IR 05000309/1978018
| ML19281B024 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 11/15/1978 |
| From: | Crocker H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19281B016 | List: |
| References | |
| 50-309-78-18, NUDOCS 7904200158 | |
| Download: ML19281B024 (21) | |
Text
{{#Wiki_filter:. . U.S. NUCLEAR REGULATORY COMMISSION @ . . OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
78-18 Docket No.
50-309 License No.
OPR-36 Priority Category C -- Licensee: Maine Yankee Atomic Power Company 20 Turnpike lioad Westborough, Massachusetts 01581 Facility Name: Maine Yankee Nuclear Generating Station Inspection at: Wiscasset, Maine Inspection conducted: September 25-29 and October 10-11, 1978 Inspectors: h h kh\\ /M / /979[ G. P.
has, Radiation Specialist dat'e signed date signed cate signed Approved by W h // 07N H. W. Crocifer, Acting Chief, 'date signed Radiation Support Section Inspection Summary: Inspection on September 25-29 and October 10-11, 1978 (Report No. 50-309/78-18) Areas Inspected: Routine, unannounced inspection by a regional based inspector of the radiation protection program during operations including: radiation protection procedures; instrumentation and equipment; exposure control; posting, labeling and control; surveys; notifications and reports; followup on previous enforcement action; and, followup on IE Bulletin No. 78-07.
Upon arrival at 5:45 p.m., September 25, 1978, areas where work was being conducted were examined to review radiation safety practices and procedures.
This inspection involved 36 inspector-hours on site by one NRC regional based inspector.
Results: Of the eight areas inspected, no items of noncompliance were identified in three areas; two apparent items of noncompliance were found in each of two areas (Infraction - failure to maintain an individual qualified in radiation protection procedures, Technical Specification 5.P.2.d; Infraction - failure to adhere to procedures, Technical Specification 6.8, Paragraph 4); (Infraction - failure to control a high radiation area as required by Technical Specification 5.12.2; Deficiency - failure to post the documents specified in 10 CFR 19.ll(a)(1), Region I Form 12 (Rev. April 77) 7904200168
. . . Inspection Summary
(2) and (3), Paragraph 7); one apparent item of noncompliance was found in each of the following areas: (Deficiency - failure to establish a procedure as required by Technical Specification 5.8, Paragraph 5; Infraction - failure to adhere to a procedure as required by Technical Specification 5.11, Paragraph 6; and, Infractior - failure to perfonn a survey as required by 10 CFR 20.201, Paragraph 8).
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. . . . . DETAILS ' 1.
Persons Contacted
- E. C. Wood, Plant Manager
- C. D. Frizzle, Assistant Plant Manager
- P. L. Anderson, Staff Assistant to the Plant Manager
- D. Sturniolo, Jr., Chemistry and Health Physics Supervisor
- S. B. Sadosky, Operational Quality Assurance Department Engineer, Yankee Nuclear Service Department (YNSD)
- E. W. Jackson, Senior Operations Engineer (YNSD)
- G. Cochrane, Jr., Health Physicist
- W. J. Paine, Operations Department Head G. Pillsbury, Health and Safety Director R. L. Bickford, Plant Shift Superintendent J. E. Hanson, Shift Operating Supervisor denotes those present at the exit' interview on September 29,'1978
denotes those present at the exit interview on October 11, 1978,
The inspector also talked with and interviewed several other licensee employees, including members of the Health Physics, Operations and Maintenance Staffs.
2.
Licensee Action on Previous Inspection Findinas References: (a) NRC Documentation Letter and attached Notice of Violation (50-309/78-04), dated March 1,1978 (b) Licensee's Response Letter (50-309/78-04), dated March 28, 1978 (c) NRC Reply Letter (50-309/78-04), dated April ll, 1978 (d) Inspection and Enforcement Report (50-309/78-04) (0 pen) Noncompliance (50-309/78-04-01): Failure to control high radia-tion areas as required by Technical Specification 5.8.B, now 5.12.
The inspector observed during tours of the facility, that the three areas described in references (a) ard (d) above, are now being controlled in accordance with the provisions of Technical Specification 5.12, "High Radiation Area."
