IR 05000250/1987036
| ML17342A940 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/30/1987 |
| From: | Hosey C, Kuzo G, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17342A938 | List: |
| References | |
| 50-250-87-36, 50-251-87-36, IEIN-87-031, IEIN-87-31, NUDOCS 8710060331 | |
| Download: ML17342A940 (25) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.IN.
ATLANTA,GEORGIA 30323 Rapor:
Nose I 50-2bO/87-36 and 50-251/87-36 L1censee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.:
250 and 251 Facility Name.:
Turkey Posn:
Inspectivri Conaucted:
August 24-28, 1987 Inspector:
G.
B.
Ku q f.
N.
Wr ht License Nos.
DPR-31 and DPR-41 ate igned Date 1gned Accompanying personnel H. germooo" n
Approved by:
i Q~
os, hl'eT Division of Radiat on Safezy and Safeguards ate i
ed SUMMARY Scope:
This routinE, unannounced inspectiol'as conducted in the areas of management controls, train1ng, external exposure control, control of radioactive material, facilities and equipment, solid wastes, transportation, and inspector followup of previously identified stems, enforcement matters, allegations, and IE IIIformation Notices.
Results:
Two violations were identified:
. (a) failure to follow Radiation Work Permit (RWP) requirements and (bj failure to properly complete a manifest for a radioactive waste shipment.
0~0331 8 0~00250 PDR ADOCH 0500
REPORT DETAILS Persons Contacted Licensee Employees
- J.
Odom, Site Vice President
- C. J. Baker, Plant Manager
- K. L. Jones, Supervisor, Technical Department
- J; Arias, Jr., Supervisor, Regulatory and Compliance Section
'*T. A. Finn, Acting Superintendent, Operations
- W. Bladlow, Superintendent, guality Assurance
'
E. Hayes, Supervisor, guality Control
"P.
W. Hughes, Supervisor, iiealth Physics (HP)
C-. A.
I arriner, Supervisor, guality Control Operations J.
D. Ferrare, Engineer, guali ty Assurance P. J. atoner, Senior Analyst, Waste Management, Nuclear Energ M. A. Jimemez, Engineer, HP 4. L. LaCarde, Radwaste Supervisor, HP k. t;. Brown, Operations Supervisor, HP J.
R. Bates, Jr.,
ALARP. Support Supervisor, HP F. Marder, Assistant Supervisor, Operations, HP R.
M. Givens, ALARA Engineer, HP J. L. Danek, Corporate Staff, HP M. L. Fedotowsky, Corporate Staff, HP M. L. Cooper, Speciality Training Coordinator W.
G. Jackson, Jr., Bioassay, HP y Staff Other Organization D.
B. Morris, Technical Representative, DURATEK Nuclear Regulatory Commission D. Brewer, Senior Resident Inspector
- J.
B. MacDonald, Resident Inspector
- Attended exit interview Other licensee employees coniacaed includea construction cra tsmen, engineers, technicians, operators, trasn1ng instructors, security office members and office personnel.
Exit Interview (3C703)
The inspection scope and findings were summarized on August 29, 1987, with those persons indicated in Paragraph 1 above.
The inspector noted that corrective actions regarding a
previous posting requirement violation (50-250, 251/87-15-01)
had not been completed as specified in a letter aated May 29, l987, and timely action io correct the item was necessar The followina violations were discussed in aetail:
(a) failure to follow Radiation Work Permit (RWiP) requirements and (b) failure to properly complete a manifest for a radwaste shipment.
.Licensee representatives stated that the failure to follow RWP requirements was licensee identified and corrective actions had been takin.
The inspector noted that the failure of previous corrective actions regarding a similar violation to prevent recurrence precluded the licensee from receiving credit for self-identification in this issue.
Iri addition, the inspector requested the licensee to evaluate health physics actions and provide information to NRC Region II concerning an unauthorized entry into containment personnel Hatch No.
on or abou.
March 10, 1987, as noted in.a security irregularity report.
The licensee ackriowledged the inspection findings.
During telephone conferences between the licensee and NRC Region II Office, on August 31, 1987 and September 1,
1987, the inspector was inforrpea that no violations of HP procedures were identified regarding the unauthorized personnel Hatch No.
4 entry on March 10, 1987.
The licensee did not identify as proprietary aiiy of the material provided to or reviewea bp the inspector during this inspection.
3.
Licensee Actioi rr; Previous Enforcement Matters (92702)
b.
(Closed)
Violation (50-250, 251/86-36-01)
Failure to obtain PhSC approval for procedures ana operating instructions as required by Technical Specification TS 6.8.2.
The inspector verified ard discussec vhe
>riiplementation of correczive actions stated in.a Florida Power and Light Company (FP8L) letter dated December 26, 1986.
(Open)
Violation (50-250, 251/87-15-01)
Failure to post Notice of Violation (NOV) and response as required by 10CFP, 19. 11(a)(4).
