IR 05000261/1989028
| ML14176A806 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/16/1989 |
| From: | Collins T, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A805 | List: |
| References | |
| 50-261-89-28, NUDOCS 8912070073 | |
| Download: ML14176A806 (9) | |
Text
Sp RUNITED STATES NUCLEAR REGULATORY COMMISSION REGION II MARIETTA STREET, ATLANTA, GEORGIA 30323 NoV 22 189 Report No.: 50-261/89-28 Licensee: Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:
50-261 License No.:
DPR-23 Facility Name: H. B. Robinson Inspection Conducte b r 30 - November 3, 1989 Inspec r: Collins atSi ned Approved by:
J. P otter, Chieat Sgned Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This was a routine, unannounced inspection in the area of radiation protection including:
organization and management controls; control of radioactive materials and contamination surveys and monitoring; as low as reasonably achievable (ALARA)
program; internal and external exposure controls; posting and labeling of radiological controlled areas; and followup on previous inspector identified item Results:
The licensee's radiation protection program continues to be effective in protecting the safety and health of station employees as evidenced by interviews with licensee management, supervisiors and personnel from station departments, and-records review. No violations or deviations were identifie..
2(7 C7:
REPORT DETAILS 1. Persons Contacted Licensee Employees M. Burch, Radiation Control Foreman M. Crabtree, Radiation Control Foreman
- J. Curley, Manager, Environmental and Radiolooical Control (E&RC)
- C Dietz, Manager, Robinson Nuclear Project Department
- A. Eaddy, E&RC Supervisor D. Gainey, Specialist, Quality Control
- S. Griggs, Technical Aide, Regulatory Compliance U Kloosternan, Director Regulatory Compliance
- D. Morgan, General Manager
- B. Ritcheky, Senior Radiation Control Specialist B. Toney, Radiation Control Foreman K. Viskup, ALARA Specialist
- H. Young, Manager, Quality Assurance/Quality Control Other licensee employees contacted included radiation control foreman, technicians, supervisors, security force members, and office personne Nuclear Regulatory Commission L. Garner, Senior Resident Inspector
- K. Jury, Resident Inspector
- Attended exit interview 2. Occupational Exposure, Shipping and Transportation (83750).
a. Organization and Management Controls The licensee is required by Technical Specification (TS), to implement the facility organization specified in TS 6. The inspector reviewed chanes made to the the licensee's orcunization staffing levels and lines of authority as they related to radiation protection and radioactive material contro The inspector verified that the licensee had not madeoranizational changes which would adversely affect their ability to control radiation exposures and radioactive materia The inspector also required reviewed the licensee's program for sel f-identification of weaknesses related to radiation protection; control of radioactive material.;
and the appropriateness of corrective actions take No violations or deviations were identifie b. Staffing and Qualifications TS 6.2 specifies minimum plant staffin Final Safety Analysis Report (FSAR) Chapters 12 and 13 also outlined further details on staffin The inspector discussed authorized staffing levels vs actual on-board staffing separately with the E&RC, Manager and E&RC Superviso The licensee's staffing levels for Radiation Control appear to be adequate in providing adequate controls for radiation safety. The licensee has 30 Radiation Control Technicians of which only one is not considered ANSI-N18.1, 1971, qualifie Additionally, the licensee has 11 Radiation Controls Specialists, three Radiation Control Foremen, and one E&RC Superviso The licensee had a recent reorganization of plant staffing in Radiation Control in which one level of management was eliminate Therefore, the E&RC Supervisor and Radiation Control Foreman report directly to the E&RC Manage No violations or dev.iations were identifie c. Audits and Surveillances The inspector discussed the audit and surveillance program related to radiation protection; waste management; and transpotation of radioactive material with licensee representative The inspector reviewed the following Quality Assurance Surveillance Reports (QASRs):
88-026,88-035, 88-051,88-053, 88-054,88-055, 88-060, 88-0621, 88-88-061,88-070, 88-090,88-101, 89-011,89-027, 89-031,89-056, 89-055, and 89-06 These QSARs consisted of the in plant radiological controls program, ALARA program, dosimetry program, whole body counting program, radwaste manaciement, transportation of radioactive waste, and air samplinq program These audits did-not identify any significant problem Effective corrective action is defined and tracked to completion with management revie No violations or deviations were identifie d. External Exposure Control and Personnel Dosimetry 10 CFR 20.101(b) specifies the permissible radiation dose to the whole body to be entered on a NRC Form 4 or equivalent record prior to allowing the individual to exceed the limits of 10 CFR 101(a).
The inspector reviewed selected occupational exposure histories for individuals who exceeded the values in 10 CFR 20.101(a).
