IR 05000261/1992017

Insp Rept 50-261/92-17 on Stated Dates.Violations Noted. Major Areas Inspected:Occupational Radiation Safety During Outages,Exam of Audits & Appraisals,Training & Qualifications & External & Internal Exposure Controls

ML14178A247
Person / Time
Site:	Robinson
Issue date:	07/20/1992
From:	Pharr E, Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14178A244	List: IR 05000261/1992017 ML14178A243 ML14178A245
References
50-261-92-17, NUDOCS 9208070040
Download: ML14178A247 (19)

Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, ATLANTA, GEORGIA 30323 JUL 2 0 1992 Report No.:

50-261/92-17 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 C ted:

J e 5,

2 and June 10, 1992 S d

Inspector:

.

Sh rt ge D e igned Approved by:

n Pote, t Signed Facilities Ra ation Protection Section Emergency 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 during outages and included an examination of audits and appraisals, training and qualifications, external and internal exposure controls, control of radioactive materials and contamination, surveys and monitoring, and maintaining occupational exposures ALARA. In addition, Information Notices and licensee response to previously identified inspection findings were reviewe Results:

In the areas inspected, two violations regarding the failure to effectively implement written procedural requirements were identified. The licensee's routine external and internal exposure programs were effectively implemented. Personnel exposures were less than 10 CFR Part 20 limit Strengths were noted in the licensee's ALARA program for maintaining personnel exposures ALARA during outage activities. Weaknesses were noted 9208070040 920720 PDR ADOCK 05000261 G

PDR

• in the licensee's self-assessment program and the training program for contractor technicians. An out-of-date Final Safety Analysis Report (FSAR) was noted as well. Also, the inspector experienced difficulty in initially gaining access to plant areas for inspection purpose The following cited violations and issues were identified:

-

Two examples of a NRC identified violation of Technical Specification (TS) 6.5.1.1.1 for failure to follow procedures for (1) requiring the work performed in the radiologically controlled area (RCA) be under the appropriate Radiation Work Permit (RWP), and (2) servicing contaminated High Efficiency Particulate Air (HEPA) vacuum cleaner NRC identified violation of TS 6.5.1.1.1 for the failure to follow procedures requiring individuals exiting a highly contaminated area to perform a whole body frisk at the nearest frisking statio Inspector Followup Item for the evaluation of the licensee's completed analysis of ring TLD and wrist TLD comparison

dat *

REPORT DETAILS Persons Contacted Licensee Employees

• R. Barnett, Manager, Outage and Modifications

• C. Baucom, Project Specialist, Regulatory Compliance

• R. Beveray, Manager, Quality Control (QC)

1. • R. Chambers, Plant General Manager

• B. Clark, Manager, Maintenance

• Collins, Supervisor, Radiation Control (RC)

1. M. Crabtree, Supervisor, Dosimetry, Instrumentation, and Respirators

1. • D. Crook, Senior Specialist, Regulatory Compliance

1. C. Dietz, Manager, Robinson Nuclear Project

• W. Dorman, Manager, Nuclear Assessment Department (NAD)

• A. Eaddy, Manager, Environmental and Radiation Control (E&RC) Support

• D. Gainey, Senior Specialist, NAD

1. • J. Harrison, Manager, Regulatory Compliance

• A. Padgett, Manager, E&RC Other licensee employees contacted included engineers, technicians, and office personne Nuclear Regulatory Commission