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However, the actions stated in reference (b) to assure further compliance with this Technical Specification have not been ade-quately implemented, in that, another instance of failure to control a high radiation area was observed during this inspection.
This instance of noncompliance is discussed in Paragraph 7.
3.
Licensee Response to IE Bulletin References: (a) IE Bulletin No. 78-07, " Protection Afforded By Air-Line Respirators and Supplied-Air Hoods," dated June 12, 1978 (b) Licensee's Response Letter (50-309), dated July 26,1978 (c) Inspection and Enforcement Report (50-309/78-15) The-licensee has developed a respiratory protection program designed to meet the requirements of Regulatory Guide 8.15, " Acceptable Pro-grams for Respiratory Protection." The licensee responded to the action requested in reference (a) in a letter to Region I, reference (b). Accordingly, Health Physics Procedure 9.1.13, " Respirator Issuance, Field Testing and Wearing" and Procedure 9.l.25, "Respira-tory Protection QA Program" have been amended to reflect the new requirements stated in reference (a).
The inspector noted from review and discussions with licensee representatives, that the licensee has not yet had occasion to apply protection factors for the use of any respiratory protection equipment.
4.
Radiation Protection Procedures a.
The inspector reviewed those procedures which have been revised or implemented since the last routine radiation protection in-spection (50-309/78-01), to determine compliance with Technical Specification 5.8, " Procedures;" 5.11, " Radiation Protection Pro-gram" and, Administrative Procedures, " Procedure Preparation, Classification and Format," Revision 3, dated July 28, 1978; and, " Procedure Review, Approval and Distribution," Revision 6, dated March 30, 1978.
The procedures reviewed are listed below:
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Procedure Revision Number Title Number . 9.1.3 Neutron Survey
9.1.10 Radiation Work Permit
9.1.12 Use of Personnel Monitoring Devices
9.1.13 Respirator Issuance, Field Testing
and Wearing ' 9.1.22 MPC Hour Accountability Program
9.1.20 Bioasssay Program
9.201 General Calibration Procedure for All
Laboratory and Portaole Instruments 9.218 Calibration of Air Samplers
b.
Technical Specification 5.2.2 " Facility Staff, item d. states, "An individual qualified.in radiation protection procedures shall be on site when fuel is in the reactor."
On September 25,1978, at 6:00 p.m. the inspector informed the ^ Plant Shift Superintendent, that part of this inspection would include verification of compliance with the above requirement.
The Plant Shift Superintendent stated that during back shifts, when no individuals from the Health Physics Organization are on site, a specially '. rained Auxiliary Operator is designated as the individual qualified in radiation protection procedures.
The inspector and the Auxiliary Operator designated by the Plant Shift Superintendent as meeting the requirement of Technical Specification 5.2.2.d conducted a tour of the con-trolled areas.
The inspector noted the following from discussion and direct observation.
1.
The individual was unable to correctly use the beta cor-rection factor marked on the portable radiation instrument he selected for use.
He incorrectly reported a gamma radiation dose rate as beta radiatio. . . .
^ 2.
The results of a contamination survey were expressed as counts per minute of activity per smear area.
The cor-rect result should have been disintegration per minute per smear area.
3.
The result of an airborne activity sample collected in the Primary Auxiliary Bui: ging (PAB) were incorrectly calcu-lated to be 1.1 X 10-uCi/cc of gross beta gamma act - The correct result of this sample was 1.1 X 10-{0 vity.
uCi/cc of gross beta gamma activity.
This incorrect cal-culation was due to lack of familiarity with the calcu-lation procedure resulting in lack of understanding of how to apply the counter geometry factor.
4.
During a tour of the PAB 11' elevation, the inspector ap-proached a rope barricade posted with a high radiation area sign near degas filter FL 33A. The whole body gamma dose rate at this barricade was measured to be 200 mrem /hr.
FL 33A measured to read up to 5000 mren/hr at contact and 1500 mrem /hr at a distance of 12 to 18 inches from the fil-ter.
