ML20153C985

Radiological Controls Insp Rept 50-309/88-12 on 880718-22. No Violations Identified.Major Areas Inspected:Radiological Controls Organization,Staffing & Qualifications,Audits,Alara & Corrective Action Sys

ML20153C985
Person / Time
Site:	Maine Yankee
Issue date:	08/23/1988
From:	Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20153C987	List: ML20153C985
References
50-309-88-12, NUDOCS 8809010383
Download: ML20153C985 (10)

See also: IR 05000309/1988012

Text

'

.

.

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-309/88-12

Docket No. 50-309

License No. DPR-36 Priority - Category C

Licensee: Maine Yankee Atomic Power Company

83 Edison Drive

Aucusta, Maine 04336

Facility Name: Maine Yankee Atomic Power Station

Inspection At: Wiscasset, Maine

Inspection Conducted: July 18-22, 198_8

Inspector: RL WM

R. L. Nimitz, Senior Radiation Specialist

8\t3 lva

date

'

Approved by: ,

"

M'~5fia7ibaky, chtet, tactlities Radiation

S/tT/ST

Gy date

,

C Protection Section

Inspection Summary: Inspection canducted on July, 18-22, 1988 (Inspection

Report No. 50-309/88-12)

,

Areas inspected: Routine unannounced Radiolo l

following: radiological co,ntrols organization,gical Controls

staffing Inspection of the

and qualifications; i

audits; ALARA; corrective action system; external and internal exposure controls I

and yard contamination, i

Results: No violations were identified.

I

I

8809010363

PDR PDC 880823ADOCK 05000309 l

l

O

'

.

.

.

.

.

DETAILS

1.0 Individuals Contacted

1.1 Mt.ine Yankee

J. B. Randazza, President

J. N. Garrity, Vice President

E. T. Boulette, Plant Manager

J. Brinkler, Assistant Plant Manager

G. Cochrane, Radiological Controls Section Head

.

G. Pillsbury, Actirg Radiological Controls Section Head <

W. K. Peterson, Manager QA Audit Group

i J. C. Frothingham, Manager of Quality Programs

S. D. Evans, Senior Licensing Coordinator

'

D. Sturniola, Principal Radiological Engineer

1.2 NRC

L. Tripp, Chief, Reactor Projects Section 3A, RI

P. Sears, Project Manager, NRR

R. Fruedenberger, Resident Inspector, Maine Yankee

The above individuals attended the exit meeting on July 22, 1988.

The inspector also contacted other licensee personnel during the course of

this inspection.

2.0 Purpose and Scope of Inspection

This inspection was a routine, unannounced Radiological Controls

Inspection. The following areas were reviewed:

- organization and staffing;

-qualifications

- corrective actlonsystem;

.

'

- audits;

- planning and preparation for the upcoming outage;

- ALARA;

- external exposure controls;

- internal exposure controls; and

- yard contamination.

3.0 Licensee Action on Previous Findings )

3.1 50-309/88-08-02 . Licensee to review and

(Closed)the

evaluate Inspector Follow

whole body up Item

counter. (The licensee's w) hole body counting i

program did not provide administrative controls to ensure that the

detectors of the whole body counter were properly aligned prior to counting

of personnel.

i

!

l

,

"

.

.

3

The licensee placed a tape marker on the whole body counting chair and

verbally instructed personnel to check that the detectors were properly

aligned prior to counting. Inspector discussions with licensee personnel

indicated all individuals who may whole body count personnel may not have

been verbally instructed. The licensee immediately issued a memorandum to

all appropriate personnel regarding this matter. The licensee performed a

preliminary review of the potential for improperly counting personnel if

the detectors were not properly aligned . Licensee review indicated some

personnel could be improperly counted if the detectors were not properly

aligned prior to counting. The licensee indicated that an evaluation would

be performed to determine if personnel may have left the site with

undetected intakes of airborne radioactive material.

This Inspector Follow-up Item is closed for administrative purposes.

Further NRC review of this matter and review of licensee evaluations and

corrective actions for this matter will be made under Unresolved Item No.

