IR 05000250/1988019
| ML17345A346 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/19/1988 |
| From: | Hosey C, Kuzo G, Lauer M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17345A345 | List: |
| References | |
| 50-250-88-19, 50-251-88-19, NUDOCS 8809010039 | |
| Download: ML17345A346 (26) | |
Text
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~ceo IP + se*~ N UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
'I01 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 AUG'
1%N RePort Nos e I 50-250/88-19 and 50-251/88-19 Licensee:
Florida Power and Light Company 9250 West Fl agler Street Miami, FL 33102 Docket Nos.:
50-250 and 50-251 Facility Name:
Turkey Point Units 3 and
License Nos.:
. Lauer i~le Approved by:
.
N. Hosey, Sect~on C ie Safety and Safeguards Division of Radiatio Inspection Conducted:
July 18-22,'988 Inspectors:
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Datqj Signe Date Signed SUMMARY Scope:
This routine, unannounced inspection of the facility's radiation protection program involved review of organization and management controls, employee training and qualifications, external and internal exposure monitoring and controls, radioactive material and contamination control, ALARA programs, solid wastes, transportation,-
and inspector followup of NRC Information Notices (INs), previously identified followup items, and enforcement issues.
Results:
For the radiation protection program areas reviewed.
training, radioactive waste management and transportation activities were adequate.
Improvements were noted in management commitment to increases in the radiation protection staff, upgrades'to radiological protection facilities and equipment, staff efforts directed to the reduction of contaminated areas within the radiation control area (RCA), and the self-identification and timely resolution of radiation protection issues.
Continued management and staff attention is needed to improve both the ALARA program and the licensee's procedure upgrade program (PUP),
and to evaluate and ensure continued improvements in the quality of the overall facility radiation protection program.
No violations or deviations were identified.
8809010039 880819 PDR ADOCK 05000250
PNU
REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J. Anderson, Supervisor, guality Assurance Regulatory Compliance
- J. Arias, Jr., Supervisor, Regulatory and Compliance Section J,. Bates, Jr., Assistant Supervisor, Health Physics (HP)
R. Brown,'perations Supervisor, HP T. Colemen, ALARA Support Supervisor, HP M. Cooper, Speciality Training Coordinator
- J. Cross, Plant Manager J.
Daneh, Corporate, HP
- R. Earl, Supervisor, guality Control
- L. Pearce, Superintendent, Operations K. Rowe, Radwaste Supervisor, HP Other licensee employees contacted included engineers, technicians, operators, mechanics, and office personnel.
Nuclear Regulatory Commission D. Brewer, Senior Resident Inspector T. McElhinney, Resident Inspector
- Attended exit interview 2.
Organization and Management Controls (83722)
'a ~
Organization and Staffing The inspector reviewed the health physics organization and lines of authority to upper management as relating to radiation protection issues, radioactive material control and transportation of radioactive material.
Technical Specification (TS) 6.2.1(a)
requires the lines of authority, responsibility and communication to be established and defined from the highest management levels through intermediate levels to and including all operating organization positions.
Those relationships are required to be documented in the form of organizational charts in the Topical guality Assurance Report and=
updated in accordance with 10 CFR 50.54(a)(3).
The inspector revi ewed and di scussed the Faci 1 ity.Organi zati on section and Appendix A, Figure 1-2, of the Topical guality Assurance Report, Rev.
12, dated June 24, 1988, with licensee representatives.
The organizational chart detailing the Turkey Point facility Health Physics (HP) organization indicated that personnel in the radiation protection man (RPH) position reported directly to the HP supervisor and thus omitted all current supervisory positions between the RPM and HP supervisor.
Discussion with cognizant Florida Power and Light (FPSL) licensing representatives and plant management indicated that the licensee was aware of the lack of detail concerning the organizational structure and they committed to upgrade the sections of the Topical guality Assurance Report with regard to the overall facility staff, supervisors and management positions for the site organization.
Changes to the Topical guality Assurance Report organizational details will be reviewed during a subsequent inspection and will be tracked by the NRC as inspector followup item (IFI) 50-250/88-19-01.
Staffing upgrades and proposed changes within the onsite HP organization were reviewed and discussed with cognizant licensee supervisors.
Since the last inspection (Inspection Report No. 50-250, 251/87-48),
management has initiated a reduction in the number of contract personnel with a concurrent increase in FPSL staff utilized for routine HP involvement in all job areas.
To provide continuous supervisory coverage, the shift super visor staff is to be increased from three to seven individuals.
An additional shift supervisor will be assigned to the ALARA program.
Three HP Engineering positions have been added to provide technical support in areas such as HP instrument support and personnel dosimetry.
The number of technicians will increase from seven to seventeen individuals to maintain 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage to perform clerical duties associated with HP records, operation of the whole body counting system, and computer data entry duties.
