IR 05000250/1995012
| ML17353A261 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/10/1995 |
| From: | Forbes D, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17353A260 | List: |
| References | |
| 50-250-95-12, 50-251-95-12, NUDOCS 9507200199 | |
| Download: ML17353A261 (13) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 303234199
+)t*++
July 12, 1995 Report Nos.:
50-250/95-12 and 50-251/95-12 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.:
50-250 and 50-251 Facility Name:
Turkey Point Units 3 and
License Nos.:
DPR-31 and DPR-41 Inspection Conducted:
June 26 - June 30, 1995 Inspector:
D.
B. Forbes D te Signed 7 /g
)5 Approved b
.
W. H. Rankin, Chief ate igned Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This announced inspection of the implementation of the new 10 CFR Part
requirements was evaluated utilizing Temporary Instruction (TI) 2515/123,
"Implementation of the Revised
CFR Part 20."
The review focused primarily
'n the areas of:
high and very high radiation are'as; Total Effective Dose Equivalent (TEDE)/ALARA program implementation; planned special exposures; and dose to the embryo/fetus for declared pregnant women.
Results:
Revisions to the Radiation Protection (RP) program incorporating revised requirements of 10 CFR Part 20 were made effective January 1,
1994.
The revised requirements, as focused by the inspection procedures, were appropriately incorporated into the RP program.
With respect to the revised
CFR Part 20 focus areas reviewed, appropriate incorporation of the requirements into procedures and training programs was noted.
9507200199 950712 PDR ADOCK 05000250
REPORT DETAILS Persons Contacted Licensee Employees J.
Bates, Support Supervisor
- Health Physics
- S. Blitchington, Supervisor, Operations
~
R.
Brown, ALARA Supervisor
- Health Physics J.
Danek, Corporate, Health Physics M. Eades, guality Assurance Specialist
- R. Earl, guality Control Supervisor
- D. Jernigan, Plant General Manager
- M. Jimenez, Health Physics Specialist, Corporate
- J. Knorr, Engineer, Licensing M. Petrowski, Specialist, Training M. Richey, Shift-Supervisor, Operations
- R. Rose, Manager,. Materials
- A. Singer, Supervisor, Operations
- E. Weinkam, Manager, 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
- Attended June 30, 1995 Exit Meeting 2.
Implementation of Revised
CFR Part 20 Requirements in Training Programs (TI 2515/123)
Training was reviewed to determine whether Radiation Protection Technicians and radiation workers were receiving appropriate instructions concerning the revised
CFR Part 20 requirements for their work assignments.
CFR 19. 12 requires, in part, that the licensee instruct all individuals working in or frequenting any portions 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 purpose and function of protection devices employed; in the applicable 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 for General Employee Training (GET) which was provided to employees needing unescorted access to only the protected area.
For workers needing unescorted access to the Radiologically Controlled Area (RCA), Radiation Controlled Area
Training (RCAT) was required, in addition to GET and Fitness For Duty Program Training.
The inspector reviewed various aspects of the licensee's training program with respect to incorporation of information related to implementation of the revised
CFR Part 20.
Through discussions with licensee representatives and a review of selected lesson plans for GET, RCAT, and Radiation Protection Technician (RPT)
Training, the inspector noted that the licensee began implementation of revised
CFR Part 20 requirements January 1,
1994, and had initiated training prior to this date during 1993.
Based on those reviews of lessons plans and discussions with licensee training representatives, the inspector noted that topics included licensee policy and procedural changes with the implementation of revised
CFR Part 20, planned special exposure, declared pregnant women, respiratory protection devices requirements, revised
CFR Part 20 terminology, annual limits for exposure, ALARA objectives,.posting requirements, and control of high radiation, areas and very high radiation areas.
The inspector also noted that high radiation area (HRA) and very high radiation area (VHRA)
training for RPTs was included in the RPT initial and continuing training program.
Plant RPTs are trained to recognize specific areas that have a potential for becoming a transient HRA or VHRA.
Through interviews and a review of specific Emergency Operating Procedures (EOPs),
the inspector determined plant operators are trained on plant operating procedures to notify the Operations Health Physics department when specific evolutions are conducted that could create unknown HRAs are VHRAs.