1. • L. Garner, Senior Resident Inspector

1. • C. Ogle, Resident Inspector

1. B. Mallett, Deputy Division Director, Division of Radiation Safety and Safeguards

• Attended June 5, 1992 Exit Meeting

1. Attended June 10, 1992 Teleconference Audits and Appraisals (83729)

The inspector reviewed the licensee's program to improve the RC Program..through-self-identification.of.performance. and programmatic deficiencies and their correction. Two assessments were performed in 1992 to date, R-ERC-92-01 and R-ERC-92-02, dated February 19, 1992 and May 27, 1992, respectively. The assessments were performed by an individual from corporate NAD and NAD assessors from each of the other CP&L plant Assessment number R-ERC-92-01, dated February 19, 1992, identified four issues which should be reviewed and considered for action by E&RC management. The inspectors noted that four Adverse Condition Reports (ACRs) were written to ensure that corrective actions would be complete Listed with each of the four issues were several

examples of poor performance or deficiencies to support the finding. In addition, observations that were not considered by NAD to be of a safety significance to warrant escalation to issues requiring an ACR were also included as an attachment to the assessments. The inspectors noted that the list of observations contained a number of items that appeared to the inspector to be both programmatic and compliance related and therefore were not considered to be minor in natur A review of assessment number R-ERC-92-02, dated May 27, 1992, revealed that the assessment team did not identify any items requiring resolution. The assessment was conducted during an outage and had associated a -comprehensive list of observations. The inspector noted that the NAD team observations listed two separate instances where personnel were observed not frisking, as required, at the nearest frisker upon exiting a contaminated area. Since observations are issues that were not escalated to ACRs and do not routinely have a written resolution or any paper trail, the inspector had to ask the licensee what was done on several observations to correct the discrepancy. In the case of improper contamination monitoring, cognizant licensee representatives stated that signs to heighten awareness were placed at or near the frisking station and that a memo to plant personnel eliciting support for proper frisking was issued. The inspector noted the frisking station that was bypassed by three employees exiting a highly contaminated area had such a sign requiring frisking; and this violation is discussed in Paragraph 8.a belo The inspector discussed with licensee representatives that the failure to monitor as required by procedure was a Technical Specification (TS) violation, previously identified in a NAD assessment but not resolved satisfactorily to prevent recurrence. The inspector also was concerned that documentation of resolutions to NAD observations was not routinely made or availabl No violations or deviations were identifie.

Training and Qualifications (83729)

10 CFR 19.12 requires, in part, that the licensee 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 *

As the result of an event detailed in Paragraph 7 the inspector reviewed the licensee program to train contract Radiation Control (RC) technician Licensee training representatives stated that upon arriva at the site four modules were provided for training decon technicians, junior RC technicians, and senior (ANSI qualified) RC technicians. All classifications of contractors received a two hour instruction on overview and administrative controls (decontamination, contamination controls, respiratory controls, etc.).

Also, each classification received training on procedures. A two hour training session was provided on radiation work permits (RWPs), radiological safety violations (RSVs), locked high radiation areas, air monitor alarms, and limits for reissue of protective clothing. Also, a list of 30 procedures was listed as required reading. Junior and senior RC technicians were provided two hours of instruction in the radiological surveillance program for radiological areas and the containment vessel (CV).

Five hours of instruction was provided to all senior RC technicians in the RWP program, air sampling, operation of and response to constant air monitors, temporary storage of radioactive materials outside the protected area, radiography operation controls, and steam generator job coverage. In addition all classifications attended general employee trainin During the event reviewed in Paragraph 7, the inspector found that the decontamination supervisor involved in the event was not given instruction in the HP Procedure (HPP 112), Use of HEPA Filtration Units and HEPA Vacuum Cleaners, Revision (Rev.) 3, dated June 27, 1991. This procedure contained information, which if trained on, may have prevented the root cause of the event. The inspector noted that for licensee RC technicians to perform the change out of a HEPA filter in a contaminated vacuum cleaner, the person must have completed the lesson plan portion of training, as well as, the plant specific training to support the task-specific sign.off on.a.gualification card.. -This was a concern expressed by the inspector to plant management in the exit interview in that the decon supervisor, a contractor, was not task qualified but was performing a job for which a licensee RC technician would have to be task qualifie The inspector learned that the licensee implemented use of digital alarming dosimeters (DADs) without providing formal training. It has been noted at other facilities in Region II that to gain the benefit of increased exposure controls provided by DADs, training must be comprehensiv Contractor technicians were providing limited instruction to workers at the instrument check out window explaining the

