IR 05000250/1992006
| ML17349A194 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/08/1992 |
| From: | Boland A, Kuzo G, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17349A192 | List: |
| References | |
| 50-250-92-06, 50-250-92-6, 50-251-92-06, 50-251-92-6, NUDOCS 9205050163 | |
| Download: ML17349A194 (47) | |
Text
~p,8 REGII UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLAN TA, G EO R G IA 30323 Report No.: 50-250/92-06 and 50-251/92-06 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 Facility Name: Turkey Point Units 3 and
March 25, 1992 Date igned
+ os y'z.
Date igned Inspection Conducted:
February 24-28, and Inspectors:
G.
B.
zo A. T. Bola
/
/
Approved by: J.
.
ot e
, Chief Da e Signed cilities adiation Protection Section Radiologic l 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 review of health physics (HP)
activities including program organization and staffing, self-assessment programs, administrative and operational controls, health physics technician training and qualifications, internal and external exposure monitoring and assessments, radioactive material and contamination controls, and ALARA program implementation.
In addition, followup on the licensee's response to previously identified inspection findings and receipt of selected Information Notices (INs) were reviewed.
Results:
The recent restructuring of the RP organization did not appear to impact overall program implementation adversely.
The level of RP staffing was adequate to support non-outage activities, and efforts were ongoing to fillvacant staff and technician positions.
Identified program strengths included the continued 9205050163 920410 PDR ADOCK 05000250
implementation of a comprehensive and effective health physics technician training program and a proactive self-assessment program which included the new supervisory surveillance initiative.
Xmprovements were noted in the areas of general housekeeping, radioactive material labeling, and overall radioactive material control.
The licensee's programs for internal and external radiation exposure controls were effective, with all exposures within 10 CFR 20 limits.
A weakness associated with the performance of leak testing for certain sealed sources was identified.
A poor industrial safety practice regarding the improper securing of compressed gas cylinders was noted and discussed with the licensee.
The RP program functioned adequately to protect the health and safety of radiation workers.
The following non-cited violation (NCV) was identified:
Licensee-identified violation for the failure to perform adequate leak testing of Fe-55 sealed sources used 'in metallurgical detectors.
NCV of 10 CFR 31.5 with licensee corrective actions initiated prior to the end of the onsite inspection.
e REPORT DETAILS 1.
Persons Contacted Licensee Employees
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Abbatiello, Acting, Quality Assurance Manager Bates, Support Supervisor Danek, Manager, Corporate Health. Physics Donis, Supervisor, Balance of Plant Engineering Supervisor Finn, Acting, Operations Manager Huba, Supervisor, Nuclear Site Engineering Jimnez, Health Physicist, Corporate Office Kirkpatrick, Supervisor, Emergency Planning Knorr, Licensing Engineer Lindsey, Supervisor, Health Physics Mowery, Licensing Engineer Murphy, Acting, Operations Supervisor Nee, Supervisor, Safety Pearce, Plant Manager Perle, Dosimetry Specialist, Corporate Office Weinkam, Manager, Licensing Williams, Dosimetry and Records Supervisor Section Other licensee employees contacted included engineers, technicians, operators, and office personnel.
Nuclear Regulatory Commission
- R. Butcher, Senior Resident Inspector J. Potter, Chief, Facilities Radiation Protection Section
- Attended February 28, 1992, Exit Meeting gParticipated in March 25, 1992 teleconference
+Participated in April 2, 1992 teleconference 2:
Organization and Staffing (83750)
a.
Organization The inspector reviewed and discussed with licensee representatives changes made to the RP organization since the last NRC inspection of this area conducted July 8-12, 1991, and documented in Inspection Report (IR) No. 50-250, 251/91-26.
Cognizant licensee representatives stated that the Health Physics Department had undergone a recent reorganization.
The number of supervisors reporting to the Health Physics Supervisor was increased from three to four.
The net effect of the restructuring was to make the ALMA and
dosimetry groups separate entities reporting directly to the Health" Physics Supervisor.
No changes related to the structure of the RP operations function were identified.
The remaining functions of instrumentation, respiratory protection, and administration were combined into a single support group reporting to the Support Supervisor.
With the department reorganization, the position of Operations Support Supervisor was created.
This position reports to the Support Supervisor and is responsible for decontamination/contaminated floor space and laundry monitoring activities.
Previously, these responsibilities belonged to the Radioactive Waste Supervisor.
Licensee representatives stated that the division of responsibilities was made to enhance the focus on radioactive waste activities.
Further, the inspector was informed that an overall plant reorganization took place in December 1991; however, the reporting chain for the RP group was not affected.
The Health Physics Supervisor continued to report directly to the Operations Supervisor.
Neither the plant nor the RP organizational changes appeared to adversely affect the ability of RP to support plant activities, and all critical functions continued.to be assigned.
No violations or deviations were identified.
Health Physics Staffing and Qualifications The RP organization was composed of approximately 82 staff, of which approximately 13 positions were supervisory.
At the time of the onsite inspection, four Radiation Protection Man (RPM) vacancies were noted, and the licensee was actively pursing recruitment for these positions.
Licensee representatives stated that all RPM on staff were qualified in accordance with ANSI 18.1 criteria, as required.
Actions to fillthe recently vacated Health Physics Engineering position were underway at the time of the inspection.
The specific duties of this position have been reassigned until the vacancy is filled. All other staff and supervisory positions allocated to the RP group were staffed.
Overall, the =current level of RP staffing appeared adequate to provide coverage for routine, non-outage activities.
