IR 05000250/1985017

Insp Repts 50-250/85-17 & 50-251/85-17 on 850513-17. Noncompliance Noted:Failure to Package Low Specific Activity Matl for Transport in Strong,Tight Container

ML20132E639
Person / Time
Site:	Turkey Point
Issue date:	06/14/1985
From:	Albright R, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20132E605	List: IR 05000250/1985017 ML20132E602 ML20132E615
References
50-250-85-17, 50-251-85-17, NUDOCS 8508020052
Download: ML20132E639 (9)

Text

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p nog UNITED STATES

,p bo NUCLEAR REGULATORY COMMISSION

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j 101 MARIETTA STREET, t ATLANTA, GEORGI A 30323

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/ JUL 0 91985 Report Nos.: 50-250/85-17 and 50-251/85-17 Licensee: Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Docket Nos.: 50-250 and 50-251 License Nos.: OpR-31 and DPR-41 Facility Name: Turkey Point 3 and 4 Inspection Conducted: May 13-17, 1985 Inspector: b R. H. Albright $

b!/Y hf Date Signed Approved by: \ klY h Dat6 Signed C. M. Hos'ey,' Section }hief Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection entailed 32 inspector-hours on site in the areas of licensee action on previous enforcement matters, training and qualifications, control of radioactive materials and contamination, surveys, and monitoring, facilities and equipment, audits, transportation of radioactive material, external occupational dose control and personal dosimetry, internal exposure control and assessment, maintaining occupation doses as low as reason-ably achievable ( ALARA), radiological investigation reports, and inspector follow-up item Results: One violation was identified - failure to package low specific activity (LSA) material for transport in a strong, tight contairer.

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REPORT DETAILS Persons Contacted Licensee Employees

• C. M. Wethy, Vice President, Turkey Point

• C. Baker, Plant Manager

• H. T. Young, Project Site Manager

• 0. Grandage, Operation Superintendent

• P. W. Hughes, Health Physics Supervisor

• R. M. Brown, Health Physics Operations Supervisor

• J. Arias, Jr., Regulation and Compliance Supervisor

• P. J. Stoner, Nuclear Energy Specialist

• R. Hart, Licensing Engineer J. Bates, Health Physics ALARA Supervisor Other licensee employees contacted included technicians, operators, mechanics, and office personne NRC Resident Inspectors

• T. A. Peebles, Senior Resident Inspector

• R. Brewer, Resident Inspector

" Attended exit interview Exit Interview The inspection scope and findings were summarized on May 17, 1985, with those persons indicated in paragraph 1 above. The violation of 10 CfR 7 for failure to package LSA material for transport in a strong, tight container was discussed in detail. Licensee management acknowledged the violation. The inspector also discussed radiological investigation reports including one where an individual failed to follow a health physics technician's verbal instruction (paragraph 12). The licensee did not N identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters (Closed) Violation 50 2:0, 251/84-27-02 - This violation concerned the failure to have a specific Radiation Work Permit (RWP) for decontamination i work in the dry storage warehouse. The inspector reviewed and verified the corrective actions as stated in Florida Power and Light Company's letter of November 13, 198 (Closed) Violation _50-250/84-40-03 and 50-251/84-41-03 - This violation concerned the use of the GoLi analyzer without having performed the daily

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j energy calibratio The inspector reviewed and verified the corrective l'

J actions as stated in Florida Power and Light Company's letter of j February 22, 1985.

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l 4. Training and Qualification (83723)

, The licensee was required by Technical Specification 6.3 to qualify health l

physics (HP) technicians including contractors, in accordance with ANSI [

N18.1. The inspector observed the radiological controls established by the ;

contract HP technicians covering the maintenance tasks discussed in ,

paragraph The inspector discussed with the Health Physics Operations l i Supervisor and the technician the observed controls and those specified on i the kW ,

i I j The inspector reviewed the program for training and qualification of ;

j contract radiation protection technician The inspector discussed with ;

training personnel and the Health Physic Operations Supervisor, the training j 1 and qualification program the Itcensee had provided and what limits had been ,

placed on contract HP activities, until the individuals were determined to l I be qualified as senior technicians. The inspector reviewed the resumes, !

