IR 05000261/1992003
| ML14178A200 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/09/1992 |
| From: | Pharr E, Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A198 | List: |
| References | |
| 50-261-92-03, 50-261-92-3, NUDOCS 9204030254 | |
| Download: ML14178A200 (22) | |
Text
REG&,
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION il 101 MARIETTA STREET, ATLANTA, GEORGIA 30323 MAR 13 1992 Report No: 50-261/92-03 Licensee: Carolina Power and Light Company P.O. Box 1551 Raleigh, NC 27602 Docket No.: 50-261 License No.: DPR-23 Facility Name: H. B. Robinson Inspection Conducted:F ry 10-14, 1992 Inspector(s).
A E. B Pharr
/
Da e igned 4 R. B.'Shortridge Date Bigned Accompanying Pe so
A. Parker Approved by:
P. Pot er, Chief D te Signed Faciliti Radiation Protection Section Emergenc Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine unannounced inspection was conducted in the area of occupational radiation safety and included an examination of audits and appraisals, training and qualifications, external and internal exposure control, control of radioactive materials and contamination, surveys and monitoring, maintaining occupational exposures ALARA, and planning and preparation for the upcoming refueling outag In addition, Information Notices and licensee response to previously identified inspection findings were reviewe Results:
Based on interviews with licensee management, supervision, personnel from station departments, and records review, the inspector found the radiation protection program to be managed adequately. The licensee's programs for external and
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internal radiation exposure controls were effective and functioning adequately to protect the health and safety of occupational radiation workers. Other identified licensee 9204030254 920313 PDR ADOCK 05000261 G
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strengths included general housekeeping and postings throughout the Radiation Controlled Area (RCA). A respiratory protection program weakness for failure to ensure Grade D air quality and a licensee-identified violation of Technical Specification (TS) 6.13.1 for a High Radiation Area entry without a monitoring instrument were identified as non-cited violations (NCV).
In addition, inspector concerns were identified to plant management involving the adequacy of the E&RC program for self identification of weaknesses and followup corrective actions, as well as outage planning and duration. An inspector followup item (IFI) was identified regarding the evaluation of the effectiveness of licensee corrective actions to prevent recurrence in response to an improperly latched control rod event during the previous outag.
Persons Contacted Licensee Employees
- R. Barnett, Manager, Outage and Modifications
- D. Beaur, Regulatory Compliance
- R. Beveray, Manager, Quality Control (QC)
- S. Billings, Technical Aide, Regulatory Compliance
- C. Bowen, Specialist, Nuclear Assessment Department (NAD)
- W. Brand, Radiation Controls (RC) Supervisor, Environmental and Radiation Control (E&RC)
- R. Chambers, Plant General Manager
- J. Dobbs, Section Manager, NAD
- W. Dorman, Manager, NAD
- D. Gainey, Senior Specialist, NAD
- E. Gardner, E&RC Support
- W. Hatcher, Manager, Corporate Nuclear Security
- A. Padgett, Manager, E&RC
- D. Stadler, Onsite Licensing Engineer
- L. Williams, Manager, Security Other licensee employees contacted included engineers, technicians, and office personne Nuclear Regulatory Commission
- L. Garner, Senior Resident Inspector
- J. Potter, Chief, Facilities Radiation Protection Section
- Attended November 14, 1991 Exit Meeting Organization and Staffing (83750)
During the inspection, Radiation Protection (RP)
organization and staffing levels were reviewed and discussed with cognizant licensee representatives. No changes were noted in the organizational structure since a previous inspection conducted November 5-8, 1990, and documented in Inspection Report (IR) 50-261/90-25. However, since the previous inspection the licensee had changed E&RC manager The inspector noted that the new manager had extensive nuclear experience with several years at the supervisory and/or managerial leve Four supervisors reported directly to the E&RC manage Since IR 90-25, the two operations RC supervisor positions had been filled by former RC technicians. Currently the RC staff consisted of 22 technicians with an additional vacant position to be filled following the upcoming refueling/maintenance outage. The inspector noted that the Dosimetry, Instruments, and Respirators (DIR) supervisor managed a staff consisting of seven technicians. The E&RC
support manager, likewise reporting directly to the E&RC manager, supervised a technical staff of 1 During discussions with licensee representatives the inspector was informed that currently several RC staff members were rotating through the ALARA group approximately every 18 month Through discussions with RP management and employees and direct observation of job support, the inspector noted that the present RC organization and staffing were adequate for ongoing activitie No violations or deviations were identifie.