The individual moved the rope barricade and sign to an area where the dose rate was less than 100 mrem /hr. The inspector asked what access control is required for an area in which the intensity of radiation is greater than 1000 mrem /hr.
The individual indicated that he was not aware of the requirements stated in Technical Specification 5.12.2 and Health Physics Procedure 9.1.6.
Control of this high radiation area is further discussed in Paragraph 7 of this report.
5.
When asked if he would unlock and permit access to the pipe tunnel, a locked and posted high radiation area, on the 11' elevation of the PAB, the individual took his key and began to unlock and open the door. The inspector declined access since he was not issued a Radiation Work Permit as required by Technical Specification 5.12.2 and Health Physics Procedure 9.1.10.
6.
In a situation where the gross beta gama airborne activity, with great 9r than a two hour half-life, was postulated to ' be 1 X 10- uCi/cc, the individual correctly stated the sample would need to be gama scanned.
He incorrectly speci- , fied that a respirator protection factor could be applied without first making a determination of the effective air-borne concentrations of the mix of radionuclides present.
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7.
The inspector noted that the individual wore his thermo-luminescent dosimeter on his belt and his pocket dcsimeter, (the device used to control his exposure accumulation) in his breast pocket.
8.
The inspector detennined that the individual was aware of the necessary precautions and survey requirements for an entry into the containment while the reactor was at power.
Based on the information noted in items 1 thru 6 above, the inspector noted that the individual designated to fulfill the requirements of Technical Specification 5.2.2.d was in fact, not qualified in radiation protection procedures.
This finding represents noncompliance with Technical Specification 5.2.2.d (50-309/78-18-01).
The inspector met with licensee representatives on September 26, 1978, to discuss this finding.
The following immediate action was taken: The Health Physicist conducted iamediate upgrading sessions with all Auxiliary Operators designated qualified in radiation pro-tection procedures to insure they are capable of providing their intended function.
The Auxiliary Operators designated qualified in radiation pro-tection procedures will receive a more comprehensive refresher course in radiation protection in the next eight weeks.
The licensee representatives will review the fonnal program used to designate those individuals qualified in radiation protection procedures.
. At 5:00 p.m., on October 10, 1978, the inspector toured the facility with the Auxiliary Operator designated qualified in radiation protection procedures.
The inspector again re-viewed his activities such as those described above.
This individual demonstrated an adequate understanding of radiation protection procedures necessary to meet the requirement of Technical Specification 5.2.2.d.
c.
Technical Specification 5.8, " Procedures," requires that written procedures be established, implemented and maintained covering the activities referenced in Appendix "A" of Regula-tory Guide 1.33, November,1972.
Operations Procedure 1-12-4, " Containment Entry," Revision 4, issued December 8, 1977,
. . . was established pursuant to item A.9. of Appendix "A", Regula- ' tory Guide 1.33, November,1972.
This procedure requires in steps 2.1 and 3.1 that a Radiation Work Permit (RWP) be is-sued and adhered to for entry into the containment.
Step 2.6 requires that if the entry takes place when containment integrity is required, two individuals, one of whom is trained in health physics procedures, are required.
The inspector noted that the Maine Yanke9 Radiation Protection Manual, Section 3.12, and Health Physics Procedure 9.1.10, " Radiation Work Permits," also require an RWP for entry into the containment.
Contrary to these requirements the inspector noted the following sequence of events from a records review and personnel interview.
On September 27, 1978, at about 9:20 a.m., the Plant Shift Superintendent noted what appeared to be indication of a decreasing primary coo'. int inventory as indicated by a decreasing volume control tank level.
He estimated a leak rate in the range of 1 to 3 gallons per minute, he also noted what appeared ' to be an increase in containment sump level.
The containment Airborne Activity Monitor had failed on September 26, 1978, at 11:23 a.m. and therefore did not provide any indication of an increase in containment airborne activity.
The containment sump pump annunciator did not activate nor did the sump pump start.
The 31 ant Jhift Superintendent suspected a primary coolant leak in the cor.tainment.
