IR 05000250/1992025
| ML17349A570 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/25/1992 |
| From: | Boland A, Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17349A569 | List: |
| References | |
| 50-250-92-25, 50-251-92-25, NUDOCS 9212300041 | |
| Download: ML17349A570 (24) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 OEC OS 1992 Report No.: 50-250/92;25 and 50-251/92-25 Licensee:
Florida Power and Light Company 9250 West Flagler Street Niami, FL 33102 Docket Nos.:
50-250 and 50-251 License Nos.:
DPR-31 and DPR -41 Facility Name: Turkey Point Units 3 and
Inspection Conducted:
November 2-6, 1992 Inspectors:
A.
.
o nd Date Signed R.
B. Shor ridge
/
Approved by: Z S, W. H. Rankin, Chief Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards rr gK Da e S'gned D te Signed SUMMARY Scope:
This routine, unannounced inspection of the licensee's radiation protection (RP) program involved review of health physics (HP) activities primarily related to the current Unit 3 outage.
The specific areas evaluated included 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.
Results:
The RP group staffing appeared adequate to support routine and outage activities, although some recent technician losses were noted.
The training program for RP contractor technician training was considered comprehensive.
External and internal exposure control programs were implemented effectively with all exposures less than
CFR Part 20 limits.
Weaknesses were noted related to the procedures associated with the Radiation Work Permit System and the performance of pre-job briefings as well as the conduct of routine 9212300041 921202 PDR ADOCK 05000250
e radiological surveys.
Site collective dose, personnel contamination events, and contaminated floor space continued to show an improving trend.
The licensee's ALARA program was effective, and the results achieved from the lithium-boron chemistry program were considered a program strength.
Overall, the licensee's RP program was conducted in accordance with approved procedures
'nd functioned adequately to protect the health and safety of=plant workers.
The following non-cited violations was identified:
Non-cited Violation (NCV):
Failure to conduct routine radiological surveys in accordance with approved procedures.
Violation of Technical Specification 6. 11 (Paragraph 7.a).
REPORT DETAILS Persons Contacted Licensee Employees
- T. Abbatiello, Acting, guality Assurance Manager J.- Bates, Support Supervisor
- Health Physics J.
Berg, Radiochemist R.
Brown, Operations Supervisor
- Health Physics
'.
Coleman, ALARA Supervisor
- J. Danek, Manager, Corporate Health Physics M. Eades, guality Assurance Specialist
- V. Kaminskas, Manager, Operations
- J. Knorr, Licensing Engineer
- J. Lindsey, Supervisor, Health Physics
- J. Marchese, Manager, Construction R. Merle, Construction Supervisor
- L. Pearce, Plant Manager
- T. Plunkett, Vice President D. Schlosser, Project Manager
- NuPac Service, Inc.
- E. Weinkam, Manager, Licensing J. Williams, Dosimetry and Records Supervisor Other licensee employees contacted included engineers, technicians, operators, and office personnel.
Nuclear Regulatory Commission
- R. Butcher, Senior Resident Inspector L. Trocine, Resident Inspector
- Attended November 6, 1992, Exit Meeting Organization and Management Controls (83729)
The inspection was conducted during the Unit 3 refueling/maintenance outage scheduled for 53 days.
The licensee was in the process of reinstalling the reactor vessel closure head and preparing for containment local leak rate test.
Eddy current work had been completed for all three steam generators (S/Gs),
the "B" reactor coolant pump had been pulled for.maintenance, and the licensee was in the process of replacing fittings on the incore thimbles at the seal table.
The inspector attended an outage planning meeting and noted that radiation protection (RP) issues were appropriately discussed and appeared to be supported by plant management.
The inspector also noted that neither the station's collective dose goals or the number of personnel co'ntamination events (PCEs)
were discussed at the meeting.