Audits and Appraisals (83750)
The inspector reviewed the licensee's program for self identification of weaknesses related to the radiation protection program and the appropriateness of corrective action taken. Specifically the inspector reviewed 1991 and 1992 internal audits, Radiation Safety Violations (RSVs),
Minor Adverse Condition logs, and procedures for implementing the licensee's program for self-identification and correctio The inspector reviewed audits performed by the licensee's Nuclear Assessment Department (NAD).
The inspector was informed that NAD periodically audited individual licensee departments. Following review of these internal audits the inspector noted that they included an indepth review of E&RC records and procedures, as well as, observations of performance and interviews with technical staff and management. During the two NAD audits which had been performed since February 1991, the inspector noted that both recognized poor radiological work practices as a significant negative finding. The inspector also noted that the audits did not analyze the root cause(s) of the problem, but did indicate that the problem did not appear to be related to a lack of knowledge or inadequate training on the part of the technical staf In response to some of the concerns brought out in the February 1991 NAD audit, E&RC revised Health Physics Procedure HPP-011, "Radiation Worker Awareness Assessment."
The revised procedure was implemented in November 1991 and required E&RC to "police" more in the RCA. By procedure, on a monthly basis, HP technicians were required to choose at least ten individuals at random signed in on a Radiation Work Permit (RWP) and complete a checklist of items related to the possession and use of dosimetry and general radiation work practices. The inspector noted that the process appeared to create more paperwork and, while it most likely
would identify more radiation safety violations and possibly adverse trends, it still did not adequately address the root cause(s) of the identified problems. The inspector also noted that it took nine months (February 1991 to November 1991) to implement the corrective actio Following review of the licensee's RSV and Minor Adverse Condition logs, the inspector noted that during 1991 only 7 and 11, respectively, were identified. Again the inspector noted that the licensee generally identified poor work practices as the causal factor without specifically addressing a true root cause or initiating corrective actions to prevent recurrence. Also with so few self identified problems and with true root causes not addressed the inspector noted that the licensee's tracking and trending system was not enhancing the program for self identification and correction. The inspector discussed with licensee representatives concerns that E&RC was not constructively self-critical in identifying and correcting poor radiological work practices through the use of RSVs, Minor Adverse Conditions, or HPP-01 During the onsite inspection a revised version of procedure, E&RC-013, "E&RC Corrective Action Program," was approved by E&RC management with an effective date of February 14, 199 The procedure established a program for investigation, resolution, tracking and trending of positive and negative work practices in the area of E&RC responsibility and provided the tools for self-assessment by initiating improvement. Licensee representatives informed the inspector that this procedure would benefit the program by accounting for the entire self-assessment program whereas previously, several procedures were required to initiate different levels of identified weaknesses and subsequent corrective actions. Also since this procedure provided a basis for identifying positive as well as negative work practices by all plant personnel, licensee representatives felt this program would become more of a plant wide initiative rather than a RC effort with negative impac The procedure, as well as recently issued memorandums reviewed by the inspector, emphasized responsibilities of plant management to ensure their personnel were aware of and complied with good HP practices, that they identify commendations and RSVs, reviewed these with the responsible party, and implemented appropriate corrective and preventative actions to avoid recurrence for identified negative finding In addition, all plant personnel were responsible for increasing attention to radiological controls and ALARA requirements and conducting their work in accordance with these established policies. Also, responsibility was placed with plant personnel, not only RC, for identifying both positive and negative work practice The inspector discussed with E&RC and plant management their expectations for the revised self-identification and corrective action program. Cognizant licensee representatives informed the inspector that following full implementation, the program should be beneficial in raising worker awareness of good and bad work practices and thereby strengthening their overall self-assessment program and correcting poor radiation work practice No violations or deviations were identifie.
Training and Qualifications (83750)
10 CFR 19.12 requires, in part, that the li censee instruct all individuals working in or frequenting any portions of a restricted area in the health protection aspects associated with exposure to radioactive material or radiation; in precautions or procedures to minimize exposure; in the purpose and function of protection devices employed; in the applicable provisions of the Commission regulations; in the individual's responsibilities; and in the availability of radiation exposure dat The inspector reviewed the licensee's overall training requirements for both CP&L and contract employees. The training program consisted of various stages dependant upon the employee's job description. CP&L employees received generic training and plant-specific training followed by completion of qualification cards (q-cards), which provided the employee with job-specific information and on-the-job training (OJT).
