IR 05000238/1993001
| ML20035F250 | |
| Person / Time | |
|---|---|
| Site: | NS Savannah |
| Issue date: | 04/07/1993 |
| From: | Bassett C, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20035F229 | List: |
| References | |
| 50-238-93-01, 50-238-93-1, NUDOCS 9304210080 | |
| Download: ML20035F250 (10) | |
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kmarco UNITED STAVES
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'o NUCLEAR REGULATORY COMMISSION I
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REGION il S
,j 101 MARIETTA ST REET, N.W.
't ATLANTA. GEORGI A 30323 i
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Report No.: 50-238/93-01 i
Licensee: State of South Carolina Patriot's Point Development Authority Post Office Box 986 Mount Pleasant, SC 29464
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Docket No.: 50-238 License No.:
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l Facility Name: N. S. Savannah
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Inspection Conducted: March 24-26, 1993
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Inspector:
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4/7[93
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C. H. Bassett, Senior Ra'diation Specialist Date Signed j
Approved by:
'C EN C-tote 4/ 7/93
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E. J. McAlpine, Chief Date Signed
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Radiation Safety Projects Section
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Nuclear Materials Safety and Safeguards Branch
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Division of Radiation Safety and Safeguards SUMMARY l
l Scope:
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This routine, announced inspection involved onsite review of radiation
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protection program activities, tour of the reactor space, and followup and
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review of licensee actions concerning a previously identified Inspector
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Followup Item.
Results:
The licensee has continued to control access to the restricted areas of the
vessel as required and has maintained these areas posted and secured. The j
l required radiation surveys and radiological environmental surveillances have
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l been performed as required.
No problems were noted with radiation levels or
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with contamination in unrestricted areas.
Review of the records for the
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vessel indicated that the required committee meetings, surveys, periodic inspections and tests, and general maintenance are being conducted / performed as required.
However, three non-cited violations were identified as follows:
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Failure to maintain the entrance to a radiation control area locked as required by Technical Specification 3.3 (Paragraph 2.c).
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9304210080 930408 l
PDR ADOCK 05000238
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Failure to maintain the intrusion alarm in a condition such that the i
audible signal could be heard by the security guard force as required by
Technical Specification 3.3 (Paragraph 2.e).
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Failure to maintain the cathodic protection system for the vessel in a fully operational condition as required by Technical Specification 3.7.4
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(Paragraph 3.f).
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J. Blandford, Associate Director for Engineering, Patriots Point
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Development Authority (PPDA)
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- C. Waldrop, Executive Director, PPDA
- L. Miller, Maintenance Supervisor, PPDA Other licensee employees contacted included security force personnel, ships maintenance personnel and office personnel.
State of South Carolina Department of Health and Environmental Control (SC DHEC) Employees
M. Batavia, Assistant Bureau Chief, Bureau of Radiological Health, SC DHEC
- D. King, Health Physicist, SC DHEC
- C. Murrell, Health Physicist, SC DHEC J. Peterson, Section Manager, Bureau of Radiological Health, SC DHEC Department of Transportation
- E. Koehler, Marine Surveyor, Maritime Administration (MARAD)
Z. Levine, Senior Advisor for Research and Development, MARAD
- Attended the exit interview on March 26, 1993.
2.
Class III Operations - Restricted and Unrestricted Areas (40755)
a.
Unrestricted Areas Technical Specification (TS) 3.3.1 defines areas that are accessible to the general public as unrestricted areas. These areas are those that may be used for museum tour routes and displays, lodging accommodations for visitors and employees and restaurant and concession facilities. TS 3.3.1 also requires that radiation levels from reactor generated radioactive materials in unrestricted areas be less than 5 microroentgen per hour (uR/hr)
above natural background as measured at one meter. from any surface.
A radiation level survey of the tour route areas open to the l
general public was conducted on March 25, 1993, for A through l
D decks, the promenade deck, the boat deck, and the navigation bridge using an NRC portable survey instrument.
No levels greater I
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than 5 uR/hr above natural were detected in the areas open to the general public.
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b.
Restricted Access Areas
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TS 3.3.1 states that areas with radiation levels in excess of 5 ur/hr but less than 250 uR/hr (or 0.25 milliroentgen per hour
[mR/hr]) as measured at one meter from any surface are restricted areas. Access to these areas is restricted to only employees, contractor personnel, escorted guests, and official visitors.