The RPH staff will be increased from 33 to approximately
ANSI qualified and 8 junior RPNs on site.
Additionally, the licensee has approved a refueling outage coordinator position to provide dedicated HP representation to the outage department.
Licensee representatives stated that vacancies for the Radwaste Supervisor and HP engineering positions have been filled and the additional approved staff positions were expected to be filled by January 1989.
Th nspector noted that the additional, dedicated FP&L staff was expected to improve the routine HP coverage and to provide increa sed review, evaluation and resolution of routine and technical HP issues.
Furthermore, the increased staff was expected to improve the licensee's HP program activities when additional contract personnel will be employed during outage activities.
No other supervisory or staff changes which could affect the licensee's ability to maintain radiation protection activities were note No violations or deviations were identified.
Management Controls The inspector discussed with cognizant licensee representatives the
. use-of Radiological Investigation Reports (RIRs)
and quality
'ssurarice
- audi,t findings in identifying concerns, notifying
'ppropriate-"ma'n'agement, and completing corrective actions regarding radiation protection activities in a timely manner.
TS 6.8. 1'requires written procedures to be established, implemented and maintained to meet or exceed the requirements and recommendations of Appendix A of USNRC Regulatory Guide 1.33.
TS 6.11 requires procedures for personnel radiation protection to be prepared consistent with the requirements of 10 CFR Part 20 and to be approved, maintained and adhered to for all operations involving personnel radiation exposure.
The use of RIRs by HP personnel to document and review HP issues were reviewed and discussed with cognizant licensee representatives.
In response to a
previous NRC Notice of Violation (NOV), (50-250, 251/87-48-01)
the licensee's RIR procedure had been revised.
The current procedure, O-HPA-008, Radiological Investigation Reports, dated Nay 26, 1988, provides details for identification, tracking, evaluation and resolution of radiation protection issues by the appropriate HP supervisors or plant management personnel, and the subsequent review of the RIR data for noticeable trends.
The inspector also reviewed the revised RIR data sheets and the RIR Root Cause and Corrective Action Evaluation forms issued for use in accordance with the current procedure.
Since June 1, 1988, approximately 110 RIRs were issued for the facility.
The majority, more than 90%, of RIRs issued involved improper use of personal dosimetry and personal contamination events in the radiation control area (RCA).
Discussions with "cognizant licensee individuals regarding the RIR procedure, verified that results were adequately reviewed for trends and the issues subsequently resolved in a timely manner.
For example,- licensee supervisors noted that increased personnel contaminations were associated with personnel performing maintenance activities in overhead areas of the auxiliary building.
Based on these data, the supervisor planned to implement periodic wipes of overhead pipes and other structures in the auxiliary building in an attempt to reduce the number of personnel contamination events associated with work in the area.
TS 6.5.2.8(a)
requires audits of the conformance of facility operation to all provisions contained within the TSs and applicable license conditions to be performed under the cognizance of the Company Nuclear Review Board (CNRB) at least once per yea Licensee Procedure O-ADM-913, Corrective Actions for Conditions Adverse to Quality, dated June 14, 1988, defines the corrective action program for safety or quality related items and the requirements, responsibilities and interfaces necessary to identify, track and correct identified issues.
Plant Quality Instruction (QI) 18, QAD 3, Scheduling of Quality Assurance Department Audits, dated June 17, 1988, and QI 16, QAD 4 Corrective Action Followup for Quality Assurance Audits, dated June 27, 1985, detail audit performance requirements and the followup and closeout of internal audit findings.
The inspector reviewed and discussed the following Quality Assurance Audits concerning selected HP areas.
QAO-PTN-87-841, Technical Specification 6.17, Process Control Program, dated July 9, 1987.
QAO-PTN-87-855, Technical Specification 6.11, dated October 22, 1987.
QAO-PTN-871, Technical Specification 6.12, High Radiation Areas, dated November 18, 1987.
QAO-PTN-87-872, Audit of Sealed Sources, dated December 2, 1987.
QAO-PTN-88-892, Technical Specifications 6.11 and 6.12, Health Physics Activities Audit, dated March 28, 1988.
QAO-PTN-88-895, Fuel Reconstitution, dated April 13, 1988.
For the formal audits 'reviewed, two findings involving procedural noncompliances, failure to follow a procedure for conducting a
quarterly sample and subsequent operability test of the site's breathing air system and fai lure to follow a procedure for conducting and subsequently assigning skin doses for a personnel contamination event, were reviewed and discussed in detail with licensee representatives.
Review of the procedural noncompliances indicated that no
CFR Part 20 limits were exceeded and corrective actions appeared adequate.
Similar violations were not identified during this inspection.
The inspector noted that TS 6.11 requires adherence to personnel radiation protection procedures, however, pursuant to
CFR 2, Appendix C.