No violations or deviations were identifie,
Health Physics Technician Training and Qualifications (83750)
Lic'ensee Administrative Procedure O-ADM-360, Health'hysics Department Personnel Training and Qualifications, dated June 15, 1991, provides for initial and continuing training programs for both Health Physics Administrative Technicians (HPATs) and RPM staff.
Through discussions with licensee representatives and review of the RPM Training Program, dated July 1991, the inspector determined that the RPM staff were provided with two cycles of continuing training per year, each consisting of between 24 and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of instruction.
Further, the HPAT Training Program, dated September 1991, provided for continuing training consisting of two cycles per year, each including between 20 and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of instruction.
Since the previous NRC inspection of the health physics technician training program conducted from July 8-12, 1991, and documented in IR 50-250, 251/91-26, Cycle II of the RPM and HPAT continuing training was provided.
At the time of the onsite inspection, 1991 Cycle II HPAT Training had been completed, and the final session of Cycle II RPM Training was underway.
According to documentation reviewed by the inspector, all RPM staff and HPATs will have attended the required training subsequent to completion of the current sessions.
The 'Cycle II RPM training topics included internal dosimetry, the new 10 CFR Part 20 changes, review of industry events, operation of the ND9900 multichannel analyzer, an Emergency Plan drill, and review of health physics procedures associated with recent inspection and audit findings (i.e., labeling, posting, and control of radioactive materials within the RCA).
The inspector noted, in particular, that the training included a systems review of pumps and valves.
Licensee representatives stated that the systems overview addressed general operation as well as health physics considerations associated with job coverage.
The training integrated maintenance personnel and included the use of a charging pump mockup.
Similar training on the residual heat removal system was planned for 1992 Cycle I training.
The inspector concluded that the course content was appropriate, and that the inclusion of mockup and integrated systems training was a positive initiative.
The inspector also reviewed other RP training program activities with cognizant licensee personnel.
The licensee continued to provide timely and informative periodic briefings to the RP staff regarding recent industry events,
.
the results of external audits and inspection findings, and
special items of interest.
The inspector noted that topics of more than a general interest were tracked by the HP Training Coordinator to assure one hundred percent attendance.
As of February 28, 1992, two such briefings-were being tracked for completion.
The inspector also noted ongoing plant efforts to support technician certification as Radiation Protection Technologists and the establishment of a Changed Procedure Review Book available to the staff for review of recent and proposed RP procedural changes.
From discussions with selected staff technicians, the inspector determined that the personnel were knowledgeable of their job function and received training, as appropriate.
The overall program for technician training appeared comprehensive and was considered an RP.program strength.
No violations or deviations were identified.
4.
Respiratory Protection Program (83750)
Revisions to procedural guidance in response to respiratory protection.program weaknesses identified in IR 50-250,
-251/91-26 dated September 23, 1991, were reviewed and discussed with licensee representatives.
The identified weaknesses involved failure follow respiratory protection procedures for issuance of respiratory protection devices and for verifying Grade D air quality for supplied-air breathing systems.
a.
Respiratory Protective Equipment Issuance
CFR 20.103(c)
permits the licensee to maintain and to implement a respiratory protective program that includes, at a minimum: air sampling 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 issuance of records; and determination by a physician prior to use of respirators that the individual user is physically able to use respiratory protective equipment.
Changes to licensee procedures for issuance of respiratory protective equipment were reviewed and discussed.
As a result of a violation involving use of an improper respiratory protection equipment, licensee procedure O-HPS-063.4, Selection and Issue of Respiratory Protection Equipment, dated October 10, 1991, was revised to include simpler qualification codes for respirator types.
The procedure now states that individuals can not issue respiratory protective equipment to themselves.
Further, HP Form 94,
Respirator Is'sue and MPC-Hour Record, dated October 15, 1991, was changed,to include the statement,
"Individuals shall not issue to themselves,"
referring to the data column required to be completed by the person issuing respiratory protective equipment.
In addition, approximately 10 to 14 individuals within the Radiation Protection Man (RPM) staff were trained in the applicable Job Performance Tasks and subsequently assigned to the respiratory protection equipment functional area.
Health Physics Administrative Procedure O-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 required prior to respirator initial use and annually thereafter.
A quantitative fit test is required prior to use and biennially thereafter.
For selected personnel issued respiratory protective equipment in February 1992, the inspector reviewed licensee Radiation Exposure Monitoring E Access Control, Training Data Base Reports and February 1992 Radiological Respirator and MPC-Hour logsheets, and verified implementation of the specified corrective actions, as well as, proper training and medical qualification status, in accordance with licensee procedures and/or
CFR Part 20 requirements.
No violations or deviations were identified.
Breathing Air Quality
CFR Appendix A, Footnote (d) requires adequate respirable air of the quality and quantity required in accordance with NIOSH/MSHA certification described in
CFR Part 11 to be provided for atmospheric-supplying respirators.
CFR 11.121 requires that compressed, gaseous breathing air meets the applicable minimum grade requirements for Type 1 gaseous air as set forth in the Compressed Gas Association (CGA) Commodity Specifications for Air, G-7.1 (Grade D or higher quality).
Licensee initiatives and procedural changes to enhance verification of Grade D quality for the supplied-air breathing systems were reviewed and discussed with
cognizant licensee representatives.
Administrative procedure O-ADM-041, PTN Respiratory Protection Plan, dated October 15, 1991, requires that prior to placing in service, and at a minimum on a quarterly basis when in service; station breathing air compressors, portable breathing air compressors, and compressors used to fill breathing air bottles to be sampled and verified as meeting or exceeding the quality defined as Grade D by the American National Standard Commodity Specification for Air, ANSI/CGA G-7.1-1989.
Guidance for completing the required analyses for the surveillance is detailed in O-HPT-061.7, Breathing Air Quality Analysis, dated January 23, 1992.
