IR 05000261/1979005
| ML14175B040 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/23/1979 |
| From: | Gibson A, Jenkins G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B036 | List: |
| References | |
| 50-261-79-05, 50-261-79-5, NUDOCS 7905230623 | |
| Download: ML14175B040 (7) | |
Text
REG(,
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30303 Report No. 50-261/79-5 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, North Carolina 27602 Facility Name:
H. B. Robinson 2 Docket No. 50-261/79-5 License No. DPR-23 Inspection at H. 4. Rob nson Site and Harris Energy and Environmental Center Inspector:
31-2 6. s I Date Signed Approved by:
31Z3 A. F. Gibson, Section Chief, FF&MS Branch Date Signed SUMMARY Inspection on February 26 - March 2, 1979 Areas Inspected This routine unannounced inspection involved 26 inspector-hours onsite in the areas of RC&T qualifications, radiation protection training, health physics related licensee audits, instruments and equipment, radiological controls, posting, and labeling, personnel dosimetry, followup on previously identified ite Results Of the seven areas inspected, no apparent items of noncompliance or devia tions were identified in six areas; one apparent item of noncompliance was found in one area (Infraction - RC&T technicians used in responsible position without sufficient experience) (79-05-01).
No apparent deviations were foun DETAILS Persons Contacted Licensee Employees R. B. Starkey, Plant Manager
- D. S. Crocker, E&RC Supervisor
- J. M. Curley, Engineering Supervisor
- W. Garrison, QA Supervisor D. R. Gainey, Jr., RC&T Foreman B. H. Webster, Director - Environmental and Radiation Control (Corporate Office)
H. Lipa, E&RC Laboratory Supervisor (Harris Center)
M. L. Layton, Senior Specialist, HP/Chemistry Training (Harris Center)
Other licensee or contractor employees contacted included one construc tion craftsman, and three technician *Attended exit intervie.
Exit Interview The inspection scope and findings were summarized on February 28, 1979 with those persons indicated in Paragraph 1 abov Licensee management acknowledged the inspector's comments regarding the use of RC&T techni cians in a responsible position without the minimum required two years experience. Licensee management stated that investigation of possible entry into containment without a proper RWP was continuin These items were also discussed with the Plant Manager by telephone on March 6, 197.
Licensee Action on Previous Inspection Findings (Closed)
Infraction (78-23-01)
Exposure greater than 5(N-18).
An inspector reviewed the procedure for routine audit of personnel dosimetry records at the Harris Energy and Environmental Center, as described in CP&L's report of August 22, 1978, and had no further question (Details, paragraph 13). Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations. New unresolved items identified during this inspection are discussed in paragraph 1.
RC&T Technician Qualifications Technical Specification 6.3.1 requires that members of the facility staff meet or exceed the minimum qualifications of ANSI N18.1 -
1971Property "ANSI code" (as page type) with input value "ANSI N18.1 -</br></br>1971" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. for comparable position Section 4.5.2, ANSI N18.1, states that technicians in responsible positions shall have a minimum of two years of working experience in their specialty. An inspector discussed RC&T technician qualifications with the E&RC Supervisor, and specifically questioned if the technicians assigned to shift coverage met the two year experience requiremen The E&RC Supervisor said that of approximately 17 technicians that have been assigned to shift coverage, about 10 have less than two years health physics experienc He said that all technicians assigned to shift are qualified in radiation protection procedures in accordance with the criteria provided by NRC pertaining to T. S. 6.2.2, but that a minimum experience level is not part of that qualification progra In this discussion and in a telephone conversation with the Plant Manager on March 6, 1979, both stated that the licensee's position had been that the Shift Foreman fulfilled the "responsible position" functions; however, both acknow ledged that Shift Foremen are not qualified in radiation protection procedures per T. S. 6. The inspector stated that the RC&T techni cians on shift appeared to be functioning in a responsible position in that they evaluate radiological hazards, specify controls, approve radiation work permits for RC&T, and, in general, carry out all health physics responsibilities during the shift. The inspector cited the assignment of RC & T technicians with less than two years experience as the health physics representative on shift as noncompliance with Technical Specification 6. (79-05-01). Licensee Audits An inspector reviewed 7 Operations QA Surveillances and 2 QA Audits conducted since June, 1978 which included radiation protection area By discussion with the E&RC Supervisor and review of followup audits, the inspector determined that adequate corrective action had apparently been taken on all radiation protection related findings and areas of concer The inspector had no further question.
Radiological Training An inspector participated in the basic radiation protection training program by observing the videotape and completing the written examina tion. The inspector discussed a new training videotape, which is in preparation, with the E&RC Supervisor and the Senior Specialist, HP/Chemistry Training at the Harris Cente The inspector commented that the following areas should receive more emphasis in the new
program:
-3 maintaining exposures as low as reasonably achievable; tool/equipment contaimination control; items required by 10 CFR 19.1 Licensee representatives achknowledged the inspector's comments and stated that these concerns either already were or would be incorporated into the new videotap The Senior Specialist, HP/Chemistry Training indicated that the new videotape would probably be complete and available for use at the plant by May, 197 The inspector had no further question.