V. A.,
a NOV was not issued due to the violations being (1) licensee identified, (2) severity level IV or V, (3)
not reportable, (4) corrected, and (5) not expected to be preventable by corrective action for a previous violation.
In addition to the formal audits, the licensee conducts an audit program involving real time monitoring of selected performance activities.
Quality Instruction procedures QI 18, QAD 4, Performance Monitoring Program, dated March ll, 1988, and QI 16, QAD 5, Corrective Action Followup for Corrective Action Request, dated
Narch 11, 1988, detail the impl ementati on of the performance monitoring program and actions regarding followup and closeout of identified issues.
The inspector reviewed and discussed with cognizant licensee representatives the following corrective action requests (CARs) regarding HP issues identified through performance monitoring activities conducted during April and Nay 1988.
CAR-88-024, High Radiation Area Naintained Locked wi,th Personnel in the Area, dated'April 26, 1988.
CAR-88-026, Improper Frisking Prior to Entering RCA Smoking, Eating, Drinking Area, dated April 29, 1988.
CAR-88-021, Failure to,Update PTN FSAR, dated April 12, 1988.
CAR-88-022, Failure to Comply with FSAR Final Radiation Survey Requirements, dated April 29, 1988.
CAR-88-027, High Radiation Area Not Barricaded, dated Nay 9, 1988.
CAR-88-028, Locking Nethod Would Have Prevented Personnel Exit from High Radiation Area, dated Nay 11, 1988.
The inspector reviewed and discussed with the HP supervisor, two CARs associated with personnel access controls for potential high radiation areas.
The first issue involved problems with access to a HP department individual overcome by heat exhaustion while working in a potential high radiation area.
The HP person was providing coverage for an operator conducting a resin transfer.
Following completion of the transfer, the operator exited the area while the HP individual remained behind to complete activities.
The HP person, who controlled the key to the area, was overcome by heat exhaustion, and thus preventing the operator from immediately returning into the area to provide assistance.
The operator was required to by-pass the barrier to gain reentry.
Licensee corrective actions included retraining individuals regarding heat exhaustion concerns and the implementation and adherence to the buddy system for all entries into high radiation areas.
The second high radiation area CAR issue involved the use of a padlock and chain to secure a high radiation area entry point subsequent to failure of the normal lock.
At the time of identification of the issue, personnel access to the area was not required.
Licensee corrective actions included the use of
'rocedures to be implemented detailing HP control of any padlocked and chained high radiation area when the normal lock mechanism is inoperable and the need to expedite repair of locks for doors providing access to high radiation areas.
For the CARs reviewed no procedural or
CFR Part 20 requirements appeared to be violate The inspector noted that the licensee programs detailed above appeared to place responsibility for identification of HP issues and concerns with the radiation protection and/or quality assurance/quality control personnel and that no formal program which documented-the identification, tracking, and resolution of other employee's HP concerns was in place for the facility.
Licensee representatives stated that the identification of any radiation protection issued by employees to their immediate supervisor was the preferred method for the resolution of concerns.
However, plant management stated that plans for a
system to document and track identified concerns and their subsequent resolution was being developed.
At the time of the inspection, the licensee had not
'stablished details of the program nor indicated when implementation was expected.
No violations or deviations were identified.
3.
Training and Qualifications (83723)
CFR 19'2 requires the licensee to instruct all individuals working in or frequenting any portion of the restricted area in the health protection aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposures, and in the purpose and functions of protective devices employed, applicable provisions of Commission regulations, individual responsibilities and the availability of radiation exposure data.
CFR 20.103(c)(2)
requires that the licensee maintain and implement a
respiratory protection program that includes determination by a physician prior to initial use of respirators that the individual user is physically able to use respiratory equipment.
The inspector reviewed selected radiation work permit (RWP) requirements (Paragraph 5.d),
interviewed personnel involved in selected tasks, and where possible, observed work being conducted under selected RWPs.
General employee training (GET)
and/or requalification, respirator training, respirator fit tests, and annual medical qualification records were verified as current for the selected personnel as appropriate.
Both FP&L and contract personnel conducting tasks for the selected RWPs appeared knowledgeable of job requirements, their current dose limits and radiation protection principles and responsibilities.
The inspector discussed training of maintenance personnel for tasks conducted during outages at the facility.
Licensee procedure O-ADM-714, Conduct of Maintenance Training, dated January 26, 1988, details the standards for the conduct of qualification training for all maintenance personnel performing maintenance tasks at the facility.
Training included both classroom and practical experience training.
The inspector toured the training center where components,
"mock-ups," of plant systems were used in training.
Components available for training included reactor coolant pump equipment, charging pumps, and all valves utilized in plant
systems.
Maintenance personnel are required to undergo an initial training period and then an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of continuing training per quarter.
Personnel are required to meet selected job performance measurement criteria prior to certification to conduct maintenance activities on a particular system.