The inspector noted that, in general, the current guidance met regulatory guidance.
However, following discussions of compressor operability and major maintenance activities, licensee representatives stated that the need for additional guidance for Grade D
verification prior to placing in service compressor systems which had undergone extensive repairs, would be evaluated.
The inspector verified current implementation of the required surveillance for the RIX 5K4B-44 compressor system.
For the surveillance test conducted February 4,
1992, all results were within the limits specified in ANSI/CGA G-7.1 -1 1989.
No violations or deviations were identified.
5.
Administrative and Operational Controls (83750)
a
~
Form NRC-4
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 18 in which an occupational dose to radiation was received.
This signed and completed form is 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).
The inspector reviewed selected licensee dosimetry records for workers involved in various radiological incidents as well outage painting and preparation activities.
For the cases reviewed, a completed Form NRC-4 was on file, as applicable.
~ No violations or deviations were identifie Exposure Record Tracking and Issuance During the current inspection, the licensee's program for maintaining exposure records and subsequent issuance in accordance with 10 CFR Parts 19 and 20 were reviewed in detail.
In particular, the, inspector reviewed records of contractor and FPEL workers who temporarily terminated from, and subsequently returned to employment at the licensee's facility on a frequent basis.
CFR 19.13, requires'that at the request of any worker, each licensee is to furnish to the worker a report of his exposure to radiation or radioactive material within 30 days from the time the request is made, or within 30 days after the exposure of the individual has been determined by the licensee, whichever is later.
CFR 20.401(a)
requires, in part, that each licensee maintain records in accordance with the instructions contained in NRC Form 5, Current Occupational External Radiation Exposure, dated October 1981.
NRC Form
requires dose to the whole body to include any dose to the whole body, gonads, active blood forming organs, head and trunk, or lens of the eye.
In addition, doses to the skin of the whole body or extremities is to include the dose delivered through a tissue equivalent absorber of 7 mg/cm
.
CFR 20.409(b)
requires that when a licensee is required pursuant to 20.408 to report to the Commission any exposure of an individual to radiation or radioactive, material, the licensee shall also notify the individual at a time not later than the transmittal to the Commission.
The inspector reviewed and discussed procedural guidance for tracking, maintaining, and as required, issuing personal dosimetry results to individuals and the Commission.
Licensee procedure O-HPA-030, Personnel Monitoring of External Dose, dated February 8,
1991, provides instructions for issuance, handling, and control 'of personnel monitoring devices and for ensuring that exposure records are maintained properly.
Administrative control of the records requires that following receipt of TLD results from Florida Power and Light, Corporate Office, the HP group verify exposure reports were generated for all personnel monitored at the site.
Required termination letters which include a worker's exposure are generated by the HP department with a copy of the exposure going to the individual and
to the Commission.
Further, licensee representatives stated that special requests by workers for exposure data are completed manually in accordance with 10 CFR 19 requirements.
The inspector noted that licensee guidance was in accordance with 10 'CFR Parts 19 and 20.
The inspector reviewed exposure data provided to workers in association with termination letter issuance and special requests completed during January 1981 through January 1991.
The review included data for approximately 20 individuals including licensee and contractor personnel.
Excluding one individual who requested a special exposure report which was issued.
on November 13, 1991; all assigned exposures records appeared complete and accurate.
For the exposure records of the individual requesting the special report, a discrepancy of 162 millirem (mrem) between the special report and a previous exposure report dated February 20, 1986, was identified.
Additional review of the.
individual's Form-5 records and discussions with licensee representatives indicated that the noted difference resulted from a data transcription error made during preparation of the November 13, 1991 letter.
This error involved the failure to include in the October 16, 1985 through January 31, 1986 monitoring period specified in the November 13, 1991 letter, the 162 mrem exposure assigned during January 1-31, 1986.
However, from review of selected exposure reports provided by the licensee to the Commission, the inspector noted that the 111 mrem and 162 mrem exposures values assigned for the periods October 1-31, 1985, and January 1-31, 1986, respectively, were provided with previous exposure records, as appropriate.
Subsequent to identification of the error, licensee representatives stated that the individual would be provided with a corrected exposure record.
The inspector discussed the extent of transcriptional errors in preparing exposure record-requests.
Licensee representatives stated that
"on rare occasion" data transcription errors have been been reported by workers.
However, the recent proCurement of new computer hardware and the upcoming future implemention of associated system software and data bases to generate exposure reports were expected to minimize such errors.
During an April 2, 1992 teleconference, licensee representatives informed the inspector that additional exposure records were being reviewed at random to
determine the degree of errors in personnel exposure records.
As of April 2, 1992, no additional errors had been identified.
No violations or deviations identified.
Leak Testing of Radioactive Sealed Sources
CFR 31.5(c) requires, in part, any person who acquires, receives, possesses, uses,
-or transfers byproduct material in a device pursuant to a general license to assure that the device is tested for leakage of radioactive material at no longer than six-month intervals or at such other intervals as are specified on the label.
The inspector discussed with licensee representatives a
recently licensee identified issue regarding the adequacy of leak testing for certain sealed sources.
As a result of industry information regarding sealed source requirements, the licensee identified that they possessed two alloy analyzers acquired in July 1990 and October 1991.
Each analyzer contained a
5 millicurie (mCi) Cadmium-109 (Cd-109)
and a 45 mCi Iron-55 (Fe-55)
source.
Although leak testing of the sources was conducted every 6 months as required by the general license, the licensee did not have the instrument capability to detect the low energy X-rays associated with the decay of Fe-55.
Therefore, leakage of these sources could have gone undetected.
At the time of the inspection, the licensee had removed the analyzers from service and had initiated actions to have the manufacturer perform the required leak test analyses.