The q-card system involved the successful completion of specified tasks or dutie The inspector noted that each employee generally received at least eight hours of q-card training each quarter. Individuals were designated as either Level I-or Level II-trained with the difference in designations being dependent upon the complexity of the work. The inspector noted that contract personnel received general procedures training (two days),
General Employee Training (three days), followed by specific, job-related procedure training. Each set of training, regardless of training level, was followed by a written test requiring successful completion with a score of at least 80 percent correc Following discussions with licensee representatives the inspector noted that the licensee's Technical Training Group consisted of a staff of seven, including three full-time instructors with two additional contract instructors brought in during outage In addition, supervisors and other individuals responsible for OJT were trained approximately every two years on how to conduct OJT. The inspector noted this was a strength of the licensee's overall progra *
Based on a review of training records and discussions with licensee personnel during the inspection, the inspector noted that the licensee's training program as well as the training staff levels were adequat No violations or deviations were identifie.
Facility and Equipment Upgrades (83750)
During the onsite inspection the inspector examined indicators of management support for the RC program. In addition to management allocating sufficient resources to reduce contaminated areas within the plant, the following equipment purchases and/or facility modifications needed for the RC program were noted:
Remote area radiation monitors to allow for remote readouts of dose rates in specific areas and remote cameras to be used in the same capacit *
Upgrades to the eight Personnel Portal.Monitors to provide an increase in detectabilit *
Surrogate tour with the mechanism to upgrad *
100 Digital Alarming Dosimeters (DAD) from the Brunswick plant for use during the upcoming outage with a corporate plan in action to implement a CP&L-wide DAD network in 199 *
Three tool monitors and one bag monito *
Stand-up Whole Body Counter to reduce counting time of personnel from approximately eight minutes to two minute *
Porta-Count system to replace the respirator fit testing booth and associated equipmen The inspector informed licensee representatives that although most utilities have previously purchased such equipment and made these modifications, the recent equipment and facility upgrades should prove beneficial to the RC progra No violations or deviations were identifie.
External Exposure Control (83750)
10 CFR 20.101 requires that no licensee possess, use, or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of
one calendar quarter a total occupational dose in excess of 1.25 rems to the whole body, head and trunk, active blood forming organs, lens of the eyes, or gonads; 18.75 rems to the hands, forearms, feet and ankles; and 7.5 rems to the skin of the whole bod CFR 20.202(a) requires each licensee to supply appropriate personnel monitoring equipment and requires the use of such equipment by each individual entering a restricted area under such circumstances that he receives or is likely to receive, a dose in any calendar quarter in excess of 25 percent of the applicable value specified in 10 CFR 20.101(a).
10 CFR 20.202 requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipmen Program Implementation The inspector reviewed 1991 external exposure records for four workers with internal contaminations resulting from uptakes and selected individuals involved with RWP activities associated with various filter changeout Following discussions with licensee personnel, the inspector was informed that throughout 1991 workers performing filter changeouts and other high radiation dose jobs were provided with wrist and finger dosimetry for each hand in an effort to determine if extremity monitoring was necessary, and if so whether ring or wrist thermoluminescent dosimetry (TLDs) were more appropriat The inspector noted that the maximum whole body and extremity doses during any one quarter were 413 millirem (mrem) and 409 mrem, respectively. The maximum annual whole body and extremity doses were 610 mrem and 444 mrem, respectively. The inspector concluded that the licensee monitored whole body and extremity doses adequately and that all external exposures were within 10 CFR Part 20 limit January 23, 1992 High Radiation Area Entry TS 6.13.1(a) states in lieu of the "control device" or
"alarm signal" required by paragraph 20.203(c)(2) of 10 CFR 20, each High Radiation Area in which the intensity of radiation is greater than 100 mr/hr, but equal to or less than 1000 mr/hr when measured at 18 inches from a source within the area, shall be barricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by
issuance of a RWP. Any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates the radiation exposure rat The inspector reviewed an Adverse Condition Report (ACR) and discussed with licensee representatives the details surrounding a licensee-identified violation of TS 6.13.1(a).
On January 23, 1992, two individuals entered a high radiation area (HRA) after being issued a survey instrument and instructed of the potential radiation hazards in the work area by RC. One individual exited the area, inadvertently taking the survey instrument with him, thus leaving his co-worker in a HRA without a survey instrument. The inspector informed licensee representatives that the failure to comply with TS requirements for entry into a HRA was a violation of TS 6.13.1(a) (50-261/92-03-01).