At 9:25 a.m., the Plant Shift Superintend'ent and a Shift ' Operations Supervisor entered the containment dressed in protective clothing and carrying a portable radiation survey instrument. They did rot inform the Health Physics Staff of their need to enter the containment, they did not obtain an RWP, nor did th.ey wear respiratory protection as called for in Procedure 9.1.6, Section 7.4.3.
No air sample was taken prior to entry or during their time in the containment.
After entering the containment they checked the pressurizer cubicle, then toured the lower level outside the crane wall looking for indications of a leak.
Meanwhile, personnel in the control room determined the cause of decreasing Volume Control Tank level to be an improper valve lineup. They corrected the lineup and notified the two indi-viduals when they called to report their negative findings after less than 10 minutes in containment.
Since they were already in
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containment and the bi-weekly inspection of containment was due, they completed the bi-weekly inspection prior to leaving the containment at 9:45 a.m.
The inspector noted that the containment entry without RWP authorization, and without respiratory protection equipment was contrary to the plant procedures and, consequently, re-presented noncompliance with Technical Specification 5.8 (50-309/78-18-02).
The inspector and the Health Physicist learned of this entry at 11:00 a.m., September 27, 1978.
The Health Physicist directed that a survey of airborne activity be made in con-tainment.
The airborne activity is discussed in Paragraph 8.
5.
Instruments and Equipment The inspector reviewed the availability and calibration of tha licensee's radiation detection instruments and equipment.
The calibration of the following items were examined against the cri-teria as set forth in the listed procedures.
Instrument Serial Number Calibration Procedure Eberline E400 2241 9.208, Revision 3 Teletector Model G112 '4424 9.214, Revision 2 Eberline E140 522 9.232, Revision 2 Eberline PIC6A 634 9.207, Revision 3 Eberline PIC6A 554 9.207, Revision 3 Eberline PIC6A 1022 9.207, Revision 3 Hurricane Air Sampler HAS3 9.218, Revision 3 The licensee has purchased a new personnel survey portal monitor device for use at the Gate House.
This device will utilize the gamma scintillation technique.
The instrument installation is nearly com-plete and initial calibration has been performed. The licensee is in the process of developing a routine calibration procedur s . . ' . ,
, Technical Specification 5.8, " Procedures," requires that written procedures be established, implemented and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, November,1972, and that each procedure be reviewed.by the PORC and approved by the Plant Shift Superintendent prior to implementation.
Appendix "A" of Regulatory Guide 1.33, November,1972, requires in Section G.5 that procedures for personnel monitoring be prepared.
' Procedure 9.1.26, "Whole Body Counting," Revision 1, issued July 28, 1977, describes the operating procedures and calibration checks for the facility whole body counter.
This procedure does not establish the quantitative calibration procedure, nor does it establish the minimum frequency at which this calibration is to be performed.
The licensee uses this whole body counter to monitor personnel for in-ternal disposition of radioactive materials. The inspector reviewed ,this finding with a licensee representative.
The individual responsi-ble for the whole body counter performs what appears to be an adequate calibration of the whole body counter sodium iodide detector by adapting information from Chemistry Procedure 7.205.6.2, " Detector Efficiency Calibration of the Germanium Lithium Detector and Canberra 8100 and 8700 Multichannel Analyzer." Any other individual would have great difficulty in performing this calibration since the adaptions of the procedure have not been documented.
The whole body counter has been calibrated by this method since 1976, at a frequency that has not exceeded six months.
Failure to have a PORC reviewed and Plant Shift Superintendent ap-proved procedure regarding the quantitative calibration of the whole body counter represents a deficiency level instance of noncompliance with Technical Specification 5.8 (50-309/78-18-03).
The inspector selected the below listed instruments from those in use, or available for use, and verified their operability and response to known sources of radiation.
Instrument Serial Number Eberline E400 2044 Eberline PAC 4S 2030 Eberline RM14 2151 Eberline RM14 2156 Eberline RM14 2121 , Eberline PIC6A 634 ,
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Instrument Serial Number Eberline PIC6A 635 Eberline PIC6A 636 Eberline PIC6A 1470 Eberline PIC6A 1445 All of the above instruments were operable and responded acceptably to known sources of radiation.