In addition, an inventory of all onsite sources had been conducted to verify that adequate leak testing could be performed, and a revision to Administrative Procedure 0-ADM-022, Procuring Radioactive Sources, was planned to ensure that prior to procuring any sources in the future that ability the to adequately perform analytical measurements of leak tests will be considered.
The inspector identified the failure to perform adequate leak testing of Fe-55 sealed sources as a violation of
CFR 31.5 (c) requirements (VIO:
50-250, 251/92-06-01).
However, because the licensee's actions in identifying and correcting the apparent violation were adequate and the criteria specified in Section V.G.1 of the NRC Enforcement Policy were met, the inspector informed licensee representatives that this licensee-identified violation would not be cite One licensee identified non-cited violation for the adequacy of Fe-55 seal sources was-identified.
6.
Self Assessment Program (83750)
a ~
Quality Assurance Audits Technical Specification (TS), 6.5.2.8 requires audits o'
facility activities to be performed under the cognizance of the Company Nuclear Review Board (CNRB) encompassing conformance of facility operation to all provisions 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.
During the onsite inspection, the inspector reviewed Quality Assurance Audits QAO-PTN-91-045, dated July 30, 1991, and QAO-PTN-91-058, dated October 29, 1991, as well as selected Performance Monitoring Reports and Quality Control Surveillances performed for the RP program subsequent to June 1991.
In general,the audits
,were determined to be detailed and sufficient in scope to include the major RP program functional areas.
Audit results contained issues of substance and were well documented, reported to licensee management, and tracked for completion of corrective actions.
Review of selected audit findings revealed that corrective actions were both appropriate and timely.
Issues identified were primarily related to administrative controls and did not involve high radiation areas or situations resulting in personnel exposure evaluations.
Discussion with licensee representatives revealed that the frequency of audits in the RP had been increased to six month intervals.
The inspector noted this to be a positive initiative by the licensee to aggressively pursue program improvements.
Overall, based on the depth of review and the issues identified, the current audit program was considered a program strength, and continued to contribute to RP program improvements.
No violations or deviations were identified.
b.
Radiological Incident Report System The inspector reviewed the licensee's RP internal program for identifying and correcting deficiencies and
. weaknesses related to the control of radioactive material.
Licensee Administrative Procedure O-ADM-603, Radiological Event Reports, dated January 16, 1992, establishes the program for classification,
documentation, evaluation, and correction of radiological events classified as performance monitoring indicators, radiological occurrences.,
significant radiological occurrences, and radiological incidents, listed in order of increasing severity.
The events are reported and tracked using the Radiological Incident Report (RIR) system.
The inspector reviewed documentation and discussed with licensee representatives recent and historical RIR information.
The distribution of RIRs for calendar year 1991 was as follows:
RIR '1'~e Numb r of Events Personnel Contamination Events Health Physics Violations Poor Work Practices Personnel Monitoring Problems Non-personnel Events Total Events 107 300
282
734 The inspector noted that the number of RIRs for 1991 had increased compared to the previous 1990 total of 712; however, the licensee attributed the increase to the large number of man-hours associated with the 1991 dual unit outage.
Review of 1989, 1990, and 1991, monthly data reflecting RIRs/1000 RWP entries confirmed a downward trend in the RIR rate of occurrence.
For 1991, the monthly rates ranged from 2.00 to 0.38.
The maximum monthly RIR rates of 2.00 and 1.85 were investigated and attributed to improper control point documentation, and initiation of the radioactive material tagging/labelling audits, respectively.
Overall, the licensee effectively tracked and assessed trends in RIR performance includ'ing informing management of trended results.
As of February 24, 1992,'pproximately 19 RIRs had been identified by the licensee.
The inspector reviewed selected RIRs for the period August 1, 1991, through February 24, 1992, and noted no significant trends or indicators of programmatic problems, Several RIRs were discussed in detail with licensee representatives and are. addressed in the appropriate topical sections of this report.
For the cases reviewed root cause analysis were performed and corrective actions were taken, as appropriate.
No violations or deviations were identified.
k
c.
Supervisory Surveillance Program Health Physics Administrative Procedure O-HPA-009, Health Physics Supervisor Surveillance, dated October 10, 1991, establishes a program by which Health Physics Supervisors routinely tour the Radiation Controlled Area to identify deficiencies and initiate corrective.
actions, as appropriate.
The program requires that each supervisor tour their assigned area of the RCA on a daily basis and provide any deficiencies observed to the Health Physics Supervisor.
On a weekly basis each supervisor is required to submit a written report addressing at a minimum, observations related to, survey maps, area postings, control of radioactive material, contamination control, instrumentation, and housekeeping.
The inspector discussed the surveillance program with several RP supervisors.
The individuals were cognizant of their responsibilities to perform the tours, document findings, and initiate corrective actions for identified deficiencies.
A review of documentation of the tours revealed that identified items were being tracked and corrective actions were implemented, as appropriate.
In addition to supplementing the audit and corrective action program, the inspector also noted that the Supervisor Surveillance Program served to provide an increased supervisory presence in the plant, and required supervisors who normally do not frequent the RCA to become familiar with their assigned area and broaden their perspective of RP operations.
No violations or deviations were identified.
7.
Internal Exposure (83750)
CFR 20.103(a)(1)
states that no licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in 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 1.
CFR 20.103(a)(3)
requires, in part, that the licensee, 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 individual Health Physics Administrative Procedure 0-HPA-031; Personnel Monitoring of Internal Dose,'ated October 15, 1989, requires initial, annual, and termination bioassay measurements for workers accessing the RCA.
