IR 05000213/1986011

Insp Rept 50-213/86-11 on 860407-11.No Violations Noted. Major Areas Inspected:Health Physics Program,Including Portable Survey Instruments,Alara Program,Personnel Dosimetry & Organization & Staffing

ML20198Q064
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/21/1986
From:	Dragoun T, Lequia D, Shanbaky M, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198Q048	List: IR 05000213/1986011 ML20198Q044
References
50-213-86-11, NUDOCS 8606090053
Download: ML20198Q064 (8)

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4 U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-11

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] Docket N i License N DPR-61 Priority - Category C Licensee: Connecticut Yankee Atomic Power Company P.O. Box 270 Hartford, Connecticut 06101 Facility Name: Haddam Neck, Nuclear Power Plant .,

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Inspection At: Haddam Neck, Connecticut

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Inspection Condu  : April 7-11, 1986 Inspectors: Jh 4 2/ PC

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T. Ora adiation Specialist ' da'te

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     . LeQuia, @atioff Specialist shdate hu in      S 2-/

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l - Approved by: M. Shanbaky, Chlef b

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Radiation Protection Section Inspection Summary: Inspection on April 7-11, 1986 (Report No. 50-213/86-11_) ! Areas. Inspected: Special unannounced appraisal of the Health Physics program by a team of 3 region based radiation specialists. Areas reviewed included: portable survey instruments, ALARA program, personnel dosimetry, and organization and staffing.

! Results: Within the scope of this review no violations were observe Several instances of programmatic weaknesses were noted in the ALARA program.

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j 1.0 persons Contacted

:  During the course of this appraisal the following personnel were contacted or interviewed:

1.1 Licensee Personnel l *R. Graves, Plant Superintendent ,

  * Bouchard, Technical Services Superintendent
  *J. Ferguson, Unit Superintendent i

R. Rodgers, Manager Radiological Assessment

  *J. LaPlatney, Assistant to Station Superintendent
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  *K. Hastings, NUSCO Betterment and Construction H. Siegrist, Supervisor Radiological Protection

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  *R. Crandall, Supervisor Radiological Engineering
  *H. Clow, Health Physics Supervisor    .

i * Nevelos, Radiation Protection Supervisor (OPS) i M. Sweeney, Radiation Protection Supervisor (Services) j R. Groves, Assistant Radiation Protection Supervisor (Services) J C. Onesti, Health Physicist

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  *J. Beauchamp, QA Supervisor l  1.2. Nkt., Personnel     I i
  *P. Swetland, Sr. Resident Inspector J   *S. Pindale, Resident Inspector k   * Denotes attendance at the Exit Interview held on April 11, 198 !

2.0 Purpose

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The purpose of this appraisal was to review the licensee's radiation

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i * Portable Survey Instruments i * ALARA Program

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Dosimetry Program

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Organization and Staffing ] ! 3.0 Documents Reviewed I 3.1 Procedures and Policies

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q i NE0 2.05 " Radiation Protection and Maintaining Occupational ! Radiation Exposures As Low As Reasonably Achievable (ALARA)" ADM 1.1-66 " Connecticut Yankee Atomic Power Co. ALARA Committee" CYSP-23 "ALARA Responsibilities and Policy" ADM 1.1-14 " Plant Operations Review Committee" j ADM 1.1-141 " Posting and Control of Work in ALARA Control Areas" j ADM 1.1-122 " Supervisor Training" II

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RAP 6.2-13 "Special and Routine Radiological Surveys" RAP 6.1-10 " Health Physics Personnel Training Program" ADM 1.1-92 "High Radiation Key Issue" ADM 1.1-120 " Radiological Incident Report" ADM 1.1-106 " Employee Nuclear Complaints and Concerns" 3.2 Reports

 " Health Physics Summary - 1985" by Connecticut Yankee Health Physics Department Staff
 " Connecticut Yankee 1984 Outage ALARA Report" by J. Powell and E. Guzallis
 " Connecticut Yankee 1985 Annual ALARA Report" by J. Powell and E. Guzallis
 " Northeast Utilities Radiation Exposure Study" by NUSCO Radiological Assessment Branch 3.3 Plant Design Change Requests 761 Permanent Cavity Seal Ring 752 Steam Generator Manway Stud Tensioner Platforms 755 CY Inadequate Core Cooling 802 Steam Generator Channel Head Decontamination 733 CY Radwaste Reduction Facility 788 Installation of Fire Damper VS-D-500 792 CY Steam Generator Support Services 789 Cavity Drain Piping 3.4 Internal Correspondence R. Graves from J. Powell/E. Guzallis, " Annual ALARA Review of Plant Design Features and Procedures" dated October 17, 1985 J.H. Ferguson to Distribution, " Radiological Considerations at Connecticut Yankee" dated November 5, 1985 J.H. Ferguson to Distribution, " Station Man-Rem" dated October 9, 1985 G.H. Bouchard from H.E. Clow, " Man-Rem Reduction Suggestions" dated October 18, 1985 R.H. Graves from J.H. Ferguson, " Annual ALARA Goals - 1986" dated November 4, 1985 4.0 Portable Survey Instruments The licensee's program for control and calibration of portable survey instruments was evaluated against the criteria contained in the following:
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ANSI-N323-1978 " Radiation Protection Instrumentation Test and Calibration"