However, these indicators were statused on the Plan of the Day handout, and the licensee was under projection in both element,The inspector reviewed and discussed with licensee representatives-changes made to the RP organization since the last NRC inspection of this area conducted February 24-28, 1992, and documented in Inspection Report (IR) No. 50-250, 251/92-06., During discussions with licensee representatives the inspector noted that the size of the Radiation Protection Han (RPH) technician staff had decreased since the last inspection.
The licensee stated that over the last eighteen months approximately eight RPHs have either left or have notified the Health Physics Supervisor of the intention to leave.
The Health Physics Supervisor stated that he had obtained authorization to hire six RPHs and two foremen.
The foremen positions were new and were being created to increase supervision in the field and to enhance job opportunities within the RP group.
In addition, during the inspection the inspector discussed the issue of personnel loss with RP management and were told that after a
disaster such a hurricane Andrew that the projection of personnel losses as high as 25-35% could be expected.
No changes in the HP supervisory or engineering staffs were noted at the time of the inspection.
Overall, the inspector noted that staffing levels and lines of authority as they related to the Unit 3 refueling/maintenance outage and routine operations support activities had not undergone any changes which adversely affected the licensee's ability to implement the required elements of the RP program.
No violations or deviations were identified.
Health Physics Technician Training and gualifications (83729)
CFR 19. 12 requires, in part, that the licensee instruct all individuals working in or frequenting any portion of a restricted area in the health protection aspects associated with exposure to radioactive material or radiation; in precautions or procedures'o minimize exposure; in the appli.cable provisions of the Commission regulations; in the individual's responsibilities; and in the availability of radiation exposure data.
The inspector reviewed the licensee's program to prepare for and procure contractor health physics (HP) technicians for the Unit 3 outage.
The licensee hired approximately 98 contractor HP technicians to supplement their routine staff.
The qualification/experience levels were as follows:
35 seniors technicians (ANSI 3. 1-1981),
one site supervisor, one site coordinator, 19 junior technicians, 18 decontamination technicians, six dosimetry clerks, and 18 control point/access control personnel.'he-licensee required at least 6,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> applied health physics experience to qualify as a senior technician.
If the returning senior contractor technician had worked at the station in the past year they were not required take site specific training, if not, they were required to take refresher training on RP procedures, policies, and practices.
All contractor HP technicians were required to successfully complete security, site specific RP procedures, and general employee training.
In addition, senior contractor technicians were required to successfully complete job performance measures and on-the-job training just as
licensee HP technicians are required to do.
The inspector reviewed the job performance measures for contractor RP personnel'and noted that the list appeared to be comprehensive to allow contractor personnel to perform independently for most RP tasks.
Licensee representatives stated that if contract HP technicians have been onsite for one year they were included in continuing training.
The inspector inquired if contractor HP technicians with less than one year onsite were receiving training on industry events or operating experience and was informed that this information was provided through shift training briefs.
Based on the above review, the inspector did not note any concerns related to the licensee's program for contractor technician training.
No violations or deviations were identified.
4.
Self Assessment Programs (83729)
a ~
guality Assurance Audits Technical Specification (TS) 6.5.2.8 requires audits of 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.
Since the last NRC inspection of this area in February 1992, no quality assurance audit of the Radiation Protection (RP)
Program had been completed.
The last such TS required audit was gAO-PTN-91-058, dated October 29, 1991.
The inspector was informed that the licensee's initiative to conduct audits on a six-month interval had been discontinued, based on the progress of RP program improvements.
The inspector noted that the currently implemented annual frequency for audits met the TS requirements.
At the time of the onsite inspection, the inspector was informed that an audit of the RP Program was underway and scheduled for a near-term completion.
Discussions with the Lead Auditor responsible for the current audit and review of the Audit Plan, dated August 12, 1992, revealed that the on-going audit included an evaluation of the licensee's overall RP Program, compliance with high radiation area requirements, and the Corporate Radiation Safety Program as well as performance observation of activities in progress.
In general, the audit scope appeared adequate to address the major program elements.
The inspector was also informed that an audit of the licensee's control of radioactive sealed sources had been initiated during October 1992.