The inspector reviewed records of selected contractor and plant personnel involved in outage painting and associated preparation activities, as well as, facial contamination events.
For the cases reviewed, initial and termination whole body analyses were performed as required.
Additionally, the licensee's program for special bioassays was evaluated.
Procedure 0-HPA-031 requires that a special bioassay measurement be performed when specific criteria are met including nasal swabs or facial contamination in excess of 5000 disintegrations per minute (dpm).
The inspector reviewed the RIRs for July through December 1991, detailing individuals reported to have positive facial contamination.
For all the reviewed cases, special whole body analyses were conducted in accordance with procedural guidance, and no positive measurements were reported.
The inspector was informed by licensee representatives that no internal contaminations in excess of 0.1 percent Maximum Permissible Body Burden (MPOB) had been identified for the calendar year 1991.
Based on the licensee's established correlation of MPOB to Maximum Permissible Airborne Concentration (MPC,),
no exposures in excess of the 40 MPC-hour control limit requiring assessments in accordance with
CFR 20.203 (b)(2) were assigned.
Since the previous NRC inspection of this area in July 1991, the inspector noted that the licensee had implemented a new Fast Scan standing geometry whole body counter.
Licensee dosimetry personnel stated that the new counter was primarily used for routine analysis, and that any required quantitative analyses would be performed using the chair geometry whole body counter.
No violations or deviations were identified.
External Exposure (83729)
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 bod Thermoluminescent Dosimetry Program
CFR 20.202(c)
requires, in part, that dosimeters used to comply with 10 CFR 20.202(a)
shall be processed and evaluated by a dosimetry processor holding current accreditation from the National Voluntary Laboratory Accreditation Program (NVLAP) for the type of radiations for which the individual is being monitored.
CFR 20.401(a)
requires, in part, that each licensee maintain records in accordance with the instructions contained in.NRC Form 5, Current Occupational External Radiation Exposure, dated October 1981.
NRC Form
requires that when the lens of the eye is not protected by shields wj.th a tissue equivalent absorber thickness of 700 mg/cm the whole body dose is to include the dose delivered thorough a tissue equivalent absorber thickness of 300 mg/cm
.
Discussions with licensee representatives revealed that a new Panasonic UD-803 TLD system was implemented in October of 1991.
The TLDs consist of 4 elemepts with density thicknesses of 19, 356, and 985 mg/cm
. The inspector was informed that the TLD analysis algorithm corrects the measured values tq report deep and shallow dose at 1000 mg/cm and 7 mg/cm, respectively.
The TLDs are processed by the Corporate Dosimetry Group located in Juno Beach which holds NVLAP certification valid through July 1, 1992, for categories I-VIII.
The inspector noted that the NVLAP certification was updated to include the newly implemented TLD system.
The inspector reviewed the licensee's program for evaluating and/or assigning dose delivered to the lens of the eye.
The licensee stated that the TLD algorithm included a beta correction factor for the lens of the eye; however, the correction factor generally was not applied due to the algorithm logic.
In response to concerns that no correctiop factor was applied to address doses at 300 mg/cm, the inspector was informed that the site beta energy spectrum was such that beta dose to the eye was not a. concern as long as the eye was provided with sufficient eye protection (i.e.
a bubble hood).
To substantiate this, the licensee provided studies performed by Pacific Northwest Laboratory (1984)
and Corporate (1985 and 1990).
The inspector was informed that bubble hoods 'were required for steam generator (S/G) work.
Subsequent to the exit meeting on February 28, 1992, the inspector was also provided documentation of RO-2 and TLD S/G surveys performed during the April 1991 Unit 4
'
and February 1990 Unit 3 outages.
Review of the survey data and discussions with'icensee representatives on March 25, 1992, indicated that the last S/G survey results were consistent with the previous beta studies, and the beta component of the-steam generator radiation field was shielded by a density thickness approximately equal to that of a bubble hood.,
The inspector noted that the TLD and RO-2 surveys were required to be performed prior to initiation of steam generator work in accordance with Health Physics Surveillance Procedure HPS-055, dated February 5,
1991.
However, no formal mechanism was in place to assure that the survey results and conclusions were provided to the Corporate Dosimetry Group for evaluation and validation of TLD algorithm.
Licensee personnel stated that Corporate generally was kept informed of changes in plant conditions; however, they would evaluate the need for a more formalized process for providing this information.
No violations or deviations were identified.
Exposure to Skin Health Physics Administrative Procedure O-HPA-034.2, Determination of Dose to the, Skin From Skin Contamination, dated January 28, 1992, details guidance for determining skin dose due to surface contamination.
Skin dose calculations are required when total exposure exceeds 25,000 disintegrations per minute-hours (dpm-hrs) for a hot particle.
The inspector reviewed two hot particle events which occurred during the 1991 dual unit outage and were documented in RIRs.
For both events, the primary nuclide of concern was Cobalt-60, and calculated doses did not exceed
CFR 20 limits or the licensee s administrative limits.
Identification, investigation, and assessments associated with the events were thorough and in accordance with approved procedures.
Further, during facility tours the inspector noted that the Unit 3 charging pump room was posted as a noble gas airborne area.
Review of selected historical air sampling records confirmed that the noble gas concentrations in the area exceeded 25% Maximum
.
Permissible Concentration in air (MPC,) requiring posting with the primary contributors being Xenon-133 and 135.
In addition, noble gas submersion skin exposure assessments were conducted based on the air sampling data in accordance with HP Procedure O-HPS-022, dated January 16, 1992, and the inspector noted that the
methodology employed was appropriate and was based on Regulatory Guide 1.109 assumptions.
No violations. or deviations were identified.
c.
