IR 05000261/1981007
| ML14365A361 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/25/1981 |
| From: | Gibson A, Hosey C, Wray J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A652 | List: |
| References | |
| 50-261-81-07, 50-261-81-7, NUDOCS 8109090516 | |
| Download: ML14365A361 (45) | |
Text
RE,UNITED STATES NUCLEAR REGULATORY COMMISS;ON REGION ii 101" MARIETTA ST., N.W., SUITE 3100 ATLANTA. GEORG;A 0303 Report No. 50-261/81-07 Licensee:
Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name:
H. B. Robinson Docket No. 50-261 License No. DPR-23 Inspection at Robinson site near Hartsville, SC Inspectors: _
_
_/__
_
_/
C. M. Hosey Date'Signed
.R.,Wray Date Signed Accompanying Personnel:
L. H. Munson, Battelle Pacific Northwest Laboratories R. D. Neff, Ph.D, Battelle Pacific Northwest Labs R. J. Serbu, Radiological Assessment Branch, NRR Approved by:/
(
A. F. Gibson, Acting Director Date Signed Engineering and Technical Inspection Division SUMMARY Inspection on January 26 - February 6, 1981 Areas Inspected This special announced inspection involved 483 inspector-hours onsit The following areas were included as part of the Health Physics Appraisal:
radiation protection organization and management; personnel selection, qualification and training; external exposure controls; internal exposure controls; routine sur veillance program; ALARA program; radioactive waste management; and, facilities and instrumentatio Results Of the 8 areas inspected, no violations or deviations were identified -in four areas; six violations were found in the remaining areas (failure to provide timely personnel exposure reports -
paragraph 6; failure to perform suitable measurements of airborne radioactivity - paragraph 7; failure to ensure Grade "D" breathing air in respiratory protective equipment - paragraph 7; failure to follow procedures - paragraphs 7 and 8; entering a high radiation area without a dose rate instrument -
paragraph 8; and unauthorized disposal of licensed radioactive material - paragraph 10).
REPORT DETAILS 1. Persons Contacted Licensee Employees
- B. J. Furr, Vice President - Nuclear Operations
- R. B. Starkey, General Plant Manager
- B. H. Webster, Manager - Environmental and Radiation Control, HEEC
- H. S. Zimmerman, Manager - Technical and Administrativ C. W. Crawford, Manager - Operations and Maintenance
- D. S. Crocker, E&RC Supervisor
- C. Scholl, Health Physics - Corporate W. MacCready, E&RC Engineer A. Eaddy, Senior Specialist - Chemistry J. Pettigout, ALARA Specialist D. Gainey, RC&T Foreman W. Ritchie, RC&T Foreman F. Watkins, RC&T Foreman R. Denney, RC&T Foreman Other Organizations G. Leonard - Institute for Resource Management, In NRC Resident Inspector
- S. Weise
- Attended exit interview 2. Exit Interview The inspection scope and findings were summarized on February 6, 1981 with those persons indicated in paragraph 1 above. The Health Physics Appraisal Team reviewed all aspects of the radiation protection program at Robinso This review included the radiation protection organization and management, personnel selection, qualifications and training, exposure controls, ALARA programs, surveillance programs, and facilities and instrumentatio The inspector identified four significant weaknesses of the licensee's program in the following areas:
(1) personnel contamination control; (2) adequacy of surveys to determine radiological conditions in the plant; (3) personnel dosimetry during work in Steam Generators; and (4) safety analysis for the settling ponds and auxiliary boilers. The licensee acknowledged the weak nesses described above and committed to strengthening these area On February 11, 1981, a Confirmation of Action Letter was issued to the
licensee documenting the corrective actions to which the plant had committed. The inspector also identified six apparent violations, which included:
(1) failure to provide personnel exposure reports within the specified time period; (2) failure to perform suitable measurements for the timely detection and assessment of individual intakes of radioactivity; (3)
failure to ensure Grade "D" breathing air in respiratory protective equip ment; (4) failure to follow procedures; (5)
unauthorized disposal of licensed quantities of radioactivity; and (6) entering a high radiation area without a dose rate instrument. The licensee acknowledged the above viola tion. Summary of Violations, Unresolved and Inspector Followup Items The following is a summary tabulation of all violations, unresolved and inspector followup items identified throughout this repor Inspector followup items (IFI)
are matters which will be examined during future inspections. Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncom pliance or deviation IFI (81-07-01)
Corporate HP audits of plant's health physics program (paragraph 4.a)
IFI (81-07-02) Improve records system (paragraph 4.b)
IFI (81-07-03) Protective.clothing removal training (paragraph 5.b)
IFI (81-07-04) Job specific radiation protection training (paragraph 5.b)
IFI (81-07-05) Escort training documentation and evaluations for permanent plant employees (paragraph 5.b)
IFI (81-07-06) RC&T.technician and foreman retraining (paragraph 5.b)
IFI (81-07-07) QA performance program for TLDs (paragraph 6.a)
Violation (81-07-08) Termination exposure reports (paragraph 6.b)
IFI (81-07-09) TLD/PD discrepancy review system (paragraph 6.c)
IFI (81-07-10) Contractor dose analyses and plant management review of dose reports (paragraph 6.c)
IFI (81-07-11) Regulated power supply for WBC (paragraph 7.a)
Violation (81-07-12)
Failure to perform measurements necessary for timely detection and assessment of individual intakes of radioactivity (paragraph 7.a)
IFI (81-07-13)
WBC trend analyses and comparison with survey data (paragraph 7. a)
IFI (81-07-14) Procedural criteria for bioassay program (paragraph 7.a)
IFI (81-07-15) Stay time records on RWPs (paragraph 7.a)
IFI (81-07-16) Calibration of CAM radiation detectors and air flow systems (paragraph 7.a)
Violation (81-07-17) Failure to follow procedures (paragraphs 7.a, 7.b and 8.h)
IFI (81-07-18) Respiratory protection responsibility (paragraph 7.b)
IFI (81-07-19) Respiratory protection training (paragraph 7.b)
Violation (81-07-20) Failure to verify Grade "D" air (paragraph 7.b)
IFI (81-07-21) CO monitor location (paragraph 7.b)
IFI (81-07-22) Management review of personnel contaminations (paragraph 8.a)
IFI (81-07-23) Additional friskers at work sites (paragraph 8.b)
IFI (81-07-24) Job specific surveys (paragraph 8.c)
IFI (81-07-25) Trend analysis of routine surveys (paragraph 8.d)
IFI (81-07-26) Secondary side system surveys (paragraph 8.e)
IFI (81-07-27) Improve RCA equipment exit surveillance (paragraph 8.f)
IFI (81-07-28)
Inventory of beta survey instruments (paragraphs 8.f and 11.b)
Violation (81-07-29)
Entering a high radiation area without a dose rate instrument (paragraph 8.h.)
IFI (81-07-30) Evaluation of ventilation flows (paragraphs 7.b and 10.b(1))
IFI (81-07-31)
Chem lab exhaust hood face velocities (paragraph 10.b(1))
IFI (81-07-32) Weather protection for HVE-15a (paragraph 10.b(2))
IFI (81-07-33) Remote parameter indications for filter systems (paragraph 10.b(2))
IFI (81-07-34)
Isolation of HVE-14 on high activity alarm (paragraph 10.b.(2))
IFI (81-07-35) Secondary side effluent accountability evaluation (paragraph 10.c)
Violation (81-07-36) Unauthorized disposal of licensed radioactive material (paragraph 10.c)
Unresolved (81-07-37) Safety evaluation for settling ponds (paragraph 10.c)
IFI (81-07-38)
Completion of evaluation pursuant to IE Bulletin 80-10 (paragraph 10.c)
IFI (81-07-39) Process monitor calibration (paragraph 10.d)
IFI (81-07-40) Determination of Transport Group I and II isotopes (paragraph 10.f)
IFI (81-07-41) QA inspections of radwaste shipments (paragraph 10.f)
IFI (81-07-42) Upgrade inspection program for laundered protective clothing (paragraph 11.a)
IFI (81-07-43) Protective clothing dose rate limit (paragraph 11.a)
IFI (81-07-44) Dedicated decontamination equipment and area (paragraph 11.a)
IFI (81-07-45) Portable instrumentation calibrations in accordance with ANSI N323 (paragraph 11.b)
IFI (81-07-46) Evaluation of calibration facility (paragraph 11.b)
4. Radiation Protection Organization and Management The Appraisal Team reviewed the plant's radiation protection organiza tion and how it relates to the overall plant organization. The radia tion protection program at the plant is managed by the environmental and radiation control supervisor who reports to the manager, technical and administratio The environmental and radiation control supervisor has direct access to the plant manager regarding radiation protection matters. Although no apparent problem with this reporting chain was identified by the Appraisal Team, the plant general manager informed the team that the licensee was in the process of reorganizing the plant staff, and when completed the position of manager, environmental and
- radiation control (E&RC)
would be established with this individual reporting directly to the plant manage The health physics supervisor will report to the manager, E&R The staff under the environmental and radiation control supervisor is as shown in Figure 1. In addition to the radiation control and test (RC&T)
foreman and the technical staff, the E&RC group has seventeen RC&T technicians permanently assigned to the plant, eleven temporarily assigned from the Shearon Harris Plant and eight assigned to the licensee's traveling maintenance area but home-based at Robinson. The licensee plans to increase the size of the health physics -staff substantially in the near future, with a total of six RC&T foremen and 52 technicians, excluding the technicians assigned to the traveling maintenance crew. At least one ANSI qualified RC&T (Health Physics)
technician and one RC&T trainee are on-duty 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per wee Written position descriptions for the E and RC group have been prepared; however, they have not been approved by the plant manager or other plant officia The position descriptions identify the posi tions, list duties and responsibilities and the reporting chai The Appraisal Team reviewed the organization of the corporate environ mental and radiation control group and discussed the support givento the plant by this grou The licensee has a corporate health physics group which is independent of the corporate E and RC grou The organization and support provided to the plants by the corporate health physicist was reviewed by the team appraising the health physics program at the licensee's Brunswick facility. The corporate E&RC group provides dosimetry services, environmental monitoring and laboratory service, and is assisting the plant in upgrading the processing and disposal of radioactive wast This group also reviews the plants health physics program on an informal basi The scope of responsibilities for the radiation protection program, including specific duties and responsibilities for the E&RC group, are contained in plant administrative and radiation control procedure The inspector discussed the audit program relating to radiation protec tion with licensee representatives and reviewed the following surveil lances of the plant which were performed by the operations quality assurance group (OQA):
OQAS-80-7(R),
Radiation Surveys, air sampling and posting July 14-17, 1980 OQAS-80-6(R), Protection clothing June 11-13, 1980 OQAS-80-5(R), Control of Radioactive Source, RWPs May 19-23, 1980 OQAS-80-2(R),
IF 300 Fuel Cask Program, March 25-26, 1980
The inspector also reviewed the following audits performed by the corporate nuclear safety and quality assurance groups:
QAA/20-17, Indoctrination and qualifications of plant employees January 22-25, 1979 QAA/20-19, Environmental, radiation control, radiological surveil lance and respiratory protection, October 15-19, 197 QAA/20-10, Environmental and radiation control, Radioactive waste transport, January 7-11, 198 QAA/20-22, Environmental and radiation control, October 20-24, 198 At the time of the appraisal the quality assurance staff assigned to the plant did not perform audits or surveillances in the areas of radiation protection or radioactive waste processing and disposa However, subsequent to the appraisal the licensee has reorganized and plant quality assurance personnel will now perform surveillances in these areas. The on-site surveillance and audits performed by the OQA and CNS&QA personnel respectively were procedural in nature and were performed primarily to identify and correct violations of regulatory requirements. Apparently the corporate health physicist does not conduct periodic reviews of the plant's health physics program.. The inspector stated that the corporate health physics and environmental and radiation control staff should perform periodic formal reviews of the plant's radiation protection program (81-07-01).