The inspector informed licensee representatives that the results of these audits would be reviewed during a future NRC inspectio The licensee's action on previously identified audit findings was evaluated and documented in IR 50-250, 251/92-06.
Overall, the corrective actions were both timely and appropriate.
Review of the current guality Assurance Open Item Tracking System noted.no open items related to the RP area.
No violations or deviations were identified.
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, established 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 were reported and tracked using the Radiological Incident Report (RIR) system.
The inspector reviewed documentation and discussed with licensee representatives 1992 RIR information.
The distribution of RIRs for calendar year 1992 was as follows:
~RIR T e
Personnel Contamination Events Personnel Monitoring Events Non-Personnel Events Health Physics Violations Poor Work Practice Number of Events
132
10
226 The inspector noted that the overall number of RIRs for 1992 had decreased significantly compared to the previous 1991 total of 734; however, the licensee was not able to conclusively define the cause for the decrease.
The licensee continued to effectively trend RIR information including assessing the rate of RIR occurrence per 1000-RWP entries.
Review of the RIR rate information noted 1992 monthly rates ranging from 0.3 to 4.23.
Discussions with licensee personnel indicated that the highest rates of RIR occurrence occurred in April through June of 1992 and were primarily associated with implementation of the new digital alarming dosimeters and the radwaste reduction program.
Regarding the former, the licensee experienced initial implementation problems associated with both hardware and usage.
The inspector noted that the licensee took appropriate corrective actions, including coordination with the vendor, to correct the identified problems.
Several RIRs were discussed in detail with the licensee and are addressed in the appropriate topical section of this repor e Ingeneral, the inspector concluded that the licensee was appropriately identifying, trending, and correcting health physics problem areas.
No violations or deviations were identified.
5.
External Exposure Controls (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 body.
CFR 20.202 requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipment.
a
~
External Exposure and Dosimetry The inspector reviewed and discussed with licensee representatives second and third quarter external exposures for plant and contractor
- employees.
The inspector verified that.all external exposures assigned at the Turkey Point site since the previous NRC inspection of this area were within 10 CFR Part 20 limits.
Review of pertinent records noted the following maximum quarterly doses:
Second uarter 1992 Third uarter 1992 Whole Body Exposure Whole Body Skin Exposure Extremity Exposure 684 mrem 780 mrem 5174 mrem 1230 mrem 1230 mrem 1503 mrem
In addition, the inspector discussed with licensee representatives the exposures associated with RWP-7406, Steam Generator Tube Plugging, RWP-7405, Steam Generator Eddy Current Testing, and RWP-7533, Conoseal Assembly Replacement.
The inspector noted that workers performing these outage activities were provided with multiple and/or extremity dosimetry due to the non-uniform radiation fields in the work area.
Review of the manual and computerized exposure records for workers associated with these work activities identified no concerns regarding the licensee's application and use of multiple dosimetry.
During tours of the Unit 3 Containment and the Auxiliary Building the inspector observed personnel wearing digital alarming dosimeters (DADs) and self reading dosimeters appropriately.
The inspector noted that the DADs were checked out at the HP Control Point upon entry to RCA, and returned at the same location upon exit.
Further,
e the inspector observed that the DADs were not directly linked to the dose tracking for recording dose real time, and the dosimetry personnel were performing this function manually.
Licensee representatives stated that DADs were introduced to the exposure control program in April of this year and as part of the system package the DADs are to be linked to the dose tracking computer in the near future, and that were it not for the hurricane, this action would have been completed for the current outage.
No violations or deviations were identified.
b.
Radiation Work Permit System The inspector reviewed the licensee's program for access control to the radiologically controlled area (RCA) including the radiation work permit (RWP), system.
During tours of the Unit 3 containment the inspector evaluated personnel performing work on RWPs relative to meeting the dress and other special requirements.
No discrepancies were noted.
Specific RWPs packages which contained ALARA briefing and pre-job
.
briefing packages were reviewed for requirements and accuracy.
