practice for counting air samples for alpha activity is to use ,

two trigger points. If the gross beta /gama counts show an activity of over I

.. .

.

9.0E-9 uCi/m1, the sample is analyzed on the gamma spectrometer. If the analysis on the spectrometer shows a Co-60 activity of over 9.0E-9 uCi/ml, the sample is counted for alpha activity. The Co-60 trigger level is based on analysis results of dry active waste, which included analyses for alpha

<

emitting radionuclides. The analyses showed that the alpha activity may be coupled to the level of the Co-60 activity so that the presence of Co-60 at less than 9.0E-9 uCi present will be belo/mlw any indicates thatlimit allowable any alpha activity that may be The MDA for the alpha channel of the alpha / beta counter did not meet the

,

'

required MDA of 25% of the applicable maximum permissible air concentration (MPC). The MDA in this case should be below 7E-12 uti/cc alpha activity. The MPC is based on the known ratios of the alpha emitting radionuclides in the sacples analyzed b

during the inspection was 2.09E-11 uCi/y the licensee. The posted MDAcc for a 20 It did not reach the desired level until the sample volume reached 60 cubic feet, which is the largest air volume used routinely by the licensee. The MDA values are based on a background counting time of 10 minutes and a sample counting time of 0.5 minute. Discussions with the licensee showed ite that the MDA the high requirements values. Infor assigning cases where intakes the MDAwere still being is greater met desp/ml, than 7E-12 uCi and the activity is less than the MDA, the MPC fraction, on which intake is calculated at the MDA. Following discussions calculations betwaen are bssed, the inspector and the licensee, the counting procedure was modified to lower the HDA to below 7E-12 uCi/ml at 20 cubic feet. This was done by increasing the sample counting time from 0.5 minute to 3 minutes.

! -The acceptance criterion for the background on the alpha channel on the automatic alpha / beta counter was I cpm. Calculations by the inspector

'

showed that this count rate, for a counting time of 10 minutes, corresponded to an MDA for a 20 cubic foot sample that is substantially higher than the desired 7E-12 uCi daily QC background check therefo/ml. This acceptance criterion on there does not g The licensee ht: since changed that criterion to 0.5 cp .3 Calibration and Testing of Air Sampling Equipment The calibration and testing of air samplers and filters were reviewed during this inspection. The licensee stated that filters used on respirators are used only once and discarded. The air sampling pumps are calibrated for air flow using a flo*:t testing jig fabricated on site. The flow tester calibration was current and NBS traceable. Observation of a typical calibration showed that the flow tester is of sufficient accuracy for its intended purpos .0 Proposed Changes in Organization Durtwf the inspection, the itcensee explained to the inspector )roposed charges in the organization of the Health Physics department. T1e current org nization includes three supervisors who report directly to the Health Physics Supervisor. One of these positions, the Radioactive Materials

. . . ..-

. .

Handling Superviser position, is to be deleted. The person filling this

)osition will become an assistant supervisor who reports to the Radiation f

report to that Radiation Protectio)n Supervisor (Operations .3rotection Supervisor The current organization chart show2 distinct groups of technicians reporting to each of these three individuals the Radioactive Materials HandlingSuervisorandtwoAssistantRadiatIonProtectionSupervisors joperations . The new organization chart shows all three su ervisors in one box" jointl with 11The the inspector technicians (health : physics and radwastereporting to them expressed oncern that this kin of organization does not clearly show the lines of responsibility and may lead to less efficient supervision. It may also lead to conflicts of interest between the radwaste and decontamination functions and the health physics functions if both are supervised by the same individual. Finally, it may lead to errors in the area of radwaste handling because of the specialized nature and requirements of this function. The licensee stated that the proposed chart is preliminary and that these concerns will be taken into consideration before making a final decisio .0 Exit Meeting The inspector met with the licensee representatives at the end of the inspection on September 9,1988. The inspector summarized the scope of the inspection and the finding .

'

,

i ,

l

l l

l

_ -- -__ - _ _ _