All were labeled indicating their last calibration date.
The inspector selected 10 articles of protective clothing from the licensee's issue bins.
These items were surveyed for radioactive material with an Eberline E140 and found to be within the acceptable - limits specified in Section 3.10 of the Radiation Protection Manual.
The inspector selected 10 full face respiratory protective masks from the licensee's storage area.
Each mask was inspected, surveyed and found acceptable with respect to the criteria of Health Physics Procedure 9.1.13', " Respirator Issuance, Field Testing and Wearing."
The inspector reviewed the licensee's results performed in accordance with Health Physics Procedure 9.217, " Performance and Calibration Check of the Yankee TLD Service." These results appeared to meet the minimum requirements of that procedure. The licensee representative stated that a scientific evaluation of the vendor supplied thermo-luminescent dosimeters (TLD) response to beta radiation is under way at the University of Lowell.
The TLD response to neutron radiation has been evaluated by the vendor and the licensee expects to be using the TLD method for monitoring neutron dose in the near future.
6.
Exposure Control a.
The inspector reviewed the exposure records of 15 individuals selected at random from the licensee's exposure control records.
These records were reviewed against the following requirements:
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Area Regulatory Requirement Dosimetry Device Usage 10 CFR 20.202, Procedure 9.1.12, "Use of Personnel Monitoring Devices" Dose Accountability (External) 10 CFR 20.101,10 CFR 20.401, (NRC Forms 4 und 5) 10 CFR 20.102 Dose Accountability (Internal) 10 CFR 20.103, Procedure 9.l.20, " Bioassay Program" Procedure 9.1.22 "MPC Hour Accountability" Increased Exposure Requests Radiation Protection Manual, Section 2.9 Personnel Exposure Requests Radiation Protection Manual, 4.11 Technical Specification 5.11, " Radiation Protection Program" states: " Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."
, The " Radiation Protection Manual, Maine Yankee Atomic Power Company" Revision 3, issued August 24, 1977 (RPM) states in Section 4.11 " Personnel Exposure Investigations" that, "Whenever a situation ' occurs involving the suspected or known exposure of personnel to ionizing radiation in excess of permissable limits specified in Section 2 of this manual, the incident shall be promptly investi-gated and personnel exposure evaluated." Section 4.11 also requires in part, that the Plant Superintendent or his designated alternate are members of the investigating committee and that a written re-port of the investigation include recommendations for corrective measures to prevent similar overexposures.
Section 2 in part 2.9.3, " Quarterly," quotes an external radiation exposure of the whole body of 2000 mrem / calendar quarter.
During the third calendar quarter of 1978, licensee records indi-cated that one individual received 2576 mrem and another received 2725 mrem by TLD results.
Neither of these two individuals had received authorization to exceed the 2000 mrem limit specified in Section 2.9.3 of the RPM. An evaluation of this suspected exposure in excess of the limits specified in Section 2 of the RPM was made by a member of the Health Physics Organization and the Health _
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Physicist. Their evaluation concluded one individual actually received 1653 mrem and the other 2028 mrem in the third calendar quarter of 1978.
The reason for this difference in exposure - was found to be a personnel ' error resulting in the addition of a chest TLD result to the head TLD result for a steam generator entry.
The individual's NRC Form 5 reflects the results of this exposure evaluation.
The inspector reviewed the evaluation, and noted from discussion with the Health Physicist that the investigation committee required by Section 4.11 of the RPM had not investigated this suspected exposure and did not issue a w:itten report as required. The inspector also noted that of the 15 individuals final exposure records re-viewed three had received quarterly exposures in the range of 2000 to 2100 mrem and the investigations required by Section 4.11 of the RPM had not been performed.
This finding represents noncompliance with Technical Specification 5.11 (50-309/78-18-04).
In discussing this matter with licensee representatives, the . inspector was informed that they had intended Section 4.11 to apply only to Section 2.8, " Technical Ove. exposure" of the RPM.
The licensee reprasentative stated Settlon 4.11 of the RPM will be revised to reflect this, b.