During the review the inspector noted that for various RWPs that required workers to attend a pre-job briefing prior to performing work on that RWP, several people were identified who had signed on the RWP as having performed work but had not attended the pre-job briefing.
HP supervision stated that for the cases identified by the inspector where this had occurred the workers had received specific HPSS autho'rization because the workers were performing a
support function and not the main task.
The inspector inquired regarding the process for this to occur.
The licensee stated that if an RWP was designated as "restricted" specific HPSS authorization was required to access it for work, and the need for a pre-job briefing was determined by the HPSS based on the actual scope of work to be performed, regardless of the RWP requirement.
Further HPSS authorizations were controlled through the dose tracking computer system.
The inspector reviewed HP procedure O-HPA-001, Radiation Work Permit Initiation and Termination, dated August 14,1992, and was unable to find any formal instructions on restricted RWPs or special HPSS authorization for accessing RWPs without the required pre-job briefing. In addition, the inspector noted that the procedure specified which forms should be retained as quality assurance records and Form HP-IE, Pre-job Briefing, was not included in this list, nor was the form contained in the master copy of the procedure maintained by Document Control. Although licensee supervision appeared to be controll,ing access to the RCA for RWP work, the inspector discussed the importance of formalizing operational methods in procedures for consistency'nd the necessity of an operations procedure to accurately reflect requirements with the Health Physics Supervisor.
At the exit meeting, the licensee stated
they had initiated actions to revise the RWP procedure to correctly state currently used operating methods and to provide instruction to RWP developers on pre-job briefing requirements.
The inspector informed the licensee that corrective actions would be followed up
.
on during a subsequent inspection, and this issue would be tracked by the NRC as an Inspector Followup Item (IFI 50-250/92-25-01).
The inspector received a pre-job briefing on Unit 3 Seal Table Thimble Work, Including Support, RWP 92-7035.
The work observed appeared to be effectively controlled radiologically.
The inspector noted that the Flux Nap Drives were required by RWP to be tagged out of service prior to the work being performed.
The inspector observed that the Flux Nap Drive was in fact tagged out in the Unit 3 Control Room.
Another exposure control in effect for Flux Wire Operation/Maintenance was the maintenance of a special HP log book for maintaining accountability of the storage location of the Flux Wires.
HP had performed the appropriate log entry for the location of the Flux Wires prior to the operation.
No discrepancies were noted.
No violations or deviations were identified.
Locked High Radiation Areas TS 6. 12.2 requires, in part, that areas accessible to personnel with radiation levels greater than 1000 mR/hr at 18 inches be provided with locked doors to prevent unauthorized entry, and the keys be maintained under the administrative control of the shift supervisor on duty and/or health physics supervision, 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 0-HPS-025. 1, General Posting Requirements for Radiological Hazards, dated December 17, 1991.
The inspector reviewed the licensee's program for administrative control of locked high radiation area (LHRA) and exclusion area keys.
Procedure O-HPA-021, Health Physics Restricted Area Key Control, dated December 31, 1990, described the administrative controls for key issuance, accountability, and maintenance.
The inspector determined that positive controls were maintained for LHRA and Exclusions Area keys by the Health Physics Shift Supervisor (HPSS)
and the Health Physics Operations Supervisor (HPOS),
respectively, through the use of limited access, locked key cabinets.
Keys were issued to RPHs upon completion of the Issue Log and receipt of a required pre-job briefing, unless the key was for an Exclusion Area which required downgrade to a LHRA first.
Keys were inventoried by HPSSs on a shiftly basis.
and by the HPOS on a
quarterly basis.
During the onsite inspection, the inspector directly observed the licensee's process for issuance of LHRA area keys as well as the
downgrade and issuance of keys for an Exclusion Area (reactor sump)
~
In addition, selected Issue Logs and documentation for the period June through October 1992 were reviewed.
Based on the evaluation, the inspector verified that the procedures for control of LHRA were being properly implemented.