The inspector reviewed iripreiiientation of corrective actions stated in FPfL "
response dated May 29, 1987.
As stated in the response a
bulletin board placed in the nuclear aaministration building riow is un lized for posting of NOVs and applicable, responses.
However, Section 4 of the response details that a notice will be placed on various bulletiri boards around the plant informina employees of this new bulletiii board, the documents available for their review and the location of such documents.
Cognizant licensee representatives stated that bulletin boards containing this information were located at borh the FP8L and contractor entrances to the nuclear production facilities.
During tours of these areas on August 22-26, 1987, the inspector noted that the requi red information. stating where appl',cable aocuments could be reviewed were not posted at the contractor's entrarice of the south gate.
The inspector discussed with licensee management concerns regarding licerisee failure to completely ir',pleriient and verify corrective actions as committed to in the FPSL response dated May 29, 198 i
Organization and Management Controls (83722)
Technical Specification (TS) 6.2.2 details the licensee's organization.
The inspector reviewed the health physics organization, staffing levels arid lines of authority as they related to radiation protection, radioactive material control and trarrsportation of radioactive material.
No organizational changes which could affect the licensee's ability tc maintain radiation protection activities have occurred since this area-previously was reviewed ( IE Report No.
50-250, 251/86-36).
Licensee represerrtatives stated that there has been a low turnover of personnel in positions above the techniciar.
level at the facility.
The licensee recently has completed outage work for both nuclear units at the site and present personnel appear adequate to provide health physics support for routine operatiorrs.
No violations or deviations were identified.
Trairing and (}ualifications (83723)
CFR 19.12 requires the licensee to instruct all individuals workirr. in or freruerting any portion of the restricted area in the health protection problems associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposures, and in the purpose or functions of protective devices employed, applicable provisions of Commission regulations, indiviaual responsibilities
'an< the availability of radiation exposure aata.
The inspector discussed the radiation protection aspects of the general employee training program with licensee representatives and toured the licensee s train'.ng facilities including the steam generator mock-up area, the personnel dress-out area and classroom areas.
Durino tours of the plant, thc inspector interviewed workers to assess their knowledge an'd unaerstaric'ir>g of radiation protection requirements.
Technical Specification 6.4.1 states that a retraining ard replacement training program for the facility staff shall be ir. accordance with ANSI N18. 1-19/1.
Paragraph 5.5 of ANSI N18. 1 states that a trainsng program shall be established which maintains proficiency of the operating organization through periodic training exercises, instruction periods and reviews.
Plant Procedure O-ADM-306, "General Employee Training and Retraining,"
dated August 14, 1985, establishes the training/retraining program for plant personnel.
The inspector discussed the replacement training and refresher training prograr<<
for radiation workers with licensee representatives and reviewed selected train>rig records.
No violations or deviations were identifie l
External Exposure Cortrol and Personnel Dosimetry (83524, 83724)
CFP, 20. 101 specifies the applicable radiation dose standards.
The inspector reviewed the computer printouts (NRC Form 5 equivalent) for the period january 1-August 25, 1987, and verified that the radiation doses recorded for, most plant pe'rsonnel were well within the quarterly limits of 20. 101(a).
The inspector reviewed selected occupational exposure histories for individuals who exceeded the values in 10 CFR 20. 101(a).
CFR 20.101(b)(3)
requires the licensee to determine an individual's accumulated occupational dose to the whole body on an NRC Form 4 or equivalent record prior xo permitting the individual to exceed the limits of 20. 101{a).
The exposure histories were being completed and maintained i equ-irido by
CFR 20.102.
CFR 2G.202 reovires each licensee to supply appropriate personnel mo>>izori'ng equipment to specific individuals and requires the use of such equipment.
During tours of the plant, the inspector observed workers wearing appropriate personnel monitoring devices,
CFR 20.203 spec>Aus the posting, labeling and control requirements for raaiat,ioi, areas, high radiation areas and radioactive materials.
Adaitional requirements for control of high radiation areas are contained in Technical Specification 6.12.
During tour=- of she plant, the inspector reviewed the licensee's posting and control of radiation areas, high radiation areas, contamination areas, radicac;ivu material areas, and the labeling of radioactive material.
The inspector also performed an independent radiation survey of areas inside
'.hc Radiac>un Control Area (RCA) and around the fence of the RCA.
Nc unexpected radiation fielas were found.
The inspector reviewed the following plant proceoures wnich are pare Gf the
'licensee's program for personnel monitor ing of external dose ir accordance with 10 CFR 20.202:
O-HPA-030, "Personnel Yionitoring of External Dose," dated April 30, 1987 O-HPT-G18, "Calibration of Survey Instruments,"
dated April 30, 1987 Licensee representatives indicated that they currently perform beta dose rate calibrations on their RO-2 and RO-2A ion chambers by using a
calibrated depleted uranium slab source.