In June, 1980 an assessment of the plant's radiation protection program was performed by an outside vendor with expertise in radiation protec tion matter The appraisal team members examined the management of records and the documentation system employed in each of their speciality areas inspected. Numerous instances of inadequate record and documentation practices were identifie A review of the individual dosimetry records at Robinson showed a general practice of changes in recorded doses without documentation of the reasons for the change Values were pencilled through and new values recorded with no signature or initial of the person making the change or reference to a justification for the changes. The inspector identified numerous examples where white-out, cross-outs, erasures, and other record modifications were made to liquid and gaseous release
records without explanations or a qualified reviewer's initial Documentation of surveys did not appear to be adequate in that records could not. effectively be used to recreate radiological conditions which exist at a given tim The inspector stated that the ability to recreate past radiological conditions is mandatory to resolve discrep ancies between TLDs and PDs regarding a worker's dose or when a WBC indicates internal exposure (see paragraphs 6.c and 7.a).
The number of documents necessary to determine if surveillance was performed on a particular task appeared to be excessive in that in most instances, 11 or 12 documents must be consulte Inadequate retention of steam generator channel head survey records resulted in a violation of 10 CFR 20.401(b) and 10 CFR 20.401(c)(2) in report 50-261/81-1 While the total number of air samples taken, both routine and special, appeared sufficient (approximately 87 air samples in a typical five day outage period) the adequacy of the coverage of work locations and activities could not be assessed due to insufficient documentation (see paragraph 7.a). The inspector stated that legal expertise should be combined with guidance available from sources such as ANSI N13.6-1966 and USAS N13.2-1962 to improve the records system (81-07-02).
Summary:
Based on the above findings, this portion of the licensee's program appears to be acceptable, but consideration.should be given to formal assessments of the plant's health physics and record/documenta tion program. Personnel Selection, Qual-ification and Training a. Technical Specification 6.3 requires conformance with ANSI N18.1-1971 for qualification of technicians in responsible positions and Regula tory Guide 1.8, September 1975, for qualification of the Environmental and Radiation Control (E&RC)
Supervisor (RPM).
Section 2.0 of the plant Administrative Procedures Manual specifies in more detail the duties of each position and minimum qualification The E&RC Super visor is required to have a bachelor's degree or equivalent plus 5 years of professional experience in applied radiation protection. The B.S. degree equivalent is defined in Technical Specification 6.3.2 as a degree in science or engineering or 4 years of applied experience in addition to the 5 years required after the degre The present E&RC Supervisor appears to fully meet the Reg Guide 1.8 and Technical Specification requirement Section 2.1.16 of the Administrative Procedure Manual states that the Radiation Control and Test (RC&T)
Foremen are first level supervisors over the RC&T technicians and at the time of their assignment they must have five years of experience in radiation protection and chemistry; one year of radiation protection, and one of chemistry must be at a
nuclear reactor facility. Related technical training should be two years with a maximum of four years substituting for the required experience. A review of all RC&T foremen at Robinson indicated that they meet the stated requirements in experience or related technical training. It is general practice for the Foreman positions to be filled with RC&T technicians who have at least 5 years of experience at Robinso Section 2.1.27 of the Administrative Procedure Manual lists the duties and qualification requirements for RC&T Technician Educational requirements include a high school diploma or equivalent. The section, states that technicians in responsible positions shall have a minimum of 2 year's experience in Radiation Control and/or Health Physics wor The definition of what is a responsible position is not made completely clear but technicians not meeting the above experience requirement are not employed in activities without adequate supervision from an ANSI qualified technician. All shifts have at least one ANSI qualified technician on dut Although not a formal requirement, a technician must have the two years of experience and pass a test administered by the Training Department before becoming ANSI qualified. A review of personnel qualifications at Robinson indicated that technicians are frequently hired without any experience and must successfully complete training and work under supervision before being placed in responsible positions. The inspector found no instances where health physics technicians in responsible positions did not meet the ANSI qualifica tion requirement The licensee contracts H.P. technicians throughout the yea During outages the number of these technicians increase It is general practice for the E&RC Supervisor to review the qualifications of all contractor technicians. In addition, all are given an incoming tes Scores on the test determine the duties to which a contractor techni cian may be assigned with very few of them ever being put in respon sible position b. The General Employee Training (GET) at H. B. Robinson is conducted by the Training Department and is required before obtaining unescorted access to the controlled areas of the plant. The outline of material covered and tapes used have recently been coordinated by the Corporate Training Department at the Harris Energy and Environmental Center (HEEC), New Hill, North Carolina. This will result in uniform GET at each of the licensee's facilities with plant specific material being added by the onsite instructor. The Robinson instructor was an RC&T technician for 5 years prior to joining the Training Departmen The GET consists of tapes and lecture material covering the appropriate subjects. Question and answer sessions are interspersed with formal training, all of which takes. approximately one full da Respirator training is provided at the end of the day for those who require i The GET observed on January 27, 1981, was the first conducted by the instructor from the new, company wide outline. The material presented and tapes shown were well developed and practice was given on frisking and wearing of protective clothin Reading of pocket chambers was covered but no practice conducted. A comprehensive test was given at the end of the training with 80% required to pas If someone fails the test he may study for a day and retake the tes If he fails again, he must go through the training program agai The inspector noted that workers were being instructed to remove protective clothing improperly. Potentially contaminated outer gloves were not removed until after most of the protective clothing worn was removed. This may have contributed to the large number of personnel contamination instances discussed in paragraph 8, especially those where contaminated faces or necks were reported. The inspector stated that if contaminated gloves are used to remove hoods and unzipper coveralls, the potential for contaminating the face and neck is increase The licensee should revise their protective clothing removal training to ensure that workers are not instructed to use contaminated outer gloves when removing protective clothing near exposed skin areas (81-07-03).
Annual retraining on GET is required of all personnel including contractors. The training department schedules this retraining and if an employee fails to attend, hi-s access badge can be confiscate Retraining is an abbreviated version of the GET with tests and passing scores identical to the initial.GE There is no formal program for job specific health physics training at H. B. Robinson. Workers are expected to obtain job specific radiation protection guidance from their supervisors or lead men and from the RC&T technicians or foreme The licensee did conduct radiation protection training for lead men in departments other than Environ mental Radiation and Control during 198 An audit of the radiation protection program conducted in June, 1980 by an outside vendor recom mended that job specific radiation protection training for workers be provided. The inspector found no documentation that the recommended continuing education and training program had been established nor that job specific radiation protection training for workers or contractors is being conducted. Inspection report 50-261/81-10 discusses the use of steam generator mockup training prior to steam generator entrie The inspector recommended that a job specific radiation protection training'program be established, implemented and maintained (81-07-04).
The training department has an outline for "escort training".
This consists of training beyond the GET consisting mainly of review of the Health Physics Manua A person desiring escort badge status must complete this training and pass a tes Permanent licensee personnel employed at the plant 60 days or more are exempt -from the escort training requirement. A licensee representative stated that radiation protection training beyond the GET is received during this 60 day indoctrination perio However, this training is informal and not documented and. no evaluation of performance is performe The inspector stated that escort training for permanent employees should be formalized, documented and employee performance evaluated (81-07-05).
Formal classroom training of RC&T technicians is scheduled and conducted by the Corporate Training Department at HEE All new technicians take the Basic Health Physics Course (4 weeks) soon after employment. Shorter courses in laboratory techniques and instrumen tation are scheduled when convenient for the plant and the training group. Not all courses on the list are required for ANSI qualification but as many as possible are taken before placement in positions of responsibility. A more thorough evaluation of the licensee's training conducted at HEEC was included with the health physics appraisal of the licensee's Brunswick Nuclear Plant (50-325/80-45; 50-324/80-43).
A licensee representative stated that technicians are tested or other wise evaluated periodically to determine retraining requirements. The RC&T foremen, who for the most part have been promoted from technician positions, occasionally attend short courses on specific topics such as radioactive waste shipment, use of lab counting systems, et However, the retraining program does not appear to have specific long-term goals and schedules. The inspector stated that although the requirements of Technical Specification 6.4.1 regarding a retraining program appear to have been met, a formal, structured retraining program with specified goals and personal schedules should be established (81-07-06).
c. Based on the above findings, this portion of the licensee's program appears to be acceptable, but improvements in the following areas should be considered:
(1) protective clothing removal training; (2) job specific health physics training; (3) escort training for permanent plant employees; and (4) RC&T technician and foreman retrainin. External Exposure Control a. Monitoring The external dosimetry system at Robinson consists of 0-500 mR pocket dosimeters for daily and on the job exposure control and monthly TLD badges for the official dose record. The personnel dosimetry service which includes processing TLD badges, maintaining dosimetry records, and preparing and distributing regulatory required reports is provided by the E&RC Section, Harris Energy and Environmental Center (HEEC).
The TLO badge consists of two LIF chips, one under 10 milligrams per square centimeter for skin dose and one under 300 mg per square centimeter for whole body gamma dos The badges are calibrated to Cs-137 only. There is no record of a quality assurance program at the plant for personnel dosimetry. No spikes of TLD badges are done nor any other method for evaluating the quality of the dosimetry service provided by HEE The inspector stated that a program should be established which will evaluate the quality of the dosimetry service provided by the corporate office (81-07-07).