Upon request by the inspector, the licensee was able to account for all LHRA keys.
During tours of the Unit 3 and 4 Auxiliary Building, Unit.3 Containment, and RadWaste Building, the inspection observed that all locked high radiation areas and exclusion areas were locked and conspicuously posted, as required.
For those areas in Containment that could not be reasonably locked, the licensee utilized flashing lights and appropriate postings to warn 'workers consistent with NRC guidance.
The inspector also reviewed the licensee access controls associated with the RadWaste Building crane ladder which had been previously addressed with licensee representatives during a February 1992 inspection.
The ladder, which provided access to the Building Crane, had been secured and posted consistent with the LHRA requirements.
Licensee representatives stated that the posting was upgraded due to the potential for transversing and accessing from overhead a
LHRA.
The inspector determined that the licensee's control of the ladder was adequate.
No violations or deviations were identified.
6.
Internal Exposure (83729)
CFR 20. 103(a)(l) 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'eeks at uniform concentrations of radioactive material in air specified in
CFR Part
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 individuals.
Health Physics Administrative Procedure O-HPA-031, Personnel Monitoring of Internal Dose, April 21, 1992, requires that special bioassay'easurements be performed when specific criteria are met including nasal swabs or facial contamination in excess of 5000 disintegrations per minute (dpm), exposure to airborne radioactivity in excess of 30 Maximum Permissible Concentration-Hours in any one week, and any real or suspected internal exposure.
The inspector reviewed the RIRs for March through October 1992 detailing individuals reported to have positive
. facial contamination.
For cases reviewed, special whole body analyses were conducted in accordance with procedural guidance, and no positive measurements were reporte e e
The inspector reviewed in detail an October 9, 1992, incident in which a
worker inadvertently fell into the reactor cavity while performing support work under RWP-7520.
Review of RIR-92-193 and discussions with licensee representatives revealed that the worker tripped on a rope, fell into the reactor cavity, and was submerged in water up to his chest for approximately 10 seconds.
Followup personnel surveys determined maximum external contamination levels of 10,000 dpm on the thighs; however, the individual was decontaminated below the licensee's action level of 1000 dpm within approximately 50 minutes.
The licensee performed successive whole body counts and collected urine samples to quantify any intake of radioactive material.
Although whole body counts initially identified the presence of Cobalt-58 and Thallium-202, the licensee determined that based on various frontward and backward counts that the positive results were due to external contamination, and ultimately a negative whole body result was obtained.
Tritium analysis of urine samples collected noted slightly positive results, with a conservative 50-year committed effective dose calculated of less than one mrem.
In addition, skin dose calculations based on the 10 second submersion and the measured external contamination were also less than one mrem.
Based on the review of the event and associated data, the licensee's actions and assessment associated with this event were appropriate and in accordance with approved procedures.
No concerns were identified.
Further, the inspector was informed by licensee representatives that no positive internal contaminations had been identified to date in 1992.
Based on the above, the inspector concluded that the licensee was effectively controlling internal contaminations with no exposures greater than the 40 Maximum Permissible Concentration-Hour control limit identified.
No violations or deviations were identified.
7.
Control of Radioactive Naterials and Contamination, Surveys, and Honitoring (83279)
a 0 Routine Surveys
CFR 20. 201(b) requires each licensee to make or cause to be made such surveys as (1)
may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radiological hazards that may be present.
Procedure O-HPA-004, Scheduling of Periodic Health Physics Activities, dated June 26, 1992, established the licensee's program for conducting routine surveys and monitoring of various'plant-locations.
The procedure provided for the development of a master matrix of required surveys as well as the approval of changes, deletions, or additions to the schedule.
The inspector reviewed the current matrices of periodic RP activities and determined that the licensee had established a
schedule of required shiftly, daily, weekly, monthly, quarterly,
e
semi-annual, and annual surveys.
Review of the matrices in detail determined that the survey frequencies were established consistent with procedural guidance.