The inspector informed licensee representatives that their training program for both general employees and licensee RPTs appeared to adequately address the facility's procedural changes associated with the revised
CFR Part 20 requirements and no concerns were noted with the training material.
Furthermore, from review of the training procedures and course outlines, the inspector determined that the radiation protection training program met the provisions of 10 CFR 19.12.
No violations or deviations were identified in this area.
High Radiation Areas (HRAs) (TI 2515/123)
This area was reviewed to evaluate the licensee's implementation of requirements specified for the control of high and very high radiation areas (HRAs and VHRAs) as prescribed in 20.1601 and 20.1602 of 10 CFR Part 20,
"Subpart G-Control of Exposure from External Sources in Restricted Areas."
CFR 20.1601(a)
requires that the licensee ensure that each entrance or access point to a HRA has one or more of the following features:
(a)
A control device that, upon entry into the area, causes the level of, radiation to be reduced below that level at which an individual might receive a deep dose equivalent of 0. 1 rem in one hour at 30 centimeters from the radiation source or from any surface that the radiation penetrates; or
(b)
A control device that energizes a conspicuous visible or audible alarm signal so that the individual entering the high radiation area and the supervisor of the activity are made aware of the entry; or (c)
Entryways that are locked, except during periods when access to the areas is required, with positive control over each individual entry.
CFR 20.1601(c)
states that a licensee may apply to the commission for approval of alternative methods for controlling access to HRAs.
The licensee's alternative measures for entry into HRAs were described in the licensee's Technical Specifications (TS) 6.12 which required, in part, that each HRA with radiation levels greater than or equal to 100 mrem/hr but less than 1000 mrem/hr be barricaded and conspicuously posted as a HRA.
In addition, any individual or group of individuals permitted to enter such areas were to be provided with or accompanied by a radiation monitoring device which continuously indicated -the radiation dose rate in the area or a radiation monitoring device which continuously integrated the dose rate in the area, or an individual qualified in radiation protection procedures with a radiation dose rate monitoring'evice.
CFR 20.1602 requires that in addition to requirements in
CFR 20.1601, the licensee institute additional measures to ensure that an individual is not able to gain unauthorized or inadvertent access to areas in which radiation levels could be encountered at 500 rads or more in one hour at one meter from a radiation source or any surface through which the radiation penetrates.
CFR 20. 1902 specifies the posting requirements for HRAs and VHRAs.
During tours of the Auxiliary Building, Waste Processing Building, and other access entrances to locked HRAs and VHRAs, the inspector observed and independently verified that required HRAs and VHRAs were locked and/or posted as required.
The inspector discussed HRA and VHRA key controls with cognizant licensee representatives, reviewed records and key control methods, and reviewed licensee Radiological Control Instruction O-HPA-021, "Health Physics Restricted Area Key Control",
dated April 21, 1995.
Licensee instruction 0-HPA-21 required the High Radiation area keys shall be signed out by and maintained under the control of=that individual to which the keys are issued.
The inspector inventoried the licensee's HRA and Very HRA key control boxes maintained by Operations and determined that at the time of the inspection, all keys to Locked HRAs and Very HRAs were accounted for.
Licensee procedures required that VHRA keys be maintained under the control of the RP supervisor and that HRA keys be maintained under the control of the RP shift-supervisor.
The keys could only be issued by the supervisor to an RPT and had to be signed back into the lock box for storage by an RP supervisor or RP shift-supervisor.
Typically only the Reactor Buildings were posted and controlled as VHRA The inspector noted that on May 23, 1995, the licensee determined a lock on a locked HRA in the Radwaste Building failed during a routine inspection of the door.
Further review of the event by the inspector determined the licensee initiated immediate corrective action to properly secure the unlocked door and documented the event in licensee condition report 95-445.
The licensee's temporary corrective action was to secure all locked HRAs and VHRAs with chains and padlocks which were routinely inspected by RPTs.
The inspector also reviewed various Radiation Work Permits (RWPs)
and determined the RWPs adequately addressed radiological controls for entering Locked HRAs and Very HRAs.
