IR 05000250/1994009
| ML17352A616 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/13/1994 |
| From: | Forbes D, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17352A614 | List: |
| References | |
| 50-250-94-09, 50-250-94-9, 50-251-94-09, 50-251-94-9, NUDOCS 9406060077 | |
| Download: ML17352A616 (21) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 303234I199 SY 13 N4.
Report Nos.:
50-250/94-09 and 50-251/94-09 Licensee:
Florida Power and Light Company 9250 West Flagler Street Hiami, FL 33102 Docket Nos.:
50-250 and 50-251 Facility Name:
Turkey Point Units 3 and
Inspection Conducted:
April 11-15, 1994 License Nos.:
D.
B. Forbes Approved by:
Date Signed G II g W.
H. Rankin, Chief Da e Signed Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUNMARY Scope:
This routine, announced inspection of the licensee's radiation protection (RP)
program involved review of health physics (HP) activities.
The specific areas evaluated included organization and staffing, training and qualifications, self-assessment programs, external and internal exposure, control of radioactive material and contamination, surveys and monitoring, and As Low As Reasonably Achievable (ALARA) program implementation.
Results:
Based on interviews with licensee personnel, records review, and observation of work activities in progress, the inspector found the RP program to be functioning adequately to protect the health and safety plant workers.
RP staffing levels appeared adequate to support on-going activities.
The licensee's self-assessment and RP training programs were conducted in accordance with requirements.
The licensee continued to implement effective internal and external exposure control programs with all exposures less than
CFR Part 20 limits.
The ALARA program continued to be effective in controlling overall collective dose.
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One non-cited violation (NCV) was identified by the inspector as a result of licensee employees failure to properly label radioactive containers appropriately as required by licensee procedure and Technical Specification (TS) 6. 11. 1 as described in Paragraph REPORT DETAILS Persons Contacted Licensee Employees
- T. Abbatiello, Manager, Site guality J.
Bates, Support Supervisor
- Health Physics S. Blitchington, Supervisor, Operations R. Brown, ALARA Supervisor
- Health Physics
- J. Danek, Corporate, Health Physics H. Eades, guality Assurance Specialist A. Horvath, Procedures/Training Coordinator
,"D. Jernigan, Manager, Operations
- J. Lindsay, Supervisor, Health Physics
- C. Howrey, Licensing Engineer
- L. Pearce, Plant General Manager
- T. Plunkett, Vice President
- E. Weinkam, Nanager, Licensing J. Williams, Dosimetry and Records Supervisor Other licensee employees contacted included engineers, technicians, operators, and office personnel.
Nuclear Regulatory Commission
- B. Desai, Resident Inspector
- T. Johnson, Senior Resident Inspector L. Trocine, Resident Inspector
- Attended April 15, 1994 Exit Meeting Organization and Management Controls (83750)
'he inspector reviewed the licensee's organization, staffing levels, and lines of authority as they related to the Radiation Protection (RP)
Department to verify that the licensee had not made organizational changes which would adversely affect the ability to control radiation exposures or radioactive material.
There had been no structural changes in the RP Department since the previous inspection conducted November 29 - December 3, 1993, and documented in Inspection Report (IR) No. 50-250, 251/93-28.
The RP staff employs approximately 40 Radiation Protection Hen (RPHs).
The RPHs observed performing work and interviewed by the inspector appeared knowledgeable and well trained.
At the time of inspection, the licensee was approximately eight days into a planned 46 day cycle 14 refueling outage on Unit 3.
The inspector discussed with licensee representatives the planned staffing for the ongoing Refueling Outage.
Licensee representatives stated that approximately
HP senior temporary contractor technicians, and
16 junior temporary contractor technicians were employed to supplement the plant organization during the outage along with 32 decon contractor technicians and eight administrative contractor technicians.
Approximately 16 Turkey Point employees were trained to assist RP in specific tasks during the outage; such as, issuing equipment and surveying laundry.
This level of additional technician support was lower than the previous outage.
Licensee management informed the inspector that personnel staffing levels would be closely monitored to ensure staffing of RP personnel was adequate for any additional increase in work scope which may occur.
Based on discussions with licensee representatives and observation of activities in progress, the RP staffing levels appeared adequate to support on-going and planned outage activities.
No violations or deviations were identified.
Training and gualifications (83750)
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 to minimize exposure; in the applicable provisions of the Commission regulations; in the individual's responsibilities; and in the availability of radiation exposure data.