training records, and tests for three contract technicians who provided !

health physics surveillance for work on an Residual Heat Removal (RHR) valve .

inside containment, j

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No violations or deviations were identifie l S. Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83726)

The licensee was required by 10 CFR 20.201(b), 20.403, and 20.401 to perform I

! surveys to show compitance with regulatory limits and to maintain records of L

! such surveys. Technical Specification 6.8 required the licensee to follow I 1 written procedures. Radiological control procedures further outlined survey '

) methods and frequencie l

Surveys i L

i i The inspector observed, during plant tours, surveys being performed by ,

i radiation protection staff. The inspector reviewed two Radiation Work i i Permits, one for removal and replacement of oil soaked insulation from I

{ "8" reactor coolant pump, and one for repair and overhaul of an RHR l

valve to determine if adequate controls were specified. The inspector ;

discussed the controls and survey results with the health physics !

j technician assigned, j During plant tours, the inspector observed radiation level and con- l tamination survey results outside selected cubicles. The inspector l

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performed independent radiation level surveys of selected areas and l 4 compared them to licenses survey results. The inspector reviewed !

selected survey records for the month of May 1985.

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l No violations or deviations were identifie Frisking During tours of the plant, the inspector observed the exit of workers and movement of material from contamination control to clean areas to determined if proper frisking was performed by workers and that proper direct and removable contamination surveys were performed on material ,

The inspector reviewed records of skin contamination occurrences and resulting evaluations and corrective actio Records and discussions :

with licensee representatives showed contamination had been promptly removed from the workers using routine washing techniques. Subsequent !

whole body counts showed less than detectable internal disposition of '

radioactive materia ;

No violations or deviations were identified, Release of Materials for Unrestricted Use  !

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The inspector discussed, with a maintenance mechanic and a HP technician, the program for releasing material from contaminated areas or the Radiation Control Area (RCA) and reviewed the procedures for such releases. The inspector observed release surveys performed by HP r technicians and documentation of result No violations or deviations were identifie . Facilities and Equipment (83727)

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Final Safety Analysis Report (FSAR) Chapters 1 and 12 specified plant layout and radiation protection facilities and equipment. During plant tours, the '

inspector observed the operation of the contaminated clothing laundry, the flow of traffic thru change rooms, the use of temporary shielding and the use of ventilated containment enclosure No violations or deviations were identifie !

7. Audits (83722, 83723, 83724, 83725, 83726, 83727, 83728, 84722, 86721)

The licensee was required by Technical Specification 6.5 to perform audits of radiological controls and chemistry operations. The inspector reviewed audits of the radiation protection operations dated March 9 April 27, November 19, and December 3,1984; the responses to those audits; and the status of selective corrective actions resulting from the audit The

'nspector discussed the results of those audits and corrective action with L Ifconsee representatives. The audits were conducted using staf f with i technical backgrounds in radiological controls and chemistr ,

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4 8. Transportation (86721) CFR 71.5(a) requires that a licensee, who transports any licensed material outside the confines of his plant or other place of use or who delivers licensed material to a carrier for transport, comply with the regulations appropriate to the mode of transport of the Department of Transportation (00T) contained in 49 CFR Parts 170 through 18 CFR 173.425 states the transportation requirements for LSA radioactive material. 49 CFR 173.425(b) requires that shipments of LSA radioactive materials consigned as exclusive use be packaged in a DOT Specification 7A Type A package or in strong, tight containers so that I there will be no leakage of radioactive material under conditions normally incident to transportatio On May 2,1985, the Itcensee initiated a radioactive waste shipment, FP&L shipment no.85-038, destined for the Chem-Nuclear Barnwell Waste Management Factitty in South Carolina. The shipment was described as LSA material packaged in a strong tight package. The truck driver noticed one box, no. 85-0880, to be leaking af ter he made a stop in Vero Beach, Florid The shipping papers indicated that the box contained 4.44 mci and weighed 5650 pounds. The driver called Chom-Nuclear personnel at the Barnwell facility, who notified the Stato i of Florida and the licensee. The truck driver used a can to coIIect i'

leakage from the waste package. Approximately three cups of water were  ;

collected from the package leakage. The water was analyzed by the Itcensee and found to contain low levels of radioactivity, specifically [