alarms for dose and dose rate. The inspector asked the contract dosimetry issue personnel if they were aware of any events that occurred in the industry involving the inappropriate response to DAD alarms and was told no. The inspector suspected that enough time had not elapsed to allow dissemination of the recent Duane Arnold escalated enforcement event, but in discussions with licensee representatives the inspector found that contract RC technicians were not given the same training on industry events as were licensee RC technician In fact, contract RC technicians were not provided with continuing training which would normally include industry events and or operating experienc The inspector discussed with licensee training personnel the industry events/operating experience training element for licensee RC technicians. The inspector obtained a list of industry events/operating experience which licensee RC technicians were trained on and noted that for the majority of those subjects a very low number signed off as having read or received training on those events. Since this was an important element in continuing training the inspector discussed this with RC managemen RC management agreed that the number was low and that there should be a good reason for this. However, none was given prior to the completion of the onsite inspectio The inspector reviewed the licensee Training Instruction (TI-114), Related Technical Training and On-The-Job Training for Environmental and Chemistry and Radiation Control Classifications, Rev. 16, dated April 22, 199 Step 8. under continuing training requires, in part, that contract HP technicians assigned to Robinson Plant, during plant operations, for longer than six months are required to complete Required Continuing Training for their classification. The inspector found that three contract technicians had been assigned at the plant since September, 199 However, both licensee RC and training department personnel reiterated.to..the inspector that training was not provided to contract RC technicians. During followup discussions with a licensing representative after the completion of the onsite inspection, the inspector was informed that the procedure requirement, step 8.4.6, was not added until the latest revision to the procedure, dated April 22, 199 No violations or deviations were identifie.

External Exposure Control (83729)

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 20.101(b)(3) requires the licensee to determine an individual's accumulated occupational dose to the whole body on an NRC Form 4 or equivalent record prior to permitting the individual to exceed the limits of 20.101(a).

The inspector reviewed selected 1992 first quarter and second quarter, to date, external exposure records. Those individuals reviewed were working under various RWPs associated with entries into the CV at power and outage RWPs associated with steam generator eddy current work and Residual Heat Removal (RHR) valve repairs and inspectio For the selected records reviewed, the maximum whole body, skin, and extremity doses during either quarter were 1.449 rem, 1.449 rem, and 0.821 rem, respectively. The inspector noted that individuals had exceeded 1.25 rem to the whole body in a calendar quarter. Following further review, the inspector verified that the licensee had documentation of the individuals' prior exposure on a NRC Form-4 and had appropriately granted the individuals an exposure extension based on annual and lifetime cumulative exposure The inspector concluded that the licensee monitored external exposures adequately and these exposures were within 10 CFR 20 limit No violations or.deviations were identifie.

Internal Exposure Control (83729)

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 The inspector reviewed selected records of internal exposure results for both licensee and contract employees during 1992 first and second quarter The inspector was informed that no internal exposures based on uptakes were identified during the year to date. The inspector verified that no exposures in excess of the 40 MPCa-hr control measure had occurred since January 1, 199 No violations or deviations were identifie.

Respiratory Protection Program (83729)

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 available for the atmosphere-supplying respirator CFR 11.121 requires that compressed, gaseous breathing air meet the applicable minimum grade requirements for Type 1 gaseous air set forth in the Compressed Gas Association (CGA) Commodity Specification for Air, G- (Grade D or higher quality).