The inspector reviewed the licensee's method of neutron monitoring and dose accountability.
The licensee has required the use of NTA film when the potential for neutron dose exists.
In addition, the licensee performs neutron surveys with a calibrated Eberline PNR4 neutron dose rate instrument.
These survey results combined with staytime information are used to calculate the potential neutron exposure.
The dose calculated from PNR-4 data is then recorded in the individual's exposure record.
A review of 1977 exposure records indicated that 10 persons re-ceived a total combined neutron exposure of 0.2 man rem.
In 1978, 5 individuals have received a total combined neutron exposure of 0.2 man rem, with the largest single dose to an individual of 58 mrem.
The licensee appears to provide adequate neutron ex-posure control and monitoring.
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. c.
The inspector selected 12 RWPs and reviewed surveys and other records and determined that adequate protection measures had been prescribed and Procedure 9.l.10 has been adhered to.
7.
Posting, Labelino and Control a.
Tha inspector toured the facility making independent measure-ments and direct observations to determine compliance with - the following, regulatory requirements and license procedures.
Area Requirement Posting of radiation, high Procedure 9.1.6 " Establishing radiation, airborne activity, and Posting Controlled Areas" and radioactive materials areas 10 CFR 20.203(b), (c), (d), (e) Labeling of containers 10 CFR 20.203(f) Control of radiation and high 10 CFR 20.10E(b)(1) and (2) radiation areas and Technical Specification 5.12 On August 29, 1978, a licensse representative contacted Region ' I to discuss the regulatory implications of a transient dose rate in excess of the limit specified in 10 CFR 20.105(b)(2) beyond the restricted area boundary as defined in Figure 1.3-2 of the FSAR.
The inspector reviewed this situation to determine compli-ance with all the above regulations.
The following facts were obtained and are noted below.
On August 25, 1978, valve LSI-68 leaked allowing unfiltered, undemineralized water to enter the Refueling Water Storage Tank (RWST).
The. RWST activity increased to 1 X 10-2 pCi/ml. This resulted in the dose rate at the FSAR designated restricted area boundary of 2.0 mrem /hr.
The licensee established a temporary restricted area boundary in the owner controlled area at a point where the highest dose rate was less than 0.5 mrem /hr.
The licensae began to filter and demineralize the contents of the RWST.
Repairs were made on valve LSI-68.
The dose rate ori-ginating from the RWST began to decrease.
On September 11, 1978, the RWST was again contaminated, increasing the dose rate to 2.5 mrem /br at the FSAR designated boundary.
The licensee found that LSI-68 had been improperly repaired, the valve was fixed. The licensee continued to control the restricted area at the temporary boundary.
The inspector verified that dose rates, posting and
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- control of this temporary boundary were correct on September 26, 1978.
The licensee was able to begin purification of the RWST contents on September 26, 1978.
The inspector noted that on September 29, 1978, the RWST activity had been reduced to 4 X 10-3 pCi/ml, the dose rate had decreased to 1.6 mrem /hr, and the temporary boundary had been reduced substantially in size.
No apparen item of noncompliance was identified in regard to this matter, b.
Technical Specfication 5.12, "High Radiation Area," states in part that: "5.12.1 In lieu of the " control device" or " alarm signal" re-quired by paragraph 20.203(c)(2) of 10 CFR 20, each high radia-tion area in which the intensity of radiation is 1000 mrem /hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by re-quiring issuance of a Radiation Work Permit... 5.12.2 The requirements of 5.12.1 above, chall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr.
In addition, locked doors shall be provided to prevent unauthorized entry into such areas and keys shall be maintained under the administrative control of the Shift Super-visor on Guty and/or the Plant Health Physicist."
On September 25, 1978, during a tour of the 11' elevation of the Primary Auxiliary Building, the inspector measured the intensity of radiation near the auxiliary charging pump to be 100 mrem /hr.
A rope barricade with a high radiation area sign attached was positioned as noted in the sketch shown in Attachment A.
The dose rate at this barricade was measured to be 200 mrem /hr.