Also, thermoluminescent dosimeter (TLU) beta dose calibrations are performed using a
90Sr-Y calibrated source.
6oth types of sources produce beta particles with mean energies in the order of 800 keV.
This is in contrast to the 268 keV mean energy of the plant beta fields, as determined by the licensee.
Licensee representatives inaicatea that they were evaluating the possibility of using beta sources such as 204TL (mean energy of approximately 250 keV)
which more closely resemble the beta energies found in the plan I Licensee representatives stated that by January 1988, they would either be performing beta calibrations on their, instruments with 204TL or similar sources or would have made additional studies to justify why changes in calibration proceaures are not necessaQ
.
The inspector stated that the evaluation of the licensee's approach to beta calibration for the TLDs and ion chambers was to be considered an inspector followup item concerning radiation monitoring instrumentation and would be reviewed during a
subsequent inspection (50-250, 251/87-36-01)
Selected records
.nd discrepancy reports between self reading pocket dosimeter (SRPD)
anc TLD data utilized for external dose monitoring were reviewed and disco.sec.
From review of anamolous SRPD data and discussion with licensee representatives, the inspector determined that not all personnel wore maintaining their dosimetry at the main HP control point when exiting the RCA.
Section 5.0.3, of Procedure OHPA-002, Requirements fur entry ano work in RCA, stares that personnel exiting the RCA should hand the technician their dosimeter and TLD.
The inspector noted that the failure wu require aosimetry to be collected ard read by the appropriate technician at the control poin'esulted in anomalous oata repc rtud (160 mR ei runeously being entered twic<<) for an individual involved in a contamination event on Yay 27, 1987 (Paragraph 14.d).
Furtheroiore, the col l ct"~on oi 'all dosimetry at thu cor rol point would allow for more accurate accountino of personnel in the RCA.
Licensee personnel sxated the>> ould evaluate their present program.
This issue will be considered inspector identified item and wilt be reviewed during a
subsequent inspdction (b0-250, 251/87-36-02).
I~o viulations or deviations were identified.
7.
Control of Radioactive liaterials and Contamination, Surveys, and l~ionitoring (83726)
a ~
b.
Surveys
CFR 20.201(b)
and 20.401 require x,he licensee to perform surveys to show compliance with regulatory limits and to maintain records of such surveys.
During plant tours, the inspector observed radiation level and contamination survey results which are posted outside selected area.
of the auxiliary building.
The inspector performed independent radiation level surveys of selected areas and compared them to licensee survev results and posting requirements.
All survey results appeared adequate.
k Frisking During tours of th~ p'lant., the inspector observed movement of workers and/or their tools from contaminat>on to clean areas.
On August 23, 1987, the inspector observeo the exit of personnel and the transfer of tools from containment during backshlia operations.
All personnel
pel formed adequate whole-body f> isks and tool s were doubl e yellow-bagged and tagged by a
HP technician prior to transfer intc nuncontaminatea areas.
To<,ls were transferred to the FP8L hot tool room for routine decontamination processing.
PCII-lB Monitors IE Inspection Report No. 50-250, 251/87-15, issued April 29, 1987, noted that the licersee planned to have state-of-the-art frisking
- booths operational at the facility in approximately four to five months.
The inspector was informed that the new monitors (PCII-1Bs)
had been received but were not operational.
Licensee management indicated that procedure development concerning operation, maintenance and calibration of the monitors, was now a priority issue and the eouipment would be functional in a timely manner.
Radi ation I@irk Permi is lechnical Specification 6.8.'.
requires written procedures to be established, implemented auld mallltdined to meet or exceed the; requlreh'cuts and recommenaations of Appendix "A" of USNRC Regulatory Guide 1.33.
Regulatory Guide 1.33, Appendix "A" requires procedures for personnel mon>toring and special work permits.
Licensee procedure O-HPA-002, 8/12/86, Section 3.2 ~ 1 requires individuals to fully understand and i'oliow all requirements of the Radiation Work Permit (RWP,'.
The inspector reviewed,, discussed and, where possible, observed work and faci l>t>e~ associated with RWFs.
The inspector reviewed and discussed RWP 2401, Overhaul of 3-B RIIR Pump, for a
'Gb conducted during July 1987 in the Unst 4 cask decon area.
Records reviewed included pre-job ALARA plans, hazard evaluations, respirator and badgina requirements.
A special tent enclosure with high efficiency particulate air (HEPA) ventilation ano washdown of the area between
'ob stages'ere utilized for contamination control.
HP coverage was continuously provided to conduct appropriate surface and airborne contamination surveys.
Air sampling was conducted in the work area and also at the boundary area.
The total cumulative dose job completion was 0.715 person-rem compared an estimated goal of'.5 person-rem.
RWP 87-1004, Auxiliary Building Unit 0'3 Spent Fuel Pit Shuffle Fuel/Perform Refueling Operations, 3/4/87, Section 8, required Health Physics (HP)
coverage for. moving fuel.