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PMP 9.6-0, Rev. 4, " Preventive Maintenance Program, HP"

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* HPDP 1.01, Rev. 1, Eberline E-140 Calibration Procedure
* HPDP 1.02, Rev. 3, Eberline R02 Calibration Procedure
* HPDP 1.03, Rev. 3, Eberline R02A Calibration Procedure
* HPDP 1.10, Rev. 1, Eberline Teletector Calibration Procedure The licensee's performance relative to these criteria was determined by the following:
* Tours of the Primary Auxiliary Building (PAB) and verification that in-use survey instruments had valid calibration stickers attache * Review of randomly selected calibration record * Independent verification' of check source dose rate * Review of source leak check records
* Physical inventory of calibrated survey instruments staged for ready-issu ,
* Interviews with the Radiation Protection Supervisor (Services) and the Assistant Radiation Protection Supervisor (Services)
* Review of the "HP-Instrumentation Calibration and Inventory List" for April 198 * Review of NBS certification records for the J.L. Shepard Model 79-2M Calibrator, Serial Number 901 The licensee appeared to have an effective program for the control and calibration of portable survey instrument Calibration is being perforraed against NBS traceable sources to within i 10% accuracy. In addition, source checks are being conducted prior to instrument use to verify operability. To facilitate these source checks the Itcensee has installed two (2) J.L. Shepard 120 militcurie' beam calibrators, one of which is placed inside containment for use during outages. However, one weakness was observed in that some source checks are performed by holding the instrument, by hand, at a measured distance from the source. This makes obtaining a reproducible geometry very difficul A monthly inventory is being performed to maintain accountability of the instruments and to insure timely recalibration of them. An adequate supply of " industry standard" survey instruments was observed to be on hand, calibrated and ready for issu Review of source leak check records for the previous two periods verified that the licensee has been performing leak checks at six (6) month intervals as required. All leak check results were <0.005 microcurie.

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Within the scope of this review no violations were identified 5.0 ALARA Program a Personnel exposures accumulated during outage years of Connecticut Yankee has been consistently higher than most other PWR stations and has been trending upward since 1983. The licensee's program to reduce these ' exposures and achieve-ALARA was reviewed against criteria contained in i Regulatory Guides 8.10 and 8.8. The licensee's performance was determined from interviews with selected personnel and reviews of selected document The licensee assigns responsibility for implementation of the ALARA program to three functional areas: Generation Engineering and Construction (engineered projects); Radiological Assessment Branch (overall corporate); and Station Superintendents (site operations and outages).

5.1 Generator Engineering and Construction ALARA This group is responsible for all engineering associated with major plant modifications. These efforts include a standardized ALARA design review checklist that is completed by the project engineer and i reviewed by the Radiological Assessment Branch. To complete the

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checklist the project engineer assesses the impact of the proposed change on personnel exposures during routine operations and during maintenance of the equipment. The results are included in the Plant

Design Change Request (PDCR) work packag Several PDCR modifica-tions performed during the recent outage were reviewed and the ALARA checklists were found to be complete. The standard checklist items constitute a reasonable compilation of ALARA considerations. During the outage a " Betterment Representative" is assigned at the site to negotiate work contracts and coordinate the performance of the PDCR work. The majority of the labor force and line supervision assigned to PDCR work are subcontractors rather than permanent licensee ' personnel. About 60% of the personnel exposures received during the current outage is associated with this work. At least one of the , primary subcontractors has a small health physics staff on site.

1 This HP staff is called upon to make ALARA recommendations for the ! ' installation work. It appears that the licensee shares a significant portion of the outage including ALARA responsibilities with the sub-

contractors.

i The PDCR packages must be submitted for PORC approval before work can

begin. However indications are that the packages are often delivered late to the work groups, are incomplete and do not adequately describe the scope of the work. As a result, the man-hours and man-rem are usually grossly underestimated and are exceeded by up to 400% at job completion. This occurs due to an apparent philosophy.

, that once a job starts it must be completed at any man-Rem expendi-l ture.

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5.2 Radiological Assessment Branch (RAB) ALARA The Manager of the Radiological Assessment Branch (RAB) has responsibility for developing and maintaining the Corporate ALARA program and assisting other departments with implementation of ALAR He establishes the annual exposure goals for the corporation. The RAB group has issued an ALARA Manual and generic HP procedures to be used by other departments in developing their programs. These were judged by the inspector to be clear and of high technical quality as were most policies and procedures reviewed during this inspectio The annual corporate exposure goal for the Connecticut Yankee station has been subdivided for 1986 into three areas: Backfit and Betterment projects; recurring outage work; and routine operation Performance will be monitored in each area by the RAB group relative to these goal The 1986 overall exposure goal was set at 980 man-Rem in order to reduce exposures to the INP0 recommended 400 man-Rem level by 198 However, preoutage estimates predicted that 1200 man-Rem would be expended. As of April 11, 1986 the site total exceeded 1400 man-Rem (150% of goal) with additional outage work and 8 months of plant operations expected to raise the final tota The performance indicates that the goal was unrealistic and did not have adequate management support. The RAB group conducts periodic audits of parts of the HP and ALARA program. However the inspector noted that no thorough appraisal of the station or engineering ALARA programs has been attempted. The Manager RAB stated that such an appraisal will be done in the near future to identify weaknesses in these program Corrective actions will be followed by the RAB group to ensure completion. This matter will be reviewed in a future inspection (86-13-01).

