IR 05000250/1991008
| ML20138F679 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/18/1991 |
| From: | Gloersen W, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20138F660 | List: |
| References | |
| 50-250-91-08, 50-250-91-8, 50-251-91-08, 50-251-91-8, NUDOCS 9610180030 | |
| Download: ML20138F679 (29) | |
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UNITED STATES
[$snego NUCLE 2 HEGULATORY COMMISSION y* , REGION il
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j 101 MARIETTA STHEET. AT LANT A, GEORGI A 30323 t
g,.....,/ APR 1 g 1991 Report No.: 50-250/91-08 and 50-251/91-08 Licensee: Florida Power and Light Company 9250 West Flagler Street Miami, FL. 33102 Docket Nos.: 50-250 and 50-251 License Nos.: DPR-31 and DPR-41 *
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. Facility Name: Turkey Foint Units 3 and 4 Inspection Condu t ebruary 25 - March 1, 1991
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Inspector :
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DfteSigned
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$. . GToe~rsen'M. .. Qhte Signed Accompanied by: E B a Approved by: ~~~
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J. A Totter,'Jhief yatif Signed Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection of the licensee's radiation protection (RP) program involved evaluation of the Units 3 and 4 outage health physics (HP) activities including program organization and staffing, management and administrative controls, employee training and qualifications, personnel exposure monitoring and assessments, radioa:tive material and centamination control, ALARA program implementacion, review of solid waste management and transportation activities, followup of NFC Information Notices (ins),
previously identified followup issues, and licensee actions regarding previous enforcement action Results:
HP staffing was sufficient to provide adequate HP job coverage. The audit program continued to be considered a program strength as indicated by licensee identification of significant technical noncompliance issues involving failure to follow procedures, failure to identify / quantify properly saste manifest radionuclides, and failure to control radioactive sources outside of the
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9610100030 R 910419 G ADOCK 05000250 > A G (G I avv s-R h
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! licensee restricted areas. Excluding respiratory protection training, employee l training / retraining and medical qualifications were condected in accordance i with procedures and/or 10 CFR Part 20 requirements. The licensee's ALARA
- initiatives for Unit 3 and Unit 4 and Resistence Thermal Detector (RTD) removal j including planning, training, implementation. and ongoing evaluations, were
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considered a program strength. All internal and external exposures were within 10 CFR Part 20 limits. Identified weaknesses included the housekeeping
, and postings / labels associated with radioactive waste processing and storage
- areas, and the need for Radiation Work Permit (RWP) guidance to match Technical Specification (TS) surveillance requirements for high radiation areas. .Also,
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concerns involving placement of the Containment High Range Radiation Monitors !
(CHRRMs) as required by NUREG-0737,Section II.F.1, Attachment 3 criteria were 1 identified and detailed to licensee representative I i
The following cited and non-cited violations (NCVs) were identified: I NRC-identified NCV of TS 6.11 for failure to follow training procedure 9o prf
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regarding frequency of respiratory protection training. Licensee-
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. corrective actions completed prior to the end of the onsite inspectio Licensee-identified NCV of TS 6.11 for failure to follow procedure M-oT 81
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requiring adherence to area postings. Licensee corrective actions (*g5 completed prior to end of the onsite inspectio Licensee-identified NCV for under-reporting Nickel-63 quantities in seven gg-03 shipments of dry active waste (DAW). Violation of 10 CFR 20.311(b) 9 W requirements with licensee corrective actions completed prior to the end O of the onsite inspectio NRC-identified violation of TS 6.11 for failure to follow procedures for M labelling resin liners maintained in waste storage area located east of Ib the old waste compactor she NRC-identified NCV of TS 6.11 for failure of RWP procedure guidance to f6 meet TS 6.12 surveillance frequency requirements regarding high radiation 9th area entry. Licensee corrective actions initiated prior to the end of the @
onsite inspectio Inspector Followup Item (IFI) regarding review of licensee's approved 4 evaluation concerning placement of Units 3 and 4 CHRRMs to implemant 9 by3 NUREG-0737,Section II.F.1, Attachment 3 criteri h
- Licensee-identified NCVs for failure to have adequate programmatic controls ,j of radioactive sources stored in unrestricted area Included were violations of 10 CFR Parts 20.105,20.203,20.205,and20.207. Identified'Og
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in Licensee Event Report (LER) No. 90-23. Licensee corrective actions 8 completed prior to the end of the onsite inspectio O
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l REPORT DETAILS l Persons Contacted ,
l Licensee Employees l
- M. Adside, Compliance Engineer j
- J. Anderson,. Regulatory Compliance Suoervisor, Quality Assurance (QA).
- J. Danek, Health Physics, Corporate Office
- R. Earl, Supervisor, Quality Control (QC)
- S. Hale, Project Manager, Engineering
- D. Hall, Supervisor, Health Physics
- V. Kaminskas, Supervisor, Technical Services N. Namish, HP Engineer L. Pearce, Superintendent Operations ,
- J. Porter, Supervisor, Engineering (
D. Powell, Supervisor, Regulatory Compliance '
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- R. Rose, Supervisor, Design Control K. Rowe, Supervisor, Radwaste *
- G. Salamon, Supervisor, Licensing ~
- G. Smith, Manager, Technical Services
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Other licensee employees contacted included engineers, technicians, )
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operators, and office personne Nuclear Regulatory Connission
i *J. Potter, Chief, Facilities Radiation Protection Section Region II l
- G. Schnebli, Resident Inspector l
- L.1rocine, Resident Inspector i i
- Mtended March 1,1991 Exit Meeting l Orgenization and Staffing (13750)
The inspector reviewed the routine RP organization and licensee and contractor staff levels utilized for the current dual unit outage activitie Organization Cognizant licensee r ycesentatives outlined changes implemented since l the previous NRC inspection of the HP organization conducted from
- April 2 through May 4,1990, and documented in Inspection Report (IR) 50-250,-251/90-08. The only organizational change ?r.volved combining Decon and Radioactive Waste Shift Supervisors' duties within a single positio The change was made to improve
coordination among decontamination and radioactiv.e waste r processing / storage activitie In addition, selected
! responsibilities regarding radioactive waste processing were
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transferred to the operations grou During tours of facility operations, no concerns regarding the current organization were noted by the inspecto No violations or deviations were identifie , HP Staffing Current Turkey Point Nuclear (TPN) Florida Power and Light (FP&L)
Company HP staffing included 60 Radiation Protection (RP) positions allocatri' to the onsite RP program. Licensee epresentatives stated
%t all RP staff were qualified in accordance with ANSI 1 criteri No significant changes were expected in the technician staffin In addition, twenty-nine supervisory positions allocated to the RP group were staffed. The current radiation protection staff md supervisory personnel appeared adequate to provide coverage for roet.ine non-outage activities. No concerns regarding the FP&L TPN permacent HP staffing levels were identifie _
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H No violatioris o.r deviations were identified, Contractor HP Techniciant Licensee representatives stated that in 'how.r.Sii UM, ippreri.Titi:ij 220 contractor HP technicians were hired for the dual unit outag The original contractor staff consisted of 34 deconers, 28 control point technicians, 3 supervisors, 10 senior administrative technicians,110 senior technicians, and 40 junior technicians. As of February 10, 1991, the contractor staff was reduced to approximately 2 supervisors, 84 senior technicians, ' 34 junior technicians, 8 administrative technicians, 8 deconers, and 20 control point personne The inspectors noted and discussed with cognizant licensee representatives the significant reduction in the current versus initial number of deconers utilized for the outage. Licensee representatives stated that subsequent to cavity decon activities, the majority of contractor decon personnel were released. Subsequent decon activities were conducted utilizing contract laborers properly l trained and supervised by HP technician Licensee representatives shted that during the current outage direct supervisory review of fiem 'tivities was doubled relative to l
previous outages. The change was initiated to improve coordination l and control of HP activities and coverage for the extensive outage
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activities. In addition, to improve coordination and review of ongoing initial outage activities, two lead technicians were assigned to both the Refueling Floor and Biowall access control points. The
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lead technicians monitored and supervised entry, and coordinated
! activities within each area. At the time of the onsite inspection,
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control point coverage for these areas was reduced to a single
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technician. During tours of the Unit 3 containment, the inspectors
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reviewed and verified implementation of RPM and supervisory staff assignment From discussion with selected work groups and observation of outage activities, the inspectors noted that HP coverage appeared sufficient for the jobs in progres No violations or deviations were identifie , Training and Qualifications (83750)
10 CFR 19.12 requires the licensee to instruct all individuals working or 1 frequenting any portions of the restricted areas in the health protection aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protection devices employed, applicable provisions of Commission regulations, individual's responsibilities and the availability .