Discussion with licensee representatives determined that HP coverage was needed to provide assistance for any contamination problems, for example, dropped t<<ols, and/or concerns if any fuel was damaged during the operation.
from a
review of licensee Incident Report HP-12, the inspector determined that on Yap 30, 1987, a licensed operator entered the Unit 3 Spent Fuel Pit area 1n the afternoon and continued fuel reshuffling actIvities without HP coverage.
Licensee representatives noted the apparent violation and initiated corrective actions
Qi,
including:
counseling of the operator of importance to follow RWPs, arid revisioni of procedures Of-16002.6, Refueling Preshuffle in the Spent Fuel Pit and OP-16002.7, Preparation anc Precautions for Refueling Fuel Shuffle.
The inspector noted that a similar violatioii occurred as discussed in Inspection Report Nos.
50-250, 251/86-04.
In the response from FP8;L to Mr. J.
M. Taylor, Director, Office of Inspection aiid Enforcement, dated May 28, 1986, actioiis taken to ensure verbatim compliance with instructions include (1)
a corporate Vice President Policy letter on compliance with RWPs, dated dune 5,
1985 alid (2) training employees in the importance of procedural ana RWP compliance.
The inspector noted that for this most recent violation, the licensee did not meet the self identification criteria of
'10 CFR Part 2, Appendix C.V.A in that the violation could reasonably bc exp',cted to have been preventeC by the licensee's previous corrective actions.
Thus, the failure to follow RWP requirements for fuel shuffle activities on May 30, 1987, was ident"', iud a..
en apparent violation of T. S. 6.8.1 (50-250, 251/87-36-03).
Facilities and Equipment (83727)
The inspector aiscussed facility charges and toured selected site fac.lities >vith licensee representatives.
Since November 1986, entry irto the radiat.ion control area (RCA) has been through a single control point.
Lsc~nsee representatives stated that the use of one entry point versus the two control points previously utilized allowed for improved control of RWP act>vent>~~
and communication between the HP staff and workers.
Changes proposed by the licensee for the site contaminated laundry fac>lities were discussed.
1hi=sc changes included more restrictive limits oii clothing contalilinalicn levels requiring resurvey and/or rewash and the use of a laundry monitor for scanning of washed clothing.
Presently, procedural development and testing for the laundry monitor is being conducted by the onsite HP staff.
'ether, furictional, the monitor will be maintained away from the
'<sundry in the decontamination facility to minimize background interfei ence.
The inspector discussed issues regaralng the whole-body counting eouipment and facilities with cognizant licensee representatives.
The licensee informed the inspector that plans for relocation of the equipment into the health physics building had been approved and should be completed in the near future.
This siiiproved location should improve problems concerning temperature fluctuations in the present facility.
The inspector questioned whether the pr&secit conaitions negatively affected the whole-body counting results.
The accuracy of the whole-body counting system was reviewed in Ceta>'i.
The inspector noted.that although quality control (OC)
checks were conducted daily, electronic drift of the equipment resulted iri a h>ft cf many measured radioiiuclide's energy peaks outside cf the acceptaiice limits (the known isotopic energy F10 keV)
utilized for identification anC subsequent quantification.
Licensee representatives stated that technicians involved with operation of the systems were aware uf the'r>ft problem and were trained to identify and
evaluate any unknowii or anomolous data.
Observations of the whole-body system operations and discussions with cognizant techriicians indicated that results were adequately reviewed and checked for.elevated concentrations and anamolous data.
Results of the licensee gC cross-check program used to verify whole-body counting measurement accuracy were reviewed and determined tc be adequate.
The licensee agreed to evaluate gC actions needec to minimize potential problems associated with electronic drift and take appropriate action.
This issue concerning drift of the whole body couriting equipment will be an inspector identified item and will be reviewed during a
subsequent inspection (50-250, 251/87-36-04).
fiaintairiing Occupational Exposures ALARA (83728)
CFR 20.1(c) states that licensees should make every resonable effort to maintain radi t-ion exposures
"as low as reasonably achievable" (ALARA).
~ Other recommended elemerits of an ALARA program are contained in Regulatory Guides 8.4 v>>a 8. 10.
The inspector examined the licensee's'LARA program and conducted interviews with 'licensee representatives to assess the degree ol maintenance and support oi the program.
Emphasis was placed on ALARA support for unscheduled work during the recent outages irI Units
alai~
A. of Ju'ly 31, 1987, unscheduled outage work in Unit 4 accounted for 404 man-rem and unscheduled outage work in Unit 3 accounted for 210 man-rerii; tlie rota 1 col lective dose for both units as of the aforementiored date was 1,410 man-rem.
Collective doses were based on pocket dosimeter ruadirigs aria these aosimeters typically over responded by approximately 20Ã.
If this over-response is considered and if there had beer, no unschedulec work this year, the licensee's collective 'exposure would have remained below the goal of 890 man-rem for this particular time frame.
