IR 05000029/1986012

Insp Rept 50-029/86-12 on 860811-15.No Noncompliance Noted. Major Areas Inspected:Radiation Protection Program,Including Organization & Staffing,Procedures Rev Project,Inpo Audit, Recordkeeping & QC Program for Radwaste

ML20206S980
Person / Time
Site:	Yankee Rowe
Issue date:	09/08/1986
From:	Dragoun T, Kaminski M, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206S971	List: IR 05000029/1986012 ML20206S966
References
50-029-86-12, 50-29-86-12, NUDOCS 8609230063
Download: ML20206S980 (8)

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. I U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 86-12 Docket No. 50-29 License No. DPR-3 Priority -- Category C Licensee: Yankee Atomic Electric Company 1671 Worcester Road Framingham, MA 01701 Facility Name: Yankee Nuclear Power Station Inspection At: Rowe, Massachusetts Inspection Conducted: August 11-15, 1986 Inspectors: _-1t h 92 [d

' dhte Th6m~as N g , Radiation Specialist N.MCtmo O N Marino'Ksminski, Rafiation Specialist 'date Approved by: M S foi Mohamed Shan5aly, Chief f I// _7! [ da'te Facilities Radiation Protection Section Inspection Summary: Inspection on August 11-15, 1986 (Report No. 50-29/86-12)

Areas Inspected: Routine, announced inspection of the licensee's radiation protection program including: status of previously identified items; organi-zation and staffing, procedures revision project, record keeping, training and qualification, QC Program for radwaste and the INP0 audi Results: No items of non-compliance were identifie PDR 0 ADOCK 05000029 PDR i

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DETAILS Persons Contacted During the course of this routine inspection the following personnel were

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contacted or interviewed:

1.1 Licensee Personnel N. N. St. Laurent, Plant Superintendent

• T. K. Henderson, Technical Director

• B. L. Drawbridge, Assistant Plant Superintendent

• G. M. Babineau, Radiation Protection Manager

• R. A. Mellor, Chemistry Manager E. Chatfield, Training Manager L. Bozek, Quality Control Supervisor P. Hollenbeck, Radiation Protection Engineer

• T. Shippee, Radiation Protection Engineer M. T. Vandale, Radiation Protection Engineer H. Farr, Radiation Protection Engineer

• J. Geyser, Radiation Protection Engineer 1.2 NRC Personnel J. W. C1tfford, NRR - Project Manager H. Eichenholz, Senior Resident Inspector Other licensee or contractor employees were also contacted or inter-viewed during this inspectio * Attended exit interview on August 15, 198 . Purpose The purpose of this routine inspection was to review the licensee's radi-ation protection program with respect to the following elements:

Status of previously identified items;

Organization and staffing;

Procedures revision project;

Record keeping;

Training and qualifications; and

Quality Control Program for Radwast . Status of Previously Identified Items (Closed) Inspector Followup Item (50-29/84 15-02) Conduct ALARA review of calibration facilities for survey meters. The calibration facility has been movei tc the safety injection and diesel room in the diesel generator building. The licensee has purchased a new calibration source that can be

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. locked in a co111 mated shield. . Licensee personnel no longer handle Cobalt-60 capsule sources for instrument calibration.

l- (0 pen) Inspector Followup Item (50-29/84-15-03) Revise calibration proce-

, dures to incorporate ANSI-323 and Regulatory Guide 8.25. Formal calibra-tion procedures are being developed for each instrument. A new calibra-i tion form has been issued. Newly developed calibration procedures will i

be reviewed during a subsequent inspection.

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(0 pen) Inspector Followup Item (50-29/85-16-01) Establish controls to ensure all requirements are met during requalification of respirator users. The present control system will be replaced by the Health Physics

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Information System (HIS) in January, 1987. This HIS will be examined during a subsequent inspection.

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(Closed) Inspector Followup' Item (50-29/85-16-02) Revise respirator class-room training to include all information required by 10 CFR 20.103(c)(3).

Procedure AP8422, Revision 6, Section 7, " Emergency Exit" addresses 10 CFR 20.103(c)(3). An addendum to the General Employee Training lesson plan includes 10 CFR 20.103(c)(3).