Prior to performing maintenance work on a
system a supervisor must ensure that an employee is trained on the system.
From discussions with licensee training representatives, the inspector determined that although input into the training requirements are received from the HP department, practical HP environmental factors, for example, use of protective clothing and radioactive contamination control procedures, are not considered during training for certification of maintenance personnel.
No violations or deviations were identified.
4.
Internal Exposure Control (83725)
CFR 20.201(b)
requires each licensee to make or cause to be made such surveys as (1) are necessary for the licensee to comply with regulations in this part and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
a
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Whole Body Counting Analyses
CFR 20.103(a)(3)
requires for purposes of compliance with requirements of this section, that the licensee use measurements of concentrations of radioactive materials in air for determining and evaluating airbone radioactivity in restricted areas and in addition, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
The licensee conducts employee entrance, termination,. annual and special
"in vivo" radiological surveys, using either whole body counter (WBC) or urinalysis methodologies, for personnel who could be exposed to airbone radioactive materials.
Guidance for monitoring of an individual's exposure using either WBC.or urinalysis methodology, is detailed in Plant Procedure O-HPA-031, Personnel Monitoring of Internal Dose, dated March 27, 1988.
Since the last NRC HP inspection conducted during December 1987, only one incident, the potential contamination of two laundry workers, required a special WBC analysis for potential exposure to gamma-emmiting nuclides.
Review of the RIR for the incident indicated that positive contamination results were attributed to external contamination of two workers by Xenon-135.
Licensee actions regarding this issue appeared appropriat guality control requirements for the WBC equipment are detailed in Plant Procedure HPT-033, Operation of the Health Physics Whole Body Counting Equipment, dated December 18, 1985.
During a previous inspection (50-250,251/87-36-04)
allegations concerning inaccuracies of WBC results identified problems with reliability of the system during routine in vivo measurements.
The unreliable performance of the equipment was believed to be function of poor temperature control for the trailer housing the electronic equipment and the age of the WBC equipment.
The licensee has moved the WBC equipment into a
permanent facility.
From di scussions with cognizant licensee representatives and review of applicable quality control data, improvements in the system reliability, including reduced heat induced trips of the electronic equipment and a reduction in nuclide peak alignment and energy calibration (E-Cal)
adjustments, were noted.
The licensee currently was evaluating the potential upgrading of their WBC equipment.
No violations or deviations were identified.
Urinalysis Results The inspector discussed the use of urinalysis data for determining exposure to airbone radioactive contaminants.
From January 1, 1988, through July 22, 1988, approximately 14 urinalysis samples were shipped to a vendor laboratory for both beta-gamma and tritium (H-3)
urine analyses.
The inspector noted that, in general, results were below the analysis detection limits of approximately 1.0 E-7 microcuries per milliliter (uCi/ml) for gamma analyses and 1.0 E-5 uCi/ml for H-3.
The only positive results were for H-3 insamples collected from two individuals, measured concentrations of 1.2
+ 0.5 E-5 and 2. 1 + 0.5 E-5 uCi/ml.
From review of licensee records the inspector verified that the positive H-3 results indicated personal exposure below
CFR Part 20 limits.
The inspector noted that the procedure did not establish methodology for determining exposure nor provided any action limits based on conservative assumptions.
The licensee stated that the use of urine sampling and retention function methods to evaluate personnel exposures was not routinely conducted and that for actual situations where a potential exposure was suspect, the person would be analyzed using the either the sites's WBC system and if necessary FPIIL's St.
Lucie WBC facility.
The licensee agreed to review their methodology for determination of exposure based on urinalysis data.
This issue will be reviewed during a subsequent inspection and will be tracked by the NRC as 1FI 50-250/88-19-02.
No violations or deviations were identifie.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83726)
a
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Surveys
CFR 20.201(b),
20.401, and 20.403 require the 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 areas of the auxiliary building.
The inspector performed independent radiation level surveys, both exposure rate and removable contamination surveys, of selected areas and compared them to licensee survey results and posting requirements.
No violations or deviations were identified.
b.
Contamination Control The inspector reviewed and discussed licensee initiatives and progress regarding a reduction in the square footage of contaminated area within the facility RCA.
In October of 1987 the licensee formed a Quality Improvement Program (QIP) team to evaluate the extent and root cause of extensive contaminated floor space in the RCA.
During December 1987, approximately 35 to 40 percent (X) of the accessible RCA space, approximately 70,000 square feet (ft'), was classified as contaminated.
The QIP team identified the lack of an aggressive contamination control program as the root cause of the problem.
The licensee initiated an extensive upgrade of leak and contamination containment structures, decon activities, preventative maintenance program for valves in the RCA, and staff training regarding contamination controls.
As of July 15, 1988, approximately 12,600 ft'f the RCA was classified as contaminated.