of radiation exposure dat l
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The inspectors reviewed and discussed the general and specific training )
qualifications for selected personnel. In addition, specific licensee l training regarding Traversing Incore Probe (TIP) hazards was reviewed in ,l detai _
~ General Employee Training (GET)
Licensee administrative procedure 0-ADM-306, General Employee Plant l Access Training, dated December 19, 1989, nscribes the training (
program for employees who require unescorted access to TPN plant i site. GET is divided into two categories. Category I is provided to
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employees requiring unescorted access to the protected area while Category II, Radiation Controlled Area Training (RCAT), is provided to employees requiring unescorted access to the Radiation Controlled Area (RCA). Both categories require 4 ainees to pass an exam with a i minimum of 80 percent correct. RCAT also requires trainees to pass performance tests. Employees qualified in GET during a given month remain qualified through the last day of that same month of the following year, at which time retraining is require From review of training procedures and course outlines, and discussions with training personnel, the inspectors noted that the program met the provisions of 10 CFR 19.12. Exams reviewed C
from both categories of GET were appropriate to verify an lvidual's understanding o' the material presente RCAT trainee's performance tests involved demonstrating proficiency in a full dress mock-up of entering and exiting contaminated areas. The mock-ups appeared adequate as wel The inspectors reviewed selected GET records for workers signed on RWPs associated with RTO removal and trash sorting activities. For the individuals reviewed, records indicated all GET was current.
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No violations or deviations were identifie <[P
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l 1 HP Technician Training l
- Licensee administrative procedure 0-ADM-360 Health Physics
! Department Personnel Training and Qualifications, dated August 5, i 1990, provides for the initial and continuous training programs for J HP technicians and also for their pending qualification. The l
procedure outlines the four levels of the RP training program. The
- first three training levels are provided to indoctrinate technicians
! in scientific and HP fundamentals and skills training. A trained and l
qualified RP is expected to assume the routine shift duties required
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by the HP Department. Level IV training is designed to provide
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continuing training for RP staff and Junior RP (JRP) staff on plant j and industry changes and lessons learned, identified knowledge and j performance weaknesses, and emergency duties.
f Following discussions with cognizant licensee employees, the inspectors noted that RP staff and JRP staff are provided with two j weeks per year of continuing training which includes systems training to accent the radiological concerns associated with particular reactor systems. This training included classroom instruction and discussion, and when applicable, involved the use of mock-ups. The inspectors were informed that all licensee RP individuals were given .
TIP training during the last training cycle of 199 Review of selected exams from TIP training verified that training adequately
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reviewed reactor functional, as well as radiological concerns associated with TIPS. Exams of all RP staff reviewed were passed l with a minimum of 80 percent correct. The inspectors also toured the licensee's mock-up training facility. Available mock-ups included l
- TIPS, reactor coolant pumps, and various other pump and valve mock-ups. During discussions with cognizant licensee employees, the j inspectors noted that extensive use of mock-ups was a training
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program strength.
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! Procedure number 0-ADM-360 also specifies training and qualifications j for contract HP technicians. In accordance with ANSI /ANS-3.1-1978
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criteria, the procedure requires ANSI contract technicians to have a minimum of three years of working experience in their specialty of which one year should be related technical training. The inspectors reviewed selected ANSI contract technician's resumes and verified compliance with ANSI 3.1 requirement Procedure number 0-ADM-360, requires unsupervised non-ANSI contract HP technicians to be qualified to perform detailed job function Qualification of a technician to perform selected tasks is demonstrated by satisfactory completion of the applicable Job Performance Measure (JPM). The inspector reviewed records for selected non-ANSI contractors technicians and verified satisfactory completion of JPM No violations or deviations were identifie ~ - . ._ . . -. - _ _. 3,
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4. Respiratory Protection Program (83750)
10 CFR 20.103(c) permits the licensee to maintain and to imr: ment a respiratory protective program that includes, at a minimum: air sampling l to . identify the hazards; surveys and . bioassays to evaluate the actual exposures; written procedures to select, fit and maintain respirators; ;
written procedures regarding supervision and training of personnel and l issuance of records; and determination by a physician prior to use of l respirators that the individual user is physically able to use respiratory 1 protective equipmen l Health physics administrative procedure 0-HPA-060, Respiratory Protection Plan, dated August 5,1990, provides guidelines and general information for maintaining, issuing, and using respiratory protective equipment to limit inhalation of airborne radioactive material. A successful medical )
exam and completion of respiratory protection training are recuired prior '
to respirator use and annually thereafter. A quantitative fqt test is required prior to use and biennially thereafter. The inspectors noted i that training and medical qualifications met 10 CFR 20.103(c) !
requirement The inspectors reviewed current respiratory protection program records to verify training, completion of medical physicals, and fit testing for selected individuals involved in activities requiring use of respiratory protective equipment as specified for selected RWPs utilized during the current 1990-1991 Unit 3 and Unit 4 (U3/U4) outage. .From review of records and discussions with licensee representatives, the inspectors verified that all personnel were fit tested and medically qualified as i required by approved licensee procedure However, contrary to procedure number 0-HPA-060, records reviewed indicated that employees were being ' retrained biennially instead of annually. The inspectors informed licensee representatives that the failure to follow training procedures for respiratory protection program activities was a violation of TS 6.11 (50-250.-251/91-08-01). During discussions with cognizant licensee representatives, the inspectors were 'l
- informed that the current procedural requirement for annual retraining was j
- an administrative erro Previous revisions of 0-HPA-60 required respirator retraining biennially and the licensee's intent following the August 1990 revision was to continue retraining biennially. Before the end of the onsite inspection activities licensee representatives had submitted a Request for Procedure Review to change respiratory retraining from an annual to a biennial frequency. The change request was reviewed and approved on February 28, 1991. The inspectors informed licensee representatives this NRC-identified violation was not being cited because criteria specified in 10 CFR 2 Section V.A of the enforcement policy were me .