The inspector discussed with cognizant licensee management, training requirements for contractor health physics personnel and observed contractors performing radiation and contamination surveys during work evolutions.
The inspector interviewed RP personnel, managers, and plant workers to determine the effectiveness of 10 CFR Part 20 training.
The revised
CFR Part 20 training was a part of a continuing training program to prepare RP personnel for procedural changes which were implemented January 1,
1994.
Based on observations and discussions with plant personnel, training in these areas appeared adequate to support ongoing work.
No violations or deviations were identified.
Audits and Appraisals (83750)
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guality Assurance (gA) 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 month The inspector discussed the guality Assurance (gA) audit process with gA auditors and gA management personnel.
Turkey Point has previously performed an annual audit in the functional area of RP.
gA management personnel informed the inspector that performance monitoring audits will be performed on a monthly basis in functional areas of RP which will equal or exceed the requirements for performing an annual audit.
The inspector discussed the monthly performance monitoring audit process with the lead auditor permanently assigned to audit RP.
Cognizant licensee representatives stated that scheduling of monthly audits to coincide with work activities provided a better opportunity to identify program weaknesses throughout the year in lieu of the once a year audit, while continuing to equal or exceed the 12 month scope.
The licensee also informed the inspector that a
major RP audit such as the audit previously conducted annually would be conducted every two years in addition to the monthly performance monitoring audits.
The inspector discussed the conduct of recent monthly audits performed in the area of RP with the gA auditor and the RP Manager (RPM).
The inspector also reviewed four Monthly Performance Monitoring Audits in the area of RP conducted during 1994.
These audits fulfilled the TS required frequency for such audits.
The Monthly performance monitoring Audits reviewed by the inspector included The following:
Surveillance of New 10 CFR Part 20 Implementation Surveillance of Transport of Irradiated Material Work Under Radiation Work Permits Radiation Work Permit Usage in the Radiological Controlled Area The gA audits identified the weaknesses to be personnel issues that require management attention and interdepartmental cooperation.'he gA audit addressed the current actions currently being developed and implemented with the RP Supervisor.
Based on a review of the licensee audits the inspector determined that the audits were detailed and were sufficient in scope to include the major radiation protection functional areas.
Non-compliances as well as areas for improvement (i.e.,
"comments" in the audit reports)
were documented, reported to licensee management, and tracked for completion of corrective actions.
Radiological Incident Reporting System The inspector reviewed the licensee's RP internal program for identifying and correcting deficiencies and weaknesses related to radiation exposure and the control of radioactive material.
The
program consisted of the Radiation Deficiency Report (RDR).
The inspector reviewed the selected RDRs written in 1993 and RDRs written in 1994.
The inspector determined the RDRs were well documented and corrective action was assigned.
No violations or deviations were identified.
External Exposure Controls (83750)
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Whole Body Exposure
CFR 20. 1201 (a) requires each licensee to control the occupational dose to individual adults, except for planned special exposures under 20. 1206, to the following dose limits:
(1)
An annual limit, which is the more limiting of:
(i)
The total effective dose equivalent being equal to 5 rems; or (ii)
The sum of the deep-dose equivalent and the committed dose equivalent to any individual organ or tissue other than the lens of the eye being equal to 50 rems; (2)
The annual limits to the lens of the eye, to the skin, and to the extremities, which are:
(i)
An eye dose equivalent of 15 rems; and (ii)
A shallow-dose equivalent of 50 rems to the skin or to any extremity.
TS 6. 11. 1 requires procedures for personnel radiation protection to be prepared consistent with the requirements of 10 CFR Part
and be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
The inspector discussed the cumulative whole body exposures for plant and contractor employees.
Licensee representatives stated and the inspector confirmed that all whole body exposures assigned since the previous NRC inspection of this area were within 10 CFR Part 20 limits.
A discussion with licensee representatives and a
review of pertinent records determined the licensee had established a site exposure goal of 375 person-rem for 1993 based on an estimated 212 person-rem for the tentative work schedule of Unit 4 Refueling Outage.
The licensee's exposure for 1993 as of December 31, was approximately 274 person-rem based on TLD readings, which included the Unit 4 outage exposure and operational exposure for Units 3 and 4.
The licensee's estimated exposure goal for 1994 was approximately 475 person-rem including outages on both Units 3 and 4.
The licensee's estimated goal for the Unit 3 was 230 person-rem.