The.
established goal for December 1988, ranged between 7,000 to 10,000 ft'ependent upon an evaluation of ALARA considerations for cleanup in selected high radiation areas, for example, spent fuel, heat exchanger, and CVCS tank holdup rooms.
No violations or deviations were identified.
c ~
Personnel, Laundry, and Equipment Monitors During tours of the plant, the inspector observed movement of workers and/or their tools from contaminated to clean areas.
All personnel performed adequate whole-body frisks and tools were observed to be double yellow-bagged and tagged by an HP technician prior to transfer into noncontaminated areas.
NRC Inspection Report No.
50-250,251/87-15, dated April 29, 1987, noted that the licensee planned to have state-of-the-art frisking booths at selected RCA access areas within the facility.
The licensee purchased Eberline PCM-1B Personnel Contamination Monitors,
three of which are located at the RCA control point exit.
The inspector reviewed Temporary Procedure (TP)
421, Operation and Calibration of the Eberline Model PCM-1B Personnel Contamination Monitor, dated January 26, 1988, and supporting documentation for the setup parameters chosen.
The monitors are operated in a mode which minimizes the count time based on preset alarm setpoints, current background, preset detector efficiencies, and a preset confidence level.
With the parameter values currently used and a typical control point background of 800 counts per minute (cpm), the licensee believes count times of approximately
seconds per person and a
false alarm rate of approximately
false alarm for every 1000 persons can be achieved.
During setup testing, the licensee used both point and 100 cm~ area sources with isotopes commonly found in contamination surveys of the plants.
Using a conservative counter efficiency of 8%, the Reliably Dectected Activity, that is, the alarm setpoini, was established as 5000/disintegrations per minute per 100 centimeters square (dpm/100cm').
Licensee representatives stated that use of the PCM-1Bs at containment exits and contaminated areas in the Auxiliary Building is currently being evaluated.
The inspector verified that
.the National Nuclear Corporation Portal Monitor located at the control point exit alarmed at the prescribed setpoint using a
1 microCurie (uCi)
Cs-137 check source.
The licensee was monitoring 100% of the clean laundry using a Bicron Laundry Monitor (BLM).
The inspector discus'sed the operation of the BLM with licensee representatives and reviewed an internal report, Contamination Limits and Guidelines for the BLM, dated September 27, 1987.
The monitor uses identical upper and lower organic scintillator detectors with sensitive areas of 15.2 x 61 cm.
The laundry pieces are pulled manually by hand between the two detectors.
Alarm setpoints have been established based on isotope activities equivalent to 1 milliRoentgen per hour (mR/hr),
equivalent to 500,000 dpm or 225 nanoCuries.
Assumptions used by the licensee to determine. the above setpoints were realistic and conservative.
No violations or deviations were identified.
Radiation Work Permits (RWPs)
TS 6.8.1 requires written procedures to be established, implemented and maintained to meet or exceed the requirements and recommendations of Appendix "A" of USNRC Regulatory Guide 1.33.
Regulatory Guide 1.33, Appendix
"A" requires procedures for personnel monitoring and special work permits.
Licensee procedure O-HPA-001, August 12, 1986, Section 3.2.1 requires individuals to fully understand and follow all requirements of the Radiation Work Permit (RWP).
The inspector reviewed, discussed and where possible, observed work associated with the following RWPs.
RWP 88-1050 Auxiliary Building Unit 4 Charging Pump Room - Weld Repair Charging Pump Drain Valve, dated July 18, 198 RWP 88-2385 Auxiliary Building (HRA) Unit
Spent Fuel Pool HX/Demineralizer, Replace Valve 3-807 Diaphram, dated July 15, 1988.
Work conducted under RWP 88-2385 required opening a contaminated system and had the potential for release of liquids.
The inspector verified through discussions with the personnel performing the task and a review of 'records that a pre-job briefing was conducted and that all RWP requirements, for example, HP coverage, use of respiratory protective equipment, multiple dosimetry, and air sampling methodologies were utilized as required.
Initial air samples collected in the work area and boundary area, concentration values of 2.3 E-10 microcurie per. cubic centimeter (uCi/cm')
and 7.0 E-11 uCi/cm'), respectively, were below the Maximum Permissible Concentrations for air (MPCa) listed in 10 CFR Part 20, Appendix B.
Monitored doses to personnel were less that 50 mrem for the initial entry into the area.
No violations or deviations were identified.
6.
External Exposure (83724)
The licensee's external exposure control and personnel dosimetry program were reviewed by the inspector.
The review included facilities, equipment, personnel records, and procedures used to control exposures and determine doses.
a
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Records b.
Exposure records, of plant and contractor personnel for January through July 1988, were selectively reviewed.
No exposures greater than limits in
CFR 20. 101 or the station's quarterly administrative limit of 2150 mRem were noted.
The inspector verified that the licensee possessed an NRC Form 4 for all individuals exceeding 1250 mRem/quarter.