HPP-110, Inspection and Maintenance of Respiratory Equipment, Rev. 12, dated March 20, 1992 sets forth instructions for sampling instrument air to ensure grade "D" air or better for breathing, supplied-air purposes. The procedure requires breathing air be sampled at specified sampling points every 92 +/- 23 days to ensure the presence of Grade "D" air or better. The procedure also requires breathing air be sampled following maintenance activities that may.degrade breathing air.qualit Maintenance Instruction, MI-113-1, Primary Air Compressor Overhaul, dated March 25, 1992; Corrective Maintenance Procedure, CM-601, Instrument Air Compressor Maintenance, Rev. 2, dated March 18, 1992; and CM-607, "C" Instrument Air Compressor Maintenance, Rev. 1, dated March 18, 1992 all require that the RC Supervisor or his designee be notified following major maintenance on either of the four specified compressor systems and that testing may be required to verify breathing air quality is Grade D or bette The inspector reviewed 1992 first and second quarter breathing air sampling records and compressor maintenance records and verified that the licensee was appropriately sampling all compressor systems according to the referenced procedures. All sample results met ANSI/CGA G7.1-1989 Grade D air quality criteria following routine or post maintenance samplin No violations or deviations were identifie.

Operational Radiation Controls (83729)

During tours of the CV the inspector observed a contractor perform the change out of a filter in a contaminated vacuum cleaner. This paragraph and others in this report describe specific aspects of the operation (see Paragraph 3 for training aspects).

TS 6.5.1.1.1 requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, Rev. 2, February 197 Regulatory Guide 1.33, Appendix A, Rev. 2, February 1978 in Section 7.e.1 recommends that procedures be written covering access controls to radiation areas including a Radiation Work Permit Syste Plant Program procedure (PLP-016), Radiation Work Permit Program, Rev. 11, dated March 26, 1992, requires in Step 5.2.1 that all work performed in the RCA, be performed under a RWP. It is the user's responsibility to perform his specific task under the appropriate RW HPP-112, Use of HEPA Filtration Units and HEPA Vacuum Cleaners, Rev. 3, dated July 2, 1991 requires in Step 10.5.1.1 that personnel involved in HEPA filtration unit and vacuum cleaner emptying or filter changes be briefed in the procedural and radiological requirements of the tas Step 10.5.1.2 requires that activities be performed under strict radiological controls with restrictions established in a special RWP. Step 10.5.1.3 requires that all activities performed while a vacuum cleaner head/body seal is broken take place in a room, containment, or tent established to control the spread of airborne radioactivit Step 10.5.1.4 requires that any room, containment, or tent described in step 10.5.1.3 be equipped with a HEPA filte HPP-006, Radiation Work Permits, Rev. 19, dated June 28, 1991, Step 3.7 requires in part that when providing continuous coverage for a job, the radiation protection technician is responsible for surveying, evaluating, and

• documenting the radiological conditions of the job; verifying that work in progress does not violate protective requirements of the RWP; and stopping work whenever changes in the radiological conditions warrant. Step 4.1.4 defines continuous coverage as continual line-of-sight view or verbal communications with the work crew or the use of electronic techniques such as closed circuit televisio On June 2, 1992, during a tour of the CV, the inspector observed a contract decon supervisor emptying a contaminated vacuum cleaner in a small containment ten The inspector noted that a low volume air sampler was sampling the atmosphere inside the tent, the worker wore one set of cloth protective clothing with a full-face respirator, the tent door was partially open, and a 8-10 inch opening was observed in one side of the tent where a HEPA ventilation exhaust should have been installed. Upon exiting containment the inspector notified the RC operations shift supervisor of the problems observed with the vacuum cleaner operatio The inspector reviewed licensee documentation to ascertain the contract decon supervisor's RWP and the RWP requirements. Licensee representatives stated the contractor was on RWP-R-92-0634-00, General Decon and Trash Removal, all aspects, for all levels of the containment vesse Protective dress requirements included one set of cloth protective clothing with respiratory protection per RC direction. This appeared to the inspector to be too general an RWP and further inquiry revealed that the specific RWP for servicing contaminated vacuum cleaner filters in containment was RWP-R-92-0826-00 which at the time of the observed incident had been deactivated by RC. RWP-R-92 0826-00, Inspect, Remove, Install Filters and or Bags in HEPAs/Vacuums to Include Transport of Vacuums/HEPAs, all