As of day 8 of the 46 day Unit 3 outage the licensee's dose was approximately 42.7 person-re During a tour of the Unit 3 Containment Building, the inspector observed workers standing by in low dose waiting areas and observed interaction between RP technicians and workers during the performance of ultrasonic testing of the reactor head to minimize external exposure.
The.inspector also observed external exposure controls being implemented by the RP technician during steam generator maintenance.
Personnel Dosimetry
CFR 20.1501(c) (1)
and (2) requires that dosimeters used to comply with 10 CFR 20. 1201 shall be processed and evaluated by a processor accredited by the national Voluntary Laboratory Accreditation Program (NVLAP) for the types of radiation being monitored.
CFR 20. 1502(a) requires each licensee to monitor occupational exposure to radiation and supply and require the use of individual monitoring devices by:
(1)
Adults likely to receive, in one year from sources external to the body, a dose in excess of 10 percent of the limits in
CFR 20.1201(a);
(2)
Minors and declared pregnant women likely to receive, in one year for sources external to the body, a dose in excess of 10 percent of any of the applicable limits of 10 CFR 20.1207 or 10 CFR 20. 1208; and (3)
Individuals entering a high or very high radiation area.
The licensee continued to implement both DRDs and self-reading pocket dosimeters (SRPDs);
however, the former were being used as the primary devices for RCA entries.
Licensee representatives stated that the DRDs system had not yet been integrated into the computerized dose tracking system; however, efforts in this area were continuing as previously discussed in IR 93-28.
During tours of the plant, the inspector observed personnel wearing appropriate monitoring devices on the location of the body as specified by the RWPs.
The inspector reviewed and discussed the licensee's dosimetry program with site personnel and determined licensee dosimetry was being processed under NVLAP certification.
Based on observations, records reviews, and interviews with plant workers the inspector concluded the licensee was effectively controlling external exposure.
No violations or deviations were identifie Respiratory Protection
CFR 20. 1703(a)(3) perpits the licensee to maintain and to implement a respiratory protection program that includes, at a
minimum:
air sampling sufficient to identify the hazard; surveys and bioassay to evaluate the actual intakes; testing of respirators immediately prior to each use; written procedures regarding selection, fitting, issuance, maintenance and testing of respirators; written procedures regarding supervision and training of personnel and monitoring, including air sampling and bioassays; record keeping; and determination by a physician prior to the use of respirators, that the individual user is physically able to use respiratory protective equipment.
The inspector reviewed records for selected employees who had recently worn respiratory protection equipment.
The inspector verified that for the records reviewed, each worker had successfully completed respiratory protection training, was medically qualified, and was fit-tested for the specific respirator type used in accordance with licensee procedural requirements.
The inspector reviewed the respirator log sheets indicating the number and types of respirators used during 1993 which included approximately 2100 full face respirators.
Licensee records reviewed by the inspector determined the licensee was continuing to track actual numbers of respirators worn by workers as related to RWPs to better establish job history to improve their overall process for respirator reduction.
The inspector discussed with the licensee over respirator reduction efforts for the ongoing Unit 3 outage with respect to engineering controls methods to be used by the licensee for future respirator reductions to enhance ALARA concepts such as, worker training, successful decontamination efforts, and various engineering controls to include worksite ventilation and face shields.
Breathing Air guality
CFR 11.121 requires that compressed, gaseous breathing air meet the applicable minimum grade requirements for Type 1 gaseous air set forth in the Compressed Gas Association (CGA) Commodity Specification for Air, G-7. 1 (Grade D or higher quality).
The inspector reviewed and discussed with the licensee representatives the program for testing and qualifying breathing air as Grade D.
The inspector inspected the in-use breathing air system which included a plant in-line system using two permanently installed compressors labeled as A and B compressors.
The inspector examined breathing air manifolds for physical integrity, current calibration of gauges, and the presence of carbon monoxide
monitoring equipment.
In addition, the inspector further noted that the supplied air hoods and hoses available for use were compatible per manufacturer's instructions as were air supplied respirators and hoses.
Review of breathing air testing records verified that the licensee was calibrating in-line carbon monoxide monitors and sampling in-use breathing air systems for certification in accordance with procedural requirements.
For the tests reviewed, breathing air met Grade D requirements.
No violations or deviations were identified.
c.
Whole Body Counting and Exposure Tracking
CFR 20. 1204(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.
The inspector was informed by licensee representatives that no positive internal contaminations had been identified to date in 1994.
Based on the above, the inspector concluded that the licensee was effectively controlling internal contaminations.