5.3 Statten ALARA Responsibility for development and implementation of the station's ALARA program rests with the station superintendent. The station has an ALARA committee, an ALARA coordinator and an ALARA assistan Various station policies and procedures have been deveioped based on guidance derived from the corporate policies issued by RA The ALARA coordinators efforts are directed towarJs " installation ALARA" that is, minimizing exposures of workers during the outag This of ten involves specifying ALARA controls and " posting" of ALARA work areas. The requirements are not included in the radiation work permi _- - .- = -_ ._ - - - _ . - - - . . - . .

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i ALARA reviews had been conducted for all jobs estimated to require 1 man-Rem or mor This was changed to 5 man-Rem when the ALARA i coordinator could not keep pace with the outage schedul ! Recommendations from the subcontractors performing the work is often

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relied upon in lieu of a formal pre-job ALARA review bj the ALARA Review Committee. The coordinator appraises management of the work that is exceeding exposure estimates during the outage. Summary i reports of total accumulated exposure, are also provided periodically ! during the outage. However, action taken by management during the l outage as a result of this information appears to be minima ; i i The Coordinator, Health Physics Supervisor, Unit and Service

Superintendents have conducted post-job reviews of the 1985 outage, t These reviews have resulted in formulation of man-Rem reduction i suggestions. Similar post outage reviews are conducted by the RAB i group. The inspector noted that these reviews are comprehensive and result in good suggestion f

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5.4 Summary and Conclusions - ALARA program i

Within the scope of this appraisal, the inspector observed that the

,  licensees policies and procedures were well written and comprehensive l
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at all tiers in the organizatio Management at all levels is { ) genuinely concerned that the exposure level is too high and is making j efforts to reduce this level. There is a separate organization  ;

:  assigned to coordinate ALARA efforts with a clear delegation of  ;

authorit). Dose saving ec spment has been purchased and used. In '

!  spite of this, the licent.e's program is tieffective. Most management j  concern and action is ta,en after the fact i.e., when the' outage work j  is completed. The ALARA goals established at the corporate and site !
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levels are unnalistic, are consistently exceeded, and do not serve ! as a useful management tool to assess the ALARA program. There is no l effort to establish accountability for meeting these goals, 3 j  ; j Planning and scheduling of the work and engineering reviews appears i to be weak as evidenced by the amount of unplanned problems  : encountered. An inadequate amount of time is allowed prior to the '

start of a job to allow for an effective " installation ALARA" review.

j The licensees control of contractor work is poor due to the large  ;

number of contractor workers on site, the amount of outage work and I the small size of the ALARA staff. As a result the contractor is , , required to perform ALARA reviews and establish exposure goals for l certain jobs rather than the license : l 6.0 Dosimetry i

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l The Dosimetry Program was evaluated against the following: .

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The licensee's performance relative to this criteria was determined by interviewing the Dosimetry Supervisor, obtaining an oral description of the TLD system specifications and Quality Assurance Program, and by reviewing the NVLAP Certification for the syste Based upon this review the following was determined:

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The TLD System did not pass the low energy pho, ton category. However the remaining NVLAP categories were satisfactor * The Site requires that TLD vs. SRD ratio be within 125%. Based upon this it was concluded that the high Man-Rem exposure at the site is not likely to be due to TLD over response. However, a more detailed evaluation of this area is planned for the futur . Within the scope of this review, no violations were note .0 . Health Physics Department Organization and Staffing The organization and staffing of the HP department was reviewed against criteria contained in Technical Specification 6.3 and ANSI N18.1 - 197 This review included the job descriptions for all positions within the department and the experience and training resumes of the incumbents occupying the positio Within the scope of this review the inspector determined that the organization complied with the T.S. requirements and the personnel met the qualification requirements. All supervisory positions were filled by permanent employees. Staffing levels were adequate. The policies describing the organization are clear as is the assignment of responsibilit The inspector noted that the licensee established training and experience criteria for each position that far exceeded the basic requirements of ANSI 18.1-1971. However, these formal training requirements were then waived for each staff member. There is no program to provide technical training to the staff although discussions with the Health Physics supervisor indicated that the staff periodically attends off-site training and professional seminar .0 Exit Interview The inspectors met with licensee personnel denoted in section 1.1 at the conclusion of this appraisal on April 11, 1986. The scope and findings of the appraisal were discussed at that time. }}