(0 pen) Inspector Followup Item (50-29/85-16-03) Review progress.of Radia-

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tion Protection Procedure Upgrade Project. The progress of the Procedure

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Upgrade Project is discussed in Section (Closed) Unresolved Item (50-29/85-23-01) ALARA Program elements needed:

hire ALARA Coordinator, issue corporate policy, establish work package

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exposure goals, track exposure performance. Licensee has hired an ALARA Coordinator. Yankee Atomic Electric Company Technical Administration Guide #15, Revision 0, 07/24/84, states the corporate ALARA policy. A

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station ALARA goal of 75 man-rem has been established. Station and departmental ALARA tracking is being done by computer.

l (Closed) Inspector Followup Item (50-29/86-04-01) Position Descriptions "

I to be revised. The position descriptions of the Radiation Protection

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Manager and the Chemistry Manager have been revised to delineate appro-priate Offsite Dose Manual Calculation responsibilitie (Closed) Inspector Followup Item (50-29/86-04-04) Format changes to computer program to determine ODCM setpoints. Program has been modified to increase the number of isotopes from 9 to 15 and to allow the input of 5 additional isotopes if found during samplin . Organization and Staffing The organization and staffing of the Radiation Protection (RP) Department was reviewed with respect to criteria contained in:

Technical Specification 6.2 Organization;

Technical Specification 6.3 Facility Staff Qualifications; Technical Specification 6.4 Training;

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ANSI N18.1-1971 " Selection and Training of Nuclear Power Plant Personnel";

YAEC Job Descriptions - Radiation Protection Manger, Radiation Protection Engineer, Lead Radiation Protection Technician, Radiation Protection Technician;

NUREG-0731 " Guidelines for Utility Management Structure and Technical Resources (Draft)" September,1980;

NUREG/CR-1280 " Power Plant Staffing" January, 1980; and

Station Procedure AP8001, " Radiation Protection Department Organization and Training," Revision The licensee performance relative to these criteria was determined from:

Discussions with the Radiation Protection Manager and Technical Director; A review of personnel experience and trsining resumes; and

Interviews with three newly appointed Radiation Protection Engineer Within the scope of this review, licensee strengths and program improve-ments were noted by the following:

The professional staff has been increased to five Radiation Protec-tion Engineers who report to the Radiation Protection Manager. Job descriptions are available and each position is filled by a qualified permanent employee. However, certain administrative procedures have not been revised to reflect this increased staffing leve *

One of the Radiation Protection Engineers is dedicated to the imple-mentation of a record keeping system using a main frame computer sys-tem recently installed on-site. The licensee indicated that a state of the art software package has been purchased and the database is currently being loaded. Full implementation of the system including new site procedures and training of site personnel is anticipated prior to the next outage in May, 198 *

The licensee has addressed a previous NRC concern regarding staff depth and development by assigning each member of the expanded staff with primary and backup responsibilities. Cross training is provided where required. Although not currently documented, the licensee stated that this program will be formalized in the training program being submitted for INPO accreditatio *

The licensee abolished the position of " tester" which consisted of RP technicians in training. Only technicians qualified in accordance with ANSI N18.1 are allowed on staf . Procedures Revision Project In the previous SALP report the licensee was advised that the radiation protection procedures at that time were poorly written, poorly understood and ambiguous. In response the licensee undertook a major project to

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revise and update all radiation protection procedures. Completion of this project was targeted for mid-1986. The status of this project and the new procedures were reviewed with respect to criteria provided in:

Technical Specification 6.8 - Procedures; _

Regulatory Guide 1.33, November 1972 - Quality Assurance Program Requirements; and

10 CFR 20 - Standards for Protection Against Radiatio The status of this program was determined from interviews with the Radi-ation Protection Manager and reviews of final and draft procedure Status is as follows:

Completion of this project has been rescheduled to late 1986. How-ever, full implementation including retraining of site personnel s anticipated prior to the May, 1987 Refueling Outag *

Some delay was caused by the licensee 's decision to develop a two tiered approach to procedures. One set of procedures would be used by the RP staff and a parallel set of simplified procedures will be developed for worker *

The procedures for Radiation Work Practices (AP-0801), Radiological Deficiency Report (AP-0802) and Radiation Work Permits (AP-0806) were determined to be clear, thorough, and of high technical qualit Within the scope of this review, licensee progress on this project is determined to be adequat . Record Keeping Routine Surveys The licensee program for conducting surveys was reviewed against criteria contained in:

10 CFR 20.201 Surveys; and

Procedure OP-8101, Revision 11, Plant Radiological Survey The following surveys were examined:

Normal Operations

Control Point and Primary Chemistry;

Waste Processing Area;

Primary Vent Stack Monitoring and Sample Room;

Clean Area II; and

Special Survey *

Refueling or Extended Shutdown

i Upper Primary Auxiliary Building I and Gas Room; and

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Control Area Machine Shop.