Such restricted areas may be entered without health physics supervision provided a health physicist has determined that
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potential exposures to any individual will not exceed five percent (5%) of 10 CFR 20.101 exposure limits and the Review and Audit Committee has reviewed and accepted the proposed use of the space.
j The inspector performed radiation level surveys of selected areas which were restricted from use by the general public but which i
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were accessible by employees without health physics supervision.
Several areas with radiation levels between 5 and 250 uR/hr at one meter from the surface were detected.
It was noted that these
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areas or the entrances to tt?se areas were posted and access to the areas was restricted. The inspector also reviewed the program, which had been formulated by supervision, implementing the use of stay times to ensure that employees' exposures did not exceed 5% of the exposure limits specified in 10 CFR 20.101. The log used to limit exposure by tracking stay times appeared to be adequate.
c.
Radiation Control Areas TS 3.3 def:.ies a radiation control area as an area of the ship
with redi. tion levels from reactor generated radioactive materials
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in excess of 0.25 mR/hr (or 250 uR/hr) above natural background as measured at one meter from any surface. TS 3.3 also requires that entrances to such areas be posted with appropriate warning signs, locked and secured with chains, and sealed with numbered seals.
During a previous inspection, an area near the aft starboard bulkhead of Cargo Hold 4 at the D deck level was noted to have radiation levels in excess of 0.25 mR/hr.
During this inspection a
the inspector verified that the radiation leveh had not increased
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but remained at approximately the same levels a had been noted in the past. The inspector noted that, since the last inspection in 1989, the licensee had placed some lead shielding on the deck and along the bulkhead which had reduced the general area radiation levels from 400 uR/hr (0.4 mR/hr) to around 50 uR/hr. The inspector verified that the area was locked and. secured as i
required, that there was a seal affixed to the locking mechanism of the door to the area, and that the area was posted with appropriate warning signs.
While touring other areas of the ship where radiation areas existed, the inspector noted that the entrance to one such area was not locked as required. The lock on the entrance to the port
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Stabilizer Room on the 14' Flat level was in place but it was not locked. The door was posted, was not on the tour route, and was
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in an area for which assess was granted only to employees. The inspector aiso noted that the seal was in place and that it had not been broken indicating that no one had entered the area even though the lock had been left unlocked. The licensee was notified
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of this problem and the lock was immediately locked.
In questioning personncl about the problem, the licensee found that no one could remember unlocking the lock or leaving the lock undone. The last time the area was entered would have been during a visit by the South Carolina DHEC personnel to check the radiation levels in the area or possibly to change out a thermoluminescent dosimeter (TLD) in the area. All personnel with access to the restricted areas of the ship were reminded to ensure that all required locks were locked when leaving a restricted /
radiation control area.
The licensee was informed that failure to comply with the requirement of maintcining the entrance to a radiation control area locked was an apparent violation of TS 3.3.
However, this NRC identified violation is not being cited because the criteria
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specified in Section VII.B of the NRC Enforcement Policy were i
satisfied (50-238/93-01-01).
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d.
Contamination Control Areas TS 3.3.1 requires that all surfaces in radiation control areas and
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in unrestricted areas be maintained with contamination levels less than those described in Table 1 of NRC Regulatory Guide 1.86.
Table 1 of Regulatory Guide 1.86 states that removable surface l
contamination for beta-gamma emitting nuclides shall be less than
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1,000 disintegrations per minute per one hundred square
centimeters (dpm/100 cm ),
Six smear samples were taken at locations on the tour route and six smear samples were taken at locations which were restricted from use by the general public but not from access by employees.
The samples were analyzed on a proportional counter in the Region II office for gamma and gross beta isotopic activity. The results showed no detectable activity on any smear above the minimum detectable activity (MDA) of the counter of 1.2 disintegrations per minuts per smear, e.
Entry into the Reactor Compartment TS 3.3 stipulates that an intrusion alarm with an interlock will be maintained on the B Deck entry door into the reactor compartment with audible and visual signals located at a manned security guard post. The signals shall be both seen and heard by the security guard on duty.