Dosimetry required on RWPs was the same dosimetry personnel were being trained to use during GET practicals. 'dditional procedures reviewed by the inspector relating to control of HRAs and VHRAs included the following:
O-ADM-600, Radiation Protection Manual, dated December 6,
1994 0-HPS-025. 1, General Posting Requirements for Radiological Hazards, dated March 30, 1994 O-HPA-001, Radiation Work Permit Initiation and Termination, dated December 2,
1994 0-HPS-031. 1, Whole Body Dosimetry Issue, dated December 6,
1994 O-ADM-604, Radiological Protection Guidelines and Practices, dated February 24, 1995 O-HPA-071, ALARA Job Reviews, dated July 7, 1994 O-ADM-009, Containment Entries When Containment Integrity is Established, dated March 24, 1994 O-HPS-020, Radiation Surveys, dated August 9, 1994 Based on a review of training, procedures, facility tours, and interviews, the inspector determined the licensee had programmatic HRA and VHRA controls which implemented the requirements of the revised
CFR Part 20.
No violations or deviations were identified in this area.
4.
Internal Exposure Control (TI 2515/123)
This area was reviewed to determine the adequacy of the licensee's use of process and engineering controls to limit exposures to airborne radioactivity, adequacy of respiratory protection program, licensee's administrative controls for assessing the TEDE in radiation and airborne radioactive materials areas, assessments of individual intakes of radioactive material and records of internal exposure measurements and assessment CFR 20.1101(b)
requires that the licensee 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.
CFR 20. 1502(b) requires each licensee to monitor the occupational intake of radioactive material by and assess the committed effective dose equivalent to:
(1)
Adults likely to receive, in one year, an intake in excess of 10 percent of the applicable ALI in Table 1,
Columns 1 and 2 of Appendix 8 to
CFR 20.1001-20.2401; and (2)
Minors and declared pregnant women likely to receive, in one year, a committed effective dose equivalent in excess of 0.05 rem.
CFR 20.1204(a)
states that for the purposes of assessing dose used to determine compliance with occupational dose equivalent limits, each licensee shall, when required under
CFR 20.1502, take suitable and timely measurements of:
(1)
Concentrations of radioactive materials in air in work areas; or (2)
guantities of radionuclides in the body; or (3)
guantities of radionuclides excreted from the body; or (4)
Combinations of these measurements.
a.
Use of Process or Engineering Controls b.
The use of process and engineering controls to limit airborne radioactivity concentrations in the plant were discussed with licensee representatives and the use of such controls were observed during tours of the plant.
These controls included decontamination of areas, covering contaminated areas, use of worksite ventilation, and other methods used in minimizing worker time in contaminated/airborne areas.
R Respiratory Protection (RP)
Requirements for TEDE/ALARA reviews were addressed in Student Handout, As Low As Reasonably Achievable (ALARA), dated November 25, 1994 and in licensee procedure O=ADM-600, Radiation Protection Manual, dated December 6,
1994.
The procedure required ALARA evaluations to be performed by RP prior to performing work in airborne radioactivity areas to demonstrate that respiratory protection provisions are consistent with the goal of maintaining individual and collective total effective dose equivalent ALARA.
The licensee was tracking and trending respirator usage for each RWP to determine effectiveness of the respirator protection program.
Approximately 70 percent of the respirators used were for steam generator maintenance activities and 18 percent were used during work activities on the flux mapper system.
The other
20 percent were used on various tasks.
The inspector reviewed licensee reports that indicated significant reductions in the use of respirators during recent RFOs.
for example, the numbers of full face respirators issued during the last two outages:
Unit 3 outage in 1994:
Issued 140, Used 119 Unit 4 outage in 1994:
Issued 42, Used
Based on those reviews and discussions with licensee representatives, the inspector determined that the licensee had made efforts to maintain TEDE exposures ALARA.
Furthermore, the inspector noted that the licensee did not observe an increase in the number of positive intakes of radioactive material for individuals who did not wear respirators for those activities that in the past individuals would have worn them.
c.
Internal Exposure Assessments
CFR 20. 1204 stated that for purposes of assessing dose used to determine compliance with occupational dose equivalent limits, the licensee, when required to monitor internal exposure, shall take.
suitable and timely measurements of concentrations of radioactive materials in air, quantities of radionuclides in the body, quantities of radionuclides excreted from the body, or combinations of these measurements.
When specific information on the behavior of the material in an individual is known, that information may be used to calculate the CEDE.