Apparently no beta calibration is performed routinely and there is no neutron dosimete The HEEC dosimetry group participated in the University of Michigan study and performed satisfactoril Neutron personnel dosimetry at Robinson is based on timed entries into containment under power and applying previously determined neutron-to gamma ratios to pocket chamber readings. The worker calls the control room before entry and again when leaving. The control room logs time spent. in containment and the pocket chamber reading as reported by the workers when leaving. RC&T then uses the logs to record neutron doses based on pocket chamber readings and the appropriate neutron to gamma ratio, usually 1:1. Since the worker reads his own pocket chamber when reporting to the control room and RC&T technicians read the chamber at the end of the week, discrepancies do occur. Usually it is a case of the worker over-reading the chamber so that a neutron dose is recorded based on his reading and then the RC&T technician reading a lower value for the gamma dos Robinson uses 0-500 mR self-reading pocket dosimeters (PD)
for daily external exposure control and on the job monitoring and RC&T reads them weekly. The licensee has acceptance criteria for new PD's and all are tested before us Almost all chambers meet the +/-10% at half scale and 2% drift in 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit The inspector noted that those not accepted are not issued. The PD's are response checked annually with the same acceptance criteri Extremity dosimetry is available at Robinson in the form of TLD badges taped to the extremities or finger ring TLD's. Extremity dosimetry is rarely used, only two occasions were found in the records for 198 The need for extremity or multiple location dosimetry is determined by the RC&T foremen based upon survey results and his evaluation of the exposure situation. In-practice very little attention is paid to these factor b. Exposure Limits Exposures and doses are required to be maintained in accordance with the limits specified in 10 CFR 20.101. Further administrative controls are based upon what is known of previous personnel exposure histor A new employee or non-company individual may receive up to 300 mrem per quarter with no exposure history, up to 1250 mrem per quarter with a personal statement on exposure for the current quarter, and 3000 mrem with a completed Form 4 and a licensee Form N Appendix A,
"Authorization to Extend Quarterly Dose Limits".
The yearly administrative control of 5 rem may not be exceeded without prior approval. A review of the personnel exposure history data supplied by HEEC indicated many cases where an exposure limit was apparently exceeded. Many instances were observed on the computer monthly report of greater than 1250 mrem for a quarter with no indication of a valid Form 4 having been completed. In actuality, the Form 4 had been filled out at the plant and a copy *sent to. HEE However, because th verifying data had not also been sent, HEEC did not accept the Form 4 as valid. Better coordination between the two groups is necessar The inspector found no reported doses greater than regulatory limit Exposure records indicated that termination notices were not always sent out in accordance with the regulatory requirements. The exposure of one worker who terminated employment at the plant on November 30, 1980 was determined on December 4, 198 His termination exposure report was not submitted to the NRC until January 19, 198 Another worker's exposure was determined on the same day he terminated employ ment (October 24, 1980) but his termination exposure report was not submitted to the NRC until December 19, 1981. A third worker termi nated employment on September 25, 1980 and had his exposure determined on September 26, 198 His termination report was not furnished to the NRC until December 16, 198 CFR 20.408(b)
requires each licensee to furnish the NRC a report of each terminated worker's exposure to radiation and radioactive material incurred during the period of employment within 30 days after the exposure of the individual has been determined., The inspector stated that failure to provide the NRC.with individual termination exposure reports within 30 days of dose determination is a violation of 10 CFR 20.408(b)
(81-07-08).
Day-to-day radiation exposure is controlled by RC&T foremen and tech nician All entries into radiation areas are controlled by RWP's where allowed doses are liste The allowed dose is based upon the jo RC&T keeps the weekly and monthly dose logs and reads the pocket dosimeters weekly during normal operation and daily during outage During outages or periods of high maintenance activity a "chit" system is used for exposure contro The chit records each worker's allowed dose for the job to 'be don RC&T technicians check worker's in and out at the control point and verify that the allowed dose has not been exceeded. If a job takes longer than expected and the allowed dose must be exceeded, the RC&T technician must call his foreman for approva Exposure Review In response to concerns at the licensee's Brunswick facility regarding TLD/PD discrepancies, a revised discrepancy evaluation format was initiated. If an individual's pocket chamber readings total greater than 500 mrem since the last TLD report or if a TLD reading exceeds 500 mrem, a "Dosimetry Evaluation Report" is filled ou This report, however, does not appear to ensure that the better estimate of real personnel exposure is recorde The analysis appears to be an evaluation of the TLD reading validity. If the TLD is found to have been functioning properly, its reading is accepte No evaluation of dosimeter location is made. No total comparison of the two systems or any trend analysis is performed. It was observed that the most recent reports showed discrepancies between Pocket Dosimeter and TLD readings greater than 25% but no explanation was available for accepting the TLD readin The inspector stated that the TLD/PD discrepancy review system should be reevaluated to include dosimeter locations, interviews with appropriate workers, and other techniques to ensure that the better dose estimate of actual personnel exposure is accepted (81-07-09).
Because of the observation of wide differences between TLD and Pocket Dosimeter results during the plant visit the RC&T department was asked to expose several TLDs and Pocket Dosimeters in their calibration facilty at the same time and compare results. At exposures of 150 mR the Pocket Dosimeters read at least 30 percent higher than the TLD's analyzed at HEEC. No explanation for the discrepancy was found and as a result the plant was asked to furnish 20 TLD badges to be sent to a national laboratory for an intercompariso The results of this comparison revealed nothing'to indicate that the TLD calibration at HEEC is not correct. One possible reason could be excessive scatter from the Robinson calibration source since it is set up in a small fan room with concrete walls close to the source and instrumen Monthly TLD readings are sent to Robinson and become the official dose values. The RC&T records technician reviews and signs the monthly report No evidence was found that plant management reviews the reports. The ALARA person does summarize permanent plant employee doses by job function but no analysis is performed on contractor doses which make up the large majority of the total man-rem dose for the plant. The inspector stated that contractor doses should be summarized and all plant dose reports should be reviewed by plant management (81-07-10). Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
(1) use of extremity dosimetry, (2) termination exposure reports, (3) TLD QA program, (4) TLD/PD discrepancy evaluation system, and (5) management review of dose report. Internal Exposure Control a. Monitoring The licensee's biosurveillance program is outlined in Volume VIII, Radiation Control and Protection Manual, and details are provided in Health Physics Procedures HP-3,
"Grab Air Sampling and Control of MPC-HRS",
HP-6,
"Respiratory Protection" and HP-32,
"Personnel Whole Body Counting".
The facility's primary onsite biosurveillance capa
bility is a mobile whole body counter using a moving bed, a 4" x 8" Nal scintillation detector coupled to a multichannel analyzer, and a computer for data analysis. A standup system for whole body counting has been purchased and plans were in progress to permanently install it at the facilit Documentation for calibration of the mobile system appeared to be appropriate and complete. Observation of the daily calibration check of the whole body counter verfied that the current procedure was available and adhered to. A QC check was performed prior to use and every six hours during continuous operatio Records of periodic checks were in place. An energy calibration using a 0.66 pCi Co-60 source and a phantom was performed whenever electrical power to the unit was removed and restored. NBS traceable certification of the source used for these periodic checks was not availabl It was determined based on discussions with licensee personnel that the whole body counter was not supplied with regulated electrical power as
recommended in ANSI N343-1978. Although this had apparently caused no identified problems, it was recommended that a regulated power supply be provided for the whole body counter when it is used and for the site whole body counter when it is installed (81-07-11).
Records of startup checks of the mobile whole body counter indicated that the unit had not been at the H. B. Robinson site from January 29, 1980 to April 25, 1980 and from May 7, 1980 to July 20, 1980. Investi gation of SRWP's and respirator issue logs indicated that at leas three individuals had come on.site, been issued respirators, worked in containment and terminated from the site with no whole body count before working or upon termination. The inspector stated that failure to perform whole body counts on workers who wore respirators was a violation of.10 CFR 20.103(a)(3) which requires in part such measure ments as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals (81-07-12).
The inspector noted that the failure to perform WBC was also in violation of procedure HP-3 Results of whole body counts were not routinely reviewed.by plant personnel; however, they were reviewed by the Harris Energy and Environmental Center (HEEC).
Providing whole body counting services and performing analyses of bioassay samples is the responsibility of HEEC. The mobile whole body counter is operated in accordance with a procedure issued by HEEC, Radiation Control Instruction RC-PD-5,
"Mobile Whole Body Counter Operation". In practice and as defined by procedure, plant personnel are notified that a whole body count had been completed but the results of that count are not transmitted to site personnel unless the results were greater than 10% of the Maximum Permissible Body Burden (MPBB).
Results of whole body counts are routinely sent to the HEEC where they are reviewed and approved by the Dosimetry Supervisor at the Center and filed in the individual's personal fil Discussions with plant personnel responsible for respiratory protection indicated that they did not receive listings of whole body count results and that they had not conducted reviews of data for trend analysis or comparisons of survey data with internal exposure result Documents had been prepared by HEEC showing the trend of whole body count results as compared to previous years but no analysis of these results versus work activity, air sample results or controls imposed were conducted. The inspector recommended that WBC trend analyses and comparisons with survey data be performed regularly by plant personnel (81-07-13).
Health Physics Procedure HP.6 provides for followup whole body counting of personnel with indications of intakes greater than 10% of a maximum permissible body burden (MPBB)
and for calcalculation of resulting internal exposure. In addition, if MPBB is greater.than 50%, a fecal and/or urine sample is require However, no specific procedural criteria has been developed either at the site or at HEEC for obtaining, handling, packaging or transporting samples; method of analysis; method. of interpreting results..or the biological models and calculational techniques to be used..
- I was recommended that action levels and corrective actions be reviewed and revised to comply with the recommendations of ANSI N343-1978 (81-07-14).
It was noted during review of Exposure Notification forms in personal folders, that internal dosimetry data was different than shown on the whole body count record The tens digit was apparently dropped by the computer printout system. Responsible plant personnel were aware of the problem and correction was in progres The method of control of MPC-HRS and stay time is defined in Health Physics Procedure HP-3, "Grab Air Sampling and Control of MPC-HRS".
Respiratory protection is required for airborne activity levels greater than or equal to 2.25 E-09 pCi/cc gross beta-gamma. Posting of areas at these levels is also required. In addition, respiratory protection is required if contamination levels are greater than or equal to 5000 dpm where work is to be done; greater than or equal to 20,000 dpm for any entry or walk through; and for cutting, welding or grinding on contaminated materia Appropriate protection factors for the respirator to be worn are used in the calculation on Form HP 3-1. No instances were noted where MPC-HR accountability was require In some instances it was not possible to verify that air samples had been taken before or during work activities to assure appropriate respiratory. proteciton requirements were specifie SPWP No. 92-35 was issued on 9-2-80 to provide radiation protection requirements for personnel removing insulation in the Residual Heat Removal Pi Respirators were required and issued to workers. No documentation of air samples taken for this work area could be found for 9-1-80 or 9-2-80. An air sample was taken on 9-3-80. SRWP No. 92-31 was issued for work in the Waste Gas Compressor Roo The SRWP stated that respirator protection was required but no respirators were issued. No air sample documentation could be found to determine air concentrations in the area or to support not complying with SRWP requirement The inspector stated that failure to perform adequate airborne surveys is another example of failure to comply with the requirements of 10 CFR 20.103(a)(3) (81-07-12).