50-309/88-12-01.

4.0 Organization and Staffing

The inspector reviewed the organization and staffing of the onsite

Radiation Protection Group with respect to criteria contained in the

following:

- Technical Specification 5.2, Organization; and

- Regulatory Guide 8.8, Information Relevant to Ensuring That

Occupational Radiation Exposure At Nuclear Power Stations Will Be As Low

As Is Reasonably Achievable.

Evaluation of licensee performance in this area was based on review of

resumes and discussions with personnel.

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

The follvwing matters were discussed with licensee representatives:

'

- The Radiological Controls Section Head who had been detailed to IHP0 for

the past year and a half has returned to the onsite organization. The

individual is currently in a turnover status with the individual who

filled the incumbent's position. The inspector observed an ap

orderly turnover of information and responsibility occurring. parent

The

licensee's initiative to improve the background of Radiological Controls

Section management by detailing personnel to INP0 was considered good.

- The licensee is reorganizing the onsite Radiation Protection Group to i

provide for a superintendent level Radiation Protection Manager.  !

Preliminary review indicates this will reduce the span of control of

some positions in the group and provide for enhanced oversight of day to

day program activities. The effectiveness of this reorganization and the

revision of applicable administrative documents will be reviewed during

subsequent inspections. l

I

l

t

"

,

,

t

4

- The licensee performed a job task analysis of the Radiation Protection

Group. The analysis indicated the need for at least two more radiation

protection technicians. The licensee is evaluating the analysis and

reviewing staffing levels of other facilities for areas of organizational

improvement at Maine Yankee. The licensee recently filled a number of

technician vacancies via qualification of a group of technician

candidates.

- The licensee recently filled the vacant positions of Respiratory

Protection Coordinator and Hazardous Waste Coordinator. With the

exception of the two technicians discussed above, the organization is

fully staffed.

- The licensee uses radiation protection technicians to perform some

limited chemistry functions. This was reviewed during Inspection No.

50-309/88-08 and found acceptable.

- Inspector review of job

Lead Radiological Contro$osition descriptions

s Specialist) indicatesfor

thesome

needpersonnel (e.g.If

to review an

update the descriptions to accurately reflect responsibilities and

authorities. The licensee recognized this need and is currently updating

the descriptions.

5.0 Qualifications

The inspector reviewed the qualifications of members of the Radiation

Protection Group with respect to criteria contained in Technical

Specification 5.3 Facility Staff Qualifications. Licensee performance in

thisareawasevaluatedbyreviewofresumesanddiscussionswithcognizant

personnel.

Within the scope of t'11s review no apparent violations were identified.

Inspector review of tne overall technical and experience level of personnel

in the Technical Support area of the Radiation Protection Group indicated a

need for enhancement in this area. The licensee has recognized the need

for this enhancement and is

personnel in selected areas (providinc

e.g.

.

additional offsite training

o sent personnelofThe licensee has als,ra

protection)ir

enhance the capabilities.

6.0 Audits

The inspector reviewed licensee audits of the Radiation Protection Program

with respect to criteria contained in Technical Specification 5.5, Review

and Audit.

Within the scope of this review, no violations were identified. Audit

quality appears to be improving. Technical Specialists from the Yankee

Nuclear Services Group continue to be used to perform audits. Audits

appeared to be more performance based. The licensee plans to audit the

area of radiation protection during the outage.

__ , _ _ _ _ _ __ __

-

-

.

l

!

. l

l

l

5

7.0 Planning and Preparation for the Upcoming Outage

The inspector reviewed the licensee's planning and preparation in the area

of radiation protection for the upcoming outage. Evaluation of licensee

performance in this area was based on discussions with personnel and review

of documentation. The following areas were reviewed and discussed with

licensee personnel:

- work scope;

- organization and augmentation of the staff to support outage activities;

- assignment of responsibilities and oversight of outage work activities;

- equipment and supplies (e.g., shielding and protective clothing);

- ALARA planning and preparation; and

- licensee actions to preclude recurrence of radiation protection problems

identified during the previous outage.