Instruments and Equipment An inspector checked selected friskers, portal monitors, and survey meters for operability and for current calibration sticker No deficiencies were identifie The inspector reviewed selected instrument calibration records to determine if calibrated in accordance with Health Physics Procedure HP-11, "Survey Instrument Calibration", and Health Physics Instruc tion HPI-200,
"Calibration of Radiation Survey and Personnel Monitoring Instruments", and if acceptable results were obtaine No deficiencies were identifie The hand and foot monitor and the two portal monitors are source checked weekly for operabilit Semi-annually the alarm set points for these monitors are checked and adjusted, if necessary, to alarm just above backgroun The inspector expressed concern that the alarm set points are based on the background reading, and that no efficiency factors are known to relate personnel contamination (dpm) to the observed net count rate (cpm).
Licensee representatives stated that efficiency factors for the portal monitors and hand and foot counter would be determined (79-05-02). Radiological Posting, Labeling and Control Through plant tours and observations, an inspector determined that high radiation areas, radiation areas, contaminated areas, airborne radioactivity areas, and radioactive material storage areas appeared to be properly posted and controlled. All radioactive material con tainers observed in the auxiliary building appeared to be properly labeled. Bags of paper clothing were observed in the drumming room without labels. Although these bags apparently contained sufficiently low-level radioactivity to be exempt from labeling requirements, the E&RC Supervisor said that plant policy is to label all such containers; the bags were promptly labele The inspector observed that items required by 10 CFR 19.11 were poste No items of noncompliance were identifie *
-4 1 Contamination Control A major plant modification was in progress involving installation of fire protection systems. The work is performed by contract personnel, and involves penetrating walls, ducts, et at various locations in the plan An inspector specifically reviewed contamination control aspects associated with this wor A contract health physics technician had been assigned specifically to support this work. By observa tions and interviews with a contract health physics technician, a contract worker involved in the modification, and RC&T personnel, the inspector determined that the workers appeared to be adequately trained and instructed and complying with contamination control, protective clothing requirements, tool and equipment removal policies, and other health physics practice No items of noncom pliance were identified in this are When questioned, licensee representatives said that periodic contamination surveys are made of tools in the tool crib located outside the Unit 2 area, but that such surveys are not documente An RC&T Foreman stated that this survey would be added to the monthly survey sheet for documentatio An inspector discussed area contamination surveys of areas outside the Unit 2 restricted area with RC&T personnel, who said that such surveys had been made in the past but recently deleted. The E&RC Supervisor stated that monthly sweep surveys of high traffic areas, including the hard-hat building and the administration building, would be initiate The inspector had no further question. Use of Radiation Work Permits A licensee representative said that some recent work on the fire protection modification had been performed inside containment while operating at powe He said the work was limited to the area outside the crane wall, and the contract workers were accom panied by a health physics technician. An inspector reviewed RWP N,
dated February 22, 1979, for Containment Vessel (CV)
entry to install conduit for fire protectio Two CV entries were made on that date by the same crew, consisting of 2 contract workers and one contract HP technician. After reviewing the RWP, the inspector reviewed the Containment Entry Log for February 22, 1979, and noted a discrepancy between pocket dosimeter readings on the log compared with the RW It appeared that the discrepancy resulted either from improper reading of the dosimeter or faulty communications between the worker and the control room personnel
-5 who take Containment Entry Log data by telephon The inspector noted that this error was not significiant and was conservative, but stated it may be indicative of a broader proble The E&RC Supervisor acknowledged the inspector's concern and stated that he would review the situatio In reviewing the Containment Entry Log for February 22, 1979, the inspector noted that it included 4 operations personnel for that dat The inspector attempted to review the RWP for CV entry by the operations personnel, but none could be located by RC& The RWP issue log was blank beside RWP number 222-13, and no RWP N was in the RWP fil The E&RC Supervisor said that an investigation would be made to determine the status of the RWP in questio The inspector identified the possibility that a CV entry was made without a proper RWP as an unresolved item (79-05-03).
12. Leak From Refueling Water Storage Tank Recirculation System During a previous inspection, an inspector noted a February 2 entry in the Operating Log regarding a leak on the auxiliary building roof while recirculating the refueling water storage tank (RWST) through a demineralizer. An inspector discussed this event in more detail with the E & RC Supervisor during the current inspection. He said the RWST water leaked into a valve chase on the roof, which overflowed to a storm drain which flows to an on-site catch basi After discovery, the drain was thoroughly flushed, grab samples taken from the pond, and the sump pump was started to send the pond overflow to the discharge cana The inspector reviewed sample results from the pon There was no detectable gamma activity based on the Ge-Li analysi A sample analysed on the low-beta counter indicated gross activity of 1.75E-8 microcuries/ml, and a tritium analysis indicated 1.36E-5 microcuries/m Both of the above results are typical of the pond activity based on routine weekly sample It appeared that no signifi cant radioactivity was released to the environment as a result of this lea.
Personnel Dosimetry Activities at Harris Energy and Environmental Center CP&L's "Report of Exposure in Excess of 10 CFR 20.101(b)(2)", dated August 22, 1978, included corrective actions involving changes to the review and audit of computer generated dosimetry record An inspector discussed this program with the Supervisor, Environmental and Radiation Control Laborator He said an audit procedure had been issued, a clerk had been hired for the audit function, and the monthly audits would commence in March, 197 The inspector reviewed Radiation Control Instruction RC-PD-12, "Audit of Personnel Dosimetry Records,"
January 17, 1979, approved by the Director, Environmental and Radiation
-6 Contro The inspector reviewed nine other Radiation Control/Personnel Dosimetry Instructions and discussed the general dosimetry program with the Supervisor, E&RC Laboratory and the Director, E&RC, and had no further questions.