Provisions were included on SRWP and supplementary RWP work roster forms to document work time on each jo Numerous instances were noted where records were incomplete. SRWP 94-41 for work on the containment vessel had instances of time in recorded but time out was.not entere SRWP 9-4-35 covered changing filters in the Waste Holdup Tank Room and contained instances where both entry and exit times were not entere The ability of the system to provide adequate MPC-HR accountability in the event of an accident or positive whole body count was questionabl For thts reason.,.the inspector stated that strict records should be maintained of stay times in RWP areas (81-07-15).
The routine air sampling and surveillance program is defined in Health Physics Procedure HP-1 "Area Radiation Surveys".
Routine daily air contamination surveillance is provided by Continuous Air Monitors (CAM's)
located in the Auxiliary Buildin Four of the CAM's were observed to be located in the upper and lower level corridors of the Auxiliary Building. The fifth, located at the entrance to the Waste Evaporator area, was also sampling corridor air because of air flow pathways at its location. The CAM observed had a calibration sticker, which was attached and dated 1-17-8 Discussions with plant personnel and review of records indicated that documentation of detector response plateau, high voltage settings, or air flow calibration certification was not available. The radiation source used for CAM detector effi ciency determination was a plated Co-60 sourc No evidence was presented which showed that other radioisotopes had been used in calibration or that self absorption in the filter media had been considered. While determination of air concentration from CAM samples were made by counting CAM filters in counting laboratory instruments, the CAM's were used to provide local monitoring and alarm indicatio In addition, the air flow indication on the CAMs was used for calcu lation of airborne concentrations when samples were counted in the laboratory counter. The inspector stated that air flow calibration of CAM's should be certified, that all portions of the CAM calibration be verified and documented and that appropriate consideration be given to filter paper self absorption to ensure that airborne radioactivity is accurately assessed and alarms set accordingly (81-07-16).
Additional routine air sampling is scheduled at four locations daily and at five other locations weekl A weekly activity sample of the instrument air is also take Section 3.3 of HP 3 required air sample data to be entered on Form HP 3-1 and attached to a Radiochemistry Laboratory Sample Submission Form. Numerous instances were noted where only Form HP 3-1 was
completed and file Form HP 3-1 required only end-results data and consequently many air sample records did not specify type of sample, location, time, flow rate, count data or person taking the sampl Review of adequacy of airborne activity determination (timing, frequency, location) and evaluation of air sample results versus work activity did not appear possible in these instance The inspector stated that failure to follow procedure HP-3 was a violation of Tech nical Specification 6.8.1-(81-07-17).
Routine counting of air samples did not include alpha analysis or Sr-90 evaluatio Weekly analysis of primary coolant did include gross alpha and Sr-90 determination With primary coolant analyses indicating less than 1.OE-06 pCi/cc gross alpha, less than 6.OE-02 *ICi/cc total activity, and exceptionally low fuel failure rates, the inspector concluded that this portion of the licensee's program appeared accept abl However, the inspector cautioned the licensee *that if fuel integrity deteriorates, a program for alpha and Sr-90 evaluations of air samples should be considere Respiratory Protection Program The respiratory protection program was reviewed for content and ade quacy of training, medical examination requirements, respirator fitting program, cleaning and decontamination methods, inspection, testing, repair, packaging and storage and inventor The licensee's respiratory protection program is described in Volume VIII, Radiation Control and Protection Manual, and in Health Physics Precedure -
HP 6, "Respiratory Protection."
A formal program was in place, a policy statement documented and credit-taken for protection factors. An RC&T foreman is assigned responsibility for the respira tory protection progra This individual is also assigned other responsibilities including foreman of a traveling crew, which is required to assist outages at another licensee facility. During his absence, program responsibilities are assumed by other foremen. While this arrangement appears to meet the technical requirement of NUREG-0041 the inspector stated that the respiratory protection program should be the sole responsibility of a full-time site employee (81-07-18).
Respiratory protection training is required upon employment and annually thereafter by Procedure -
HP 6, Section 2.2, as part of the conditions for authorization to wear respiratory protectio The classroom training consisted of a 24 minute vendor supplied video tape followed by an oral presentation, demonstration of a visual inspection, negative pressure test, respirator removal technique, and a ten-question examination. A grade of 70% was necessary to pass the examination. The inspector-stated that the training program needed improvement in the areas of engineering control description and use (81-07-19).
Documentation of the classroom training was provided in the training files and entered on a Respirator Qualification Card. This card also provides space for documentation of medical examination and the fit test results for each type of respiratory device use A medical examination is required, prior to initial authorization to wear respirators and annually to maintain authorization, to verify physical and mental ability to wear respi.rators under simulated and actual working condition A signed statement.by a physician specifically testifying to the individual's ability to wear respiratory protective devices is required to be on file for all personnel (permanent, contractor and visitors).
Medical criteria has been developed and provided to examining physician An annual fit test is required for each type of respiratory device to be worn. Procedure for a qualitative fit test is described in Section 2.3.3 of HP-6. A challenge atmosphere of isoamyl acetate is used in a test booth. The aerosol is manually sprayed into the booth, and the lack of detection of the banana oil odor by the applicant is regarded as indication of an acceptable respirator fi The prodecure specified eight simulated work conditions that an applicant may be required to perform during determination of respirator fi However, during observation of fit tests being administered, only two of the tests were use A written procedure was not seen at the test booth during fitting. The inspector stated that failure to follow prodecure HP-6 was a violation of Technical Specification 6.8.1 (81-07-17).
The appraisal team recommended that a quantitative fit system be established to provide objective and quantitative fit dat Discus sions with plant personnel indicated that this was a recognized deficiency, and plans and budgeting were in process for purchasing a quantitative fit syste Upon successful completion of respirator training, medical examination and respirator fit test, a Respirator Qualification Card is completed for each individual and placed in a file in the Health Physics Offic The respirator training and medical examination information on the card is supported by documentation in the individual's exposure history fil However, the only documentation of respirator fit is a date entered on the Respirator Qualification Card. It was recommended that an authorizing signature be included with the date on the car Respirators are issued by RC&T personnel at the health physics office if required by the Radiation Work Procedure (RWP). Upon request for a respiratory device, the RC&T technician verifies that the individual is currently authorized to wear respiratory devices by checking the
Respirator Qualification Card file. If authorized, the appropriate respirator is issued and the name of the individual, RWP number, date and respirator identification number is entered in the Respirator Issue lo Users are instructed to replace the used respirators in the plastic bag and deposit it in a "used respirator" barrel in the auxil iary building near the HP counting roo While routine verification that each respirator had been returned is not done, licensee personnel, stated that, if respirators are found in the facility, the issuer is traced using the Respirator Issue log and reinstructed on the proper procedur A random selection of names from the Respirator Issue log was reviewed to verify authorization to wear respirators. Respirator Qualification Cards were on file and complete for all reviewe A cross check of exposure history files to. verify medical authorization showed two instances, one CP&L employee and one contract employee, where no documentation was in the file. A licensee representative produced the appropriate documentation from permanent personnel files at the Harris Energy and Environmental Cente The respirator cleaning, deconta mination, drying, surveying, packaging and storage area is located in a small room near the counting laboratory. Used respirators are removed from the receiving barrel, placed in a large plastic bag and carried to the cleaning room. According to plant personnel, no radiation survey of respirators is conducted when they are removed from the barrel and placed in the transfer bag or when removed from the transfer bag and placed. in -the cleaning sin Plant personnel.also indicated that no air samples are taken during these operation It was recommended that a survey of respirators be conducted prior to removal from the plastic bag to preclude spread of contamination from grossly contaminated respirators to the area and to other respirators in the sink. It was also recommended that air samples be taken during transfer of respirators to the sink to assure that handling personnel are not exposed to unacceptable levels of airborne contaminatio This was especially important in the respirator cleaning room where air flow tests indicated essentially no ventilation in this area (81-07-30).
Respirators to be cleaned are disassembled, filters removed and dis carded, and respirators placed in a wash solutio The respirators are individually brushed and then placed in two sequential rinse solution Section 5.2 of Procedure HP-6 specifies a two minute submersion in a disinfectant solution. During the cleaning process observed by the appraisers, no disinfectant was used. The individual performing the work was asked if the procedure for the job was availabl A hand written instruction sheet was produced but the formal procedure was not at the location. The inspector stated that not disinfecting respira tors following cleaning was failure to follow procedure HP-6 in viola tion of Technical Specification 6.8.1 (81-07-17).
After rinsing, respirators are placed on a wall rack for air dryin When dry, each respirator is surveyed and smeared by RC&T technicians, and the smears are counted on a laboratory counte Radiological conditions required prior to reuse include less than 0.2 mrem/hr and less than 200 dpm/100 sq cm beta-gamma on any accessible surfac Respirators not meeting these criteria are recleaned or discarde Clean respirators and associated parts are inspected, reassembled, and new filters are installed and packaged in plastic bags. A tag certi fyi:ng that the respirator has been cleaned and.surveyed with date and name of surveyor is placed on the ba Respirators are'stored on shelving in the cleaning room with a limited supply stored in the health physics office for issu A supply of spare parts is located in bins at this same location. Additional supplies, both respirators and parts, are available at the site central stores warehouse.. Supplies of respirators and parts appeared to be adequat Section 4 of Procedure HP-6 requires a quarterly inventory of respira tory equipment and associated spare part Inventory records were complete through March 1980 but had been stopped at that tim Dis cussions with plant personnel indicated that the central stores facility had been established and that its computer inventory of site equipment was to be used to fulfill the quarterly inventory requirement specified in HP-However, a quarterly inventory of respiratory equipment and replacement parts was not include The inspector stated that not performing quarterly inventories-of respiratory equipment and, associated replacement parts was failure to follow procedure HP-6 in violation of Technical Specification 6.8.1 (81-07-17).