One. NCV of TS 6.11 for failure to follow respiratory protection training procedures was identifie ._ . - _ - -- -
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5. Administrative Controls (83750) _
- Posting and Notices 10 CFR 19.11(a) and (b) require, in part, that the licensee post current copies of Part 19, Part 20, the license, license conditions, documents incorporated into the license, license amendments and oper .aon procedures, or that a licensee post a notice describing thest focuments and where they may be examine CFR 19.11(d) requires that a licensee post Form NRC-3, Notice to Employee Sufficient copies of the required forms are to be posted i to permit licensee workers to observe them on the way to or from i licensed activity location !
I During the onsite ' inspection, the inspectors verified that Form NRC-3 and notices referencing the appropriate 10 CFR Part 19 and Part 20 and licensee documents were posted in accordance with the applicable j regulation. Forms were posted at the FP&L and contractor entrances j to the protected area in view of all employees entering the protected I are No violations or deviations were identifie Form NRC-4 l 10 CFR 20.102(b) requires, under certain circumstances, the licensee to obtain a certificate on Form NRC-4, signed by the individual ;
showing each period of time after the individual attained the age of l 18 in which an occupational dose to radiation was received. This signed and completed form shall be obtained before permitting the .
individual in a restricted area to receive an occupational radiation !
dose in excess of the standards specified in 10 CFR 20.101(a). l The inspectors reviewed licensee records of workers signed on RWPs .
associated with 03/U4 RTD removal to verify completion and !
maintenance of individual's Form NRC-4, as appropriate. The inspectors noted a completed Fonn NRC-4 on file for all workers as ;
applicabl l No violations or deviations were idratifie !
I Termination Reports
10 CFR 20.408(b) states that when an individual terminates employment
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- the licensee shall furnish a report of the individual's exposures to :
radiation and radioactive materials within 30 days after the exposure of the individual has been determined by the licensee or 90 days after the date of termination of employment or work assignment, whichever is earlie . . . .. . -. . _ - - = . .- . - . - --. .
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The inspectors reviewed selected records of contractors associated with RTO removal work and verified that all had termination letters issued within 30 days of the date on which they received their termination whole body count.
( No violations or deviations were identifie . Audits and Appraisals (83750) ,
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? Audits y
TS' 6.5.2.8 requires audits of facility activities to be performed
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encompassing conformance of facility operation to all provisions
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contained in the TSs and applicable License Conditions at least once per 12 months, and the Process Control Program (PCP) and implementing procedures at least once per 24 months.
I The inspectors reviewed and discussed with licensee representatives l the following QA audits conducted since the last inspection of the RP program conducted in April 1990, and documented in IR 50-250,-251/90-08:
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QA0-PTN-90-033, Radioactive Materials Release, dated August 2, 1990 l
QA0-PTN-90-035, Performance Monitoring Activities for June 1990, dated July 24, 1990
QA0-PTN-90-038, Radw' o Handling and Shipping, dated July 31, l 1990
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QA0-PTN-90-048, Radiation Protection Program and High Radiation l Areas, dated October 30, 1990
QA0-PTN-90-069, Control of Radioactive Material (Technical Specifications 3.11 and 4.13), dated January 9, 1991 In general, the audits were found to be well planned and well documented and contained items of substance related to the radiation l protection program. The reports of audit findings to management also l were reviewed as well as the responsive commitments by management to
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effect corrective actions for the deficiencies identified.
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l From a review of th< audit reports, the following licensee-
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was reviewed and discussed in detail with licensee representative The following licensee-identified violation was identified:
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Violation of TS 6.11.1 for failure to follow HP administrative l procedure 0-HPA-002, Requirements for Entry and Work in an RCA, l ,
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dated July 14, 1989 which requires that entry into any RCA shall be in accordance with posting and RWP requirements for that particular area. On May 1,1990, a mechanical maintenance helper was found in the respiratory cleaning room, which was posted as a high radiation area, without HP coverage or a dose
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rate meter (50-250.-251/91-08-02)4 <
Licensee corrective actions included documenting the event as a radiological incident report (RIR), counseling the individual on procedural requirerrants for working in the RCA, being aware of radiological postings, and various disciplinary actions; the individual was restricted from the RCA and rescheduled for GET; and revising- resin transfer procedures 0-HPS-053.2, 0-HPS-053.3, and 0-HPS-053.4 to require, where practical, posting high radiation areas at waist level. The corrective actions to prevent recurrence were determined to be acceptable. The inspectors informed licensee representatives that this licensee-identified violation would not be cited because the criteria specified in Section V.G.1 of the NRC -
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Enforcement Policy were me ~
The inspectors noted that based on the depth of review and significance of identified issues, the present audit program was considered a program strength and had contributed to the RP program improvement One NCV concerning the failure to follow RP procedures was identifie Radiological Incident Reporting System The inspectors reviewed the the licensee's internal RP program for identifying and correcting deficiencies and weaknesses related to the control of radiation and radioactive material. The licensee has five categories of RIRs: (1) Type 1- personnel contamination events; (2)
Type 2- HP violations; (3) Type 3- poor work practices; (4) Type 4-personnel monitoring problems; and (5) Type 5- non personnel event During 1990, the licensee identified 712 RIRs. The RIRs were distributed in the following manner:
Type 4 - 403
Type 1 - 214 )
Type 2 - 61 ;
Type 5 - 29
- Type 3 - 5 l As of February 28, 1991, there were approximately 178 RIRs identified by the licensee. The inspectors reviewed selected Types 2-5 RIRs from Juuary 1990 to February 28, 1991, and did not observe any significant programmatic problems. In cases where licensee-identified ;
deficiencies were observed, the inspectors noted that the rwy-
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deficiencies were addressed properly, and as appropriate, a root l cause analysis was performed and corrective actions were take No violatior.s or deviations were identifie l Internal Exposure (83750)
10 CFR 20.103(a)(1) states that no licensee shall possess, use, or N transfer licensed material in such a manner as to permit any individual in l a restricted area to inhale a quantity of radioactive material in any ;
period of one calendar quarter greater than the quantity which would '
result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in 10 CFR Part 20, Appendix B. Table 1, Column CFR 20.103(a)(3) requires for purposes of determining compliance with the requirements of this section, the licensee to use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, to use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any ,
j combination of such measurements as may be necessary for the timely ]
l detection and assessment of individual intakes of radioactivity by exposed individual _
'l e Licensee implementation of air sampling, and annual and/or special whole
! body analyses, and internal exposure assessments for workers conducted t during the current U3/U4 outage were reviewe Air Sampling l The analytical capability of the licensee's air sampling system was !