Licensee representative stated that the station's collective dose through June 1988, using thermoluminescent dosimeters (TLD)
and direct reading dosimeters (DRD),
was 209 man-Rem.
The highest individual whole body dose observed for the first and second quarter was 1762 mRem and 933 mRem, respectively.
No violations or deviations were identified.
Direct Reading Dosimeter (DRD)
Licensee procedure HP-32, Pocket Dosimeter Source and Drift Check, specifies methodology and acceptance criteria for DRD source and drift checks.
The inspector observed a batch of DRDs being source checked.
Methodology and acceptance criteria followed guidance delineated in Regulatory Guide 8.4, February 1973.
No violations or deviations were identifie Thermoluminscent Dosimeter (TLD) Use Inspection Report No.
50-250, 251/87-36 identified possible deficiencies in the licensee's method for TLD beta dose calibrations.
The licensee has performed general plant beta spectral analyses, reviewed their current beta algorithm and concluded that Thalium-204 (Tl-204) was the most appropriate isotope for TLD beta calibrations and that an update of the beta dose algorithm was needed.
An Apri 1 22, 1988, memo to the HP Supervisor documented completion of both these improvements.
No violations or deviations were identified.
Extremity Monitoring Through discussions with licensee representatives, the inspector determined that extremity monitoring for the hands is accomplished using wrist TLDs.
For selected tasks in radiation fields with steep gradients the use of wrist dosimetry can be nonconservative in measuring extremity doses relative to finger-ring dosimetry.
Licensee representatives stated that fi,nger-ring TLDs will soon replace wrist TLDs for extremity monitoring pending vendor delivery of equipment and system testing, tentatively planned for implementation by early 1989.
The inspector rev'iewed individual extremity dose totals for 1988, and observed a maximum extremity dose of 1070 mRem.
Since this represents only 6X of the 18.75 Rem limit specified in 10 CFR 20. 101, overexposures due to the underestimation of dose by wrist dosimetry were considered unlikely.
The inspector informed licensee personnel that the initation of extremity monitoring using finger-ring TLDs, including procedure revision and evaluation of selected wrist versus finger-ring TLD dose data would be reviewed during a subsequent inspection and would be tracked by the NRC as IFI 50-250/88-19-03.
No violations or deviations were identified.
Exposure to the Skin Licensee representatives stated that from January 1988 through June 1988, 55 skin/clothing contaminati ons were documented.
The inspector selectively reviewed personnel contamination reports for 1988, including a
small number of hot particle events which were reviewed in detail.
Identification, investigation, and assessment of these events was thorough and adequate with no dose values exceeding
CFR 20.101 limits or the licensees administrative limit of 5.5 Rem/quarter.
As identified in Inspection Report No.
50-250, 251/87-48, the licensee uses a skin dose calculation methodology which is more conservative than VARSKIN (NUREG/CR-4418, 1987).
Licensee representatives stated that a revision to the procedure delineating skin dose calculation methodology, HP-70, Decontamination of Personnel, Hay 28, 1987, was in final concurrence stages and
includes VARSKIN methodology.
Skin dose assessment for air submersion was described in HPA-030, Personnel Monitoring of External Dose, April 30, 1987.
Beta dose factors used for this assessment-were reviewed by the inspector and found to be in accordance with Regulatory Guide 1.109, October 1977.
No violations or deviations were identified.
7.
Maintaining Exposures As Low Reasonably Achievable (83729)
The inspector reviewed the licensee's program for maintaining occupational exposures as low as reasonably achievable (ALARA), including; changes in ALARA policy and procedures, ALARA staff, worker awareness and involvement in the ARARA program, and the establishment and realization of goals and objectives.
A new individual was recently assigned the responsibilities of ALARA Supervisor.
The individual vacating the position will remain in the health physics (HP)
organization as an HP supervisor assistant.
Experience level and background of the new ALARA Supervisor was reviewed and found to be strong in operational HP but, lacked specific ALARA training.
Licensee representatives stated that training for the ALARA Supervisor is planned but specifics had not been finalized.
The inspector was also informed that in the near future three additional individuals will be assigned ALARA duties and trained accordingly.
A limited reviewed of the licensee's General Employee Training indicated a
lack of ALARA information being conveyed during this training.
The licensee was aware of this inadequacy and was assessing corrective options such as internally developed training or the purchase of an ALARA training package.
The inspector noted that plant workers were knowledgeable in basic ALARA information such as their current collective dose and dose margins, and the definition of ALARA.
However, knowledge in more specific ALARA concepts such as the Time-Distance-Shielding rule was not evident.
The inspector inquired as to the dates and results of recent audits of the ALARA program.
Licensee representative stated that audits did not specifically review the ALARA program but that ALARA issues were reviewed during a recent HP program audit, conducted by corporate personnel.