No violations or deviations were identified.
7.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83250)
CFR 20.1902 specifies the posting and control requirements for radiation areas, high radiation areas, very high radiation areas, airborne radioactivity areas, and radioactive material areas.
CFR 20. 1904(a) requires the licensee to ensure that each container of
'licensed material bears a durable, clearly visible label bearing the radiation symbol and the words "Caution, Radioactive Material," or
" "Oanger, Radioactive Material."
The label must also provide sufficient information (such as radionuclides present, and the estimate of the quantity of radioactivity, radiation levels, kinds of materials, and mass enrichment) to permit individuals handling or using the containers, to take precautions to avoid or minimize exposures.
CFR 20. 1501(a) 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 radioactive hazards that may be presen TS 6. 11. 1 requires procedures for personnel radiation protection to be prepared consistent with the requirements of 10 CFR Part 20 and be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
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b.
Routine Surveys, Posting, and Labeling The inspector independently verified radiation and/or contamination levels during tours of the Dry Storage Warehouse, RadWaste Building, Auxiliary Building, and outside radioactive material storage areas and no concerns for area surveys or postings were noted.
The inspector noted by independent radiation surveys that three containers of radioactive material, stored in the Dry Waste Storage Building, had been labeled with incorrect dose rate information which indicated which indicated the hazards of the material to be lower than they actually were.
The inspector reviewed licensee procedure O-ADH-605, Control of Radioactive Tools, Equipment, and Components, dated September 9,
1993, which required the maximum radiation levels on the item to be on the label.
The licensee initiated immediate corrective actions to re-survey and label the items identified.
The items included a storage drum containing radioactive material labeled less than
millirem per hour (mRem/hr) which re-survey by RP indicated approximately 5 mRem/hr, a storage box labeled 8 mRem/hr in which RP re-survey indicated 30 mRem/hr with a small spot on the bottom of the container approximately 200 mRem/hr, and a bag of radioactive material labeled 40 mRem/hr in which RP re-survey indicated 120 mRem/hr.
The inspector discussed the survey results with licensee management.
The inspector informed licensee management that failure to properly label radioactive containers was a violation (50-250, 251/93-09-01) of TS 6. 11.1 and licensee procedure O-ADN-605.
Prior to the end of the onsite inspection, the licensee had properly surveyed and labeled the items identified, briefed workers on the findings, and conducted additional surveys to radiation levels of additional containers of radioactive material.
The inspector informed licensee representatives that based on their actions, the criteria specified in Section VII.B of the Enforcement Policy were met and therefore the violation was not being cited (NCV 50-250, 251/94-09-01).
During tours of the facility, the inspector noted that areas inspected were appropriately posted.
The inspector also reviewed selected records of radiation and contamination surveys and concluded the licensee was effectively maintaining survey records.
High Radiation Areas TS 6. 12. 1 required, in part, that each High Radiation Area (HRA)
with radiation levels greater than or equal to 100 mrem/hr but less than or equal to 1000 mrem/hr be barricaded and conspicuously
posted as a
HRA.
In addition, any individual or group of individuals permitted to enter such areas are to be provided with or accompanied by a radiation monitoring device which continuously indicates the radiation dose rate in the area or a radiation monitoring device which.continuously integrates the dose rate in the area, or an individual qualified in radiation protection procedures with a radiation dose rate monitoring device.
During plant tours, the inspector noted that high radiation areas (HRAs) were locked as required and other entry controls were in place as necessary.
In addition, HRA keys were adequately controlled by RP and no major problems were noted.
c.
Area and Personnel Contamination The licensee maintained approximately 117,746 square feet (ft') of floor space as a Radiologically Controlled Area (RCA).
The licensee maintained approximately 4300 ft's contaminated or 4 percent of the RCA.
As of April 14, 1994, the licensee was tracking approximately 6084 ft'ffloor space as contaminated which equated to approximately 5 percent of the RCA.
The inspector reviewed Personnel Contamination Event (PCE) reports prepared by the licensee to track, trend, determine root cause, and any necessary followup action.
The licensee incurred 131 skin or clothing contaminations in 1993 as of December 31, 1993, and had incurred approximately
PCEs as of April 14, 1994.
d.
Radiation Detection and Survey Instrumentation During facility tours, the inspector noted that survey instrumentation and continuous air monitors in use within the RCA were operable and displayed current calibration stickers.
The inspector toured the instrument calibration room and observed instruments staged for issue.
The inspector further noted an adequate number of survey instruments were available for use.
