IR 05000261/1982031

IE Insp Rept 50-261/82-31 on 820823-27.Noncompliance Noted: Area in Drumming Room W/Radiation Level Above M/H Not Locked & Failure to Follow Health Physics Procedures HP-7 & HP-28

ML20027E595
Person / Time
Site:	Robinson
Issue date:	09/16/1982
From:	Albright R, Barr K, Debs B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20027E576	List: IR 05000261/1982031 ML20027E580 ML20027E587
References
50-261-82-31, NUDOCS 8211150521
Download: ML20027E595 (6)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSIOR

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101 MARIETTA STREET, N.W.

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ATLANTA, GEORGIA 30303 o

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September 22, 1982 Report No. 50-261/82-31 Licensee:

Carolina Power and L ight Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name:

H. B. Robinson Docket No. 50-261 License No. OPR-23 Inspection at H. B. Robinson site near Hartsville, SC Inspectors 9 //4 / L HT Albright Dat'e S16ned 9f/4ffL

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Ofteggned Technical Inspection Branch Division of Engineering and Technical Programs SUMMARY Inspection on August 23-27, 1982 Areas Inspected This routine, unannounced inspection involved 61 inspector-hours on site in the areas of control of radioactive material, the RWP program, contamination control, control of high radiation areas, and compliance with approved procedures.

Results Of the five areas inspected, no violations or deviations were identified in three areas; three apparent violations were found in two areas.

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

• R. B. Starkey, Plant General Manager

• S. Crocker, Manager, Environmental and Radiation Control

• A. McCaully, Principal Engineer Corporate Nuclear Safety

• D. Baur, Project Specialist QA/QC

• F. Gilman, Project Specialist Regulatory Compliance

• W. MacCready, Supervisor Radiation Control

• C. Wright, Specialist Regulatory Compliance B. Ritchie, RC Foreman Other licensee employees contacted included 8 technicians..

NRC Resident Inspector

• S. Weise

• Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on August 27, 1982, with those persons indicated in paragraph 1 above. The inspector discussed with licensee management the apparent violations of failure to follow procedures, and an unlocked, unguarded high radiation area.

The violations were acknowledged by the plant general manager.

3.

Licensee Action on Previous Enforcement Matters Not inspected.

4.

Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraph 5.

5.

Control of Radioactive Material During a tour of the facility the inspectors observed personnel decontamina-ting a 500 gallon waste oil tank. The tank was posted with stickers indi-cating that the tank was internally contaminated with contact dose rates outside the tank up to 0.3 mr/hr. Initial discussions with the Padiation

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1 Control foreman in charge of the decontamination effort indicated that the origin of the tank, its contents or the disposition of the contents were not known.

The Manager E and RC was able to determine that the tank had been moved from the fossil fueled unit I area to the nuclear unit 2 radiation control area after sampling of the tank contents indicated that the tank contained radioactive material.

The tank sampling occurred as a plant requirement for sampling prior to sale of the waste oil to a reprocessing company.

Tank sampling first occurred on August 3 at 9:30 a.m., with results of 3.74E-7 microcuries/mi and Co-60 was the identified isotope. At 2:30 p.m.,

that day the tank was resampled with results 9.54E-7 microcuries/ml. The

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minimum detectable concentration for this operation is 1.0E-7 microcuries/

ml.

The licensee began an investigation of the origin of the contaminated oil at

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the inspector's request. It was then learned that the tank had been cleaned in January 1982. After that, time records indicated that no oil was sold from the tank until June 1982. A gamma-scan of an oil sample from the tank prior to the June 1982 sale did not indicate that any contamination was present. The licensee is currently attempting to determine the origin of the contaminated oil in the tank.

Further investigation of this problem indicates that the licensee does not have a procedural requirement to sample fluids being unconditionally released from the radiation control area.

In addition, the method of sampling waste oil may be inadequate in that the oil is not mixed prior to sampling.

The inspector has requested the licensee to determine the origin of the radioactive material found in the tank.

This is an unresolved item.

(82-31-01)

6.

RWP Program The inspectors reviewed survey records for routine RWP 2 which is written

to cover general decon, trash removal, and laundry handling.

The RWP was i

initiated March 5, 1982, and is still in effect; however, the last contami-

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nation survey in the file was dated July 16, 1982. The survey records for j

the RWP contained only two surveys that were performed to cover decontamina-tion work. During the last outage lasting from March 1982 thru August 1982,

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extensive decontamination work occurred.

However, survey records for the decontamination work were not maintained. The Manager E and RC stated that decontamination personnel conduct surveys for their work and take the smears to the counting room for counting.

The counting room then notifies these personnel of the counting result... The counting room documents that smears were counted and the results.

However, there is no documentation to corre-late surveys with the decontamination work performed. Since contamination surveys cannot be correlated to decontamination work, the licensee is not

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able to demonstrate that respiratory protective devices were or were not required for the decontamination werk.

Discussions with decon personnel confirm that surveys were performed although not recorded.

The inspector

stated that records of surveys should be maintained to demonstrate compli-ance with regulations. The routine RWP program and supporting sueveys will be inspected during a future inspection. (82-31-02)

7.