l reviewed in detail. From discussion with licensee representatives and review of selected servey records, the inspectors noted Cobalt 57 (Co-57) and Co-60 were ti e potential primary contributors to exposure l from airborne radioactive materials. The ins i
' reviewed the lower limit of detection (LLD) pectors for thediscussed licensee'sand I routine sampling volumes and analytical detection limits. Based on !
routine air sample volume and subsequent counting times, cognizant ,
licensee representatives calculated a LLD of approximately l
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4.0 E-11 microcuries per cubic centimeter for Co-57/Co-60. The
- inspectors noted that the calculated LLD for the licensee's methods
- and analytical system was less than 0.5 percent of the Maximum Permissible Airborne Concentration (MPCa) detailed in 10 CFR Part 20, Appendix B Table 1 Column The inspectors noted that the licensee's methods appeared adequate to assess properly, workers'
< internal exposures to airborne radioactive material Licensee records of air sampling results used to evaluate airborne I radionuclide concentrations associated with Unit 4 RTD removal were i
, reviewed. The inspectors noted that the majority of air sampling l
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results indicated that airborne concentrations were less than 25 percent of the MPC The inspectors observed one air sampling result with an airborne concentration of approximately 132 percent MPC For the three individuals conducting the particular job, all in full-face respirators, the licensee assigned internal exposures less than 0.25 MPCa-hrs, in addition, for the period January 1 through February 26, 1991, the inspectors noted that licensee records indicated that less than 0.25 MPCa-hrs were assigned to RPM individuals associated with RTD removal activitie No violations or deviations were identifie Whole Body Analyses The inspector verified implementation of both routine and special whole body analyses for personnel involved in current outage activitie Cognizant licensee representatives stated that routine whole body analyses were required annually and that special analyses were conducted subsequent to specific incidents where the potential for worker internal radioactive material exposure was indicated. The inspectors reviewed and verified completion of annual whole body counts for selected RPM as recuired. Additionally, 0-HPS-026.1, Decontamination of Personnel, cated July 20, 1990 requires, in the event of a facial contamination, a whole body count after .
decontamination is complete The inspectors reviewed 1990 RIRs
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detailing individuals reported to have positive facial contamination and verified that whole body counts were conducted in accordance with procedural guidance. Further, from review of the selected whole body analysis records the inspector noted that no positive whole body analyses were identifie No violations or deviations were identifie . External Exposure (83750)
10 CFR 20.101 requires that no licensee shall possess, use or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter a total occupational dose in excess of 1.25 rems to the whole body; head and trunk; active blood forming organs; lens of the eyes; or gonads; 18.75 rems to the hands and forearms; feet and ankles; and 7.5 rems to the skin of the whole body, l
During the audit, the inspectors reviewed the radiation program guidance l
for conducting multibadge exposure monitoring for workers involved with
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removal of RTDs from U3/U4.
, Multibadge/ Extremity Exposure Monitoring
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The inspectors reviewed and discussed multibadging and resultant
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exposure records for selected individuals conducting work in
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accordance with RWPs 4214 and 7214 associated with removal of RTDs from Unit 4 and Unit 3 during the period January 8-22, 199 Procedure 0-HPA-031.2, Multibadge Exposure Monitoring, dated November 16, 1990, requires the Health Physics Shift Supervisor (HPSS) to establish multibadge requirements for applicable RWP Following discussions with the HPSS, the inspectors were informed that all workers were multibadged for both U3/U4 RTD removal Licensee representatives stated that due to a lack of experience with the task, multibadging was conducted for all personnel. From review of selected records, the inspectors verified that procedural requirements were met for multibadging RTD worker The licensee employed the same workers for both units and multibadges were processed following completion of the RTO removals from both l
unit The inspectors verified through review of records and ,
discussion tPth cognizant licensee representatives that doses I assigned to each worker were the maximum whole body and extremity TLD l
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reading. The inspectors noted that the maximum worker whole body and extremity doses were 814 millirem (mrem) and 1430 mrem, respectively, for workers involved in the RTD removal tas No violations or deviations were identified, Skin Dose ~ Evaluation Licensee HP administrative procedure 0-HPA-034.2, Determination of Cose to the Skin From Skin Contamination, dated June 20, 1989, details guidance for determining skin dose due to skin contaminatio Skin dose calculations are required when total exposure exceeds ;
l 25,000 disintegrations per minute-hours (dpm-hrs) for a hot particl !
The inspectors reviewed selected RIR data, Personnel Contamination i Reports, and Hot Particle Logs iscued from January 1,1990 through l January 31, 199 Skin dose calculations conducted for selected personnel were reviewed and discussed with cognizant licensee -l l - representatives. The inspectors noted that a skin dose assessment was not conducted for a senior manager involved in an April 12, 1990
[ contamination event identified subsequent to tours of selected i
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Auxiliary Building areas. Following review of the incident data and discussion with cognizant licensee representatives, the inspectors ncted that the amount of contamination measured on the manager's shoe, approximately 20,000 dpm, did not meet the criteria-- for '
conducting a skin dose assessmen The contamination was detected during a routine survey conducttd prior to leaving the Auxiliary
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Buildin Followup gross masslin survels conducted by licensee
- representatives did not identify any hot particles nor areas of
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excessive contamination within the auxiliary areas toured by the
- manage Licensee actions regarding this issue were considered j adequat For all RIRs reviewed involving hot particles, skin dose
- evaluations were initiated as appropriate.
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10 CFR 20.1(c) states that persons engaged in activities under licenses -
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issued by the NRC should make every reasonable effort to maintain-
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radiation exposures ALAR HP administrative procedure 0-HPA-071, details, in part, methodology for implementing ALARA work planning and controls, and reviewing jobs in progres The inspectors reviewed and discussed with cognizant licensee representatives ALARA program implementation and initiatives for the U3/U4 RTD removal activities. The following RP issues regarding the RTD removal were reviewed and discussed in detai A detailed site organization regarding the RTD removal operation was established reporting through the site construction supervisor to site managemen The RTD construction organization included a HP/ALARA group comprised of former HP personnel. The groups function was to oversee all RP field issues and to coordinate activities with the TPN site HP ALARA and Operations groups. Approximately eight RP technicians were dedicated to the projec *
Extensive pre-planning was conducted prior to initiation of the tas Planning activities included representatives from both site and corporate HP and construction organizations, and vendor organization and were conducted and coordinated through the ALARA review board meetings. ALARA reports were reviewed and discussions with cognizant personnel were conducted regarding lessons learned for RTD removal performed at other utilitie The RTD project group, including HP personnel, toured the vendor's mock-up facilities prior to initiation of the tas *
Specialized / modified tools for cutting the RTD pipe were developed to minimize exposur All pipe cuts were thoroughly planned prior to i their implementatio ,
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Extensive mock-up training was provided both at. the vendor's corporate facility and at the TPN sit *
Dose reduction techniques were utilized, or identified and implemented as appropriate. A significant reduction in collective dose involved the decision to not erect scaffolding for pipe cuttin .When possible ladders were utilized for workers to reach the RTD pipe area to be cut. Scaffolding was erected only after completion of the RTD pipe remova However, from review of the initial RTD pipe removal conducted in U4, the licensee identified the need to improve q shielding activities associated with the reactor coolant system 1 l
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t pipin The improved shielding was initiated for the U3 RTO pipe removal activitie The inspectors reviewed and discussed with licensee representatives the collective dose expenditure for both U3 and U4 RTD bypass elimination tasks. An initial estimate of 105 man-rem per unit was projected for completion of the task. As of January 28, 1991, a total of approximately 85 and 35 person-rem were expended for U4 and U3 RTO removal activities, respectively. The licensee projected a dose expenditure of 92 and
! 62 person-rem to complete the task for U4 and U3, respectively. Licensee-I representatives stated that this projected dose expenditure for the U3 RTD bypass elimination, approximately 60 percent less than original estimates, would be among the lowest reported for the industry.