Whole Body Exposure The inspector discussed the 1991 cumulative whole body exposure for station employee Licensee representatives stated that all whole body exposures were within 10 CFR Part 20 limits.
Review of pertinent records revealed that maximum annual whole body exposure to an individual for 1991 at the Turkey Point site was 2.703 Rem.
In addition, the, maximum whole body dose recorded for the fourth quarter of 1991 was 2.085 rem.
The inspector reviewed in detail the circumstances surrounding a December 1991 administrative overexposure.
The event, documented by RIR 591-748, involved a painter, who as a result of discrepancies between TLD and direct reading dosimeter data, exceeded the licensee's annual administrative limit of 2500 mRem.
The total whole body annual dose assigned for the worker was 2703 mrem, based on TLD measurements.
The licensee took immediate actions to restrict the individual from the RCA and initiate an investigation.
The licensee s
investigation, health physics evaluations, and followup actions related to this event were considered appropriate.
The inspector noted that no quarterly or annual
CFR 20 dose limits were exceeded, and the event appeared to be isolated and was not indicative of an RP programmatic weakness.
I No violations or deviations were identified.
9.
As Low As Reasonably Achievable (83750)
CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures ALA&.
The inspector reviewed and discussed with cognizant licensee representatives the ALARA final assessment for the 1991 dual unit outage.
The original exposure goal for the 48 week outage was approximately 1532 person-rem by direct reading dosimeter (DRD).
The actual exposure incurred for the outage of approximately 960 person-rem (by DRD) was a
significant reduction from the original estimate.
The licensee attributed the lower than estimated dose to the use of increased amounts of shielding and the decreased dose rates associated with the resistance temperature detector (RTD) removal.
The license estimated that RTD removal
reduced general area dose rates inside the biowall by approximately 50 percent.
The ALARA aspects of the RTD bypass elimination and the Unit 4 S/G eddy current testing were reviewed in detail during the July 8-12, 1991, NRC inspection of this area as documented in IR 50-250,
-251/
91-26 dated August 16, 1991.
The inspector reviewed the AIdQQ. package for the Unit 3 painting and associated preparation inside the biowall.
The actual expenditure of approximately 50 person-rem was reduced compared to the initial dose estimate of 80 person-rem.
As discussed previously, the majority of the dose reduction was attributed to decreased general area dose rates and increased shielding; and in addition, the filling of the RCS loop piping.
Documentation'evealed that appropriate pre-job evaluations including the need for engineering controls (i.e. ventilation)
were performed.
In addition, RWPs and pre-job briefings appeared adequate to support the work scope.
A particular strength noted by the inspector was the comments and recommendations provided by the ALARA Zone Coordinators during monitoring of job activities.
Overall, for this job, as well as the previously reviewed RTD and S/G work, AL2Q& program activities were implemented effectively.
At the time of the inspection, the licensee stated that ALARA planning associated with the August 1992 Unit 3 outage had begun.
High dose activities being considered for the outage included S/G nozzle dam installation and a reactor coolant pump pull.
In addition, licensee representatives stated that the installation of the ultra-fine filters for the Chemical and Volume Control System were targeted for a summer installation pending completion of the appropriate procedures.
During the onsite audit, the inspector reviewed and discussed with cognizant licensee representatives, selected quantitative parameters regarded as indicators of RP program effectiveness.
The reviewed parameters included person-rem expended, personnel contamination events (PCEs),
and the percentage of the RCA regarded as contaminated.
Personnel Dose Expenditure:
For the period January
through December 31, 1991, the site cumulative personnel exposure per unit was approximately 469 person-rem as compared to a goal of 655 person-rem.
The licensee's 1992'dose goal is approximately 212 person-rem per unit.
Long term dose reduction goals included achieving 162.5 person-rem/unit by 199 Personnel Contamination Events (PCEs):
For the period January 1 through December 31, 1991, the licensee reported 107 PCEs as compared to a goal of 120.
This value represented a significant decrease from the 214 PCEs reported for 1990.
Licensee representatives continued to attribute the decrease primarily to the improved laundry facilities and protective clothing.
The licensee's PCE goal for 1992 is less than 100 cases.
As of February 24, 1992,
PCEs were identified.
Contaminated Surface Area Control:
Continued licensee efforts to reduce contaminated floor space were noted.
As of December p1, 1991, the licensee reported 6158 square= feet '(ft ) of contaminated space.
This represented approximately 5 percent of the total recoverable space of 117,746 ft.
As of January 31, 1992, the contaminated floor space had been further reduced to 4194 square feet.
No violations or deviations were identified.
10. Facility Tours (83750)
During the onsite inspection, the inspector toured selected areas of the U-3 and U-4 Auxiliary Building and radioactive waste processing and/or storage locations.
The inspector observed facility operations, and selected work activities to evaluate the implementation and effectiveness of the licensee's RP program.
The following specific radiation protection issues and concerns were noted and discussed with licensee representatives.
a.
Instrumentation All survey meters and continuous air monitors in use within the RCA were observed to be operable, calibrated, and source checked daily in accordance with licensee procedures.
No violations or deviations were identified.
b.
Locked High Radiation Areas TS 6.12.2 requires that "areas accessible to personnel with radiation levels greater than 1000 mRr/hr at
inches to be provided with locked doors to prevent unauthorized entry in addition to the requirements of TS 6.12.1.
The inspector noted, however,-that an administrative limit of 800 mR/hr had been established for posting locked high radiation areas in accordance with O-HPS-025.1, General Posting Requirements for Radiological Hazards, dated December 17, 199 During tours of the Unit 3 and 4 Auxiliary Building and RadWaste Building, all locked high radiation areas were verified to be locked and conspicuously posted.