Followup investigations revealed that the worker was in a low dose waiting area for approximately two minutes while in the HRA without a survey instrument. In addition, neither worker involved received a significant exposure to radiation. At the time of the onsite inspection an ACR had been written on the event and RSVs were written against both workers involve Also disciplinary actions had been taken against the worker who left his co-worker in the HRA without the survey instrument. The inspector informed licensee representatives that this licensee-identified violation of TS 6.13.1(a) would not be cited because criteria specified in 10 CFR 2, Section V.A of the enforcement policy were me One NCV of TS 6.13.1(a) for failure to comply with dose monitoring requirements for entry into a HRA was identifie.
Internal Exposure Control (83750)
10 CFR 20.103(a)(1) states that no licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a quantity of radioactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in Appendix B, Table 1, Column CFR 20.103 (a)(3) requires, in part, that the licensee, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any
combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individual CFR 20.408(b) and 10 CFR 20.409(b) require that the licensee make a report to the Commission, and notify the individual involved, of the radiation exposure of each individual who has terminated employment. The report is to be furnished within 30 days after the individual's exposure was determined by the licensee or 90 days after the date of termination of employment or work assignment, whichever is earlie The inspector reviewed air sampler results associated with selected filter changeouts and incore detector RWP wor The inspector noted all air sampler results reviewed were less than 25 percent of the maximum permissible airborne concentration (MPCa).
During discussions with licensee representatives the inspector was informed that MPCa-hrs were not tracked for workers if air sampler results were less than 25 percent of MPCa or if respiratory protection factors reduced air sampler results to less than 25 percent of MPCa. Following review of MPCa-hr assignments for selected individuals the inspector noted that the maximum assigned internal exposure based on air sampler results was 0.40 MPCa-hrs. The inspector noted that the exposure was assigned to an individual associated with an internal contamination even The inspector verified that no exposures in excess of the 40 MPCa-hr control measure had occurred since January 1, 199 During discussions with licensee representatives the inspector was informed that during 1991 four internal exposures based on uptakes were identified. The inspector reviewed records associated with each uptake and noted that the maximum permissible organ burden (MPOB) was 4.8 percent to the lower torso. The licensee calculated 3.7 MPCa-hrs for the individual based on a deposition of 21 nanoCuries (nCi) of cobalt-60 in the lower torso. However, the actual internal exposure assigned to the individual was 0.40 MPCa hrs based on the area air sampler. The inspector also reviewed the seven day cumulative exposure for the individual and noted no other MPCa-hrs were assigne Following discussions with licensee representatives, the inspector was informed that the licensee requires annual and termination whole body counts for all radiation workers and all facial contaminations required followup whole body count For selected RC staff members and workers signed in on selected filter changeout RWPs, the inspector verified that all received an annual whole body count during 199 Also, the inspector verified that for selected individuals
who terminated during 1991, termination whole body counts were performed. In addition, the inspector verified termination exposure reports were issued to those individuals generally within thirty days following their termination date. The inspector also reviewed personnel contamination event logs for January 1,-December 31, 1991 and verified that all personnel with facial contaminations received followup whole body counts. For those selected individuals reviewed, the inspector noted all whole body count results were less than the minimum detectable limit (MDL).
No violations or deviations were identifie Respiratory Protection Program Program Implementation 10 CFR 20.103(c)(2) permits the licensee to maintain and to implement a respiratory protection program that includes, at a minimum: air sampling to identify the hazard; surveys and bioassays to evaluate the actual exposures; written procedures to select, fit and maintain respirators; written procedures regarding the supervision and training of personnel and issuance of records; and determination by a physician prior to the use of respirators, that the individual is physically able to use respiratory protective equipmen The inspector reviewed records for selected employees signed in on RWP 92-0132 for work associated with the Seal Table Room incore detector changeout. The inspector verified that for records reviewed each worker was trained to use respiratory protective equipment, fit-tested, and medically qualified in accordance with appropriate requirement No violations or deviations were identifie Breathing Air Quality 10 CFR 20 Appendix A, Footnote (d), requires adequate respirable air of the quality and quantity in accordance with NIOSH/MSHA certification described in 30 CFR Part 11 to be provided for the atmosphere supplying respirator CFR 11.121 requires that compressed, gaseous breathing air meets the applicable minimum grade requirements for Type 1 gaseous air set forth in theCompressed Gas Association (CGA) Commodity Specification for Air, G-7.1 (Grade D or higher quality).