Management agreed that the quarterly inventory would be reinstitute Bagged respirators ready for issue were inspected for currentness of inspection tags, obvious defects and radiological,conditions. All respirators inspected had current tags, appeared to be in good condition and were within the radiation and contamination levels allowed for reus Breathing air is supplied from the facility service air compressor for airline respirators and bubble suits and from the Fire Brigade air compressor for the SCBA unit The service air compressor, an oil lubricated pump with teflon rings, is located outside the auxiliary building. The air is routed through a cooling and purification system to a receiving air tank. Regulatory Guide 8.15, "Acceptable Programs for Respiratory Protection" requires as a minimum that respirable air of approved quality be provided in accordance with NUREG-004 Section 5.2.4.1 of NUREG 0041 specifies that breathing air quality should meet
S
the requirements for Grade "0" air. Analyses of breathing air quality were performed in July 1978 by a contract laboratory and in-house in January 1981 using detector tube Review of the in-house testing indicated that the sensitivity of the detector tubes used was not adequate to verify that Grade "D" air is supplied for respiratory protectio The inspector stated that failure to use respiratory protective equipment as stipulated in Regulatory Guide 8.15 is a violation of 10 CFR 20.103(c) (81-07-20).
In addition, no procedure had been prepared for test performance and the CO monitor had not been calibrated to assure the ability to detect the appropriate CO concentrations for at least two years. This defi ciency was recognized by the licensee, and calibration gas has been ordere The breathing air line contains an in-line carbon monoxide (CO)
monitor. It was recommended that the CO monitor read out and alarm functions be moved to a more readily accessible locatio It was located near the Waste Condensate tanks inside a radiation and contam ination zone and not visible from clean areas. Relocating the readout and alarm functions to a readily visible position would increase the assurance of identifying and responding to abnormal conditions (81-07-21).
The Fire Bridage air compressor used for filling SCBA units is an Eagle compressor supplying a purification trai No documentation was available except a general statement by the manufacturer, to indicate the quality of the air. Discussions with plant personnel indicated that no testing had been conducted on the output of this unit. Licen see personnel agreed to implement an appropriate program of testing breathing air supplie Training of personnel performing the cleaning, inspection and repair of respiratory equipment had been provided and documented. Training for personnel inspecting and repairing SCBA regulators had been provided by the equipment manufacturer, and training for other personnel was provided by CP&L training facilitie Based upon the above findings, improvements in the following areas are required to achieve an acceptable program:
(1) requirements for whole body counts for workers in radiation controlled areas, (2) routine site review of whole body count data, (3)
routine appraisal of the effectiveness of the internal. exposure control program,
(4)
procedural criteria for the direct and indirect bioassay program, (5) evaluation of airborne radioactivity pertaining to employee exposures in work situations, (6)
calibration of CAM radiation detectors and air flow systems, (7)
procedural controls of cleaning and disinfecting respirators, analyzing breathing air, calibrating CO monitor, and.completing entry and exit times on SRWP's, (8) regulated power to whole body counting equipment, (9) certification of whole body counter check sources, (10) quantitative respirator fit test system, (11)
CO monitor location, and (12)
respiratory protection trainin * Surveillance Program a. The licensee's surveillance program was evaluated in accordance with the requirements and guidance contained in 10 CFR Part 20.201, 20.401, 19.12; Technical Specifications; USAS N13.2-1969; ANSI 13.6 -
1966Property "ANSI code" (as page type) with input value "ANSI 13.6 -</br></br>1966" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. (R1972); Regulatory Guide 8.8; and H. B. Robinson Radiation Control and Protection Manual Health Physics Procedure The basis for radiation and contamination surveillance activities, including schedules, locations, methods, frequency, and requirements, is addressed in procedures HP-1, 2, 3 an However, the objective of using survey records to control personnel exposures to radioactivity in occupied controlled areas is not reflected in personnel contamination report While routine surveillance activities conducted by the licensee have shown radiological conditions which are compliant with procedures and requirements, many workers have been contaminated within the controlled area, without having entered designated contaminated areas. A review of the licensee's records revealed 72 instances of personnel contamination which originated during a one month non-outage period in areas outside of contaminated areas but within controlled areas where the licensee controls contamination levels to below 200 dpm per 100 sq cm. Approximately 10% of the contamination instances which occurred outside of contaminated areas in the Auxiliary Building appeared to originate from the.Auxiliary Operator's desk. Most of the personnel contaminations which originated from areas in the Auxiliary Building, but outside of contaminated areas were hand and foot. contami nations which were traceable to areas where only sweep surveys are performe While relatively few people were involved in Spent Fuel Cask work during the period evaluated, 18 workers were contaminated, of which 12 were skin contamination instances. The Drumming Room and Hot Machine Shop are other prime scources of contamination instances. About 1/3 of all contamination instances involved skin contamination. The inspector reviewed records which indicated that several individuals have had as many as 5 to 14 repeat instances of personnel contaminatio While these examples may not be fully representative of results obtainable from a more complete statistical analysis of availab.le data, it is, evident that the licensee needs to evaluate personnel contamination data more fully to detect deficiences in training, work practices, procedures, work control, or surveys, and identify personnel and area problem Procedures should be developed so that each individual contamination instance is promptly investigated so that the cause and location of each occurrence is determined and corrective actions applied so that additional personnel contamination can be prevente At the time of the appraisal, contractor technicians were documenting each personnel contamination instance, but were not routinely investi gating cause and origin, or reporting the occurance to licensee RC&T technicians or supervisors. In those cases where RC&T technicians were informed, follow-up usually consisted of determining which RWP the individual worked under, and taking a sweep survey of the walkway adjacent to the work area. Mutiple or repeat personnel contaminations received no special treatmen On 1/29/81, four separate consecutive instances of personnel contamination occurred during "B" Charging Pump work. The licensee should formalize the investigation of personnel contamination instances to determine extent, causes, and corrective actions and provide supervisory involvmen The personnel contamina tion records from personnel monitoring provide valuable data which should be analyzed and correlated to provide meaningful information on the licensee's contamination control progra Areas, tasks, situa tions, and individuals with a strong relationship to instances of personnel contamination should be identified and corrective measures developed. The inspector stated that cases of personnel contamination should be routinely reviewed by plant management and measures provided to prevent recurring instances where appropriate (81-07-22).
b. The self-monitoring procedures employed at Robinson have proved to be excellent in many respects, but need to be expanded to improve the area of contamination contro Self-monitoring practices at H.B. Robinson involve a whole-body frisk (using an HP-210/RM-14 frisker).
This is required for every individual leaving the Auxiliary Building controlled area. The exit area is posted with clear "frisking" requirements and the "frisking" station is monitored by a radiation protection techni cian who ensures that a proper and thorough whole body survey is
performed and also monitors the actions taken for occasions when skin and/or clothing contamination is detecte An additional frisking station, where hand and foot frisking only is required, is located outside of the licensee's controlled area at the exit from the protected area. This station is also manned by a radiation protection technician who monitors proper frisking and potential contamination problems. The whole body frisking required at Robinson has proved to be an excellent means of detecting personnel skin and clothing contamination. An analysis of licensee records showed that over a selected one month non-outage period in December 1980 - January 1981, 258 instances of personnel contamination were recorded, of which about 1/3 were skin contamination events. During an outage in 1980 approx imately 2700 individuals were contaminated; a third were skin contam inition incidents. This average of approximately 10 personnel contam in'ation instances per regular working day compares to the 10-15 personnel contamination instances per day noted during the appraisal period. Since many of these cases (72)
involved individuals who did not enter any contaminated areas within the controlled area, the inspector recommended the use of additional friskers for personnel monitoring at each contaminated area worksite (81-07-23).
The licensee.limit for personnel contamination is 100 cpm by friske Random checks of friskers showed all to be in calibration with alarms set at 100 cpm above backgroun Radiation survey procedures do not require specific, detailed surveys in areas where work is to be performed. In most cases RWPs are pre pared using dose rates and contamination levels from informal maps kept in the RWP office, or general area routine surveys. Radiation surveys typically consist of a general area scan, with only a single general area dose rate value entered on the survey log Smear surveys may include the maximum value from only three swipes within an are Airborne surveys typically reflect CAM results from the previous day's air sample, or a grab sample from a designated area where the CAM is not functiona These surveys, as documented, do not identify all "hot spots".
Hot spots are not routinely surveyed nor documented when surveyed by the licensee. The inspector stated that since unnecessary or inadequately monitored exposure can result when unknown localized exposure "hot spots" exist in work zones, the licensee should identify and post hot spots in conjunction with regularly performed routine surveys or special prework survey Contamination surveys are not detailed enough; do not identify high/low areas, and do. not include walls, pipes, valves, valve handles, or equipment located in an area. Airborne surveys logged on the survey sheets reflect values from CAM's located outside the work zones and are
affected by dilution and particulate settling. A review of RWP records from (10/19/80) indicated that the same dose rate range (3-100 mr/hr)
was used for several different jobs in different parts of the same are Three RWPs required respiratory protection but no air sample analyses were available (see paragraph 7). RWPs for work in the Hot Machine Shop involving decontamination of contaminated scaffolding indicated contamination levels greater than 200 dpm/100 sq cm when the potential levels were several thousand dpm/100 sq c The inspector stated that specific radiation and contamination surveys should be performed to support a. specific activity requiring an RWP (81-07-24). Routine surveyresults are reviewed daily by a first line supervisor and the E&RC Supervisor. However, the documentation of routine surveil lance is general, and comments on corrected or changing conditions are not provided. Direct or detailed information is not readily available for overview and analysis. Over a one-week period during January of 1981, a review of dose rate changes indicated a three-fold increase or decrease in some daily survey results with no attendant explanation The licensee should develop more detailed routine surveys, including area maps, explanatory remarks, and annotation of "out-of-specifica tion" conditions, so that supervisors and subsequent surveyors can detect trends in dose rate, contamination levels, airborne activity, work practices, and equipment performance more readily. The inspector recommended that detailed routine surveillance data be reviewed by responsible plant management regularly so that trends in radiological conditions throughout the plant can be readily recognized (81-07-25).
e. At the time of the inspection, the licensee did not conduct compre hensive surveys of secondary side systems. Radiological controls for secondary systems had not been defined nor incorporated into proce dure The plant has experienced primary to secondary leakag Secondary system components found during the appraisal to be con taminated included the blowdown lines, auxiliary boiler condensers, and auxiliary boiler vacuum pumps. Identification of removable radioacti vity in the Unit 1 fossil plant at the Robinson site resulted in a special inspection on April 21-22, 1981 (see Inspection Report 50-261/
81-13). The inspector stated that thorough surveys of secondary side systems should be included in the facility routine surveillance program (81-07-26).
f. Tools, equipment and material are bagged when appropriate at the work site and surveyed by health physics personnel at the personnel frisker station near the exit of the controlled are The inspector stated that surveys should be performed at other than the normal controlled area exit. On February 3, the inspector surveyed a contractor clean material storage area and discovered a contaminated scaffold reading 0.6 mR/hr and 10,000 cpm loose contamination using a HP 210/RM-14
detector. On February 2, the inspector discovered a vacuum cleaner in the I&C shop reading 0.2 mR/hr and 450 cpm above background with the same detecto Although unrestricted area release limits did not appear to be exceeded, the licensee should improve the surveillance program of tools, equipment and material leaving the controlled area (81-07-27).