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The inspectors informed licensee representatives that their ALARA activities and initiatives associated with the U3 and U4 RTD bypass removal operations were considered a program strength.
l No violations or deviations were identifie _
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L 10. Solid: Radioactive Waste Management and Transportation of Radioactive l Materials (86750) Training and Qualification of Personnel The inspectors reviewed the qualifications, training, and experience l of selected personnel responsible for the processing, storage and shipping of low level radwaste and radioactive materials. The inspector noted that radwaste technicians received periodic training l in D0T/NRC regulations, waste license burial requirements, and j operating procedures for the transfer, packaging, and transport of
- radioactive material. The most _ recent training workshop was provided i by a waste processing contractor in December 1989. The licensee had I scheduled periodic retraining for radwaste and supervisory personnel l in March 1991. In addition, radwaste personnel had received l specialized computer software program training in waste
' classification, characterization, and radioactive materials shipments in October 1989. The inspectors also noted that selected individuals had received specialized training in hazardous materials, chemicals, waste management, and compliance in 198 In general, the licensee's training program for shipping and transportation was sufficient to instruct radwaste technicians for proper performance of their dutie No violations or deviations were identified.
, Low-1,evel Wastes Disposal and Transportation 10 CFR 20.311(b) requires each shipment of radioactive waste to a 2 land disposal facility to be accompanied by a shipment manifest that l
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indicates as completely as practicable: a physical description of the waste; the volume; the radionuclide identity and quantity; the total radioactivity; and the principal chemical for CFR 71.5 requires that a licensee who transports licensed material outside 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 Department of Transportation (DOT) in l 49 CFR Parts 170 through 18 CFR 172.203(d)(1) requires the description for a shipment of radioactive material to include the name of each radionuclide in the ;
radioactive material and the activity contained in each package of !
the shipment in terms of curies, mil 11 curies, or microcurie ,
The inspectors reviewed selected records of radioactive. waste and radioactive materials shipments performed in 1990 and 1991. The l l
shipping manifests examined were consistent with the applicable 49 CFR Parts 170 - through 189, requirements. The radiation and contamination survey results were within the limits specified for the mode of transport and shipment classification and the shipping documents were completed and maintained as require . - Through interviews with licensee personnel, the inspectors determined l
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that the licensee had identified an error in the Dry Active Waste (DAW) data base which was used by the licensee's shipment manifest calculation software. The licensee discovered that Nickel-63 (Ni-63)
was not reported by their vendor analytical laboratory during the last sample collection period in 1989 and thus no scaling factor was included in the data bas A cognizant licensee representative noted that Ni-63 had been a consistently quantifiable isotope'during the past several years and thus, the previous year's scaling . factor should have been used. The omission of Ni-63 affected seven DAW shipments (90-12, .90-13, 90-20, 90-21, 90-22, 90-26. . and 90-28) made in 1990 to the licensee's waste processor. In all cases, the waste classification was not affected. The total amount of Ni-63 that was not reported was 42.45 mil 11 curie The inspectors informed licensee representatives that the failure to report the quantity of Ni-63 in seven radwaste shipments was a violation of 10 CFR 20.311(b)
requirements (50-250,-251/91-01-03). .
The inspectors reviewed and discussed corrective actions previously implemented. t.icensee's actions included: (1) issuance of a revised notice of manifest to the licensee's waste processor and the Florid Department of Health and Rehabilitative Services; (2) revision of radwaste data bases; and (3) revision of shipping documents. The inspector also noted that the licensee requires the radwaste supervisor and the HP/radwaste shift supervisor to review the scaling factor Jata base especially in cases when the new software program flags a nuclide whose scaling factor changed by more than a factor of
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te The inspector informed licensee representatives that the licensee-identified violation of 10 CFR 20.311(b) requirements for
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failure to report the quantity of Ni-63 in seven radwaste shipments in 1990 was not being cited because the criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfie One licensee-identified NCV of 10 CFR 20.311(b) requirements for failure to report the quantity of Ni-63 in seven radwaste shipments was identifie . FacilityTours(83750,86750)
During the onsite inspection, the inspectors toured selected areas of the U3/U4 Auxiliary Building, U3 Containment, U3/04 Spent Fuel Storage Fools, and radioactive waste processing and/or storage locations. The inspectors observed facility operation , and selected work activities to evaluate the implementation and effectiveness of the licensee's HP program. The following specific RP issues and concerns were noted and discussed with licensee representative l
. Instrumentation i All survey meters and portal monitors in use within the RCA were observed to be operable and calibrated in accordance with licensee procedure No violations or deviations were identified.
, Labelling and Posting 10 CFR 20.203(e) requires each area in which licensed material is used or stored and which contains any radioactive material in an amount exceeding ten times the quantity of such material specified in Appendix C of this part to be posted with a sign or signs bearing the radiation caution symbol and the words: " Caution, Radioactive ,
Material (s)." 10 CFR 20.203(f) requires, in part, each container of
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licensed material to bear a durable, clearly visible label identifying the radioactive contents. The label is to bear the m
radiation caution symbol and the words " Caution, Radioactive Material," and also provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposure HP Surveillance Procedure 0-HPS-041, Control of Radioactive Material Inside the Radiation Controlled Area, dated January 15, 1991, requires, in part, that containers with radiation levels equal'to or
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greater than 1.5 millirem per hour (mrem /hr) on contact be labelle The label shall indicate the radiation level, contamination or activity level, the type or kind of material, the name and phone i
number of the owner / user of the radioactive material, desired
- disposition of the material, date of label issue, and signature of l
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te The inspector informed licensee representatives that the licensee-identified violation of 10 CFR 20.311(b) requirements for failure to report the quantity of Ni-63 in seven radwaste shipments in 1990 was .not being cited because the criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfie One licensee-identified NCV of 10 CFR 20.311(b) requirements for failure to report the quantity of Ni-63 in seven radwaste shipments was-identifie . FacilityTours(83750,86750)
During the onsite inspection, the inspectors' toured selected areas of the ,
l U3/U4 Auxiliary Building, U3 Containment, U3/U4 Spent Fuel Storage Pools, and radioactive waste processing and/or storage locations. The inspectors I observed facility operations, and selected work activities to evaluate the l implementation and effectiveness of the licensee's RP program. The j
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following specific RP issues and concerns were noted and discussed with licensee representatives, Instrumentation All survey meters and portal monitors in use within the RCA'were observed to be operable and calibrated in accordance with licensee procedure !