TS 6.11 states procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposur HPP-110, "Inspection and Maintenance of Respiratory Equipment, Rev. 11," dated April 27, 1991, provides instructions for inspection and maintenance of routine use of respiratory protective equipmen The procedure requires breathing air to be sampled every 92 +/- 23 days to ensure air quality of Grade D or better for each compressor, if serviceable. The procedure also requires the sampler to ensure that a representative sample is obtained from A, B, C, and Primary compressors. In addition, if a sampling point is unavailable for testing, the procedure requires that Attachment 7.1 of PLP-024, "Surveillance Test Exception Form," be completed and routed to the RC superviso Licensee representatives informed the inspector that HPP-110 had been revised to require quarterly sampling of each of the licensee's four supplied-air system compressors, when serviceable, in response to URI 90-25-0 The URI was issued to determine procedural and/or operational guidance, and to review operational records in an effort to verify that each of the four compressor systems potentially supplying input to the supplied-air system were sampled and Grade D air verified on a routine basis. Following review of January 1, 1989 through September 30, 1990 records, the licensee was unable to determine which compressor was in service at the time of sampling nor to verify for the period reviewed that each of the compressors, which could have potentially been supplying breathing air, were providing Grade D quality air. The inspector informed licensee representatives that the previously identified URI would be considered a violation of TS 6.11 for failure to have adequate procedures to ensure Grade D quality air for all supplied-air breathing system compressors. From review of 1991 quarterly sampling records the inspector noted that as required by procedure each of the licensee's four compressor systems were sampled quarterly, if serviceable, or the appropriate Attachment 7.1, "Surveillance Test
Exception Form," was completed for compressors out of service. The inspector verified that for each quarter each compressor tested met ANSI/CGA G7.1-1989 Grade D air quality criteri During review of supplied breathing-air compressor maintenance records and discussions with licensee representatives the inspector identified an additional concern regarding adequacy of the current procedur The licensee's procedure did not allow for verification of Grade D air following major maintenance activities and prior to routine quarterly sampling. Specifically, the inspector noted that compressor system "C", one of the primary station compressors, was not serviceable and thus was not sampled the second and third.quarters of 1991. Review of maintenance records indicated a total of 26 days during the months of March, May, June, July, and September, for the performance of major maintenance work on compressor "C".
Further, operability of the system could not be determined during the period from March 22, to October 28, 199 On October 29, 1991, compressor "C" was sampled and met Grade D air criteria. The inspector discussed with licensee representatives the importance of ensuring Grade D air quality and informed the licensee that the failure to do so following major maintenance was an additional example of an inadequate procedur Licensee representatives acknowledged the inspector's concerns regarding the procedural deficiency and committed to implement corrective actions by March 31, 199 The inspector informed licensee representatives that the URI regarding procedure adequacy to ensure Grade D air quality for all four of the compressor systems on a routine basis, and following major maintenance was a violation of TS 6.11(50-261/92-03-02).
The inspector noted that the licensee initiated immediate corrective actions in response to the URI and additional commitments were made to correct HPP-110 by March 31, 1992, to ensure Grade D quality air following major maintenance. The inspector informed licensee representatives this NRC-identified violation was not being cited because criteria specified in Section of the enforcement policy were me One NCV of TS 6.11 for failure to have adequate procedures to ensure Grade D quality air for all supplied-air breathing system compressors was identifie.
Operational Radiation Controls (83750) Facility Tours During tours of the facility, the inspector observed the licensee's posting and control of radiation areas, high radiation areas, contamination areas, radioactive materials areas, and labeling of radioactive material and noted no apparent problems. During these tours the inspector observed a generally clean and tidy facility, including freshly painted floor In addition, the inspector noted that survey and monitoring equipment was operable and calibrated on a semiannual frequenc No violations or deviations were identifie Area Contamination Following discussions with licensee representatives the inspector noted that the licensee had expended a significant amount of resources to reduce contaminated areas of the plant since the previous inspection conducted November 4-8, 199 The inspector noted that the licensee had initiated a Contaminated Process Equipment Area (CPEA) program which required the floors in a specified area be maintained below the licensee's contamination limits while any equipment in the area was potentially contaminated. The basis for the licensee's program was to permit general observations and tours of areas within the plant with contaminated equipment without the contaminated area protective clothing requirements. Licensee representatives stated that in addition to significantly reducing the amount of contaminated area within the plant, the program had also been beneficial in reducing the volume of contaminated waste and laundry generated by the facilit Following discussions with licensee representatives, the inspector was informed that the RCA contaminated area averaged approximately 1,349 square feet (ft ) in 1991, 1.56 percent of the totpl area in the RCA, while the 1990 average was 2,820 ft.