The inspector noted that comprehensive surveys with a micro R meter were being performed on clean trash removed from the restricted are An-independent survey conducted by..the inspector disclosed no viola tions of regulatory or licensee requirement Beta radiation surveys are generally not conducted by the licensee (e.g.,
a Teletector is used for radiation surveys).
Since significant beta exposure can occur during maintenance, particularly when systems containing radioactivity are open, the licensee should conduct beta survey The licensee should also increase the available supply of portable beta detecting and measuring instruments. Only two such instruments were available during the appraisal (81-07-28).
g. The inspector examined radiation surveydata and personnel monitoring techniques related to steam generator tube plugging opreations in 198 Survey. data showed that non-uniform and complex radiation fields existed in both hot and cold leg sections of each steam generator (SG).
Personnel radiation monitoring consisted of thermoluminescent dosimeters (TLDs) and self-reading pocket dosimeters (PDs) enclosed in plastic bags and attached to the workers' chests. A licensee represe ntative acknowledged that an evaluation of the survey data did not generate sufficient concern to warrant use of extra dosimetry in the area of the worker's head and gonads. The inspector stated that based on review of the available information, it appeared workers may have received a significantly greater whole body dose than previously recorded by dosimetry worn on their ches At the exit meeting the licensee agreed to reexamine steam generator survey data to determine if modifications to personnel exposure records for 1980 is require The inspector noted that procedure HP-12, "Steam Generator Inspection and Maintenance", had recently been revised to require head, chest and gonad TLDs for each steam generator entr h. On January 29, 1981, an inspector toured that portion of the Auxiliary Building near the Boric Acid Evaporator Roo The room was posted with a sign stating "Caution-Locked High Radiation Area", "Survey Instrument Required for Entry" and "RWP Required for Entry".
RWP 129-2 stated that the dress requirements for entries into contaminated areas would
be posted at the entrance to each location and must be adhered to. A sign at the Boric Acid Evaporator Room indicated that full protective clothing was required for entries except for sampling operation Technical Specification 6.13 states that a dose rate survey instrument must be used by workers when entering high radiation area The inspector observed a worker climbing in the overhead piping with no other protective clothing but shoe covers and glove The inspector stated that failure to follow the protective clothing dress requirements of RWP 129-2 was in violation of health physics procedure HP-8 and Technical Specification 6.8..1 (81-07-17).
The worker was also found to be without a dose rate 'survey instrument. Dose rates in the room at the time were greater than 100 mR/h The inspector stated that entering a high radiation area without a dose rate survey instrument was a violation of Technical Specification 6.13 (81-07-29). Based on the above findings, improvements in the following areas will be required to achieve an acceptable program:
(1) management review of personnel contamination instances; (2) location of additional friskers; (3) specific surveys for RWPs; (4) management review of routine survey results; (5) secondary side surveillance program; 0(6)
tool, equipment and material exit surveillance program; (7) beta survey capability; (8) personnel monitoring during steam generator work; and (9) adherence to posted requirement. ALARA Program 10 CFR 20.1c states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation expo sure as low as reasonably achievable (ALARA). The recommended elements of an ALARA program are contained in Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for Main taining Occupational Radiation Exposures ALAR The licensee has a written policy and commitments to an ALARA program. The program is described. in the "Corporate Health Physics Policy", and imple mented at the facility through the Radiation Control and Protection Manual, Health Physics Procedure HP-1 These documents identify organization, personnel, and responsibilities for development and implementation of the ALARA program at all management levels. A senior ALARA specialist has been
assigned full responsibility for ALARA development and implementation at the plant and reports directly to the E&RC Superviso An ALARA Committee, composed of technicians and engineering personnel has also been established to provide review and input for the program at the implementation leve The responsibilities of these individuals are consistent with those.outlined in Regulatory Guide Training and instruction which emphasizes ALARA at a functional level are provided in the General Training progra The licensee's efforts in planning and preparation for major tasks appeared to be adequat For example, exposures from steam generator work ha decreased over the last two years due to pre-planning, review of previous work, and use of mockup (see Inspection Report 50-261/81-10 regarding adequacy of personnel monitoring and evaluation of survey data for steam generator work). Review of design modifications and equipment selection is evidenced by recommendations to modify valve operations in a high dose rate filter area and use of reactor head vent shielding to reduce exposures during refueling. The inspector stated that it appeared a major reason for the apparent adequacy of the ALARA program is good fuel cladding integrit This has resulted in relatively low radiation levels throughout the facility (with the exception of an RHR heat exchanger) due to low fission product activity outside of the primary coolant syste However, the inspectors identified several areas which need additional development through the ALARA program including: (1) training and retraining in contamination controls; (2) contractor exposure analyses; (3) hot spot reductions; and (4) decontam ination operation Based on the above findings, this portion of the licensee's program appears to be acceptable, but consideration should be given to the above recommenda tions to improve the progra.
Radioactive Waste Management a. Gaseous and Liquid Releases An inspector selectively reviewed calendar year 1980 gaseous release permits 80-1 thru 80-179 for conformance with the requirements of Technical Specification 3. Releases from the Waste Gas Decay Tanks, Pressure Reliefs of the containment, and Containment Purges are accounted fo The releases appear to meet the requirements of the technical specificatio Liquid release permits 1 thru 916 for releases during 1980 were reviewed against the requirements of Technical Specification 3. Section 3.9.1 of the technical specifications states that the annual average release rate of unidentified radionuclides will not exceed 26 mCi/day, exclusive of tritium, and the annual average release rate of
tritium will not exceed 10.5 Ci/day. On July 14, 1980, eight separate liquid releases totaled 28.16 mCi gross beta gamm The inspector noted other examples where daily releases of liquid radwaste exceeded 26 mCi gross beta-gamma or 10.5 curies tritiu However, the annual average daily release appeared to be within technical specification limit No liquid release greater than the limit specified in Tech nical Specification 3.9.1.2 was identifie b. Ventilation/Filtration System (1) On January 30, 1980, inspectors examined air flow patterns through out the Auxiliary and Decontamination Buildings and the chemistry hot laboratory using a hot wire anomometer and smoke tubes. Most areas appeared to exhibit adequate air flows from areas of lower contamination to areas of higher contamination in keeping with good health physics practice However, three areas were identified as having inadequate or improper ventilatio The health physics/hot chemistry counting laboratory exhibited air inleakage from the Auxiliary Building which would prove to be detrimental during periods of high auxiliary building airborne activity. Air flowed from the gas stripper room and the drumming room into the north hallway of the Auxiliary Building on the 246 foot elevation. The respirator decontamination and cleaning room exhibited stagnant air flow patterns. Air flowed from the highly contaminated "B" Waste Evaporator room into the upper hallway of the Auxiliary Building. Multiple instances were observed of air passing over contaminated areas in the Hot Machine Shop during decontamination operations to uncontaminated areas of the building. The inspector recommended a ventilation balance study be performed to determine which areas exhibit air flows from'
contaminated to less contaminated or clean areas and provide adequate immediate and permanent ventilation to ensure that air flows in the proper direction (81-07-30).
The inspector tested the hot chemistry laboratory air hoods with a hot wire anomomete When the exhaust fans for the hoods are operating, it appeared that partial closure of the door was required to obtain an average 100 linear feet per minute suction across the face opening. NBS Handbook 92 recommends that for low to moderate levels of radioactive materials, the average velocity through openings in the hood must be 100 linear feet per minut During the inspection, the hood exhaust fans did not appear to be operating even though samples were observed within the hot chem istry laboratory hood The inspector stated that technicians should use the hood exhausts when applicable and means should be provided to ensure proper face suction velocities when in use 181-07-31).-
(2)
The inspector reviewed the HEPA and charcoal filter testing program. Technical Specifications, Sections 4.12, 4.15, and Item 14 of Table 4.1-3, require laboratory analysis of charcoal samples and inplace DOP HEPA and halogenated hydrocarbon charcoal testing of the following filter systems:
Emergency Spent Fuel Building (HVE-15a),
Containment Purge (HVE-1),
Control Room (HVE-19),
and Emergency Auxiliary Building Exhaust (HVE-5). Tests are required to be performed in accordance with ANSI N101.1(1972).
Periodic Test CPL-PT-24..0 provides, instructions for HEPA and charcoa filter testing of the technical specification filter systems and the following units: Auxiliary Building Exhaust (HVE-2),
Fuel Handling Building Exhaust (HVE-14),
and Spent Fuel Building Exhaust (HVE-15).
The inspector reviewed results of tests performed in 1979 and 1980 pursuant to CPL-PT-24.0 and the requir ements of the Technical Specification Records indicate that frequency and acceptance criteria for these filter systems have been me A licensee representative stated that filter tests have been performed in accordance with ANSI N510 (1975) and that a new periodic test procedure is being prepared to upgrade the filter testing program to reflect the more recent ANSI standar The inspector agreed that although not required by the licensee's Technical Specifiations, performing filter tests in accordance with ANSI N510 (1975) would be good practice. The inspector had no further comments on the licensee's filter testing progra Theinspector accompanied by a licensee representative conducted an inspection of the filter units and associated instrumentatio The filter systems appeared to be in adequate condition except for HVE-15 The Emergency Spent Fuel Building unit (HVE-15a)
contained material and equipment in the compartment upstream of the prefilters. This unit is not required except when moving fue The licensee removed the objects and stated that this filter train was being worked on to fix what appeared to be a leaky gaske Whenever it rains, water leaks into the filter unit. The inspector stated that a roof should be considered for protection of HVE-15a from adverse weather since the unit is located outside and it is a technical specification filter syste The licensee representative stated that if the repair work on the gasket does not solve the problem, alternative solutions will be considered (81-07-32).
Local and remote (Control Room) indications of HEPA and charcoal filter system operating parameters appear to be minima Local readings appear to include only differential pressure on most
system (The refueling filter system contains a humidity gauge which is monitored hourly during fuel handling operations in accordance with Technical Specifications.)
The inspector noted that differential pressure on all the systems are monitored weekly by the auxiliary operators and recorded on a weekly checklis Requests for HEPA filter changes are made when differential pressure readings reach approximately 2 inches water, well below the limit of 6 inches specified in Technical Specifications. The control room contains on/off indicators for the filter system fans and an alarm which annunciates when flow through the system decreases below a predetermined limi No other operating para meter indications are available in the control roo The inspector stated that although it appears the requirements of the Technical Specifications have been met, the above observations reflect conditions in disagreement with recommendations of Regula tory Guide 1.52, Regulatory Guide 1.142, ANSI N509-1980, and ORNL-NSIC-65,
"Design, Construction, and Testing of High-Effi ciency Air-Filtration Systems for Nuclear Application".