The inspector reviewed completed scheduling matrices and documentation of routine surveys conducted during the period December 1991 through October 1992.
For the records reviewed, the inspector identified to the licensee the following apparent
.discrepancies:
(1) The monthly required survey for the Maintenance Tool Repair and Calibration Shed was not performed for May 1992.
Surveys were attempted on May 17, June 4, and June 8, 1992; however, no surveys were performed because the facility was locked; (2)
Documentation of three shiftly surveys for the HP Control Point could not be located by the licensee.
The missing surveys were for both shifts on October 18, 1992, and the evening shift on October 29, 1992; and (3) The 1991= annual environmental surveys (Form HP-55, surveys onsite, inside the protected area)
were shown as
"Not Applicable" on the survey matrix and not performed in 1991.
The inspector informed licensee representatives that the failure to conducted required surveys in accordance with approved procedures was a violation of TS 6. 11.
Regarding the environmental surveys, the inspector was informed that the annual surveys using Forms HP-55 were not performed 'in 1991 as shown on the matrix, because they were a duplication of other surveys performed on a quarterly basis (Survey Forms 44:99, 98, 97, 96, and 68).
The inspector verified that the surveys were comparable, and the corresponding fourth quarter surveys were performed.
However, the inspector noted that the procedures should reflect actual practice and any changes to the scheduled survey frequency should be approved by management.
The inspector was informed that master matrix was revised with management approval on March ll, 1992, to reflect the deleted requirement, and the June 26, 1992, revision to the scheduling procedure included requirements for management prior approval of surveys deemed
"Hot Applicable."
At the time of the onsite inspection, the licensee informed the inspector that arrangements for gaining routine access to the Maintenance Tool Shed as well as a review of the overall survey matrix were in progress.
Based on the isolated nature of the missing surveys, the low safety significance of the missing HP Control Point surveys, and the previously implemented corrective actions associated with the environmental surveys, the inspector informed licensee representatives that the violation would not be cited because the criteria specified in Section VII.B of Enforcement Policy were met (50-250, 251/92-25-02).
One non-cited violation for the failure to perform routine surveys in accordance with procedural requirements was identifie Personnel and Area Contamination Th'e licensee maintained approximately 117,750 square feet (ft') of
.floor space as radiologically controlled.
As of October 31, 1992, the licensee was tracking approximately 11,866 ft'ffloor space as contaminated which equated to approximately 10 percent of the RCA.
The inspector noted that the Unit 3 outage activities contributed to a higher than average value.
The licensee's overall goal for contaminated area was established at 5000 ft'or the year.
Although the licen'see had only achieved the goal during 3 separate months in 1992, an overall downward trend from previous years conti.nued to be noted.
As of October 31, 1992, approximately 53 Personnel Contamination Events (PCEs)
had occurred in 1992 compared to a 1992 goal of 100.
'iscussions with licensee representatives and a review of PCE data revealed that 29 were skin contaminations and 23 were clothing contaminations.
The licensee continued to pursue improvements-in the laundry monitoring to reduce the potential for contamination events.
In particular, the inspector reviewed a recent study conducted in October 1992 as a result of a hot particle found during a post laundry survey.
The study was targeted to evaluate the ability of the laundry monitors to effectively detect hot particle and distributed contamination of approximately 20,000 dpm whether inside or outside of the protective clothing.
At the time of the onsite inspection, the licensee was evaluating the various recommendations of the study.
The inspector reviewed selected aspects of the spent resin transfer spill event of July 9, 1992 which resulted in the spillage of radioactive liquid and contamination of approximately 2000 ft'f floor space in the RadWaste Building.
As detailed in IR 50-250, 251/92-16, dated August 18, 1992, the spill resulted from the failure to properly connect the drain line hoses between the primary and secondary fill containers.
All spilled liquid was contained within the RadWaste Building with no release to the environment.