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1 Procedure OP-8101, Revision 10, Attachment A requires that the Control ,

Point and Primary Chemistry Surv!y be conducted at least daily during normal operation On 02/17/86 and 07/25/86 the licensee failed to perform this surve The inspector determined that the survey on 02/17/86 was missed due to a misinterpretation of the procedur The licensee has taken the following corrective actions:

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• Supervisory personnel met with the responsible technician and discus-sed the situation, though documentation of this meeting is missin * The licensee has issued a memorandum providing the correct interpre-tation of the procedur ,

• The next scheduled survey of the area was performed and no abnormal results were note Because the licensee has met the five criteria specified in 10 CFR 2, Appendix C (V)(A) and the licensee's followup action was determined to be adequate, no violation will be issue The inspector determined that the survey on 07/25/86 was missed due to human oversight. The licensee is in the process of taking the following corrective actions:

• Supervisory personnel will meet with the responsible technician to discuss the situatio This meeting will be documente * A new revision of this procedure is due at the end of September which will include a new survey char * Technicians will receive training on the new procedur Supervisory response to this incident has been good. Because the licensee has met the five criteria specified in 10 CFR 2, Appendix C (V)(A)

and the licensee's followup action was determined to be adequate, no violation will be issue However, this item will remain open (50-29/86-12-01) until the licensee has fully implemented all corrective action . Health Physics Technician Requalification Training The licensee's Health Physics Technician Requalification training course ;

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was reviewed with respect to criteria contained in:

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• Procedure AP-8001;

• Technical Specification 6.4.1;  ;

• Procedure AP-0226;

• ANSI N18.1 1971; and

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The licensee's performance was determined by:

Examination of course lesson plans and handouts;

Conversation with the instructor; and

Direct observation of classroom instructio In response to an INP0 recommendation, the licensee has contracted for a one week requalification course for Health Physics technicians. The course provides review of basic health physics theory. The structure of the course is informal as evidenced by the following:

Licensee management did not preview the course lesson plan;

Licensee management will not receive the lesson plan until the course is completed;

No attendance sheet is used, though attendance will be documented in the instructor's report; and

The instructor will grade the exams but is not aware of the passing criteri The licensee stated that a more formalized course is being developed as a part of the INPO accreditation effor The inspector noted a good management / technician interaction in the train-ing on new procedures. Technician feedback is used to upgrade procedure The inspector noted this as a strong point in the program. The inspector found the course to be satisfactor . QC Program for Radwaste In the Fall of.1985 the licensee established an independent Quality Con-trol Department at the plant to provide oversight for radwaste and other programs. This group provides the radwaste checks required by 10 CFR 20.311, 10 CFR 61.55 and 10 CFR 61.5 The status of this program was determined from discussion with the QC Manager and a review of selected documents and procedure Within the scope of this review it was determined that the QC program for radwaste is fully operational. The initial training and qualification of two QC inspectors is complete. Inspection checklists, holdpoints in pro-cedures, and inspection schedules have been issue The inspector noted that this program exceeds regulatory requirements considering limited amount and level of radwaste generated by the plan . INPO Audit The licensee provided the inspector with the results of an audit of the Radiation Protection Program by INPO in January, 1986. The inspector l

became concerned regarding certain findings and reviewed these in detail with the licensee. Based on additional information provided by the

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licensee, the inspector concluded that workers are adequately protected, no major programmatic weakness is indicated, and that regulatory action is not warrante Within the scope of this review, no violation was observe . Exit Interview The inspector met with licensee personnel at the conclusion of the inspec-tion on August 15, 1986 to discuss the scope and findings of the inspec-tion.

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