Cs-137 at approximately 4500 picoeuries/litor (pC1/1), Cs-134 at approximately 200 pC1/1 and Co-60 at approximately 290 pCi/1. The

concentration of radioactive material that leaked from the package was significantly less than one percent of the concentration that would be allowed to be released as an ef fluent to an unrestricted area. This release of radioactive material would not poso any significant risk to the publi The truck driver for this shipment was an employee of Chem Nuclear System, Inc., and was knowledgeable of required actions in the event of a vehicle accident or observed leakage from a package. The driver had also been provided instructions concerning who to call in the event of an accident or observed leakage from a package. The driver used a G-M instrument to measure does rates around the truck and of the water leaking from the package. Those dose rates were reported to personnel at the Darnwell site who then contacted the Itconsee. The dose rate

- of the collected water was not above normal background and dose rates around the truck did not indicato changes to measurements made prior  ;

to shipmen The licensos and State of Florida representativos surveyed the truck  ;

and did not find loose contamination outside the package. The IIconsoo l and State of Florida representatives also surveyed the truck stop where l

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the truck was parked when the leak was noticed. No radioactivity above background was measure The package was caulked, inspected by the State and the licensee, and after the surveys were complete, the shipment was returned to the licensee facility were it originate The licensee determined that the leaking package contained dewatered condensate polishing resin and non-compressible equipment. The volume of the dewatered resin was 1.49E+6 cubic centimeters and weighed 2755 pounds. The specific activity of the resin was 3.305 E-7 microcuries per cubic centimeter. The water in the box apparently originated in the resin. The resin is not normally wet enough to yield free standing water that would leak from the packag ,

State of South Carolina representatives at the Barnwell site determined that the Barnwell site can receive packages of waste containing both dewatered resin and non-compressible waste. The limit on free standing .

water then depends of the volume of the resin. The allowable volume of free standing water for this package was 0.5% of the resin volume or 7.45 liter The three cups of liquid collected from the box were significantly less than the volume limit on free standing wate The activity in the box was mainly due to the non-compressible waste which weighed 2375 pounds and contained 4.4 millicuries of activit The inspector discussed with Itcensee representatives the results of an investigation conducted by the licensee during which it was concluded that the water in the shipping package resulted from the wetting of the resin by rain while it was stored outside in a dumpste The water leaking from the package originated from the material inside the package as indicated by the slight amount of activity in the wate Failure of the licensee to package the LSA material in a DOT Specifica-tion 7A package or a strong, tight container as evidenced by the leakage of the water from the container during transport was identified as a violation of 10 CFR 71.5 (50-250, 251/85-17-01), Enforcement Conference An enforcement conference was held with the persons Itsted below in attendance on June 4, 1985, in the Region !! Office. The topic was the i

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failure to ship LSA radioactive material in a strong, tight package as required by 49 CFR 173.42 '

Licensee Personnel C. O. Woody, Vice President - Nuclear Operations i C. M. Wethy, Vice President - Turkey Point C. J. Daher, Plant Manager - Nuclear P. W. Hughes Health Physics Supervisor J. Danek, Corporate Health Physicist A. J. Gould, Senior Specialist, Radlochemistry and Waste Management

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NR1 Personnel J. N. Grace, Regional Administrator R. D. Walker, Director, Division of Reactor Projects (DRP)

P. R. Bemis, Director, Division of Reactor Safety G. R. Jenkins, Director, Enforcement and Investigation Coordination Staff D. M. Collins, Acting Director, Division of Radiation Safety and Safeguards (DRSS)