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i TS 3.7.6 requires the licensee to conduct an annual inspection to
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determine any degradation of the primary and secondary systems of
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the ship.
On March 25, 1993, the inspector, PPDA personnel, SC DHEC
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personnel, and MARAD personnel made an entry into the reactor i
space surrounding the reactor vessel to perform the annual inspection of the primary and secondary systems of the ship. All l
systems appeared to be in a stable condition with degradation no i
worse than would be expected for the given situation. No standing
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water was noted and no other problems were apparent. The use of a i
mechanical dehumidifier instead of desiccant was discussed in order to maintain the reactor compartment dry.
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A radiation level survey performed in the reactor space by the SC l
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DHEC personnel identified a pipe (located near the entry to the bottom level of the reactor space) with a radiation level of 450 mR/hr at contact. The general area radiation level in the
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Space was 1 mR/hr.
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During this entry, the PPDA personnel tested the intrusion alarm on the door to the reactor compartment and the associated audible and visual signals. The visual signal, a flashing red light mounted on top of the Pilot House / Navigation Bridge, operated properly. However, the audible signal, a horn also mounted on top of the Pilot House / Navigation Bridge, did not function. Upon l
investigation of the problem, the licensee found that the horn was full of moisture and would not operate. The cause of the failure t
of the audible alarm was thought to be the severe weather that had
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occurred in the area in the recent past. The strong winds of the recent storm apparently forced water into the horn, shorting out the system. The licensee replaced the horn and retested the system. The new horn operated properly and could be heard by the security guard on duty at the main gate.
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The licensee was informed that failure to comply with the l
requirement of maintaining the intrusion alarm in a condition such l
that the audible signal could be heard by the security guard on
i duty was an apparent violation of TS 3.3.
However, this violation i
will not be subject to enforcement action because the licensee's
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efforts in identifying and correcting the violation meet the criteria specified in Section VII.B of the NRC Enforcement Policy (50-238/93-01-02).
Two non-cited violations were identified.
3.
Class III Operations - Record Review (40755)
a.
Review and Audit Committee Meetings TS 3.6 stipulates the composition of the Review and Audit Committee, details its audit functions, outlines the issues to be
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reviewed during its meetings, and requires that the Committee meet at least annually.
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l The inspector reviewed the minutes of the Committee meetings held January 12, 1989, December 14, 1989, January 23, 1991, January 14, 1992, and January 28, 1993. The Committee was noted to be meeting
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at the required frequency and there were sufficient participants
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to conduct each meeting as required by the TS.
The issues that were discussed included: TS changes; modifications to the controlled area alarm system; the repair of the cathodic protection system for the vessel; proposed changes to the required l
radiation surveys; the results of inspections that had been i
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performed; the hull inspection results; damage that resulted due
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to Hurricane Hugo; and the annual reports issued by the PPDA with l
input from the SC DHEC.
b.
Semi-annual Radiological Surveys and Annual Inspections l
TS 3.7.2.2. and 3.7.6 require that annual radiation surveys of the
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ship be made and that semi-annual environmental surveillances be i
conducted by the SC DHEC, Bureau of Radiological Health.
The inspector reviewed the results of radiological surveys performed for the licensee by SC DHEC personnel during the past three years. These surveys appeared to be adequate and reflected
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l radiation levels similar to those that were noted by the inspector during tours of the ship. The results of the semi-annual harbor water and bow sediment analyses were also reviewed with no problems noted.
During this inspection, the inspector also accompanied SC DHEC personnel while they performed a portion of their annual radiation and contamination level surveys of the ship for 1993. The SC DHEC survey results were consistent with those that had been obtained by the NRC inspector during the current inspection.
c.
Quarterly Intrusion Alarm and Seal Inspections TS 3.7.2.1 requires that periodically, and at least once per quarter, PPDA personnel will inspect the seals on the control area doors and test the intrusion alarm.
The inspector reviewed the inspection log sheets and verified that the seals on the control area doors were being checked and that the intrusion alarm was tested at least once per quarter. While discussing these inspections with the licensee, it was noted that the intrusion alarm tests (that had been performed in the past to satisfy this requirement) consisted of a check of the alarm circuitry and not an actual sounding of the audible signal.
Senior licensee management directed that subsequent tests include briefly opening the entrance to the reactor space on B Deck to
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cause activation of the audible alarm.