Within the scope of this review, no apparent violations were identified.

Overall licensee planning and preparation appeared to be adequate. The

licensee purchased additional supplies to support the outage.

Person-loading and organizational charts were under development. Identified

outage work was being pre-reviewed both from an ALARA stand point and from

an in-field radiological controls stand point. Specific procedures were

under development to specify radiological controls for the outage. Special

worker instructions were being developed to provide consistent radiological

controls for activities.

8.0 External Exposure Controls

The inspector reviewed licensee external exposure controls with respect to

criteria contained in applicable licensee procedures t.nd 10 CFR 20,

Standards for Protection Against Radiation.

The following matters were reviewed:

i

-

Sosting, barricading and access control, as appropriate, to radiation and

ligh radiation areas; and

- radiation exposure of personnel, including maintenance of appropriate

exposure history files. ,

.

The licensee's program for controlling external exposure was reviewed by I

the following methods: '

- discussion with personnel;

- review of selected personnel exposure records;

- review of licersee exposure investigations; and

- tours of plant areas and review of High Radiation Area controls.

i

Within the scope of the above review, no violat',ons were identified.

l

l

.. . -

.

.

"

. ,

6

The inspector noted during plant tours that systems and piping exhibited a

considerable number of "hot spots" which tended to increase general area

background radiation levels. The licensee was aware of the concern

associated with the hot spots and was reviewing them.

The inspector noted that the licensee identified several instances where

termination reports detailing exposure received at Maine Yankee were not

transmitted to personnel as required. The identification was made during

licensee efforts to computerize all exposure files. The licensee is further

reviewing this matter. Licensee follow-up and resolution of this natter is

unresolved and will be reviewed during a subsequent inspection

(50-309/88-12-02).

9.0 Internal Evgosure Controls

The inspector reviewed selected aspects of the internal exposure controls

program. The review was with respect to criteria contained in applicable

licensee procedures and regulatory requirements. The following matters

were reviewed:

- posting of airborne radioactivity areas; and

- bioassays and personnel airborne radioactivity intakes.

Evaluation of licensee performance in this area was based on discussions

with personnel, tours of the facilities and review of documentation. Within

the scope of this review, no violations were identified. No apparent

intakes of airborne radioactivity by personnel in excess of 40 mpc-hrs.

were identified for 1987. The licensee is currently in the process of

upgrading his whole body counting capabilities with state of the art Geli

systems. The following areas for improvement were identified:

- The licensee's procedure guidance for whole body counting of personnel

specifies that whole body counts are to be given when an individual was

exposed to an airborne radioactivity concentration of 10 x MPC.

Consideration should be given to counting of selected workers on jobs

with a high potential of generating airborne radioactivity. This would

provide some oversight of the quality of the respiratory protection

program and the adequacy of the licensee's airborne radioactivity

sampling program. Licensee personnel indicated this would be reviewed.

- Although the licensee is taking action to install drip collectors on

leaking valves to limit the spread of contamination and thus the

potential for personnel contamination and intakes of airborne

the station exhibits a total contaminated area of about

radioactivity,

15% not including containment. Additional action as appropriate, should

be Initiated to further reduce the extent of station contamination.

!

'

'

.

,

.

.

7

10.0 ALARA

The inspector reviewed selected aspects of the licensee's ALARA Program.

Emphasis was placed on licensee performance during the past outage and

planning and goal setting for the upcoming outage. The review was with

respect to criteria contained in the following:

- Maine Yankee Radiation Protection Manual

- Maine Yankee ALARA Program

- Procedure 9.1.28, Implementation of the Maine Yankee ALARA Program

- Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational

Ex)osure at Nuclear Power Stations Will Be As Low As Is Reasonably

Ac11evable

- Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational

Radiation a Lou As is Reasonably Achievable

- NUREG/CR-3254(ow

Radiation As As Is Reasonably AchievableLicensee Programs for Maintai

- NUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power

Stations; Study on High-Dose Jobs, Radwaste Handling and ALARA

Incentives.