V. L. Brownlee, Branch Chief, DRP S. A. Elrod, Section Chief, DRP C. M. Hosey, Section Chief, DRSS T. A. Peebles, Senior Resident Inspector, DRP The licensee discussed the cause of the event and its safety signif t-cance. The licensee stated the actions taken by the truck driver and their personnel were appropriate to protect the health and safety of the public. The licensee's prompt corrective actions to stop the leak, transfer the shipment to St. Lucie and results of radiation and contamination surveys associated with the leak were also discusse The licensee emphasized that the very low concentrations of radioactive material in the leakage demonstrated the negligible safety significance of the leakage. The mooting concluded with the licensee's discussion of their corrective action . External Occupational Dose Control and Personal Dostmotry (83724)

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The Itcensee was required by 10 CFR 20,202, 20.201(b), and 20.101 to provide appropriate dostmotry equipment and maintain worker's dosos below specified levels. The licensee was required by 10 CFR 20.203 and Technical Specifica-tion 6.12 to post and control access to plant areas. During observation of work in the plant, including work outlined in paragraph 5, the inspector observed the wearing of TLDs and pocket dosimeters by workers. The inspector discussed the assignment and use of dosimeters with protection technicians and supervisio During plant tours, the inspector checked the security of the locks for selected lock high radiation areas and the Unit 3 reactor vessel sump and observed posting of survey results and the use of controls specified on two RWP The inspector discussed key control for locked high radiation areas including the Unit 3 reactor vosso1 sump with HP technicians and the Health Physics $upervisor. The encore detector thimbles were withdrawn into the reactor vessel sump. The inspector verified by observation of the locked entry, posting of the locknd entry and through discussion with the Health Physics Supervisor that the unique controls required to provent unauthorized entry to the reactor vessel (RV) sump, with the thimble withdrawn, woro in plac i

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No violations or deviations were identifie . Internal Exposure Control and Assessment (83725)

The licensee was required by 10 CFR 20.103, 20.201(b), and 20.405 to control uptakes of radioactive material and assess such uptake During plant tours, the inspector observed the use of temporary ventilation systems, containment enclosures, and respirators. The inspector discussed the use of this equipment with HP technician The use of respiratory protective equipment and the results of air sample surveys for work described in paragraph 5 were discussed with technicians covering the wor Documentation of air sample results were also reviewed for this wor No violations or deviations were identifie . Maintaining Occupational Doses ALARA (83728)

10 CFR 20.1(c) specifies that licensees should implement programs to keep workers' doses ALARA, ALARA Reviews The inspector reviewed the ALARA review documentation for activities during the Unit 3,1985 spring outage with the ALARA coordinator. The planning interface between the outage groups and health physics ALARA were discussed with the ALARA coordinator. The process for determining that temporary shielding was required, the engineering review of

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shielding sites and controls over installation and removal were dis-cussed with the ALARA coordinator. Documentation of engineering reviews for temporary shielding sites was also reviewe ALARA Reports The inspector reviewed the ALARA Report for January - April 1985. The plant man-rem goal for 1985 is 1350 man-rem. The total cumulative dose for January 1 through April 30,1985, was 593 man-rem or about 44 percent of the 1985 man-rem goa No violations or deviations were identifie . Radiological Investigation Reports The inspector examined the Radiological Investigation Reports and resulting corrective actions for the period January through May 1985. One investiga-tion report dated May 4,1985, discussed an individual who did not obey verbal instructions from health physics technicians during his work on

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pressurizer piping or while removing his contaminated protective clothing (PCs). The worker was contaminated as a result of his disobeying verbal instructions while removing his PCs. Corrective action for this event was not complete; however, the individual had been restricted from entering the RCA until corrective action was complet No violations or deviations were identifie . Inspector Follow-up Items (Closed) Inspector Followup Item (IFI) (50-250/84-40-01, 50-251/84-41-01) -

This item concerned the need for a procedure to use in evaluating whole body count dat The inspector reviewed procedure 0-HPA-031, Personnel Monitoring of Internal Dose, which incorporated criteria to use in whole body count data evaluation. The inspector had no further question (Closed) IFI (50-250/84-40-02, 50-251/84-41-02) - This item concerned the need to document acceptance test criteria and results for instruments calibrated by a vendor. The inspector reviewed the new receipt inspection form that now includes this data. The inspector had no further question l

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