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d.
Security Patrols
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TS 3.3.2 requires that the vessel be positioned alongside a pier with controlled access. The pier entrance is required to be under 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> security and surveillance.
Security personnel shall patrol and visually inspect the vessel at the close of each day, and ensure that areas not in use are secured.
The security personnel are also required to patrol and inspect the vessel at least once each shift for possible fire, flooding, and other
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l abnormal occurrences. TS 3.7.1.6 requires that at night, on l
weekends and holidays, and after normal museum hours, security
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t personnel will patrol the vessel at least once during a l
twenty-four (24) hour period.
While discussing these requirements with the licensee to verify that they were being met and observing daily operations, the inspector determined that the pier entrance and the vessel were under 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> security and surveillance. Also, the ship is inspected and/or patrolled at least once cach shift during normal museum hours and inspected approximately every two hours during l
other times (back shift hours). This appeared to be more than
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adequate to meet the requirements stipulated in the TS.
e.
Hull Inspection TS 3.7.5 requires an underwater inspection of the hull to be I
conducted at least every four years.
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The inspector verified that such an inspection had taken place
within the past four years and reviewed the results of the underwater inspection of the hull that was performed by a
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contractor during September 14-29, 1992. The contractor noted
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100% hard fouling of the hull which consisted of oyster shells, barnacles, tube worms, and grasses. The contractor also observed that the hull coating was becoming detached in large sheets exposing the black oxidized metal hull underneath. The report also indicated that the cathodic protection system was not i
functioning properly.
Based upon the results of this latest
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inspection, MARAD personnel are considering drydocking the vessel in the near future; an actual date has not been established.
f.
Cathodic Protection System
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TS 3.7.4 requires that a cathodic protection system will be provided and properly maintained to protect the underwater areas of the vessel's hull to minimize corrosion damage to the hull.
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Based on the results of the underwater inspection of the hull, the licensee reviewed the operations of the cathodic protection J
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system. The system appeared to be functioning properly when one
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inspected the control panel because the proper lights were lit
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indicating the system was operating. However, when the licensee examined the situation further, it was determined that there was a wiring problem which gave an erroneous indication. This was
subsequently corrected with the assistance of a contractor and the system now appears to be operating adequately.
r The licensee was informed that failure to comply with the requirement of maintaining the cathodic protection system in a condition such that it would protect the underwater areas of the vessel's hull was an apparant violation of TS 3.7.4.
However, this violation will not be subiect to enforcement action because the licensee's efforts in identifving and correcting the violation meet the criteria specified in Section VII.B of the NRC i
Enforcement Policy (50-238/93-01-03).
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One non-cited violation was identified.
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Actions of Previous Inspection Findings (92701, 92702)
(Closed) Inspector Followup Item (IFI) 50-238/89-01-01: Followup on resolution of the apparent inconsistency in TS requirements for security patrols.
l During a previous inspection, an apparent inconsistency in the TS requirements for security patrols was noted.
The inspector reviewed this issue with the licensee and noted that the security patrols were
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actually being performed more frequently than required by TS (see l
Paragraph 3.d above).
Therefore this item is considered closed.
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5.
Exit Interview
The inspection scope and results were summarized on March 26, 1993, with those persons indicated in Paragraph I above. The licensee was informed l
that no problems were noted except for the non-cited violations
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discussed in Paragraphs 2 and 3 above. Also, no abnormal radiation levels were noted in comparison to those observed during the last i
l inspection. The apparent inconsistency in the security patrols was i
discussed and the licensee was informed that this previous Inspector
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i Followup Item was closed.
l Item Number Description and Reference
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I 50-238/93-01-01 NCV - Failure to maintain the entrance to a l
radiation control area locked as required by l
Technical Specification 3.3 (Paragraph 2.c).
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l 50-238/93-01-02 NCV - Failure to maintain the intrusion alarm in a condition such that the audible signal could be heard by the security guard force as required by Technical Specification 3.3 (Paragraph 2.e).
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item Number Description and Reference
50-239/93-01-03 NCV - Failure to maintain the cathodic
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protection system for the vessel in a fully i
operational condition as required by Technical
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Specification 3.7.4 (Paragraph 3.f).
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