Based on discussions with personnel involved in the event and the procedures used for the transfer the inspector noted the following:
housekeeping in the area was poor which contributed to the improper hose connection; the interface between vendor procedures and licensee procedures for setup of the transfer equipment was weak; all procedural steps in the vendor and licensee procedure were not signed off prior to initiation of the transfer; and although they were quality assurance documents, completed procedures associated with event were difficult to retrieve.
In response to an NRC violation cited in the aforementioned inspection report related to this event, the licensee committed to various corrective actions which included procedural changes, correction of RadWaste Building floor drain problems, and improved equipment tagging and labelling.
At the time of the onsite inspection, all corrective action had not
e
been fully implemented, and the inspector informed licensee representatives that this area would be reviewed during future inspections.
No violations or deviations were identified.
c ~
Posting and Labeling
CFR 20.203 specifies posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactivity areas, and radioactive materials.
During tours of the Unit 3 Containment, Auxiliary Building, RadWaste Building, and various radioactive material storage areas, the inspector noted that radioactive materials were appropriately posted, labelled, and safeguarded consistent with the hazard present with one noted exception.
During a tour of the Auxiliary Building, the inspector observed a step-off pad and a posting attached to a rope barrier that was intended to prevent unobstructed access to the
'Unit 3 Sample Room. -The posting was for a contaminated area and was hanging down on one side of the access.
The inspector notified HP.
supervision and the area was immediately posted in accordance with licensee procedures.
In response to the event HP initiated a
Condition Report describing the event and the corrective actions taken to prevent recurrence.
Initial corrective actions were to stop work in the area and conduct a briefing for contractors working in the area.
Later the inspector learned that a briefing of the event and what was required to prevent recurrence 'was given to all personnel in the applicable department.
The inspector noted during subsequent tours of the Auxiliary Building that all postings were in accordance with procedure requirements.
No violations or deviations were identified.
d.
Area and Radiation Monitors TS 3/4.3.3.6 details the limiting conditions for operations and surveillance requirements for the radioactive gaseous effluent monitoring instrumentation.
The inspector reviewed the. status of Unit 3 area and effluent radiation monitors that were affected or damaged as a result of the August 24, 1992, hurricane.
As stated in IR 50-250, 251/92-21, dated November 13, 1992, all effluent radiation monitors had been placed back in service with the exception of those 'associated'ith the Unit-3 Steam Jet Air Ejector (SJAE).
This instrumentation, consisting of a Geiger Nueller (GH) 'detector and a System Particulate Iodine Noble Gas-4 (Sping-4) detector, has not been required to be in service since the hurricane due to the refueling outage status of Unit-e
The inspector discussed with licensee representatives the current status of the U-3 SJAE instrumentation.
According to licensee representatives the damage assessment revealed that the GH detector and associated cabling had been damaged as well as the sample port for the SPING-4.
The inspector reviewed Plant Construction/Maintenance (PC/H) order 90-240 which outlined previously planned modifications for this instrumentation.
Licensee representatives stated that repair work was to be performed in association with this modification.
Review of the licensee's construction outage schedule confirmed that the PC/M was scheduled for completion by November 20, 1992, prior to the end of the U-3 outage and restart.
A tour of the Turbine Building which housed the radiation instrumentation provided verification that the licensee was actively working the PC/H.
In addition, the inspector reviewed the status of U-3 area radiation monitors.
The inspector noted that the R-17A area radiation monitor associated with the component cooling water system lost indication subsequent to the hurricane.
The licensee's assessment determined that the loss of indication was due to a blown fuse, and no damage to the detector or cabling was identified.
Through a review of maintenance records, the inspector determined that the licensee repaired and conducted post-maintenance testing of the monitor.
These activities were completed by September 6,
1992.
No violations or deviations were identified.
8.
Program for As Low As Reasonably Achievable (ALARA) (83729)
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 ALARA.
The inspector reviewed the licensee's program to maintain occupational exposures ALARA.