The licensee's goal for contaminated area during 1991 was 2000 ft.
No violations or deviations were identifie Radiation Work Permits (RWP)
The inspector reviewed selected RWPs for appropriateness of the radiation protection requirements based on work scope, location, and
conditions. The inspector reviewed the following RWPs:
92-0132:
All activities associated with Seal Table Room Incore Detector Changeout
91-0150:
All activities aissociated with Waste Holdup Tank (WHUT) Filter Changeout
91-0148:
All activities associated with Spent Fuel Pit (SFP) Filter Changeout
91-0146:
All activities associated with Reactor Coolant System (RCS) Filter Changeout Each RWP, as well as its associated pre-job briefing, appropriately addressed radiological concerns and provided for appropriate RC monitoring and surveying throughout the job. Pre-job ALARA reviews contained appropriate ALARA recommendation The inspector verified that workers signed on the RWP attended the pre-job briefing. The RWPs also required proper protective clothing, respiratory protection, and dosimetry as needed. The inspector also noted that periodically RC supervisors performed job coverage
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evaluations that included critiques of radiation worker practices and recommendations for improvements. The inspector found the licensee's program for RWP implementation to adequately address radiological protection concerns, and to provide for proper control measure No violations or deviations were identifie.
Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA) (83750)
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 exposures as low as reasonably achievable. 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 Maintaining occupational Radiation Exposures ALARA."
The inspector reviewed the licensee's program to maintain occupational exposure ALARA. The review consisted of an examination of the 1990-1991 refueling Outage 13 Report, internal memorandum, and interviews with maintenance and ALARA personne The licensee experienced a significant amount of collective dose in 1991 as a result of the failure to latch the C-7 control ro During recovery this and several other
unplanned events occurred that increased the unbudgeted dose to approximately three quarters of the 1991 collective dos Approximately 140 person-rem was incurred during the 75 day outage extension in 1991. During the rest of the operating year the licensee averaged 4.7 person-rem per mont The inspector reviewed ALARA reports that listed factors affecting the increased outage duration. In refueling/maintenance outage 13 the licensee incurred approximately 110 person-rem from added scope projects and modifications. Approximately 100 modifications were projected but 124 modifications were actually worked. The outage report recommendations section frequently contained the recommendation to get the approval modifications on-site before the outage start date. The intent is to allow enough time to plan for dose reduction methods to be implemented and to procure needed resources and equipment. One extreme case of a modification arriving late during the last outage resulted in 42 field revisions and incurring 50 person-rem in lieu of the 30 person-rem projected. ALARA group personnel stated that 16 modifications are planned for refueling maintenance outage 14 and that only two are not onsite and approved. The 18 modifications have a budget of 127 person-re The licensee has made improvements in their dose reduction program by implementing corporate identified dose reduction initiatives. To reduce outage durations a freeze was placed on adding work to the outage schedule six months prior to the outage. Also, all modifications should be identified by being on the outage schedule six months prior to the outage start date. For refueling/maintenance outage 14, full time outage coordinators have been assigned to planning from Maintenance and Technical Support. A scaffolding coordinator position was established and filled to better plan and utilize scaffolding during the upcoming outag Attempts to reduce the number of entries into the RCA of the plant have been aided by using the surrogate tour during pre-job ALARA briefings. The surrogate tour consist of a large number of digitized photographs of reactor systems inside containment that allow the user different views of valves, piping, and components, as if walking. The results generally reduce the need for trips into radiation areas and better prepare the worker for the job, thereby reducing occupational dos A number of initiatives are being used by the licensee to reduce out of core source term. A controlled shutdown procedure focused on achieving conditions necessary for decomposition and solubilization of corrosion products during the reducing phase of shutdown (hydrogen was
controlled to enhance the decomposition of nickel ferrites, cobalt, and nickel oxides).