The inspector stated that methods should be considered for providing the control room with remote indications of filter system operating parameters such as temperature, humidity, differential pressure, and flow rate (81-07-33).
The inspector reviewed Engineering Flow Diagram N G-190304,
"HVAC-Turbine, Fuel, Auxiliary, and Reactor Buildings" which indicated that the Fuel Handling Building filter system (HVE-14)
processes air from the hot machine shop, cask decontamination area, gas decay tank area, and the holdup tank areas and exhausts to the atmosphere through a radiation monitor. A licensee repre sentative stated that on a high radiation alarm from the process monitor (RMS-20),
the filter system is shutdow The inspector stated that if high activity were being released through HVE-14 directly to the atmosphere, the filter system should not be isolate It appeared this would likely permit high radioactivity to be released to the environment without being filtered and monitore The inspector stated that automatic isolation of HVE-14 on a high radiation alarm from RMS-20 will be examined during a future inspection (81-07-34).
c. Effluent Accountability An inspector reviewed the effluent accountability program to ensure that all activity and release pathways are accounted fo The inspector examined records of the weekly secondary side water loss calculations and was informed that the average secondary loss is approximately 110 gpm to 120 gp Water loss is determined weekly from differential level measurements of the Condensate Storage Tank over a
24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. Effluent records indicate that continuous blowdown of the Steam Generator Blowdown Tanks accounts for nearly 80 gpm of this total and close to 100% of the reported liquid activity released from the plant. The inspector questioned the licensee about the remaining secondary water losses and the potential for previously unreported associated radioactivity releases. In particular the inspector asked about activity associated with venting of the steam generator flash tank, releases through the steam reliefs following a reactor trip, potential gaseous releases from the auxiliary boiler, liquid releases out the-yard drain system, and atmospheric venting of yard tanks such as the Condensate Storage Tank. A licensee representative stated that the existing sampling and monitoring program addresses most of these areas of concern. The inspector commented that if analyses of release points reveals a path where Technical Specification release limits could be exceeded, installation of a continuous monitor should be considered. In any event, the sampling program must be adequate to assure accountability of all potential effluent paths. The inspector stated that, since the data appears to be available, the licensee should consider a mass balance approach on the secondary side between make-up to the secondary side water systems and losses from the secondary side to obtain a more inclusive view of potential release A licensee representative stated that they will examine their effluent accountability program to ensure each potential release point is accounted for and that their sampling and monitoring program is ade quate (81-07-35).
'In 1977, the licensee constructed two settling ponds to collect non radioactive oily discharges form Unit 1 in response to requirements imposed by their National Pollutant Discharge Elimination System (NPDES) permit. The system provides a method whereby oily residue is skimmed off the water surface and solids will settle to the bottom-of the pond as sludge. Relatively clean water flows over a weir to the unrestricted are Approximately biannually the oily wastes are removed from the facility by an offsite disposal contracto This waste oil is monitored prior to disposal to ensure that unrestricted area release limits are not exceede By design, outside drains from Unit 2 also empty into the settling pond. The Unit 2 drain system may contain radioactive liquids if contaminated water leaks from the secondary side. Consequently, a composite sample is taken of the water flow to the unrestricted area and a radiation monitor is provided on the settling pond influent to divert the flow to the discharge canal if a predetermined setpoint is exceede CFR 20.301 states in part, that no licensee shall dispose of licensed material except by transfer to an authorized recipient as provided in Part 30, 40 or 70 of Title 10 to the Code of Federal Regulations, as authorized pursuant to 20.302, or as provided in 20.203 (release of material. into., sanitary sewerage system), 20.304 (disposal by burial in soil) or in 20.106 (Radioactivity in Effluents to
Unrestricted area).
10 CFR 20.302 states that any licensee may apply to the Commission for approval of proposed procedures to dispose of licensed material in a manner not otherwise authorized in the regula tions. In July, 1980 the licensee transferred approximately 3000 cubic meters of sediment containing an estimated 20 milliCuries, principally Co-60, from the east settling pond to an ash pond which is located outside the restricted area but on licensee property. Five samples of the sediment were collected and analyzed.to quantify the amount of licensed material present in the sediment. The average activity of the sediment was determined by the.licensee to be 4.13E-06 microCuries per gram. A safety analysis was performed by the licensee to assess the impact of placing the sediment in the ash pon Based on the analysis, the licensee concluded that placing the sediment in the ash pond would not have an adverse effect on the environment and the exposure received by members of the general public would be negligibl The inspector reviewed the safety analysis, laboratory analyses of the sediment, performed independent radiation surveys in the vicinity of the ash pond and collected sediment samples which were analyzed by the license The independent samples collected by the inspectors indicated that the actual concentration of licensee radioactive material in the sediment may be as much as two times higher than reported in the safety analysis. However, this higher value would not change the conclusions reached by the licensee. The inspector stated that five samples taken from the surface of the sediment in the settling pond would not be considered representative sampling. In addition, the inspector stated that the safety analysis. did not consider the hydrological charac teristics of the area, potential for contamination of ground water supplies in the area, or procedures that would restrict access to the area. It should be noted that the licensee analysis was based on a procedure whereby the sediment was hydrovacuumed out of the settling pond and dumped on the bank of the ash pon Any sediment remaining on the bank of the ash pond was to be washed into the pon However, after dumping the sediment into the pond a high bank at the edge of the pond was bulldozed over the sediment, in essence burying the materia Although the ash pond is located on licensee property, it is accessible to the general public. The inspector stated that although the disposal did not pose any threat to the health and safety of the public, the Commission is concerned with the spread of licensed radioactive material outside the restricted are Such disposals of radioactive material would also further complicate efforts to remove all licensed material from the site upon decommissioning of the facilit The inspector stated that failure to receive prior approval of the Commission to dispose of licensed material in a manner not otherwise authorized in regulations was a violation of 10 CFR 20.302 (81-07-36).
The licensee should consider if additional environmental sampling is needed in the vicinity of the ash pon CFR 50.59 permits the holder of a license authorizing operation of a production or utilization facility to make changes to the facility as described in the Safety Analysis Report, without prior Commission approval, unless the proposed change involves a change in the technical specifications incorporated in the license or an unreview safety questio The licensee is required by 10 CFR 50.59 to maintain records of changes in the facility which shall include a written safety evalu ation which provides the basis for the determination that the change does not involve unreviewed safety questions. Plant management stated that they thought a safety analysis for the settling pond construction had been performed. However, the written report could not be located during the appraisa The inspector stated that this matter will remain unresolved pending further attempts by the licensee to find the written report (81-07-37).
The inspector stated that failure to perform the safety evaluation and/or to maintain the report would be in violation of 10 CFR 50.5 IE Bulletin 80-10 specified that the licensee either decontaminate nonradioactive systems that have become contaminated or to perform a 10 CFR 50.59 safety evaluation to determine that the operation of the
.system as a radioactive system does not involve an unreviewed safety question or a change to the Technical Specifications. During tours of the plant, the inspectors observed that the A and B auxiliary boilers were labeled "internal contamination-fixed" with posted radiation levels of 3.5 mR/hr. Independent surveys performed by the inspector indicated that additional components and piping in the auxiliary boiler system were contaminated with radioactive levels as high as 3.5 mR/h The safety evaluation performed by the licensee in response to Bulletin 80-10, was incomplete, in that the following elements specified by the Bulletin were not included:
(1) assessment of potential releases of radioactivity to the environ ment, and (2) comparison of-such releases to the radioactive effluent limits of 10 CFR 20 and the facility's Technical Specification The licensee agreed to complete the evaluation by March 30, 1980 (81-07-38). Radiation Monitoring System Technical Specification Section 4.10 applies to the periodic monitoring and recording of radioactive effluents and Table 4.1-1 requires daily checks, monthly testing, and calibrations each refueling interval for the radiation monitoring system. An inspector examined procedures and reviewed resuIts of instrument tests and calibrations to ensure that the requirements of the Technical Specifications were being me Periodic Test CPL-PT-12.1 provides instructions for the daily opera bility and response check of the radiation monitoring syste The inspector reviewed records of this test and had no further question Periodic tests CPL-PT-12.2 and 12.3 apply to the bi-weekly tests performed by the health physics and I&C departments respectively, on the process monitoring system to verify operability of automatic functions and response to an external radioactive sourc The inspector reviewed records of the bi-weekly tests performed pursuant to the monthly requirements of Item 19 in Technical Specification Table 4.1-1 and had no further question Health Physics procedure HP-42, "Calibration of Radiation Monitoring System",
had been issued immediately prior to the appraisal and replaced Periodic Test CPL-PT-29, the refueling calibration P The inspector reviewed records of the calibration tests and concluded that the requirements of Technical Specification Table 4.1-1 regarding frequency of calibration of process radiation monitors had been me However, the inspector stated that it appeared certain calibration activities were being performed not in accordance with ANSI N323-1978,
"Radiation Protection Instrumentation Test and Calibration".
.HP-42 requires calibration curves to be generated over the entire range of the instrument for some process monitors by applying a least-squares analysis to two or three calibration points obtained from standards of one radionuclide. Calibration curves for the remaining detectors; for which only one calibration data point is required, assume a linear response from the single data point through the origin. For G-M tube detectors, dead time losses are calculated and factored into the calibration equation. The ANSI standard recommends that where instru ments will be used in radiation fields of widely differing energies, the response of the instrument at several energies should be deter mined. The inspector stated that detector responses to more than one representative radionuclide should be considered were applicable and as a minimum on RMS-18, Liquid Waste Disposal System Effluent Monito Furthermore, it was recommended that several calibration data points be obtained for each monitor and isotope and that a linear response should not be assumed (81-07-39).
The inspector accompanied by a licensee representative conducted an inspection of the area and process radiation monitor The area radiation monitors appeared to be appropriately located and functioning adequately. The inspector noticed two inactive monitors which were not listed in the FSAR nor in HP-4 The licensee representative stated that the scintillation detector used at one time to continuously monitor the settling ponds was damaged by cold weather. The licensee is considering replacing this system. The inspector was also informed that condensate-from the Steam Generator Flash Tank damaged the contin uous monitor used at one time on the flash tank ven Releases from this source are accounted for by RMS-19 which monitors the gassed steam generator blowdown before it reaches the flash tan The inspector
noted that RMS-15, Condenser Air Ejector Monitor, which is an in-line G-M detector, is shielded in a well inside the vent line because of the characteristics of the vapor released through this pathwa The licensee representative stated that RMS-19 is used initially to identify a primary to secondary leak and that if a sample of the Steam Generator Blowdown is greater than 1.OE-4 yiCi/ml, a sample is taken from the air ejector for iodine and particulate analyses and included in effluent report The inspector examined RMS-18, Waste Disposal System Liquid Effluent Monito The monitor appears to be appropriately located in a low background are A review of release permits indicated that internal detector background varied between 3,000 cpm to 20,000 cpm during December 198 A licensee representative stated the monitor setpoint varies with the number of circulating pumps in use and the liquid waste discharge flow rate and is based on 80% of the MPC at the discharge canal (1.OE-07 UCi/ml) with no internal background contamination. The greater the internal.background on the monitor, the less activity permitted to be released in the waste stream. The inspector concluded from observation of the monitor and associated piping and valve layout that adequate controls appear to be in effect to prevent a release of radioactive material following a high activity alarm on RMS-1 The inspector noted that high external background, attributable.by the licensee to activity in the Refueling Water Storage Tank, exists at RMS-14 (Plant Vent Monitor).