Tho
'.ii pector reviewed ALARM pre-anic post-job reviews for selected Radiation Work Permits (RWPs)
used during the outages and verified that the licensee evaluated the degree of success or failure of exposure-reduction techriiques used.
Licensee'epresentatives indicated that the evaluations were filed and kept for future reference.
They also indicated that approximately 270 man-rem were saved during the outage due to the exwens>ve use of temporary shielding, decontamination techniques, moving equipment to low dose rate areas for maintenance and ensuring that staridby personnel waited in low dose rate areas.
No violations or aeviations were. identified.
Solid l'astes (84722)
CFR 20.311 requires a
liicensee who transfers radioactive waste to a
1ar,c:
di sposa I
iacility to prepare all waste so that the waste-is classified in accordance with
.0 CFR 61.55 and meets the waste
Cl
characteristic requi reri ert'f 10 CFR 61. 56.
It further establishes specific requirements for conducting a quality control program.
The inspector reviewed the methods used by the licensee to assure that waste was properly classified, met the waste form and characteristics required by
CFR 61.56 and the disposal site license conditions, and discussed the use of these methods with licensee representatives.
The inspector oiscussed with licensee representatives their program of waste s-ream sampling in order to develop waste classification scaling
=
factors.
Licensee Prccedure O-HPA-040, Shipping and Receiving Radioactive Hater<;1, dated February 10, 1987, outlires the waste classificatiu>>
procedure and lists high level resin, process resin, carbon media, aqueous
"ilters, dry active waste, and activated metal as waste streams.
= The procedure requires that analysis of'ach-stream be performed annually.
The ',nspector determined that the licensee's procedures provided minit.'z'.
guidance in the sampling process, anal>>sis, selection criteria, and schedule for updating the waste stream scaling factors.
In addition, the
'roccdi regis
~lid. not describe the, responsibilities of the corporate health physics staff in determining scaling tactor recommendations.
The ins~ii=ctor determined that the licensee had identified the need to strenc,then its radioactive waste procedures and was currently in the proce~s uf improving radwaste procedures at the St. Lucie facility.
The licensee plans to revise the Turkey PUinw proceoures in the same furmat as the St. Lucie procedures.
The inspectvr reviewed the results of the most recent waste stream analysis documented in an interoffice correspondence titled Turkey Point Unit,s
aild
Scaling Factor Yalidation arid Pecommendations, dated November 5,
1986.
The document was prepared by the corporate health physics staff utilizing the sample analysis results provided by a vendor laboratory.
The dccument. briefly described the bases for the scaling factor recomi.iendutsons.
The inspector reviewed waste classification deterr.ir atsuns filed with selected sh>pping records.
The site Quality Control (QC) organization provided inspections covering radwaste preparation, packaging, and shipping.
The inspector determined that the QC inspector ri:sponsible for radwaste activities had received training in the shipment of radwaste in a
vendor training program.
Specific surveillance checklists were utilized for monitoring radwaste activities associated with various type radwaste shipments.
Mandatory inspection hold points were utilized in procedures related to preparation, packaging, and shippinc, and required inspection by QC personnel prior to contiruat,ion oi the procedures.
Review o
records related to radwaste shipment showed that the designated QC activities had been completed.
The site Qualiay Assurance Organization routinely scheduled audits of radwaste storage and shipment of radioactive waste including the Process Cuntivl f rugram (PCP).
The inspector reviewed the results of the following radwaste auoit report gAG-PTN-06-738 conducted April 7-May 28, 1986 gAO-PTN-87-841 conducted June 2-July 8, 1987 The inspector reviewed the audit checklist and the qualifications of auditors associated with the audit reports.
The checklist accompanying the audits viere primarily concerned with compliance with licensee Procedure O-HPA-40, Snspping and Receiving Radioactive flaterial.
The inspector determined that the principal auditor met the requirements of ANSI N45.2.23, gualification of (juality Assurance Program Audit Personnel for Nuclear Power Plants and llad'imited training in radwaste shipment and health physics through vendor training programs.
The inspcctol noted that all audit finding had been resolved in a timely manner.
The licensee ensu'res waste stability through use of high integrity containers.
Through discussions with licensee personnel, the inspector determined that no solidification of waste was performed at the site.
The inspector reviewed the licensee's activsties in the dry storage warehouse.
The licensee utilized a box compactor capable cf compacting dry active viaste (DAW) to 30 pounds per cubic foot (ft3).
The licensee had secured a contrac
. w"vh a vendor zo compacl the DAli to 70 to 80 lbs per
'-.
At, riage time of inspection the licensee had an inventory of c pf'l 0Ylmatcly 14 000 ft3 of DAV
"
The 1 i cellsee planned to
- lhove the radiation control area (RCA)
boundary from outside the dry storage viarehouse tc the middle of the warehouse to allow a
por tion of the building ao remain outside the RCA.