During discussions with licensee.representatives the inspector was informed that the collective dose for 1992 through October 31, 1992, was approximately 268 person-rem.
The licensee's goal for 1992 was 425 person-rem which, and based on the work remaining in the current outage, appeared achievable.
The total collective dose was primarily attributable to routine operations and the current Unit 3 outage, as well as two forced outages early 1992.
The inspector noted that during February and March 1992, the licensee achieved their lowest ever monthly doses of 5 and 6 rem, respectively.
Licensee ALARA representatives attributed much of the overall dose reduction to the decrease in the contractor workforce.
The inspector reviewed and discussed with licensee representatives ALARA program initiatives and dose estimates for several Unit 3 dose intensive work evolutions.
In particular, RWP 92-7533, Unit 3 Containment Perform Conoseal Assembly Replacement, Including Support Work, was initially projected to cost 780 person/hours and 8.500 person-rem, and actually cost 1265 person/hours and 22.367 person-rem.
Licensee ALARA
representatives stated that scaffolding set-up and support were responsible for the excessive number of person-hours and, thus, the overrun on the ALARA dose projection.
In addition, the licensee reported on a number of refueling/maintenance tasks that were under the original dose projection.
The detensioning of the reactor vessel head was one of these that was performed for 2.943 person-rem of the 10.000 person-rem budgeted.
The savings was attributed to new reactor vessel stud tensioning/detensioning devices and good crew training on the devices.
The licensee developed a chart for the outage that showed for each major task their best historical performance for the task compared to their performance this outage.
For the majority of tasks this outage the actual person-rem was below their best past performance.
In reviewing the licensee's program for out-of-core source term reduction the inspector reviewed data that showed the change to a lithium/boron coordinated chemistry program was making significant reductions in radiation levels in the reactor coolant loop piping and in the S/G channel heads.
For this process, the licensee injected boron into the reactor coolant system (RCS) following shutdown which produced a crud burst.
The crud burst method consisted of two phases.
First, the reactor coolant was borated, and lithium was removed before cooldown below 350 degrees F.
An acid reducing phase resulted, and pH decreased which improved solubility.
For the second phase, hydrogen peroxide was added and created an acid oxidizing phase which caused dissolution of different isotopes.
During these phases the boron/lithium ratio was maintained within very close specifications.
The reactor coolant pumps (RCPs)
continued to run to remove cobalt (Co),
and after Co-58 removal reached the maximum peak the RCPs were secured and the RCS underwent depressurization and draindown.
Chemistry and HP data indicated that for Unit 3 the S/G channel head average radiation levels dropped from 11.0 to 5;5 rem per hour.
Likewise dose rates in the RCS loop piping have decreased significantly.
The inspector discussed these initiatives with licensee management and noted the significant accomplishments at the exit interview.
In addition, the inspector reviewed and discussed the licensee's Long Term Exposure Reduction Plan, most recently revised January 22, 1992.
The inspector noted the licensee had completed many of the items being tracked such as removal of the Resistance Temperature Detectors and implementation of a lithium-boron chemistry program.
However, the inspector discussed with licensee several items which had not yet been implemented such as ultrafine filtration and a video tour system.
At the exit, the inspector encouraged the licensee to continue to pursue these dose savings initiatives as they are becoming commonplace within the industry.
Based on the above, the inspector informed licensee representatives that the ALARA program appeared to be effective in reducing overall collective dose.
No violations or deviations were identifie e
9.
Exit Interview (83729)
The inspection scope and results were summarized on November 6, 1992, with those persons indicated in Paragraph 1 above.
The general program areas reviewed and the inspection findings and non-cited violation listed below were discussed in detail.
Licensee representatives acknowledged 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 Descri tion and Reference 50-250/92-25-01 50-250, 251/92-'25-02 IFI:
Evaluate changes to Radiation Work Permit procedures regarding the conduct of pre-job briefings (Paragraph 5.b).
NCV:
Failure to conduct routine radiological surveys in accordance with approved procedures (Paragraph 7.a)