The exposure histories were being completed and maintained as required by 10 CFR 20.10 TS 6.5.1.1. requires written procedures to. be established, implemented, and maintained to cover the activities in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, and it subsequently recommends written procedures for Radiation Work Permits (RWPs). The inspector reviewed plant procedure HPP-006, RWPs which provided detailed instructions on the preparation and processing of RWP The inspector reviewed selected active RWPs for appropriateness of the radiation protection requirements based on work scope, location and conditions.. During tours of the Radiation Controlled Area (RCA),
the inspector observed the adherence of plant workers to the RWP requirements and discussed the RWP requirements with plant workers and a Radiation Control Specialist at the job sit The inspector concluded that RWPs specified adequate.controls and that workers were aware of these control No violations or deviations were identifie e. Internal Exposure Control 10 CFR 20.103(a) establishes the limits for exposure of individuals to concentrations of radioactive materials in an in restricted areas, and requires measurements of airborne concentrations of radioactive materials in restricted areas and appropriate bioassays to detect and assess individual intakes of radioactivit The inspector reviewed selected results of bioassays (whole body counts)
and the licensee's assessment of individuals intakes of radioactive material performed during the period of January September 198 The inspector determined by review that no individual intakes.had exceeded one percent of a maximum permissible organ burden (MPOB).
requires the licensee to use process or other engineering controls, to the extent practicable, to limit concentrations.of radioactive material in air to levels below that specified in Part 20, Appendix B, Table, 1, Column 1, so that concentrations, when averaaed over the number.of hours in any week during which individuals are in the area, are less than 25 percent of the specified concentration During tours of the RCA, the inspector observed the use of process and engineering controls to limit airborne radioactivity concentrations in the plant and the inspector discussed these controls with a Radiation Control Specialis The inspector reviewed the following plant procedures:
HPP-101 Administrative Controls of Respirations HPP-102 Respirator Fit Testing
HPP-105 Grab Air Sampling and Control of MPC-Hour HPP-110 Inspection and Maintenance of Respiratory Equipment HPP-111 Use of Respirators HPP-113 Respirator Leak Testing DP-018 Personnel Whole Body Counting DP-020 Assessment of Internal Dose These procedures, which established the licensee's internal exposure controls and assessment program, were consistent with regulations, TSs, and cood health physics practice No violations or deviations were identifie f. Control of Radioactive Materials and Contamination, Surveys, and Monitoring The licensee was required by 10 CFR 20.201(b), 20.403, and 20.401 to perform surveys to show compliance with regulatory limits and to maintain records of such survey TS 6.5 requires the licensee to follow written procedure Radiological control procedures further outlined survey methods and frequencie The inspector observed, during plant tours, surveys being performed by the radiation protection staff. The inspector reviewed selected RWPs during the inspection to determine if adequate controls were specified. The inspector discussed the controls and monitoring with the radiation protection technician assigned, and one worker for each tas During plant tours, the inspector noted radiation level and contamination survey results outside selected cubicle The inspector performed independent radiation level surveys of selected areas and compared them to licensee survey result The inspector reviewed selected survey records for the month of-October 1989, and discussed with licensee representatives methods used to disseminate survey result The inspector noted that only approximately 1044 square feet (ft 2) or 1.5 percent of the RCA was controlled as contaminate At the same time, no new contamination controlled areas had been added. The licensee's goal for 1989 was approximately 2000 ft2 or 2 percent of the RCA. The inspector also noted that the licensee has had only 80 personnel contaminations through October 1989, or 64 percent of their goal for 1989 of 12 No violations or deviations were identifie As Low As Reasonably Achievable (ALARA) Program 10 CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposure ALAR The recommended elements of an ALARA program are contained in Regulatory Guide 8.8, "Information
Relevant to Ensurina the Occupational Radiation Exposure-atNuclear Power Stations will be ALARA," and Regulatory Guide 8.10, "Operating Philosophy for Maintain Occupation Radiation Exposures ALARA."