One NRC-identified NCV for failure to properly label radioactive containers appropriately as required by licensee procedure and no deviations were identified.
Program for As Low As Reasonably Achievable (ALARA) (83750)
CFR 20.1101(b)
requires that the licensee shall use, to the extent practicable, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members of the public that are As Low As Reasonably Achievable (ALARA).
The inspector interviewed the ALARA Supervisor, the HP Supervisor and other licensee representatives to discuss ALARA program implementation and ALARA initiatives to reduce dose such as, establishing a program to use insulation blankets which will reduce installation time by a factor of two.
The blankets are also. reusable, which will reduce radioactive waste.
A pilot program has been established to assign person-rem managers for individual departments to enhance ALARA performance.
The licensee has assigned a system engineer to implement a program for using ultra fine filters on primary systems to reduce source term radioactivity.
The licensee is ordering and installing low to no stellite replacement parts/equipment such as the installation of non-stellite valve parts being installed during Unit 3 outage on the component cooling system valves.
A Health Physics/Chemistry team has been established to improve plant chemistry during startups, operations, and shutdowns to reduce cobalt 60 in primary systems.
Since the last inspection in December 1993, the licensee flushed the Unit 3 RHR system piping to reduce dose rates to operators performing routine work evolutions in the auxiliary building.
The flushes reduced dose rates on the Unit 3 RHR system by approximately 26 percent to 40 percent.
An ALARA task team has also been established to reduce dose to RP technicians.
Based on the above, the inspector informed the licensee representatives that the ALARA program continued to be effective in controlling exposures.
Overall, collective dose expended was consistent with the work performed.
No violations or deviations were identified.
Operational and Administrative Controls (83750)
Radiation Work Permits (RWPs)
The inspector reviewed selected routine and special RWPs for adequacy of the radiation protection requirements based on work scope, location, and conditions.
For the RWPs reviewed, the inspector noted that appropriate protective clothing, respiratory protection, and dosimetry were required.
During tours of the plant, the inspector observed the adherence of plant workers to the RWP requirements and discussed the RWP requirements with selected plant workers.
The inspector observed several pre-job briefings conducted by RP
. personnel which adequately addressed the RWP requirements.
At the time of the inspection, an RPN stopped workers from performing work based on the workers protective clothing (PCs) not being adequate for the work scope where the potential for changing radiological conditions existed.
A licensee Condition Report was written by the licensee to address the issue of adherence to
radiological control requirements.
As a result of the Condition Report, correspondence from plant management was promptly issued to ensure all workers were reminded of the requirements of licensee procedure 0-ADM-600 to obey radiological control requirements.
The inspector reviewed Radiological Status Boards used to enhance RWP survey information.
The status boards contained current survey information and were color coded to emphasize particular radiological areas such as HRAs and locked HRAs.
The inspector found the licensee's program for RWP implementation to adequately address radiological protection concerns, and to provide for proper control measures.
b.
Notices to Workers
CFR 19.11(a)
and (b) require, in part, that the licensee post current copies of 10 CFR Part 19, Part 20, the license, license conditions, documents incorporated into the license, license amendments and operating procedures, or that a licensee post a
notice describing these documents and where they be examined.
CFR 19. 11(d) requires that a licensee post form NRC-3, Notice to Employees.
Sufficient copies of the required forms are to be posted to permit licensee workers to observe them on the way to or from licensee activity locations.
During the inspection, the inspector verified that NRC Form-3 was posted properly at plant locations permitting adequate worker access.
In addition, notices were posted referencing the location where the license, procedures, and supporting documents could be reviewed.
The inspector interviewed selected licensee and contractor personnel and verified personnel were familiar with the requirements of 10 CFR 19. 11(d).
No violations or deviations were identified.
10.
Exit Interview (83750, 92701)
At the conclusion of the inspection on December 3, 1993, an exit meeting
. was held with those licensee representatives indicated in Paragraph l.
The inspector summarized the scope and findings of the inspection and informed the licensee that all findings were preliminary and subject to NRC management review and approval.
The inspector informed the licensee of the NRC identified NCV for labeling items with improper dose rates as discussed in Paragraph 7.a.
The licensee did not indicate any of the
information provided to the inspectors during the inspection as proprietary in nature and no dissenting comments were received from the licensee.
Item Number Status Descri tion and Reference 50-250, 251/94-09-01 Closed NCV - Failure by licensee to properly label radioactive containers (Paragraph 7.a).
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