This would allovi nevi material entering the warehouse to be unpackaged outside the RCA for 1,he purpose of reducing the amount of DAl generated.
No violations or o~viar.ions were identified.
iranspor:ation of Radioactive Material (8672J,'0 CFR 71.5(a)
requires each licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, to comply with the applicable requirements of the regulations appropriate to the mode of transport of the DOT in 49 CFP, Parts 170 through 189.
CFR 172.200 -requires a
person, who offers hazardous material for transportation, tu describe the hazardous material on shipping papers.
CFR 172. 101 defines radioactive material as a hazardous material.
CFR 172.203(d)(s)
radioactive material radioactive material shipment in terms of requires the description 'or a
shipment of to include the name of each radionuclide in the and t,he activity containea in each package of the curies, millicuries, or microcurie g The inspector reviewed selected records of'adioactive waste shipments.
performed dur>ng 1987.
The inspector selectively performed independent ca 1 cul ati ons using the 1 ice nsee '
records of radi oacti ve nucl ide composition and verified that the shipments reviewed had been properly
.'lassified.
J Shipment Number 87-03, consisting of dewatered charcoal filter media in a steel liner, was shipped to the radioactive waste disposal facility near Barnwell, South Carolina on January 20, 1987.
The shipment was classified as low specific activity (LSA) and was transported in an exclusive use transport vehicle.
The inspector, noted that the shipment manifest did not list antiriiony-125 (125Sb)
as one of the radionuclides identified in the radioactive waste sample analysis.
The nuclide identification surrimary for th>>
sample reported the 125Sb concentration to be 5.712 E-2 microcuries per cub',c centimeter (uCi/cm').
Licensee representatives stated that the isotopes identificavion and quanti'ty had been inadvertently omitted from the shipment manifest.
The 125 Sb radionuclide contributed an additional 194. 1 millicuries (mCi) to the 2274.85 mCi reported on the manifest or approxirretely 8 percent of the total activity.
Failure to include the narre of each radionuclide.in the radioactive material and the correct activity contained in each package of the shipment in terms of curi<<s, millicuries or microcur>es was identified as an apparent violauon of 10 CFR 71.5(a)
(50-250, 251/87-36-05).
CFR 173.475('j staves that before each shipment of any radioactive materials package, th~ shipper shall ensure by examination or appropriate tests that external radiation and contaminatsun levels are within al 1 owabl e 1 imits.
49 CFf'I3.441(b)(2) specifies that radiation levels at any point on the outer surface of exclusive use vehicles, including top and underside of the veh>cle, must not exceed 200 rrillirem per hour during. transportatIon.
4& Gff'73.441(b)(3) specifies that radiatior: levels at any point 2 meters from the outer lateral surface of exclusive use vehicles, including top and underside of the vehicle, must not exceed 10 ri~illirem per hour during transportation.
CFR 173.441(b)(4)
specifies that radiation levels in any normally occupied space of the vehicle must not exceed 2 millirem per hour during transportation unless personnel dosimetry is provided under the provisions of a state or federally regulated radiation protection program.
" Lic<<nsee quality assurance audit gAO-PTN-86-738 identified a problem with radioactive waste/material shipping survey documentation.
The findirg reported numerous radioactive waste/material shipping records did rot adequately document 2 meter, unaer truck, and cab radiation levels.
The finding also reported that compliance to the vehicle radiation levels of 200 mR/hour at contact, less than 10 mR/hour at 2 meters, and less than
2 mR/hour in vehicle cab was met in that contact readings of the vehicle were less than 0.1 mR/hour.
The finding recommended standardizing th'e survey form for radioactive waste/material shipments and reinstruction for personnel using the new survey form.
The audit report documented corrective action completion prior to the post audit conference.
Failure of the licensee to insure by examination or appropriate test that external radiation levels at two meters, underneath side of the transport vehicle, and in the vehicle cab wer'e within the allowable limits was identified as an apparent violation of 10 CFP, 71.5(a);
however, pursuant to
CFR 2, Appendix C.V.A it was determined that a Notice of Violation would not be issued due to licensee self identification of the problem.
The inspector pointed out to corporate health physics representatives that a
similar survey documentation problem -for failure to survey the underneath side of a transport vehicle had resulted in a violation at the licensee's St.
Lucie facility the following year.
The inspector stated that effective communicatior!
between the licensee's two facilities concerning ide<<tified problems could help prevert duplicate violations.
12.
IE Information Notices (IEN) (92717)
The inspector aetermined that Information Notice No. 87-31, Blocking, Bracing, ar;d Securing of Radioactive Material Packages in Transportation, had been received by the licensee, reviewed for 'applicability, distributed to appropriate personnel and that action,
=as appropriate, was taken or planned.
13.
Inspector Followup Items (92/Olj (Closed)
Inspector Followup Item ( IFI)
(50-250/87-15-02, 251/Gi-15-02),
Review of corrective action for licensee-identified violation for failure to have respiralor policy statement.