During a walkthrough of the RadWaste Building, the inspector noted a ladder, determined to access the building crane, was posted as a high radiation area.
The licensee stated that the -posting was provided because the crane platform and rails could reach high radiation area levels when the crane traversed the filling room locked high radiation area.
The licensee subsequently provided surveys to verifying the maximum general area radiation level as 90 mR/hour, and the inspector concerns with the posting were resolved.
Prior to the end of the onsite inspection, however, the licensee locked the access ladder and provided additional postings in the ongoing crane construction work area.
No violations or deviations were identified.
Labeling and Posting
CFR 20.203(f) requires each container of licensed material to bear a durable, clearly visible label identifying the radioactive contents and providing sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
Licensee actions in response to a violation identified during a previous inspection conducted July 8-12, 1991, and documented in IR 50-250,-251/91-26
'were reviewed and discussed.
Corrective actions included procedural revisions and increased supervisory review.
Licensee procedures O-HPS-041, Control of Radioactive Material Inside the Radiation Controlled Area, dated September 9,
1991, and O-ADM-605, Control of Radioactive Tools, Equipment, and Components, dated January 16, 1992 were revised to simplify tagging requirements for radioactive material containers.
In addition, survey sheets (HP Form 40 series)
were revised to include verification by signature that radioactive material in the area is labeled properly in accordance with applicable procedures.
From discussions with selected personnel, the inspector verified that specific supervisors were assigned responsibility for ensuring proper posting and labeling in assigned areas.
The inspector noted that the corrective actions should enhance corrective actions for previously identified weaknesses for posting and labeling of radioactive materials and radiation area During tours of radioactive materials and waste storage areas, the inspector noted that radioactive material and containers were tagged and labeled with the radiological information as required by the licensee's procedures.
However, the inspector noted several examples of vacuum cleaners stored in the Dry Storage Warehouse in which the labels were not clearly visible; however, the licensee confirmed that the equipment was labeled as required; The inspector discussed the importance of providing clearly visible information to workers handling or working in the vicinity of radioactive materials.
Licensee representatives stated that additional training would be provided to the RPM staff on the need for visible. labels and the applicable procedures would be revised to include such a
requirement.
No violations or deviations were identified.
Independent Surveys During the facility tours, the inspector independently
"verified radiation and/or contamination levels in radwaste areas, various Auxiliary Building locations, storage vans, RadWaste Building, and general waste processing/storage locations.
The inspector noted that in all cases containers, materials, and areas were
'osted, labelled and safeguarded in accordance with the radiation hazards present.
General Observations Industrial Safety:
During the tours of the facility, the inspector noted multiple.examples of compressed gas cylinders which appeared to be improperly stored.
These examples included numerous cylinders secured with tied ropes, a cylinder attached to an electrical conduit in the Unit 4 charging pump room, and an unsecured cylinder in the Radwaste Building.
The licensee took prompt action to stabilize the unsecured cylinder.
However, licensee safety representatives stated that the practice of securing cylinders with rope was an acceptable OSHA practice.
Licensee management personnel informed the inspector that the policy regarding 'securing cylinders would be evaluated.
Housekeeping:
Licensee efforts to inventory radioactive material and reduce the quantity of stored waste were noted.
Significant improvements were observed in the overall condition of yard and radioactive materials storage areas.
Licensee representatives stated that a Task Force had been established to better manage ongoing
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waste reduction efforts, particularly related to the Dry Storage Warehouse.
Although continued focus in this area is needed, the licensee's ongoing efforts have been successful in improving overall radioactive material control.
11.
Followup Items (92701)
The following NRC Inspector Followup Items (IFIs) and NRC Information Notices (INs) were reviewed and discussed with cognizant licensee representatives.
a.
INs The inspector determined that the following INs had been received by the licensee, reviewed for applicability, and distributed to appropriate personnel for action.
According to licensee representatives, two of the Ins, 91-35 and 91-39, had not been received.
Prior to the conclusion of the onsite inspector, copies of these Ins were provided to the licensee.
Fitness-For-Duty IN 90-82:
Requirements for Use of NRC Approved Transport Packages for Shipment of Type A Quantities of Radioactive Material IN 91-10:
Summary of Semiannual Program Performance Reports on Fitness-For-Duty (FFD) in the Nuclear Industry IN 91-35:
Labeling Requirements for Transporting Multi-Hazard Radioactive Materials IN 91-36:
Nuclear Plant Staff Working Hours IN 91-37:
Compressed Gas Cylinder Missile Hazard
Compliance with 10 CFR Part 21,
"Reporting of Defects and Noncompliance" IN 91-40:
Contamination of Nonradioactive System and Resulting Possibility for Unmonitored, Uncontrolled Release to the Environment IN 88-63, Supplement 2:
High Radiation Hazards-from Irradiated Incore Detectors and Cables IN 91-60:.
False Alarms of Alarm Ratemeters Because of Radiofrequency Interference
Emergency Access to Low-level. Radioactive Waste Disposal Facilities IN 91-76:
CFR Parts 21 and 50.55(e)
Final Rules IN 91-77:
Shift Staffing at Nuclear Power Plants b.
IFIs
(Closed) IFI 50-250, 251/91-08-06:
Review -licensee evaluation concerning placement of Units 3 and
Containment High Range Radiation Monitors (CHRRMS)
to implement NUREG-0737,Section II.F.1, Attachment 3 criteria.
This concern identified that for both Units 3 and 4, the current configuration of the CHRRMs included one unit located at the 30" 6'levation near the personnel hatch where the it appeared to be shielded by the bioshield wall.
The ability of CHRRM to meet the requirements of NUREG-0737,Section II.F.I were questioned when no data/evaluations were found addressing the significance of the bioshield between the detector and main containment volume.