The inspector discussed the ALARA goals and objectives for 1989, with licensee representatives and reviewed the person - rem estimates and results. The licensee's goal for 1989 was set at 150 person-rem. As of October 30, 1989, the licensee's actual collective exposure was 184.7 person-rem which is 123 percent of the projected goa The reason for the licensee exceeded their projected goal was due to unanticipated. extended maintenance outages. Even though the licensee has exceeded its 1989 person-rem goal, the total exposure expended for 1989 should be well below the national averaae for a sinale unit Pressurized Water Reactor -(PWR).of 346 person-rem, through 198 The licensee has not established a formal coal for 1990, however, in discussions with licensee representatives it appears that the projected goal will exceed the national averaae for a sinale unit PW The reasons are primarily due to maintenance and modifications scheduled for planned outages for the year of 199 The inspector reviewed the ALARA evaluations for several major jobs performed during 1989 and concluded that adequate ALARA reviews were performed to maintain exposures ALAR The inspector discussed with licensee representatives the initiatives that have been approved or implemented to further reduce the total person-rem at the statio The following initiatives have been implemented:
O Elevated lithium concentration in the Reactor Coolant System (RCS) for crud reductio o Resistance Thermocouple Detectors (RTDs) by-pass lines have been eliminated in-containmen o RCS filter size has been chanced from 5 to 1 micro Chesterton die-form graphite packing was installed in 621 valves in the primary system of which 70 of these values have live load packing installed. RCA leakage is at a record lo o Steam Generator (S/G)
manway bolts have been replaced with stud O Closed Circuit TV Cameras have been instituted on several major job C Reduction of contaminated square footage to approximately 1.5 percent of the RC o Reactor-Cavity decon using a strippable coatin o Use of remote handling tools for filter change-out O A WYE Connector has been added to "D" 5 path in the Seal Table Room so that power entries will not have to be made to manually adjust the 5 path for flux mapping operation O Reach rods have been fabricated, for valve manipulation on the Spent Fuel Pool (SFP) filter syste O Operations entering the containment on a monthly basis for normal routines instead of weekl o Licensee representatives have attended dose reduction seminar O A permanent outage manager and team has been establishe No violations or deviations were identifie. Followup on Previous Inspector Identified Items (IFIs) (92701)
a. (Closed)
IFI 50-261/88-26-01:
Management was not involved in managina collective dose on a sufficient frequency to achieve established dose goal The inspector noted that the licensee has established a Plant.Management ALARA Review Committee (PMARC) which includes each department manager. The PMARC holds scheduled meetings as necessary to discuss. radiation exposure goals successes, and problems and to assign action items for resolution and followup when appropriate. This committee provides a forum for plant management to receive up-to-date information and have an in-depth involvement in the ALARA Program. The ALARA Subcommittee reports directory to th PMIARC and provides.information for review and actio b. (Closed) IFI 50-261/88-26-02:
The number of personnel entering the RCA with measurable exposure is consistently higher than the industry nor The inspector was informed by licensee management representatives that the utility is evaluating a organizational analysis (OA) of the utilities work force. The OA was completed in September 1989 and a reduction of work force was completed at Robinson. The licensee has established a policy to insure activities unrelated to nuclear or personnel safety will be highly scrutinized as to need or benefit. The licensee has enforced greater emphasis on preplanning required jobs and work activities, thus reducing the number of personnel entering the RC The licensee has also reinforced work group awareness so that each. group is held accountable for-minimizing the number of persons in its work force while maintaining individual exposures ALAR In addition, the licensee has relocated its Thermoluminescent Dosimeters (TLDs)
and
'Self-Reading Pocket Dosimeters (SRPDs)
from the entrance to the Protected Area (PA)
to the entrance of the RC This should help
7 '
reduce the total collective exposure by decreasing the total number of TLDs issue c. (Closed) IFI 50-261/88-26-03:
The licensee's audit program is not resulting in ALARA program improvement Licensee representatives informed the inspector that the utilities Radiation Control and Protection Manual (RC&PM)
was revised to further define the licensee's Health Physics Assessment Program and the responsibility for conducting these assessment The inspector reviewed these revisions of the RC&PM and determined that the RC&PM does contain a chapter on ALARA with a section requiring periodic ALARA assessment The ALARA assessments will be performed by a technical specialist qualified to perform audits resulting in program improvement d. (Closed) IFI 50-261/88-26-04:.ALARA sub-committee meetinas have not been well attended by members or manacement. The inspector discussed this issue with licensee management representatives and as stated in Paragraph 3.a of this section, this item is considered close (Closed) IFI 50-261/88-26-05:
The process of estimating man-hours needed to perform a job are frequently overestimated and result in discrepancies between estimates and actual man-hours worke The licensee has implemented a computer based Automated Maintenance Management System (AMMS)
for tracking and controllina maintenance work activitie The AMMS provides a component history file containing actual man-hours expended in performing specific task Further development of the AMMS data base and utilization of the AMMs information for future job planning should allow maintenance and planning personnel to more accurately estimate man-hours required and person-rem expecte The inspector concluded that with further expansion and utilization of historical data on specific tasks should help eliminate the large discrepancies between estimates and actual man-hours worke (Closed)
IFI 50-261/89-FRP-01:
Followup and document a licensee identified violation which was described in LER 89-003-00 where two contract workers exceeded 1250 mRem with an incomplete NRC Form-The inspector discussed this issue with licensee management representatives and reviewed the subject LE The two contract workers did not reveal to the licensee that they had previous occupational exposure in the first quarter of 1989, where upon arrival at the licensee's facility no exposure was recorded on their NRC Form-4 for the first-quarter of 198 One of the two contract individuals exceeded the 1250 millirem quarterly radiation exposure by 253 millirem and the other individual by 683 millire Both cumulative radiation exposure totals were well below the 3000 millirems permitted under 10 CFR 20.101(b)(1).
On February 11, 1989 the licensee became aware of certain radiation exposure history information not properly recorded on a NRC Form-4 and the licensee denied access of the individuals into the restricted area The licensee submitted this LER. in accordance with
The inspector concluded after review that the licensee reported this event as required and the actions taken by the licensee were considered adequat. Exit Interview The inspection scope and findings were summarized on November 11, 1989, with those persons indicated in Paragraph 1 abov The inspector described the areas inspected and discussed in detail the inspection finding Licensee management acknowledged the inspectors findings. The licensee was informed of the status of the items in Paragraph Proprietary information is not contained in this report and no dissenting comments were received from the licensee.