At hot shutdown the RCS was borated to refueling concentrations and lithium was remove Oxidizing conditions were achieved by adding hydrogen peroxide to the system and subsequently using filtration to remove the source term. Significant channel head dose rate reductions have occurred in the steam generators and RCS loop piping. The licensee attributes the reductions to elevated lithium operation during refueling cycle 1 In reviewing collective dose records for 1990 and 1991, the inspector noted that a significant amount of exposure to radiation was incurred when control rod C-7 was not properly latched. The problem was not discovered until control rod drop testing was performed just prior to scheduled startup in late December 1990. The test showed that the drive shaft was not attached to the control rod. Further investigation required the removal of reactor head. The investigation showed that the drive shaft for C-7 was approximately two
.inches higher that the other drive shafts. The drive shaft was verified by weight to be unlatched from control rod C-7 and a subsequent video inspection revealed that areas of the C-7 guide tube had been damaged by the free fall of the unattached drive shaft through the guide tube. Due to this, the guide tube had to be replace Upon preparation for removal of the reactor head, the reactor ductwork was dropped in the cavity resulting in a bent spool piece on the reactor head. During removal of the upper internals package, a neutron source assembly from core location H-2 was withdrawn from the core with the packag The source and package were located clear of the reactor vessel and over the lower internals storage stand where the source assembly was dislodged and allowed to fall to the cavity floor. The source rod was later recovered and transferred to the Spent Fuel Pit for storage. The upper internals lift, when the H-2 source became dislodged, resulted in elevating the upper internals package to a higher than anticipated level, resulting in additional unbudgeted exposure to radiatio An electrical fire in the reactor head storage area extended the scope of the C-7 rod project resulting in the overall project exceeding its exposure budget. Upon storage of the reactor head, electric lights were placed in the reactor head flange stud bolt holes to help maintain the flange at a steady state temperature. Polyvinyl chloride (PVC) sheeting was placed over portions of the head and flange to help insulate the heat from the outside environment. An electrical overload resulted in ignition of the PVC sheeting causing chloride contamination on the underside of the reactor head. This required extensive decontamination and
sampling to achieve acceptable limits. Radiological consequences were, general radiation levels of 5 Rem/hour and 400 millirad beta contaminatio Overall, radiological consequences as a result of 75 unscheduled days of outage in 1992 appear to have been as high as 140 person-rem for the C-7 rod event and subsequent problem The inspector reviewed the licensee progress toward determining the root cause and performing corrective actions. The inspector noted that one report stated that neither drive shaft failure nor latching tool failure was the cause. During discussions with licensee representatives the inspector was informed that personnel ekror in latching was determined to be the primary root cause of the event with the lack of procedural guidance and tooling aides as contributors. The inspector reviewed a draft procedure, which if approved as written, will require the specific qualification of contractor operators for performing specific refueling tool operation. The responsibility would fall to the Manager of Operations for procedure implementatio In addition, the licensee was discussing changes of markings on refueling tools for verification of position, as well as, procedures that would checkout refuelin The inspector upon further review in the Region, and with management's concurrence, determined that the completion of corrective actions to this event would be an Inspector Followup Item (IFI)(50-261/92-03-03).
1 Outage Planning and Preparation (83750)
The inspector reviewed the licensee's preparations for the refueling/maintenance outage scheduled to begin on March 28, 1991 and end in early July 1991. The review consisted of discussions with several ALARA Coordinators, maintenance planning, a review of the previous Refueling 13 (1990-1991)
Outage Report, and the Refueling Outage Action Item List (ROAIL).
A review of the previous outage report showed that outage duration was a problem. Faulty work during a control rod latching operation during core reassembly lead to a dropped rod event just prior to unit startup. Corrective actions to this and subsequent problems extended the outage duration approximately 75 days. A review of outage durations since 1986 showed an adverse trend that requires management's attentio Year Outage Duration 1986 48 days 1987 81 days 1988 106 days 1990 183 days The inspector discussed the appearance of an adverse trend in outage duration with RP management and plant managemen Licensee representatives made the inspector aware of a number of actions that are planned and being taken to ensure refueling/maintenance outage 14 is completed on time. One action was to freeze outage work scope six months prior to the outage. This would require modifications to be completely identified. However, the inspector learned that two modifications still had to be issued to the plant and thus were overdu A review of the ALARA Report from the 1990 refueling/maintenance outages showed that the report concentrated on individual ALARA Work Packages with a discussion, conclusion, and recommendation for each major job. The report covered, or summarized 41 major jobs and identified many positive as well as negative factors that occurred during the job that could be used to plan for refueling/maintenance outage 1 Among the more significant problems identified, where unnecessary collective dose was reviewed, was the late identification of installation and removal of scaffolding, use of inexperienced crews, and poor planning regarding procurement. The outage report also listed the addition of modifications and added projects as problems that increased outage duratio As one means of determining readiness for the upcoming outage, the inspector reviewed the ROAIL. The ROAIL is a list of action items that were identified both during and at the end of refueling/maintenance outage 13 in March of 199 The list covered 245 action items, items to be corrected prior to the next outage. Each of the 245 items contained a description, person responsible, status, and three dates: a due date, a forecast date, and an actual completion dat The ROAIL reviewed was dated February 12, 1991, and revealed that there were significant problems with the status of items to be corrected. Of the 245 action items, 70 or 29%
had no date and in many cases no status filled in for the action item, 150 had no date for forecasting completion, and 160 or 65% of the items had no date for actual completio In several cases the inspector observed where an action item was listed as being completed but in reality resulted in another action item for someone but had not been picked up as such or relisted. While the ROAIL was only one measure
of the licensee performance in correcting problems and being prepared for the upcoming outage, the inspector informed plant management on two separate occasions that performance in this area was incomplete, for ALARA planning purpose No violations or deviations were identifie.