Contact dose rates on degas filter Fi '33A measured up to 5000 mrem /hr.
The intensity of radiation near this filter was such that a major portion of the whole body could have been exposed to 1500 mrem /hr.
No locked doors, gates, or other similar re-straint was provided to prevent unauthorized access to this specific area.
This finding represents noncompliance with Technical Specification 5.12.2 (50-309/78-18-05).
. . ATTACHMENT A Degas Initial rope barricade Filter - and sign N / FL 33A , V., - ' ,- ' ,- . Auxiliary Charging Pump .
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The licensee representative immediately repositioned the rope barricade to an area where the intensity of radiation was less than 100 mrem /hr.
On September 26, 1978, the filter, element in FL 33A was replaced.
This reduced the contact dose rate on FL 33A to 20 mrea/hr, thereby, reducing the whole body dose to less than 100 mrem /hr.
c.
10 CFR 19.11, " Posting of Notices to Workers," requires that each licensee post current copies of those documents stated in 10 CFR 19.ll(a)(1), (2) and (3) or the licensee may, according to para-graph (b), "If posting of-a document specified in paragraph (a)(1), (2) or (3) is not practicable, the licensee may post a notice which describes the document and states where it may be examined."
Paragraph (d) requires that such notices appear in a sufficient number of places to permit incividuals engaged in licensed acti-vities to observe them on the way to and from any particular licensed activity location to which the docuinere applies.
On September 27, 1978, the inspector and a licensee representative toured the facility and were unable to locate either the documents referenced in 10 CFR 19.ll(a)(1), (2), (3) or a notice which de-scribed these documents and states where they may be examined, on any of the following bulletin boards: main entrance hall, contrcl room, lunch room, and the main entrance to the controlled area.
The documents were not posted to permit individuals engaged in licensed activities to observe them on the way to or from any particular licensed activity location to which the document applies.
This finding represents noncompliance with 10 CFR 19.ll(a), (b) and (d) (50-309/78-18-06).
The licensee representative stated that such a notice had been posted in the past. An interim notice was posted on the four mentioned bulletin boards on September 28, 1978.
A final notice meeting the requirements of 10 CFR 19.11 was posted on October 6, 1978.
8.
Surveys The inspector selected numerous survey records for review to determine compliance with the following requirements.
Area Regulatory Requirement Personnel Monitoring 10 CFR 20.202 External Exposure 10 CFR 20.101 .
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Area Regulatory Requiremen Internal Exposure 10 CFR 20.103 Posting 10 CFR 20.203 Records of Surveys 10 CFR 20.401 Leak Check and Inventory of Sealed Procedure 9.l.5, " Radioactive Sources Source Inventory and Leak Test" 10 CFR 20.201(b), " Surveys," requires that such surveys be conducted as may be necessary to comply with the regulations contained in each section of Part 20.
A " survey", as defined in Paragraph 20.201(a), means "an evaluation of the radiation hazards incident to production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. When ap-propriate, such evaluation includes a physical survey of the location of materials and equipment, and measuraments of levels of radiation or concentrations of radioactive materials present."
As previously described in Paragraph 4, on September 27, 1978, two individuals entered the containment while the reactor was at power in search of a primary coolant leak.
This entry is discussed in Paragraph 4.c of this report.
The containment airborne activity monitor had been out of service since 11:23 a.m., September 26, 1978.
The individuals involved, suspected a primary coolant leak of 1 to 3 gallons per minute. The Health Physics Organization was not informed prior to the entry, and thus were not able to measure airborne activity or evaluate the radiation hazards incident to an entry under these conditions. The , containment is posted as an " airborne activity area".
The individuals entered the area without respiratory protection.
The individuals did not collect a sample of the air while in the containment.
Failure to perform an evaluation of the airborne radioactivity as was necessary to comply with the requirements of 10 CFR 20.103, "Ex-pesure of individuals to concentrations of radioactive materials in air in restricted areas," represents an item of noncompliance with 10 CFR 20.201(b) (50-309/78-18-07).
After learning of this entry, the Health Physicist directed that an , air sample of the containment be taken.