The inspector discussed the audit area and findings with the corporate individual who conducted the audit.
The audit did not appear to include detailed review of all ALARA program areas.
The inspector noted that the depth of ALARA audits needed improvement.
For the upcoming outage, the licensee plans to utilize
"ALARA Zone Coordinators."
These individuals will be liaisons between HP and the working groups.
This task would include attending planning meetings, enhancing post-job critiques, and the identification of ALARA improvements in daily outage activities.
Licensee representatives have not decided whether these individuals are to have health physics or a
maintenance/construction background.
Licensee representatives stated that
for outage work, an individual from the HP staff or an individual with HP background will be included in pre-job walkdowns for all maintenahce/construction jobs in high radiation areas.
The inspector discussed goals, and the current and past collective plant doses with licensee representatives.
The 1987 collective dose total was 1290 person-Rem.
Licensee representatives stated that this large exposure value resulted from unplanned outage work.
The 1987., Unit 3 planned outage dose.total was 714 person-Rem.
However, a
second reactor head removal was required before start-up, with an expenditure of an additional 160 person-Rem.
Also in 1987, a
Cono Seal repair on Unit 4 contributed 412 person-Rem.
The next planned Unit 4 outage was initially estimated at 660 person-Rem, however, the work scope has increased significantly to included a large amount of valve replacement in containment which will greatly increase this estimate.
A revised man-Rem estimated was not available at the time of the inspection.
No violations or deviations were identified.
Solid Waste (87422)
CFR 20.311 requires a licensee who transfers radioactive waste to a
land disposal facility to prepare all waste so that the waste is classified in accordance with
CFR 61.55 and meets the waste characteristic requirements of
CFR 61.56.
The regulation further established specific requirements for conducting a quality control program.
The inspector reviewed the licensee's solid radwaste management program, including:
changes to equipment, procedures, and staff; processing, control, storage of solid wastes; adequacy of required records and reports; and implementation of procedures to properly classify and characterize waste.
The Radwaste Supervisor was recently hired.
The background and experience level of the individual were reviewed and determined to be adequate.
Training for the Radwaste Supervisor included a
week course in December 1987, which presented waste classification, package requirements, marking, labeling, and shipping paper completion.
Licensee representatives stated that in the near future 3 to 5 technicians will be assigned to the radwaste group and trained accordingly.
Specifically, HP technicians will be assigned extended rotation duty within the radwaste area.
The licensee sorts for salvagables and surveys
"clean" trash taken from the RCA in a trailer equipped with a
HEPA ventilation system, table detectors, and bag counter.
Contaminated trash is sorted for removal of liquids and noncompactables, and compacted in a building separated from the Auxiliary building.
The compactor building was equipped with a HEPA ventilation system and a
contihuous air monitor.
The licensee was
"pre-compacting" contaminated trash and then sending it to an offsite
vendor for supercompaction.
Licensee representatives stated that currently, approximately 4, 141 cubic feet (ft') of dry active waste, 2,145 ft~ of low level spent resin, and 1,280 ft~ of contaminated asbestos are being stored onsite.
The volume shipped January through July 1988, was 5,653 ft'.
Volume shipped in 1986 and 1987, was 12,011 ft'nd 9580 ft~, respectively.
The decrease in 1987, was partially due to the decreased activity in this area as a result of the extended vacancy of the Radwaste Supervisor position.
The inspector reviewed the results of the recent waste stream analysis documented in an interoffice correspondence, Turkey Point Units 3 and
Scaling Factor Validation and Recommendations, dated June 30, 1988.
The document was prepared by corporate HP staff utilizing sample analysis results provided by a vendor laboratory.
The document briefly described the current scaling factors and recommendations for changes.
The inspector reviewed guality Assurance Audit gAO-PTN-841, Radioactive Waste Program and Process Control Program, dated July 9, 1987, which demonstrated compliance with Technical Specification 6.17.
The inspector established that appropriate areas were reviewed and that an adequate level of management reviewed existed.
The inspector 'selectively reviewed waste shipments for 1988, and verified that the shipments were properly classified and characterized and that manifests were properly completed.
No violations or deviations were identified.
Transportation (87621)
CFR 71.5(a)
requires each licensee who transports licensed material outside the confines of its plant or other place of use to comply with the applicable requirements of the regulations of the Department of Transportaion (DOT)
presented in
CFR Parts 170 through 189.
CFR 71. 12 provides a general licensee to transport, or to deliver to a carrier for transport, licensed material in packages for which a license or certificate of compl.iance has been issued, provided the licensee has an approved quality assurance program in accordanace with
CFR 71, Subpart H.
The.inspector reviewed the following shipments and verified that package quality control checklists were completed, where applicable, and that shipping manifests were completed in accordance with DOT and NRC regulations:
Shipment No.88-002, January 6, 1988.