Information Notices (92701)
The inspector determined that the following Information Notices (IN) had been received by the licensee, reviewed for applicability, distributed to appropriate personnel, and that action, as appropriate was taken or scheduled:
90-47:
Unplanned Radiation Exposures to Personnel Extremities Due to Improper Handling of Potentially Highly Radioactive Sources 90-48:
Enforcement Policy for Hot Particle Exposures 90-49:
Stress Corrosion Cracking in PWR Steam Generator Tubes 90-50:
Minimization of Methane Gas in Plant Systems and Radwaste Shipping Containers 90-56:
Minimization of Methane Gas in Plant Systems and Radwaste Shipping Containers 88-63, High Radiation Hazards from Irradiated Incore Supp. 1:
Detectors and Cables 90-66:
Incomplete Draining and Drying of Shipping Casks 90-75:
Denial of Access to Current Low-Level Radioactive Waste Disposal Facilities 90-81:
Fitness-for-Duty 91-10:
Summary of Semiannual Program Performance Reports on Fitness-for-Duty in the Nuclear Industry 91-35:
Labeling Requirements for Transporting Multi Hazard Radioactive Materials 91-36:
Nuclear Plant Staff Working Hours 91-37:
Compressed Gas Cylinder Missile Hazard 91-39:
Compliance with 10 CFR Part 21, "Reporting of Is Defects and Noncompliance"
91-40:
Contamination of Non-Radioactive System and Resulting Possibility for Unmonitored Uncontrolled Release to the Environment 88-63, High Radiation Hazards from Irradiated Incore Supp. 2:
Detectors and Cables 91-60:
False Alarms of Alarm Ratemeters Because of Radiofrequency Interference 91-65:
Emergency Access to Low-Level Radioactive Waste Disposal Sites 1 Licensee Actions on Previously Identified Inspector Findings (92701 and 92702) (Closed) 50-261/90-25-02:
Potential failure to verify Grade D quality air for all supplied-air breathing system compressor Results of the inspector's review and resolution of the issue is documented in paragraph 7.b. of this repor The inspector informed licensee representatives that this item would be considered closed based on previous actions and ensuing corrective action (Open) 50-261/90-25-02:
Evaluate the effectiveness of using ring TLDs versus wrist TLD During discussions with licensee representatives, the inspector was informed that since the fourth quarter of 1990 the licensee had been providing wrist and finger dosimetry to radiation workers involved primarily with various filter changeout jobs. The purpose of which has been to gather data to determine if extremity monitoring is necessary for the work performed and if so whether ring or wrist TLDs are more appropriat The licensee plans to continue to gather such data throughout the course of the upcoming outag Following completion of the outage the licensee plans to compile all the data and following a technical and statistical evaluation the licensee will make a decision regarding the use of extremity dosimetr The inspector informed licensee representatives that following their review of the compiled extremity data the inspector would be inclined to close the ite )
1 Exit Meeting The inspector met with licensee representatives, denoted in Paragraph 1, at the conclusion of the inspection on February 14, 1992. The inspector summarized the scope and findings of the inspection, including the two NCVs. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents or processes as proprietar Item Number Description and Reference 50-261/92-03-01 NCV:
Failure to comply with dose monitoring requirements for entry into a HRA in accordance with TS 6.13.1(a).(Paragraph 6.b.)
50-261/92-03-02 NCV:
Failure to have adequate procedures to verify Grade D quality air for all supplied-air breathing system compressors in accordance with TS 6.11.(Paragraph 8.b.)
50-261/92-03-03 IFI:
Evaluate the effectiveness of ALARA licensee corrective actions to prevent recurrence of an improperly latched control rod event during the previous outag (Paragraph 10)