This ai sample indicated gross airborne gaseous activity to be 1.53 X 10- pCi/cc.
The major
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isotope was Xe133 at 1.65 X 10-4 uCi/cc.
The gross particulate activity was 7.4 X 10-9 uCi/cc and 1131 activity was 1.14 X 10-10 uCi/cc.
The inspector noted that, had the leak actually existed in the containment, the expected airborne activity would have been substantially greater.
9.
Notification and Reports The inspector selected 10 personnel exposure records of individuals who had terminated their work assignments at the facility.
These records were reviewed to establish compliance with 10 CFR 20.408 and 10 CFR 20.409 exposure reports to workers.
Numerous requests for exposure records made pursuant to 10 CFR 19.13 " Notification and Reports to Individuals," were reviewed.
The licensee response appeared to be in compliance with this regulation.
10.
Exit Interview The inspector met with the licensee representatives (denoted in para-graph 1) at the conclusion of the inspection on October 11, 1978.
The inspector sumarized the scope and findings of the inspection as presented in this report.
The licensee representative emphasized two points: 1.
Since the licensee has met their intent of Section 4.11 of the Radiation Protection Manual (RPM), they believe the example discussed in Paragraph 6 should not be an item of noncompliance.
2.
The single incident discussed in Paragraphs 4 and 8 should not result in two items of noncompliance.
The inspector noted with regard to (1) above, Section 4.11 of the RPM clearly states a requirement that had been properly reviewed and approved.
The inspector noted that the containment entry discussed in Para-graphs 4 and 8, although a single incident, resulted in noncompliance with two separate significant requirements.
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i ! - . U. S. NUCLEAR REGULATORY COMMISSION - a OFFICE OF INSPECTION AND ENFORCEMENT . - - Region I Report No.
78-21 . Docket No.
50-309 ~ License No. OPR-36 Priority Category C -- Licensee: Maine Yankee Atomic Power Connany _ 20 Turnpike Road stborough, Massachusetts 01581 Facility Name: Maine Yankee Nuclear Generating Station Meeting at: 20 Turnpike Road, Westborough, Massachusetts Meeting conducted: October 27, 1978 , NRC Personnel: " 6D bk //[#//'7[ . H. W. Crocker, Acting Chief, Radiation date signed ~ fuggSection, FF & MS' Branch /[/ gg , E. 'J/l 8Eunner, ptef,. Reactor Operations date signed I hk //!Z.y!78 . [.Allan,Depuft ~ date signed Dir or Approved by: w r,_ / ///&Z[7 f .m G.
. Sr[ith, Chief, Fuel Facility and dates @ned aterials Safety Branch Meeting Summary: Management Meeting on October 27, 1978 (50-309/78-21) Areas Covered: Meeting held at the licensee office to discuss Region I concerns with the management control in the area of the radiation protection program.
The meeting involved 6 man-hours by three NRC staff members.
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Region I Form 12-1 ~ (Rev. August 77)
, T~ . DETAILS 1.
Personnel Present a.
Maine Yankee Atomic Power Comoany D. E. Vandenburgh, Vice President L. H. Heider, Assistant Vice President Operations D. Moody, Manager Operations E. C. Wood, Plant Superintendent D. Sturniolo, Jr., Chemistry and Health Physics Supervisor G. Cochrane, Jr., Health Physicist J. Mcdonald, Radiation Protection Group Manager W. Johnson, Vice President b.
Central Maine Power Company J. Radazza, Vice President c.
Region I J. M. Allan, Deputy Director E. J. Brunner, Chief, Reactor Operations and Nuclear Support Branch P. J. Knapp, Chief, Radiation Support Section, Fuel Facility and Materials Safety Branch 2.
Agenda Enforcement options available to the Commission were reviewed.
The Region I staff expressed concern over the nature of findings of noncompliance with radiation protection procedures and with high radiation area control requirements.
It was noted that the findings indicate a need for strengthening the radiation protection program and a need to resmphasize the necessity of procedural adherence to all individuals at the facility.
Licensee management stressed its intention to improve the radiation protection program and to assure compliance with regulatory requirements.
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