During the inspection ihe inspecTor reviewed the respirator policy statement detailed in Section 5. 1 of 0-HPA-060 Respiratory Protection 3/24/87.
b.
(Closed)
IFI (50-250, 251/87-15-03):
This item dealt with ALARA planning and controls placed ir!to effect for the splice replacement work.
Through. discussions with licensee representatives and review of records, the inspector verified that the total collective dose associated
>>ith i;he splice replacement project in both units was 141 man-rem (as per self-reading pocket dosimeters),
or 14 man-rem less than the estimated 155 rilan-rems for the project.
The application of'ose-reauctir!
techniques such as temporary shielding, moving the cables to low radiation area~
and pre-job planning contributed to the man-rem saving.
Allegation Followup (99014)
Alleg~tion (PII-87-A-0049)
The alleger stated that unexplained discrepancies in external exposure data existed between self reading pocket dosimeters (SRPD)
and monthly TLD results fur personnel at Turkey Point Nuclear Plant from October through December 1985.
In aadition, whole body counting results for selected individuals were inaccurate, in that printouts describing the results indicatea an acquisition date of January 1981 for analyses conducted or, December 13, 1985.
Discussion The inspector reviewed specific SRPD And TLD data assigned to the alleger dur>ng th<< times specified.
No anomalous data or changes to the data were noted.
All SRPD/TLD discrepancies woulo have been sub'ect zo the discrepancy investigative procedure detailed in Section 5. 14 of Plant Procedure O-HPA.-030, Personnel monitor>ng of external dose.
In addition, selective records of both FPKL ana contractor personnel were reviewed for the time period specified.
No discrepancies or unresclved descrepancies between the SRPD and TLD were noteu.
ih~ >nspector deters'ined from discussion and actual demonstration oi the whole-body counting system, that for the system an improper acquisii>on date and time would riot affect the quantitative results.
Licensee representatives indicated that when the system goes off-line and then restarts, the system defaults to a January 1981 date.
The failure to update the acquisition date and time would not affect the results, provident that the count date and uptake dates were entered properly into the computer system.
A'eview of the alleger's records confirmed that the, count, ana uptake dates were appropriate.
t Findinc The allegation was paYtially substantiated in that the aquisition dates differed from the actual whole body count counting dates.
However, this discrepancy did not affect the accuracy of the whole-body counting analyses.
All external exposure data were found to be properly reported.
There were no indications of data
.falsification nor violations of NRC exposure limits.
No violations or deviations were identified.
b.
Allegation (RII-87-A-0057)
Aaditional health and safety concerns regarding the allegatior were received in June 10, 1987 correspondence received from the allege The adoitional concerns reviewed during this inspection were as
.
follows:
1.
The alleger was required to decon a
pump outside that was reading greater than 50,000 dpm while wearing a wet suit and respirator.
2.'n o)
arouna llay 15, 1987, grinding was performed on the reactor head and air samples were not taken due to nonworking electrical outlets.
A person trying to take the sample was contaminated.
3.
f> spec>i'ied individual was terminated and given a urinalysis because the whole body counter was closed.
Discussion Prior to and durino the present inspection, HPC representatives made repeated ef orts to contact the alleger to attempt to obtain more specif>c infurmatior for example, the exact location and dates, necessary to substantiate these radiological health and safety issues.
The alleger failed to provide any further information.
The inspector discussed the general substance of the al.,legation with 1";cans~a, representatives and iriterviewc,d licensee employees involved in these issues.
The inspector also reviewed licensee records and procedures, ana where applicable, observed current work in progress, similar to selected work regarding the allegations.
The specific issues are discussed as follows:
(1}
Contaminated equipment having levels of contamination greater than 5G,COC dpm are routinely decontaminated in the cask decon areas located outside of the auxiliary building.
Protective
'lothing and respiratory protection requirements are detailed on PWPs assoc,>ated with each project concerning equipment decontamination.
For equipment having survey levels greater than 50,000 dpm, a
respirator ana appropriate protective cloThing are required.
In addition, HP coverage is utilized to conduct air sampling and conduct contamination surveys as appropriate.
A review of previous records concerning decontamination of pumps and also equipment decontamination work in progress during the inspection indicateo RWPs and/or procedures were followed.
(E)
Specific locatioris, dates and times of this event within containment were not provided by the alleger.
Dur>ng grinding operations
>>ithin conta'inment, respirators were worn and air samples
< cre routinely taken.
Licensee representatives stated that if air sampling could not be conducted, HP had the authority to terminate or prevent such grinding operatioris.
The inspector reviewed selected air sample logs and tlPC-hr assignments, associated with grinding activities in containmenx frigo tray 4, 1987 through llay 15, 1987.
Based on breathing zone
and boundary air sample results and issuance of respiratory equipment, it appeared that licensee raasological controls were adequate for grinding jobs performed in containment.