i No violations or deviations were identified, Labelling and Posting 10 CFR' 20.203(e) requires each area in which licensed material is I used or stored and which contains any radioactive material in an *l
- - amount exceeding ten times the quantity of such material.specified in Appendix C of this part to be posted with a sign or signs bearing the radiation caution symbol and the words: " Caution, Radioactive Material (s)." 10 CFR 20,203(f) requires, in part, each container of licensed material to bear a durable, clearly visible label identifying the radioactive contents. The label -is to bear the radiation caution symbol and the words " Caution, Radioactive
. Material," and also provide sufficient information to permit individuals handling or using the containers, or ' working in the vicinity-thereof, to take precautions to avoid or minimize exposure HP Surveillance Procedure 0-HPS-041, Control of Radioactive Material
Inside the Radiation Controlled Area, dated January 15, 1991,
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requires, in part, that containers with radiation levels equal to or j greater than 1.5 millirem per hour (mrem /hr) on contact be labelle The label shall indicate the radiation level, contamination or activity level, the type or kind of material, the name and phone
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number of the owner / user of the radioactive material, desired i disposition of the material, date of label issue, and signature of
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the qualified RPM issuing the label. The inspectors noted that the current procedure met met posting and labelling requirements specified in 10 CFR 20.20 During tours of licensee radioactive waste storage areas on February 25-26, 1991, the inspectors noted three resin liners maintained in a roped-off area east of the Old Compactor Waste Buildin During subsequent inspection of the area, the inspectors did not observe any labels on the liners indicating the radiation levels. Followup radiation surveys of the liners conducted on February 26, 1991, measured contact radiation exposure levels y exceeding 1.5 mrem /hr for the three containers. The inspectors informed licensee representatives that the failure to follow RP # '
procedures for labelling containers was a violation of TS 6.11 (50-250,-251/91-08-04). Licensee representatives stated that the area was posted " Caution Radioactive Materials / Caution Radiation l
, Area," and that a label was affixed to the top of the liners to caution any individual working directly on top of the containers.
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Radiation exposure information regarding the subject storage area was not on area survey maps nor on postings associated with the insnediate or surrounding storage areas. The inspector noted that the liners were in a heavily trafficked area during the current outage and that the label was required to be visible by employees working with the liners and also by workers working in the inanediate vicinit One violation of TS 6.1'1 for failure to maintain adequate labelling for resin liners was identifie High Radiation Area RWP Control TS 6.12.1.a requires, in part, each high radiation area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr to be barricaed snd conspicuously posted as a high ;
radiation area and entrance thereto to be controlled by issuance of a RWP and any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area, or with an integrating alarming dosimeter, or accompanied by an individual with a radiation dose rate monitoring device responsible for l providing positive control over activities within the are I HP Administrative Procedure 0-HPA-001, Radiation Work Permit "
initiation and Termination, dated December 31, 1990, requires that the frequency of periodic radiation surveillances provided by the RP L technician be specified by the HPSS on RWPs for high radiation areas
! where a RP technician with' a dose rate meter is responsible for
- providing positive' control,over activities within the are During tours of the V3 Containment on February 27, 1991, the i inspectors noted digital Alarming Radiation Monitors within the
bioshield wall as general area controls. Subsequent discussions with
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i licensee representatives of controls implemented for the area indicated that positive controls for selected tasks included providing workers with radiation dose rate monitoring device or by RP technician coverage requiring periodic radiation surveillance '
During review of selected U3 Containment RWPs for work conducted
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within the bioshield, the inspectors noted that contrary to the
" licensee's procedure the RWP did not include guidance regarding the frequency of periodic radiation surveillances to be provided by the RP technician providing coverag The inspectors informed licensee l
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representatives that the failure to follow radiation procedures to l include surveillance radiation areas was a frequencies on RWPs, associated with .high6.11')(5 violation of TSC From review of U3 activities in progres 6d discussion with workers and RPM staff, the inspector verified that proper surveillances were l l being conducted. Prior to the end of the onsite inspection, licensee representatives stated that the appropriate changes would be mad The inspectors informed licensee representatives this NRC-identified violation was not being cited because criteria specified in 10 CFR 2, Section V.A of the enforcement policy were me One NCV of TS 6.11)for failure to follow HP administrative procedures regarding developinent RWP guidance for high radiation area entries was identifie Locked High Radiation Areas TS 6.12.1.b requires each High Radiation Area in which the intensity of radiation is greater than 1000 mrem /hr to be subject to the provisions of 6.12.1.a. and in addition locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under administrative contro During tours of the U3 containment and the site Auxiliary Building, the inspectors verified that all locked high radiation area doors were maintained locked as appropriat No violations or deviations were identifie Containment High Range Radiation Monitors (83750)
NUREG-0737,Section II.F.1, Attachment 3, requires licensees to install in-containment radiation level monitors with a maximum range of 1 E+08 rad per hour. In addition, a minimum of two such monitors that are physically separated shall be provided and the monitors shall be developed and qualified to function in an accident environment. NUREG-0737 further clarified that the monitors shall be located in containment in a manner as to provide a reasonable *
assessment of - area radiation conditions inside containment. The
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monitors shall be widely separated so as to provide independent
- measurements and shall " view" a large fraction of the containment
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volume. Additionally, the monitors should not be placed in areas which are protected by massive shielding and should be reasonably accessible for replacement, maintenance, or calibratio During tours of the U3 Containment on February 27, 1991, the inspectors observed that one of the two CHRRMs was located on the 30'
6" elevation near the personnel hatch and apparently in an area protected by massive shielding. The inspectors informed licensee representatives that the CHRRM on the 30' 6" elevation did not appear to be located in accordance with the requirements specified in NUREG-0737,Section II.F.1, Attachment The inspectors discussed this concern with licensee representatives during the observation and during the March 1,1991 exit meeting. At the exit meeting, the licensee management agreed to provide an engineering evaluation of the U3/U4 CHRRM locations within 30 days. The inspectors stated that l this commitment to provide an their evaluations concerning the issue -
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and subsequent NRC review would be tracked as an inspector followup item (IFI) (50-250,-251/91-08-06).
During a March 22, 1991 teleconference, licensee representatives discussed engineering justifications for the CHRRMs locations and additional documentation that would be provided. The licensee I indicated that a search for the original CHRRM location documentation was continuing. NRC representatives indicated that any l information and/or explanation regarding CHRRM location should be l sent to the NRC Region 11 office so that a technical review with respect to NUREG-0737, II.F.1, Attachment 3 could be mad One IFl regarding review of licensee evaluation of U3/U4 Containment CHRRM 30' 6" elevation locations was identifie . FollowupItems(92701)
The following NRC IFIs and NRC Information Notices (ins) were reviewed and discussed with cognizant licensee representatives, Inspector Followup Items (Closed)IFI 50-250/89-14-05: Review licensee actions regarding retraining or requalification program for returning contract HP technician Licensee representatives stated that in response to this issue, Administrative Procedure 0-ADM-269, Health Physics Department Personnel Training and Qualifications, dated July 5,1990, was revised to incorporate a FP&L Corporate HP recomended practice on continuing qualification Contract HP technicians are required to attend annual Contract Technician Training unless the individual is participating in applicable portions of RP technician level IV or HPAT Level III Continuing Trainin Contractor HP technicians remaining onsite for more than six
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months are included in those areas of RP technician or HPAT Continuing Training related to their duties as specified by the HP supervisor. Also, returning contractor HP technicians who have not worked at TPN within the past twelve months are required to receive refresher training on specific policies, procedures, and practices related to their specific dutie The inspectors informed licensee representatives that based on i
the review of the completed actions, this item would be l considered close . (Closed) IFl 50-250/89-14-06: Review licensee actions regarding improving work coordination and man-hour estimates to improve dose projection estimates.