The background is approximately twice the countrate obtained from Waste Gas Decay Tank (WGDT)
samples used for RMS-14 calibrations. The low activity in the WGDT appears to be a result of the good fuel integrity of the present fue A licensee representative stated that a good calibration of RMS-14 is difficult to obtain because of the low activity of WGDT samples and high background at the stack, and the irreproducible geometry of the system for remote calibration purposes. The inspector stated that shielding to reduce the background, acquisition of NBS standard calibration gases with greater count rates, or other alternative methods should be devised so that an accurate calibration of RMS-14 can be performe Solid Radioactive Wastes An inspector reviewed records, examined system and equipment, and observed radwaste handling operations. The quantity of solid radwaste generated does not appear to have created a deleterious situation at the facility. The licensee is actively pursuing from an ALARA stand point further means to reduce the amount of solid radwast Trash within the protected area is separated as clean and radioactive in color coded bag Yellow bags containing radioactive trash are routinely collected and compacted in 55-gallon drum The licensee has ordered a new trash compactor which will reduce the volume of compacted radwast Clean trash bags are collected in dumpsters and individually surveyed prior to burial in an onsite sanitary landfil The inspector accompanied a licensee representative while conducting a routine trash survey of the landfil No violations or deviations were identifie Health physics procedure HP-33,
"Drumming of Evaporator Bottoms, Compacting Trash and Dewatering of Spent Resins" sets forth the method for drumming evaporator bottoms, compacting trash and dewatering spent resins. The inspector observed workers compacting trash and had no comments. A:licensee representative stated that there are no plans to ship spent resins offsite until -a high integrity container has been tested and approved. However, CP&L has applied to the State of South Carolina for an extension to their license through June 1981 which will permit dewatered spent resin shipments when such shipments contain less than 1% liquids. The capacity of the licensee's Spent Resin Tank appears to be adequate to store one years generation of spent resin Portable demineralizers are not used at the facilit The inspector observed workers drumming evaporator bottoms. Although HP-33 requires 7 bags of concrete for each drum, it was evident that only 6 bags could be accommodated. Documentation of studies performed by the licensee indicates that the solidified 55-gallon drums of evaporator bottoms meets the burial requirements at the Barnwell facility. The inspector noted that workers were wearing their dosi meters at chest level when it appeared that their gonads would be exposed to greater levels of radiation. The inspector stated that the licensee should ensure that personnel dosimetry is worn in the area of greatest potential exposur A licensee representative stated that a new solidification building and system has been approved and is being designe The new system will include increased storage, remote drumming and modern solidification equipment. Plans also include a new evaporator which will concentrate to 50 percent solids rather than the present 12 percen This will further reduce the amount of solid radwaste on sit Radioactive Waste Shipping The inspector selectively reviewed shipment records for calendar year 1980 and discussed preparation of. shipping papers with licensee repre sentatives. Records indicate that 87 shipments of spent resin, evapo rator bottoms and trash were mad Activity is determined from samples
for evaporator bottoms and spent resin shipment Determination of activity content of compacted waste is based on a method developed by corporate engineers and published in the Health Physics Journal, 1976, Volume 3 Both methods of activity determination would not reveal pure beta or alpha emitting isotope The inspector stated that estimates should be made of Transport Groups I (alpha)
and II (beta)
isotopes because they would probably concentrate in resin beds, evap orator bottoms, and possibly trash. A ratio of applicable isotopes in the primary coolant can be used with appropriate equipment DFs to determine isotopic abundances from GeLi analysis and, portable survey measurements of waste package The inspector stated that the only apparent exemption from listing Transport Groups I and II isotopes on the shipping record is that specified in 10 CFR 71.7(a)
and 49 CFR 173.389(e) which exempts the licensee from all requirements for pack aging and transporting radioactive wastes, including isotope identi fication, if each package contains less than 0.002 microcuries/gram of the licensed materia A concentration determination and comparison to the exempt quantity should be performed on each package (81-07-40).
The inspector reviewed records of receipt of radioactive material and concluded that adequate documentation is, provide The licensee possessed onsite copies of licenses for each company to whch the licensee made radioactive shipment The inspector had no further question The inspector accompanied licensee personnel during loading and final check surveillance of a shipment of radioactive trash. No violations or deviations were identified. However, it was noted that the Quality Assurance department does not audit outgoing radwaste shipments. The inspector verified that the health physics department inspects posting, slings, condition of truck tires, lights, etc., but stated that an independent site group, such as the Quality Assurance department, should conduct independent compliance and safety inspections of outgoing radwaste shipments (81-07-41).
g. Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
(1) ventilation air flows in the auxiliary building; (2) weather protection of HVE-15a; (3) control room indications of HEPA/charcoal filter system operating parameters; (4) isolation of HVE-14 on high radiation alarm from RMS-20; (5) effluent accountability based on secondary side mass balance; (6) radioactivity releases from settling ponds in sludge; (7) safety evaluation for settling ponds and auxiliary boilers;
(8)
process monitor calibrations; (9) identification of Transport Groups I and II isotopes in radwaste shipments; and (10)
QA audits of shipment. Facilities and Instrumentation Facilities Personnel decontamination fa.cilities and the protective clothing dress areas did not appear adequate to support the licensee's radiation protection progra The dress out area became flooded whenever it rained, wetting the protective clothing which were ready for us Protective clothing was in a po6r state of repair, the majority of the gloves and coveralls examined by the inspectors contained holes. This may have contributed to the large number of personnel contamination instances discussed in paragraph 8, especially the skin contamination cases. The inspector stated that the inspection program of laundered protective clothing should be upgraded so that unacceptable protective clothing is not made available for use (81-07-42).
Licensee procedures allow a 5 mR/hr gamma dose rate on anti-C's worn during outages. The inspector recommended a lower maximum dose rate, such as 1 mR/hr beta-gamma be used especially in view of potential beta doses from the current limit (81-07-43).
The inspectors observed decontamination in the Hot Machine Shop of equipment and small tools and reviewed records which indicated that decontamination operations are frequent and routin However, the licensee did not appear to have dedicated decontamination equipment nor an adequate decontamination are The inspector recommended that an equipped, dedicated decontamination facility be provided (81-07-44). Instrumentation Numbers and types of portable instruments appear to be barely adequate to support the radiation protection progra On February 2, 1981, only 19 of 51 portable survey instruments were available for use, including very few ion chamber instruments and no neutron survey instrument Although RC&T personnel indicated that they felt no acute shortage of available instruments, it was observed that for most of one day, almost no instruments were in the instrument room available for check-out and use. The inspector stated that additional portable survey instruments should be obtained including more beta sensitive equipmen A licensee represenative stated that additional instrumentation has been ordered and efforts will be made to expedite delivery (81-07-28).
The licensee has developed a record system for all portable instruments which includes the information recommended in ANSI N323 regarding calibration, maintenance, repair and modificatio Maintenance is performed on portable instruments by the I&C Shop on a fairly low priorit No instrument technician is assigned solely to RC&T instruments repair but the RC&T personnel have observed only occasional -instances of slow servic However, the inspector stated that although the portable instrument accountability system appears to be adequate, more management attention is needed to assure timely maintenance and availability of these instrument The licensee appears to maintain adequate laboratory instrumentation and equipment to support the radiation protection progra Counting room equipment included gamma pulse height analysis equipment and alpha and beta counting equipment. Calibration of the health physics lab oratory counting equipment was observed to include appropriate NBS standards and calibration procedure Personnel monitoring instrumentation consists. of friskers, direct reading pocket dosimeters, and TLD's and appears to be adequate to support the licensee's programs. Calibration of portable instrumen tation is the responsibility of the RC&T Department. All technicians and foremen are supposed to be capable of performing calibration However, in practice one technician takes care of the instrument check-out room and calibrations. Instruments are calibrated to Cs-137 gammas from a 100 Curie source for high ranges and smaller sources for lower ranges. Calibration frequency is quarterly unless an instrument is out of calibration or has been serviced. Procedure HP-11 contains calibration procedures and is available to the technicians but no manuals from manufacturers are available. Calibration and adjustment are done at approximately 75% of full scale on each scale. ANSI N323 recommends that adjustments be made at half scale and 'calibration checked at 20% and 80% full scale. The inspector stated that portable survey instruments should be calibrated in accordance with the recom mendations of ANSI N323 (81-07-45). The inspector also stated that an independent licensee organization such as Quality Assurance should review the calibration program on a regular basi Appropriate NBS traceable standards are used for calibration of all instruments. The calibration is performed in a crowded fan room with very little open space to allow for avoidance of scatte An inde pendent calibration facility check using an NRC RO-3B portable instrument indicated that calculated dose rates from the source were from 7% to 50% lower over a range of exposure rates from 3.0 mR/hr to
3.0 R/h Discrepancies which appear to be attributable to the licensee's facility were also identified through a TLD exposure study conducted during the appraisal. Due to the non-conservative direction of calculated calibration source dose rates and its consistency over the normal dose rate ranges found at a nuclear facility, the inspector recommended a reevaluation of the calibration room (81-07-46).
c. Based on the above findings, this portion of the licensee's program appears to be acceptable, but improvements in the following areas should be considere (1) inspection program for laundered protective clothing; (2) protective clothing dose rate limit; (3) decontamination facility; (4) beta sensitive survey instrument inventory; and (5) calibration facilit anageT A
E&RCSuv o
j E2"C LrAineer r Specdatist-Chee RC&T Foreman RC&T Foreman RC&
For Health Physic-Emg Plan-Environ Sr ALARA Spe Chem Engineer RC&T Techntician
.ALAIV E6RC Engineers RC&T Technicians Health Physics Shipiig RCT Technicians Decon Crews Chemistry Environmental
.
E&RC Technicians Hlealth Physics Counting IC&T Technicians RCT Technicians TC&T Technicians Health Physics Chemistry ealthPhys ConmpatHs Environmental and Radiation Control Organization 1-7-31 Fipure I.