At the request of NRC RII, the Office of Nuclear Reactor Regulation (NRR) conducted a review of the issues identified in IR 50-250,-251/91-08.
The evaluation included additional system details provided in a letter from Mr. T. Plunkett, Vice President, Turkey Point Nuclear, to NRR dated April 8, 1991, and from discussions with the NRC Project Manager, RII personnel, and licensee representatives.
Based on evaluation of drawings and photographs provided, each monitor was determined to view a large segment of the containment volume under post-accident conditions.
The monitor located near the S/G cubicle was determined to provide a view of containment atmosphere activity and radiation from the Emergency Containment Filters.
The other monitor located near the personnel hatch, approximately 15 and 41 feet at the nearest and farthest points from the bioshield wall respectively, also was determined to be open to the 30'" operating floor and to the upper containment volume.
The review indicated that no material existed in the immediate area to shield the monitor from ambient area radiation or prevent circulation of the atmosphere around the monito Further, the evaluation determined that in the event of an accident, released radioactive materials would be mixed throughout, the containment volume by circulation fans and emergency containment coolers.
Potential differences in readings for the two monitors was determined to be addressed adequately in the licensee's Emergency Plan Implementing Procedure No. 20126, Off-Site Dose Calculations, which specifies that the higher of the two values is used for dose assessment purposes.
The review concluded that the present CHRRM locations are adequate to meet the'equirements of NUREG-0737,Section II.F.I, Attachment 3,
and the criteria'pecified in Regulatory Guide 1.97.
The inspector informed licensee representatives that based on NRR's evaluation this item would be considered closed.
(Open) IFI 50-250, 251/91-26-04:
Review licensee's evaluation and actions regarding audibility of the containment public address system during outage activities.
The inspector discussed with licensee emergency preparedness representatives the plan for upgrade of the public address (PA) system in response to this finding as well as previous findings associated with emergency exercises.
The licensee stated that the PA system upgrade package, including the page volume boost and integration of the fire alarm system, had been approved and scheduled for installation.
At the time of the inspection, the Unit 3 system upgrade was scheduled for the August 1992 outage and the Unit 4 upgrade was scheduled for the early 19'93 outage.
The, licensee maintained an internal commitment of June 1993 for the operation of the PA system upgrades.
The inspector informed the licensee that this issue would remain open pending final installation and testing of the system.
12.
Licensee Actions Regarding Previous Enforcement Items (92702)
a.
(Closed)
VIO 50-250, 251/91-26-01:
Failure to follow respiratory protection procedures for issuing and using respirators and verifying Grade D breathing air quality for breathing air compressors.
The inspector reviewed and verified implementation of corrective actions stated in Florida Power and Light Company's (FPEL's)
response dated September 12, 199 A
The inspector informed licensee representatives that based on review of selected respiratory protection program procedural changes and verification of their implementation as documented in Paragraph 4, this item would be considered closed.
(Closed)
VIO 50-250, 251/91-26-03:
Failure to follow surveillance procedures for labeling an onsite storage container.
The inspector reviewed and verified implementation of corrective actions stated in FP&L's response dated September 12, 1991.
The inspector informed licensee representatives that based on recent licensee surveillance initiatives procedural changes, and observations conducted during the current inspection as documented in Paragraph 10.c, this item would be considered closed.
(Closed)
VIO 50-250, 251/91-26-05:
Failure to maintain a continuously operable telephone line for use in accordance with hazardous transportation activities.
This identified violation resulted from the inability of an inspector to verify operability and proper manning of a telephone required to be operable continuously during transport of a radioactive waste shipment.
The inspector reviewed and verified implementation of corrective actions stated in FPSL's response dated September 12, 1991.
Procedural revisions in response to the noted violation included designating the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> emergency phone number contact as the Control Room with the HP Shift Supervisor phone identified as an alternate.
The inspector verified that the appropriate changes were included in O-HPS-044.9, Radioactive Material Shipment Documentation, dated August 22, 1991; O-HPS-040.9, Radioactive Waste Manifests and Documentation for Shipments to Barnwell, dated January 28, 1992; and O-HPS-041.9, Radioactive Waste Manifests and Documentation for Shipments to Waste Processors, dated August 22, 1991.
During tours of the Control Room and HPSS office and from discussion with operators and HP Shift Supervisors, the inspector verified that current copies of the applicable procedures were available in each area, copies of radioactive material manifests were maintained on file during shipment, and that all personnel were trained properly regarding actions to be taken.
Subsequent to discussions regarding
responsibilities for initial training of new operators and/or periodic retraining, licensee representatives committed to include responsibilities and requirements within the appropriate operations procedure.
The inspector informed licensee representatives that based on the completed actions and discussions with cognizant individuals, this item was considered closed.
13. Exit Interview (83750, 92701, 92702)
The inspection scope and results were summarized on February 28, 1992, with those persons indicated in Paragraph 1 above.
The general program areas reviewed and the apparent NCV identified during this inspection and 3.isted below were discussed in detail.
The licensee was informed that pending NRC management review, an IFI and three violations detailed in Paragraphs 11 and 12, respectively, would be closed during this inspection.
Licensee representatives acknowl'edged the inspector',s comments and no dissenting comments were received.
The inspector informed licensee representatives that although proprietary information was reviewed during this inspection, such material would not be included in the report.
Item Number 50-250, 251/91-26-01 Description and Reference Licensee-identified VIO:
Failure to perform adequate leak testing of Fe-55 sealed sources associated with metallurgical detectors.
NCV of 10 CFR 31.5 with licensee corrective action initiated prior to the end of the onsite inspectio.'4I '
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