- Licensee actions included improvement in departmental radiation exposure tracking and control. An exposure tracking process flowchart with a quality indicator to minimize variance of of actual man-rem for department goals was developed. The flowchart detailed information flow and subsequent improved evaluation between the ALARA group and various plant departments utilized for the timely reporting and evaluation of group man-rem estimates either by RWP or by work group, for .
adjustments made to man-hour and exposure estimates, and for
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post job evaluation of tasks with man-rem exposure 20 percent
- outside of man-rem exposur Further, cognizant licensee representatives stated that repetitive job planning has improved by the use of detailed and expanded job files maintained by the ALARA group. Input to the files included input from ALARA field monitors and operations personnel. Licensee representatives stated the actions outlined have resulted in improved man-rem estimates for both defueling and RTD removal activities associated with the current V3/U4 outage activitie The inspectors informed licensee representatives that based on the review of the completed actions, this item would be considered close . (Closed) IFI 50-250/89-35-01: Review licensee's evaluation of need to include analysis of repeatable occurrences and root l cause analysis in audit program implementatio l l
In response to this issue the licensee revised Quality Assurance l Manual, Quality Procedure (QP) 16.1 dated November 20, 199 l The procedure now includes requirements that for all identified i conditions adverse to quality the root cause is to be determined i and documented and corrective actions taken to prevent l recurrenc This guidance is required for finding identified by I either site, corporate, or external audits.
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The inspectors informed licensee representatives that based on the review of the completed actions, this item would be considered close . (Closed) IFI 50-250/89-35-09: Review licensee progress in meeting action plan goals of reducing contaminated floor spac The inspectors reviewed with cognizant licensee representatives l current activities regarding contaminated floor space at TPN.
l The use of catch containments, tracking and repair of leaks, j j
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improved preventative valve maintenance activities, and increased TPN personnel awareness regarding contamination control were cited as initiatives to reduce contaminated floor space. Further, refurbishment of floor coatings was identified as a initiative to improve decontamination effort effectiveness following work in selected Auxiliary Building areas. In November 1990, prior to the current dual unit outage approximately 6,661 square feet (ft2), less than six percent of the approximate 110,000 ft2 floor space tracked was contaminate As of January 31, 1991, approximately seven percent, 9042 ft2 of 119,015 ft2 currently tracked, was listed as contaminate Further the licensee projected the contaminated floor area to decrease to 6345 fta by December 1991, following completion of the current outage activities.
l l The inspectors informed licensee representatives that based on
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the current discussions and a previous review of this issue ;
documented in IR 50-250,-251/90-08, dated July 18, 1990, this l l
item would be considered closed.
l l (Closed) IFI 50-250,-251/90-08-04: Review licensee's final report and followup on corrective actions regarding May 2, 1990 spent resin transfer proble .
I The inspectors reviewed the event noted above in which the
" licensee experienced operational difficulties during a resin transfer from the Spent Resin Storage Tank (SRST) to a high l
' integrity container (HIC) located in the Radwaste Building.
l During that evolution, the licensee was unable to flush the l
resin transfer line, either by back flushing to the SRST or L completing the transfer to another HIC. With spent resin in the
transfer line, the licensee was required ~ to maintain l approximately 15,700 square feet of the auxiliary building as a
! locked high radiation area. Of that area, the Component Cooling l Water System (CCWS) area could not be locked, and thus was I required to be posted, barricaded, and directly observed and !
controlled by qualified HP personnel. The resin transfer event
' was reviewed and critiqued by the licensee. The inspectors reviewed the critique and the corrective actions with licensee representatives. The following is a sumary of the corrective actions:
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- The SEG fill and dewatering system was upgraded to include a fill flow diverter which will, on the OP-HIGH alarm, automatically redirect the waste flow from the primary HIC to a second HI * HP Procedure 0-HPS-042.5. Transfer and Dewatering Bead Resin in RADLOK 500 High Integrity Containers, was revised to reflect the system upgrade and to require that a second HIC be available for flush and overflo *
A single individual was designated by management to be responsible for overall planning and coordination of the resin transfer proces *
Remote radiation monitoring systems were used to monitor the dose rates in selected areas near the HIC *
An extension rod was used to manipulate the outboard isolation valve so that the operator does not have to come in close proximity to the transfer lin *
Individuals involved with the resin transfer process have been counseled on the potential hazards of working outside the scope of planned activities in a high radiation are *
The procedure for posting prior to a resin transfer from the SRST to the Radwaste Building was revised to include a requirement to post the CCW room as a locked high radiation area and to use a waist-high barrier at the boundary to alert individuals to the new posting The inspectors ~noted that subsequent resin transfers were successfully completed and .that the corrective actions were effective and that besed on their actions this item would be considered close Information Notices The inspectors verified that the following ins were received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or planne . -
IN 90-31: Update on Waste Form and High Integrity Container
,.. Topical Report Review Status, Identification of Problems with Cement Solidification, and Reporting of Waste Mishaps
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IN 90-33: Sources of Unexpected Occupational Radiation Exposures at Spent Fuel Storage Pools
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IN 90-35: Transportation of Type A Quantities of Non-Fissile
- Radioactive Materials
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IN 90-44: Dose Rate Instruments Underresponding to the True Radiation Fields
IN 90-47- Unplanned Radiation Exposures to Personnel *.
Extrtemi ti < Due to Improper Handling of Potentially Highly
- Radioactive Sources
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IN 90-48: Enforcement Policy for Hot Particle Exposures IN 90-49: Stress Corrosion Cracking in PWR Steam Generator Tubes
IN 90-50: Minimization of Methane Gas in Plant Systems and Radwaste Shipping Containers
IN 90-56: Inadvertent Shipment of a Radioactive Source in a Container Thought to be Empty
IN 88-63, Supplement 1: High Radiation Hazards from Irradiated Incore Detectors and Cables l
IN 90-66: Incomplete Draining and Drying of Shipping Casks IN 90-78: Previously Unidentified Release Path from Bi'R Control
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IN 90-82: Requirements for Use of NRC Approved Transpcrt Packages for Shipment of Type A Quantities of Radioactive Material 13. Licensee Actions Regarding Previous Enforcemtnt Items (92702) (Closed) VIO 50-250,-251/90-08-01: Failure to follow RWP procedure for U3 containment cooler system maintenance activitie This issue involved the failure of contractor personnel to follcw requirements for contacting the HPSS prior to initiating U3 Containment Chiller maintenance activities. The violation resulted in the workers unknowingly entering slightly elevated radiaticn field The inspectors reviewed and verified implementation of corrective actions stated in the FP&L response dated July 3,1990. Corrective actions included changes to RWP Entry Log requiring workers to rotify HP prior to start of work activities; review of contractor knowledge regarding RWP compliance; establishment of spare copy RWP file for use by all workers; and changes to Radiation Worker Training to emphasize RWP complianc ,
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i Based on review of licensee corrective actions and observation of work practices during the current inspection, the inspec.~rs infonned .