Within the scope of this review no violations were identified. The

following matters were discussed with licensee personnel:

1987 ALARA Performance

The licensee sustained 7 total exposure for 1987 of 690 person .em. Of l

this 597 person-rem was sustained during the outage. About 409 person-rem i

oft $e597wasreviewedbytheALARACommittee.Reviewofseveralmajor l

steam generator dryer replacement

tasks

and sea(lworkandsteamgeneratorinspectIcnreactor coolant

indicated pump impeller

generally adequate

ALARA preplanning. Licensee exposure totals r)eflect an aggressive effort to

maintain plant availability and sr.fety through considerable preventive

maintenance. Licensee exposure totals for ma;or tasks (such as reactor

coolant pump seal replacement comoare favorably with industry averages.

Although licensee several areas for

improved performance wereperformance)

noted and discussedcompared

wit favorably,h the lice

- There is a need to better understand the principal contributors of

personnel accumulated radiation exposure sustained during "routine"

outage work. Inspector review of 1987 exposure data indicated that about

200 person rem of exposure was sustained from routine outage wot k. This

exposure received little if any ALARA review. Since this exposure

represents about 30% of the total accumulated exposure for 1987, efforts

to identify the sources and limit this exposure should be initiated.

- The licensee's ALARA Program does not require a job to receive an ALARA

review unless 1.5 person-rem of exposure will be received. This action

. point for ALARA reviews should be considered for reduction. The licensee

is in the process of reviewing his ALARA Program for improvement.

_. .- . _. ._

_ . . - _ _

_ _ - - _

.

,

e

8

- Review of some work tasks indicated the following:

- There is a need to improve coordination of work groups. Multiple work

groups were noted working in one area. Multiple work groups hampered

effective use of shielding.

- Some work crews were switched from one job to others resulting in the

need for familiarization of different work crews to a particular job.

- In light of significant reactor ecolant pump work, consideration should

be given to purchase of a pump mock-up.

- Some exposure goals for tasks were not challenging (e.g., steam generator

dryer replacement)

Licensee personnel were aware of these areas and were reviewing them to

prepare for the upcoming outage. .

1988A1ARAG0ALS

The licensee is taking action to enhance his understanding of expenditure

and accumulation of exposure during the outage.

With in the scope of this review, the following matters ware discussed with

licensae personnel as areas for imprcvement:

l - The licensee has selected an 19% occupational exposure goal of 600 ,

person-rem. Inspector review M vork scope and discussions wnh

'

personnel at the time of this i..spection indicated an apparent evosure

total (by years end of considerably less than this value. Licensee

personnel indicated)that additional work may be performed. The inspector

indicated an effort should be made to identify additional outage work in

a timely fashion in crder to provide sufficient time to perform ALARA

pre-planning of this work.

11.0 Corrective Action System and Performance Monitoring

The inspector reviewed selected aspects of the licensee's corrective action

and performance monitoring program. The review was with respect to criteria

contained in the following:

- Procedure 9.203

- Procedure 9.1.25,Radiolc,gical

RadiologicalControls

Incident Performance

Reports. Assessment

Licensee radiation protection supervisors perform weekly plant tours as

part of the performance monitoring program. Action is initiated to correct

observed deficiencies. A quarterly review of job observations is made and

transmitted for station management review. Radiological incident reports

are sumarized on a yearly basis.

- _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ .

.

.

-

.

,

.

.

9

.

.

Inspector review of data indicated a reduction in the frequency and

severity of findings. However, pro *ulems continue to be identified in

selected areas indicating a need for more aggressive corrective action by

management and accountability on the part of all station groups and

Repeat problems continue in areas such as adherence to and

personnel.

adequacy of radiation work permits, lack of radiological surveys and

personnel contamination control. Some recurrent observations -in high

radiation control were identified and are discussed later. In addition come

radiological inc6' ant r6 ports were not transmitted to plant management as

required by procedure. The inspactor considered the corrective action

program to be in need of improvement. Licensee personnel indicated the

program would be reviewed.