No discrepancies were notea.
In addition, no licensee and contract personnel recalled air, sampling problems resulting from nonworking electrical outlets.
(3)
When the whole body counting system is unavailable for use, lice>>see procedures allow th~ use of urinalysis methodology to evaluate the potential for internal radionuclide contamination.
Urinalyses were conducted by a
vendor laboratory.
For the specified i>>dividual alleged not to have received a whole boay cou>>t, licensee records indicated that a termination whole body count was conaucted as required.
Furthermore, review of selected licensee bioassay data indicates no action points nor regulatory exposure 1'ionts were exceeded for those individuals analyzeo using urinalysis methodology.
Finoings (I,)
~ Thu a'i',ugation was substantiated in that decontamination of equlpmant wii.h contamination levels as high as 500,000 dpm has occurred.
Decontami>>ation of selected equipment with contamination levels greater than 50,000 dpm has been conoucted as alleged.
I-'owever, licensee procedures provide adequate radiological controls for conducting this work.
(2)
The allegation could not be substantiated.
A>r samples were collectec durl>>g a>>y work requiring respirator protection.
The lack of specific Cata regarding the event precluded a
more thorough investioatinr, of this allegation.
From general discussions with personnel and review of records, no examples of improper licensee practices. were noted.
(3)
The allegation was not substantiated.
Licensee practices for bioassap
.analyses appeard to be adequate to evaluate potent>al uptake of radioactive contaminants.
In addition, records for the individual specified to have received a urinalysis indicated that a termination whole body was conducted in April 1987.
No anomalous measurements were reported.
No violations or deviations were identified.
Allegation (RII-87-A-0068)
On June 8,
1987, NRC Region II forwaraed to the licensee an allegation pertaining to failure to follow contamination control procedures for the transfer of tools and equipment from contaminated areas
.into clean areas.
In a letter dated July 24, 1987, the licensee forwarded to the NRC the results of their independent investigation into the allegations.
The inspector reviewed the
i
licensee's response and-conducted additional review of the allegations.
Discussion The inspector determined that the licensee's response was adequate.
Fror discussion with licensee training personnel and also limitec interviews and observations of work in progress, the inspector determined that proper radiation control procedures were taught and fo'allowed.
1he inspector noted that both non-contaminated and contaminated tools were stored in the separate areas of contractor tool storage building.
Cognizant contract personnel indicated that removal of contaminated tools from their storage area required the appropriate controls, than is, HP surveys and the use of double bags and tags.
Finding
'This aliegation coula not be substantiated.
ho violations or deviations were identified.
Allegation (Rli-87-A-0083)
The alleger stated that he was exposed to airborne contamination during Unix.
3 outage work at the Turkey Point Nuclear Plant on May 27, l987.
This exposure incident resulted in positive uptake as determined by whole bocy counting results.
The alleger was informed regulato>~
1'.mits were not exceeded and that routine whole-boay counts conducted for job termination purposes on June 6,
1987, inaicated normal results.
The'lleger was concerned that elevaxea gross counts, approximately 1200 compared to 600-700 normally npvrteo, for a subsequent whole-body analysis conducted at another utility.indicated an ever'xposure to airborne radioactive contaminants der>ng the incident at the Turkey Point Facility.
Discussion The inspector reviewed records and discussed this issue with cognizant licensee representatives.
Licensee representatives stated that while exiting from a work area in the reactor head, physical damage to the alleger's respiratory protective equipment resulted in exposure to and the subsequent positive uptake of radioactive material.
Licensee representatives lrritiated routine contamination evaluation and decontaminatiun procedures.
Subsequent, to preliminary decontamination, a series of whole bGG3 counting analyses through time were conducted.
The inspector reviewed and discussed whole body counting results with licensee representatives.
All data relating to the specific incident appeared to be appropriately identified, analyzed, and evaluated by licensee personnel.
The inspector reviewed licensee Maximum Permissible Concertration-hour (MPC-hour)
calculations based on the Turkey Point whole-body counting results.
For the specific event a 7.1 t)PC-hour exposure value was assicred to
'Ile
'I nGi vidual.
Licensee records indicated that the 1ndividual received ar, additional 0.5 NPC-hour exposure for the quarter.
The inspector discussed detection capabilities of the whole body cour ting system with cogni'zant licensee representatives.
Detection capabilities were adequate.
The significance of the difference between the gross counts recorded by the two whole body counting systel is callhot be determined, due to variations in background, calibration of the systems, and types of detection and analysis systems.
Finding The
',i~ensee's actions ana calculations of exposure to airborne radioactive contamination appeared to be adequate.
The allegation was partially substantiated in that the exposure event occurred as stated, however, the assigned 7.6 t~iPC-hour exposure was below the
CFR 20.103 quarterly l'immit of 520 YiPC-hours.
lie violations or deviations were identified.