licensee representatives that this issue would be considered close )
, (Closed) VIO 50-250,-251/90-08-05: Failure to maintain adequate l postings associated with a radioactive materials / waste storage are j This issue involved the failure to maintain adequate postings associated with a radioactive materials / waste storage are The inspectors reviewed and verified implementation of corrective actions stated in the FP&L response dated July 3,1990. Corrective !
actions included imediate restoration of the required barrier, review of other potential problem areas, establishment of routine !
surveillances to check radiologica' posting, and emphasizing Radiation Worker Training regardc 1diological postings,
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Although no additional concerns regarding posting noncompliances.were
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identified, an additional concern regarding adequate labelling within
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the radioactive material / waste storage area was identified during the current inspection as detailed Paragraph 11.b of this report. The inspectors noted that baseo on the new findir.g regarding compliance with 10 CFR 20.203 requirements, the effectiveness of the current corrective actions for this program area needed to be reviewed. The
, inspectors noted that this current item would be considered closed I and licensee actions regarding this progcam area would be tracked l under the item regarding compliance with labeling identified in l Paragraph 1 . Onsite Followup of Written Reports of Nonroutine Events (92700)
(Closed) LER 90-23: Exposure of plant personnel to a newly arrived l
radicactive source in Storage Warehous The inspectors reviewed LER number 90-023, dated November 15, 1991, Exposure of Plant Personnel to a Newly Arrived Radioactive Source located in the Stores Warehouse. The inspectors verified that the reporting l requirements were met, a root cause analysis was performed, anu that corrective actions were implemented. This LER documented an event identified during a routine inspection by a QA auditor who noticed an open shipping container in the Stores Warehouse which contained a 100 millicurie Cs-137 source calibrator. The calibrator had a maximum dose l rate of 110 mrem /hr on ' contact. The QA auditor notified the HP group of the situation and they immediately dispatched personnel to investigat Upon arrival, HP personnel secured and guaroed the package until the
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I calibrator was moved to the HP source cage located within the RCA. Upon
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further investigation, the licensee identified that the failm to post, establish and maintain procedures for safely opening packages, and control access to this source resulted violations of 10 CFR 20.203 (b), 20.205, I
and 20.207. The inspectors reviewed the following corrective actions to prevent recurrence:
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' Integrated doses for the affected personnel vere calculated and no l
individuals exceeded regulatory limit * RWP-90-177 was created for HP and stores personnel to receive and handle future radioactive material shipped to the Stores Warehous * A lockable storage box was placed in the warehouse for temporary l
storage of radioactive materials with access to the box controlled by H * 0-ADM-023, " Inventory Control and Accountability of Radioactive Sources," was revised to ensure that a source container be properly posted, labeled, and controlled .
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- 0-HPA-040, " Receiving Radioactive Materials," was revised to require
' a survey while unpacking radioactive material in accordance with the ( applicable RW * 0-HPS-025,1, " General Posting Requirements for Radiological Hazards,"
l was revised in require radioactive materials, including sources, used
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or stored or the RCA to be posted properly. In addition, a ,
boundary are "n. the radioactive material shall be'~ defined as a restricted ea such that the dose rate at the boundary was less than
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L or equal to 0.5 mrem / hour.
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After review of this event, this licensee-identified violation for failure l' -
to post and control. access to radioactive material is not being cited j because the criteria specified in Section V.G.1 of the NRC Enforcement l . i'oi' icy were satisfied (50-250/91-08-07). ,
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A licensee-identified NCV for failure to establish and maintain program l
controls for radioactive materials stored outside the licensee's RCA was l identified.
l l 1 Exit Interview (83750, 86750, 92700, 92701, 92702)
The inspectors scope and results. were summarized on March 1,1991, with those persons indicated in Paragraph 1. The general program areas reviewed and the apparent NRC or licensee-identified violations reviewed and/or identified during this inspection and listed below were discussed ,
in detai The inspectors noted continued concerns regarding the l radioactive material / waste storage area as identified by a labelling violation identified during the current inspectio As a result of
current ' noncompliance and issues identified during previous NRC inspections, the inspectors stated that increased ~ attention to activities
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within this program area was needed. The licensee was informed that i
pending NRC management review, previous IFIs, violations, and a LER i detailed in Paragraphs 1"..a 13, and 14, respectively were closed during i this inspection. The licensee did not identify any documents or processes reviewed by the inspectors as proprietary. Licensee representatives ..
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acknowledged the inspectors' coments and no dissenting coments were received.
During a March 22, 1991 teleconference, licensee representatives discussed I the engineering design bases regarding location of the U3/U4 Containment CHRRMs and difficulties in finding original documentation associated with the projec The inspectors informed licensee representatives any supporting information available regarding location of the monitors should j
be provided in a timely manner. Licensee representatives that a search
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for the original documentation was continuing and that a current sumary of the design bases and associated documentation would be provide Item Number Description and Reference 50-250,-251/91-08-01 NCV for failure to fcilow training procedure frequency of respiratory protection regarding(Paragraph training 4). SL-5 VIO of TS 6.11 with
i licensee corrective actions completed prior to the end of the onsite inspectio ,-251/91-08-02 NCY for failure to follow procedure requiring adherence to area postings (Paragraph 6.a).
Licensee-identified V10 of TS 6.11 with corrective actions completed prior to the end of the onsite inspection.
l 50-250,-251/91-08-03 NCV for under-reporting Nickel-63 quantities in l seven DAW shipments (Paragraph 10.b). I Licensee-identified violation of 10 CFR 20.311(b)
requirements with corrective actions completed prior to the end of onsite inspectio ,-251/91-08-04 SL-4 VIO for failure to follow radiation protection procedures for labelling resin liners maintained in waste storage area located east of e the old waste compactor shed (Paragraph 11.b). Violation of TS 6.11 requirement ,-251/91-08-05 NCV fer failure of RWP procedure to meet TS 6.12 surveillance frequency requiren,ents regardi ;
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high radiation area entry (Paragraph 11.F L-5
' V10 with licensee corrective action implemented prior to the end of the onsite inspection, i
50-250,-251/91-08-06 IFI regarding review of licensee's approved evaluation concerning placement of U3/U4 CHRRMs to implement NUREG-0737 Sectinn II.F.1, Attachment 3 criteria (Paragraph 11.e).
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50-250,-251/91-08-07 l4CV for failure to have adequate programatic
. controls of radioactive sources stored in unrestricted areas (Paragraph 14). Included violations of 10 CFR Parts 20.105 20.203, 20.205,
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and 20.207. Identified in LER No. 90-23. NCV i with licensee corrective actions completed prior i to end of onsite inspection.
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