Shipment No.88-106, June 1,
1988 Shipment No.88-026, July 5, 198 Shipment No.88-028, July 18, 1988.
The inspector verified that the licensee had a copy of the Agreement State License issued to the vendor to which shipments are made for supercompaction.
The inspector reviewed selected radioactive material receipt surveys for 1988.
No violations or deviations were identified.
10.
Followup Items (92701)
The inspector discussed and reviewed with cognizant licensee representatives their actions regarding the following inspector followup items (IFIs) and NRC Information Notices (INs).
a ~
Inspector Followup Items (Closed)
50-250, 251/87-36-01 Accur acy and calibration of radiation monitoring instrumentation:
ion chambers, TLDs, whole body counter, and PCM-1B Monitor.
This item involved review of the licensee's methodology for calibration and operation of the selected instrumentation.
Details regarding the licensee's actions are discussed in the following sections of this report:
whole body counter (Paragraph 4),
PCM-lB Monitor (Paragraph 6.c),
and TLD (Paragraph 6.c).
The inspector reviewed the licensee's actions concerning ion chamber calibrations.
Inspection Report No.
50-250, 251/87-36 identified concerns regarding the licensees method for beta dose rate calibrations on their RO-2 and RO-2A ion chambers.
Specifically, the licensee was using a
depleted uranium slab source for calibrations with an average beta energy of approximately 0.440 megaelectron volts (MeY) while studies have shown average beta energies throughout the plant are approximately 0.242 MeV.
The inspector reviewed a licensee report, Study of the Response of the Eberline RO-2 Survey Instrument to Large Area Beta Plaques, December 1987.
In the Study the licensee used the depleted uranium plaque, a-Pm-147 plaque, a Tl-204 plaque, and a Sr-90 plaque.
The study calculated an average beta corrective factor (bcf) for the uranuim plaque of 4 rad/R and an average bcf for the other three beta plaques of 4.01 rad/R.
Therefore, the licensee concluded that the present method of calibration (using the depleted uranium)
was appropriate and that there was no need for a change.
No concerns were identified.
ii.
(Closed)
50-250,251/87-36-04 Electronic drift of the whole body counting equipment.
Licensee actions regarding this issue are detailed in Paragraph 4 of this report and are considered adequat b.
NRC Information Notices (INs)
Guidance for the recei'pt, review and followup of INs is detailed in Administrative Procedure AP 0103.15, Operating Experience Feedback (OEF) Program, dated October 22, 1987.
The inspector determined that the following NRC Information Notice (INs) had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that actions, as appropriate, were taken or scheduled.
Lost or Stolen Gauges IN 88-80:
Chemical Reaction with Radioactive Waste Solidification Agents IN 88-21:
Inadvertent Criticality Events at Oskarshamn and at U.S. Nuclear-Power Plants IN 88-22:
Disposal of Sludge from Onsite Sewage Treatment Facilities at Nuclear Power Stations IN 88-32:
Prompt Reporting to NRC of Significant Incidents Involving Radioactive Materials IN 88-34:
Nuclear Material Control and Accountability of Non-Fuel Special Nuclear Material't Power Reactors ll.
Licensee Action on Previous Enforcement Matters (92702)
. (Closed)
Violation (50-250,251/87-48-01)
Failure to follow and to have adequate procedures for radiation protection activities.
The inspector reviewed and verified implementation of corrective actions stated in FP&L's response dated February 26, 1988 (Paragraph 2.b).
Procedural changes for the RIR system and, control of filters having potentially high dose rates were reviewed and discussed in detail with licensee representatives.
During discussion of procedureal changes for control of high dose rate filters the inspector noted that all procedures or tasks involving high doses should be reviewed for applicability of these corrective actions in regard to the licensee's procedure upgrade program (PUP).
Licensee management agreed to review the applicability of the corrective action for other procedures involving high dose rates as part of the procedure upgrade program.
12.
Exit Interview The inspection scope and results were summarized on July 22, 1988, with those persons indicated in Paragraph 1 above.
The inspector noted that one previous NOV (Paragraph ll) and two IFIs (Paragraph 10)
were considered closed.
Improvements in contamination control were noted for the facility.
The need for a more thorough review and evaluation of procedure changes as part of the procedure upgrading program and the need to increase efforts in the ALARA programwere discussed.
Three additional
IFIs were identified.
The licensee acknowledged the inspection findings and took no exceptions.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
Item Number Descri tion and Reference 50-251/88-19-01 50-250/88-19-02 50-250/88-19-03 Inspector Followup Item - review detail of licensee Topical guality Assurance Report for Improved Organization Detail (Paragraph 2).
Inspector Followup Item - review use of urinalysis data to evaluate personnel exposure to radioactive airborne contamination (Paragraph 4).
Inspector Followup Item - review and evaluate licensee use of finger-mounted TLDs for extremity dose monitoring (Paragraph 6).