The inspector reviewed and discussed the licensee's program for monitoring internal dose and reviewed the results of assessments for personnel having indications of positive intakes of radioactive material.
No problems were found during a review of the procedure or of selected bioassay records.
The inspector concluded that the licensee's program for monitoring, assessing, and controlling internal exposures was conducted in accordance with regulatory and licensee procedural requirements with no exposures in excess of 10 CFR Part 20 limits identified.
No violations or deviations were identified in this area.
Planned Special Exposures (PSE)
This area was reviewed to determine whether the licensee's program for PSEs met the regulatory requirements..-
CFR 20.1206 permits the licensee to authorize an adult worker to receive doses in addition to and accounted for separately from the doses received under the limits specified in 10 CFR 20. 1201 provided that certain conditions are satisfied.
Such exposures cannot exceed the dose limits in 10 CFR 20.1201(a)
in any year or five times the annual dose limits during an individual's lifetim Licensee procedure O-HPA-035, Planned Special Exposures, dated September 21, 1993, provided the licensee's requirements for requesting, working, and documenting PSEs.
Through discussions with licensee representatives and a review of records, the inspector determined that the licensee had appropriate procedural guidance for allowing PSEs.
At the time of the inspection, the inspector was informed by the licensee that a
PSE had never occurred at the Turkey Point Nuclear Plant.
I Based on a review of training, procedures, and interviews, the inspector determined the licensee had programmatic controls which implemented the requirements of the revised
CFR Part 20 if the licensee determined it necessary to implement a
PSE.
No violations or deviations were identified in this area.
Dose to the Embryo/Fetus and Exposures of Declared Pregnant Women (DPW)
This program area was reviewed to determine that the licensee's program for DPWs met the regulatory requirements and that the dose to the embryo/fetus were within the regulatory limits.
CFR 20. 1208(a) requires that the dose to the embryo/fetus not exceed 500 mrem during the entire pregnancy due to occupational exposure of a DPW,
CFR 20.2106(e)
requires each licensee to maintain the records of dose to an embryo/fetus with the records of the DPW.
The declaration of pregnancy shall also be kept on file, but may be maintained separately from the dose records.
Section 5.7.1 entitled,
"Dose Limits and Guidelines" of O-ADM-600, entitled,
"Radiation Protection Manual," dated December 6,
1994, and licensee procedure HP-ll.F entitled,
"Turkey Point Prenatal Radiation Protection Summary," dated June 19, 1995, detailed the licensee's program and policies regarding declaration of pregnancy as well as exposure monitoring and dose limits for the declared pregnant woman and embryo/fetus.
The inspector noted that the procedures were consistent with 10 CFR Part 20 requirements and Regulatory Guide 8.13 provisions.
The inspector reviewed the licensee's policy and procedural guidance regarding DPWs, and verified that DPW-related information was discussed and reviewed in GET and
CFR Part 20 training.
Copies of Regulatory Guide 8. 13 were made available during training.
The inspector reviewed licensee form HP 13.5 which was the declaration of pregnancy form made available to employees desiring to declare pregnancy.
Licensee procedures provided instructions to ensure an individual would be allowed the opportunity to declare or undeclare a pregnancy.
The inspector learned from discussions with licensee representatives that three workers had declared to be pregnant in 1994 and 1995.
The inspector reviewed the declaration forms for the declared pregnant women and independently verified that no administrative or regulatory limits were exceeded with regards to any of the three pregnancies.
The
licensee provided the declared pregnant women an opportunity not to continue access into the Radiation Controlled Area (RCA) and all three women elected to not re-enter the RCA, thereby, terminating the use of a TLD for the remainder of the pregnancy period due to the fact the women and their embryo/fetus were not exposed to occupational radiation.
No concerns were noted with the licensee's declared pregnant women policy or procedures which incorporated the requirements of 10 CFR 20.2106.
No violations or deviations were identified in this area.
Exit Interview (2515/123)
At the conclusion of the inspection on June 30, 1995, an exit meeting was held with those licensee representatives indicated in Paragraph l.
The inspector summarized the scope and findings of the inspection.
The licensee did not indicate any of the information provided to the inspector during the inspection as proprietary in nature and no dissenting comments were received from the licensee.