The follow ig weaknesses in High Radiation Area access control were

, discussed eth licensee personnel:

4

- There were four sepi' ate findings in 1987 dealing wit' failure to control

access to High Radiation Areas. On June 17, 1987 an dRC 1-'pector found

the posi3d High Radiation Area access door of the upper elevation of the

Sen. The licensee was notified immediatrly and corrective

spray

actionsbuilding

were ta, ken to prevent t'ecurrer.ee. The correct::e actions were

completed on June 24, 1997. On June 25, 1987 an NRC inspector again

t'aund tne same door open. A Notice of Violation was issued on July 30

1987. The licensee's August 28, 1987 responsetotheviolationspecifIed

that all plant personnel had been reminded of the need to verify that

doors are locked upon exiting such areas and that all locks had been

checked for propar optration. This was verified during a subsequent NRC

review.

1

1:Jwever during review this inspection the inspector noted that the

licensee,throughhisHighRadiationkreaaccessdoorsurveillance

program, had identified the above discussed door sgain open on November

24, 1987. In addition, the High Iadiation Area access door to t;.t i

Auxiliary Drain Tank was found open on December 2,1937. Licensee review  :

ind: cates that the doors were apparently left open by unknown  :

individuals. Inspector review of limited available radiation surveys for

, areas entered did not indicate that radiation levels at that time were

i

such that a majcr portion of the body could be exposed to a dose rate l'

ex:ess of 1000 mR/hr. How:ver, the inspector conc 1Lued that the two ,

i additional examples indicate some con'.inuin '

High Radiation Area access control program.g The weaknesses in the licensee'.

two dears identified l

were to ta controlled in accordance with Technb.a1 Specification 5.12.2.

The licensee i * stracted operations personnel following the incidents.

As of the date 'c' inst f* ion no additional examples were identified.

High Radiatic nisc , cess co.h ils will be reviewed during future

inspections.

.

, - _ - - - , ., . . _ _ . , , - _ _ , , _ _ _ _ _ _ _ _ , _ , , _ __ .,,- ,_

._. . .

..

,

.

. ..

I

10

22.0 Yard Contamination

The inspector reviewed licensee follow up of radioactive contamination of

the soil areas in the back yard areas of the station. The soil

contamination apparently or10insted from poor contamination control

practices during work on contaminated equipment in the back yard area this

past outage and as a result of unplanned leaks associated with tanks. The

contamination ranged from several thousand disintegrations removabic to

about 30 mr/hr. on samples of soil associated with a leaking lir.e

essociated with a tank. 1he licensee has excavated significant quantities

of soil for disposal and is working on a plan to fully decontaminate,as

appropriate, the back yard areas.

Some apparent trace quantities of cont aination remain in excavated areas.

The licensee has performed a preliminary safety analysis wh!ch shows off i

site consequences to be minimal. The licensee has comritted to submit an

evaluation in accordance with 10 CFR 20.302 to discuss the contaminated

areas. This submittal will be made in about 90 days Licensee follow-up

and disposition of the contaminated areas is considered an unresolved item

and will be reviewed during a subsequent inspection ( 50 309/P8-12-03 ).

Within the scope of this review the following area for improvement was

identified

- Although the licensee does require frisking prior to exiting the l

radiological controlled area, the licensee does not provice friskers or

require their use by all personnel wiio exit the Reactor Building. The

inspector observed personnel leave tne Reactor Containment a

'

contaminated area removetheirprotectivec1cthincandexItoutsideinto

theenvironmentwIthoutperforriinganyfrisking.Thisisconsidereda

4 poor practice considering the potential for personnel contamination when

in containment and er tracking of contamination into the envirnnment. ,

Licensee personno) ndicated some one he,d apparently removed the frisker

,

r

from the con hinment exit without replacing it. ,

13.0 Exit Meeting

The inspectors meet with licensee representatives denoted in section 1 of

this report on July 22, 1988. The inspector summarized the purpose, scope i

and findings of the inspection. l

l

l

!

:

+

1

I