Contamination Control i

On August 25, 1982, the inspector removed a small amount of crystalized Boron which generally covered a valve bonnet located in the Spent Fuel Pit Heat Exchanger Room. The inspector counted the smear with a licensee RM14 radiac equipped with a pancake probe.

The smear read approximately 1500 DPM/ smear. The room was not posted as a Contaminated Process Equipment i

Area as required by H. B. Robinson Plant Procedure HP-1.1.

The licensee conducted a smear survey of the room and found no contamination in excess of 1000 dpm/100cm. The inspector offered to show licensee management where

the contamination was found. Licensee management declined. On August 26, 1982, the inspector took a smear of a pump foundation mount in the Spent Fuel Pit Recirculating Pump Room.

The smear read approximately 2,500

dpm/100 cm. The room was not posted as a Contaminated Process Equipment Area.

The licensee conducted a survey of the room and found no loose surface contamination exceeding the HP-1.1 limit. The inspector offered to show licensee personnel where the smear had been taken. Again licensee personnel declined.

The licensee contamination survey technique will be reviewed during a future inspection. (82-31-03)

8.

High Radiation Area Controls

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On August 25, 1982, an inspector observed that the cage fence door of the Drum Storage Area, posted as a High Radiation Area, located in the Drumming Room, appeared to be secured by a chain and padlock.

When the inspector gave a slight push on the door, the chain fell away from its anchor point in the wall. It appeared that the eyebolt used to anchor the chain to the wall had been dislodged at an earlier time and had been placed in the over-

size hole to give the appearance of being locked. Licensee Health Physics personnel were immediately notified of this situation.

Initial licensee management investigation alleged that the eyebolt had been accidentally knocked out of the wall during day shift drum movement from the room. The inspector directed licensee management to the Health Physics Shift turnover log.

A 0000 to 0800 log entry on August 25, 1982, identified that the aforementioned door would not secure and could not be locked.

Further licensee investigation indicated that a contractor identified the door as unsecurable sometime on the day of August 24, 1982.

No compensatory actions were taken to preclude unauthorized entry into the high radiation area.

Licensee radiation surveys of the Drum Storage Area on August 22, 1982, indicated general radiation levels to 3 rem /hr. Failure to adequately control the entrance to the high radiation area is a violation of Technical

Specification 6.13.lb.

The cause of the violation appears to be that personnel (contract technician who found the area to be unsecurable, the

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licensee technician who made the entry in the HP shift turover log, and licensee personnel who subsequently read the log) did not know what action was required when a locked high radiation area is found to be unsecurable.

(82-31-04)

9.

Compliance With Approved Procedures a.

On August 24, 1982, as the inspectors were frisking out of the plant Radiation Control Area, a frisker alarmed indicating approximately 1000 dpm on the inspector's hand.

A resurvey of the area by the control point technician again caused the frisker to alarm.

The instrument was set to alarm at 100 CPM above background as required by

procedure. The inspector asked the technician if a personnel contami-nation report would be completed. The technician replied that for low

level contamination that could be removed after one decontamination j

attempt, as occurred at this time, no personnel contamination report i

was required.

No personnel contamination report was completed. The l

inspector reviewed health physics procedure HP-28 and found that section 3.2.1.2 of that procedure requires a personnel contamination report.

The inspector stated to licensee management personnel that failure to complete a personnel contamination report i s a violation for failure to adhere to procedure HP-28 as required by techr*1 cal specification 6.11. (82-31-05)

b.

On August 25, 1982, while on a tour of the facility during the evening shift, the inspectors observed personnel in the drumming room.

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personnel were drumming evaporator bottoms. The inspectors found that these personnel were signed in on RWP-2 for general decon work and not RWP-13 which was written for drumming evaporator bottoms. The survey

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j requirements of RWP-13 had been met by the radiation control staff.

The inspector stated that failure to be on the correct RWP indicated

that these personnel had not read and understood the provisions of the correct RWP as required by health physics procedure HP-7, Radiatica

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Work Permits. This is a failure to adhere to health physics procedures required by Technical Specification 6.11. (82-31-06)

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10.

Radioactive Gaseous Effluent Monitoring Discussions with licensee management ir.dicated that the licensee does not

have provisions for correcting pressure differentials between the main vent exhaust stream and the associated offline sample system. The inspector stated that this situation could result in a nonconservative systematic error in the plant's radioactive gaseous effluent monitoring.

Licensee management stated that they would evaluate gas monitoring chamber pressure l

conditions in the offline sampling system. This evaluation will be reviewed

during a future inspection. (82-31-07)

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11.

Concentration of Natural Radioactivity During the inspection the inspector observed 55 gallon drums of mixed bed resins that the licensee used in the make-up water system.

The water filtered through these resins is pumped from deep wells on the plant site.

The resins remove minerals and natural radioactivity.

The natural radio-activity is concentrated by this process and drums containing the resin have contact dose rates up to 0.6 mrem /hr. The inspector notified the licensee regulatory compliance staff at H. B. Robinson that the plant should contact the state for licensing requirements in handling and disposing of this material. The results of this contact will be determined during a future inspection. (82-31-08)

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