.aspects, specifically required a pre-job briefing prior to removal of used filters and or bags from vacuums/HEPAs, to include making workers aware that radiological conditions during the job were subject.to change; and that respiratory protection and continuous' RC coverage be provided while removing used filters or bags from vacuums/HEPAs. The inspector interviewed the contractor and found that continuous RC coverage had not been provided nor had a pre shift briefing been given. A review of records showed that for RWP-R-92-0826-00, approximately six vacuum cleaner servicings in the CV were performed previously. Records reviewed by the inspector also indicated that only one pre shift briefing had been performed and documented in the record and in the post-job briefing section, there was a statement that no continuous RC coverage had been provide The inspector interviewed the RC operations shift supervisor and noted that one licensee RC technician, who was task specific qualified to empty/service HEPA vacuum or ventilation units, was in the upper level of the CV at the time of the observed incident but was assigned to that specific area and therefore could not have provided direct supervision. The inspector reviewed the contractor's training and found that he had not been specifically task trained as had the licensee RC technician. In addition, the inspector, after reviewing training records, found that the procedures training provided by the licensee to contract technicians did not include training on HPP-112, the procedure that delineated specific requirements for servicing contaminated HEPA vacuum cleaners and HEPA ventilation unit The licensee RC technician was required to have a qualification card signature for servicing contaminated vacuum cleaners with supporting documentation for the task specific qualification and the contractor did not have specific on-the-job training, or training in HPP-11 Therefore, the inspector questioned the qualification of the contractor to perform vacuum servicing. To determine the extent of licensee failure to comply with HPP-112 requirements, the inspector requested a RWP printout of all work performed on RWP-R-92-826-00 since the outage bega The printout indicated that on six different occasions entries had been made. The inspector attempted to interview the personnel on the printout noting that all but one were contract decon personnel. The inspector was informed tha these people would not return to shift until the Monday following the completion of the onsite inspectio The inspector interviewed the contract decon supervisor, who also appeared on the RWP printout for performing a contaminated vacuum cleaner servicing on April 24, 1992, and inquired if it was normal not to have a pre-shift briefing nor continuous RC job coverage and he stated that normally these.were.not.provided. The inspector interviewed the site contract HP supervisor and was given the same answer. Thus, the inspector determined that when vacuum cleaner servicing was performed on the correct RWP, it was not performed in accordance with pre-job briefing and continuous RC coverage requirements. This was supported by the one pre-job briefing form from May 20, 199 The inspector informed the licensee that the failure of the contractor to perform the servicing of a contaminated vacuum cleaner on the correct RWP was an apparent violation of TS 6.5.1.1.1 and had associated with it multiple examples of procedural violations (50-261/92-17-01).

• The inspector requested the site contract HP supervisor to interview those contract technicians that would return to site on Monday, June 8, 1992 to determine if (1) each of the entries on the RWP printout were for contaminated vacuum servicings, and (2) if pre-job briefings and continuous RC job coverage was provided. On June 10, 1992 the inspector contacted the site contract HP supervisor who stated that the personnel on the RWP list had in fact made entries to service contaminated vacuum cleaners and on each entry they had received a pre-shift briefing and continuous RC job coverage, which was contrary to previous informatio The inspector further noted that associated with the June 2, 1992 incident an air sample taken during the vacuum Sleaner servicing between 0830 and 1044 hours0.0121 days <br />0.29 hours <br />0.00173 weeks <br />3.97242e-4 months <br /> showed 9.36x10 pc/c Later in the day, M 1537 hours0.0178 days <br />0.427 hours <br />0.00254 weeks <br />5.848285e-4 months <br /> a back up air sample showed a level of 8.47x10 pc/cc outside the tent and the CV 2nd level air 1$ample taken between 0925 and 1825 showed a level of 5.4x10 'pc/cc. Thus the operation did not, based on air samples, generate significant levels of airborne radioactivity either inside or outside of the containment ten Further investigation revealed that the HEPA ventilation was removed from the tent at some prior time to replace a HEPA ventilation unit on the refueling floor that had been disservice One violation of TS 6.5.1.1.1 with several examples for-failure to follow a RWP and procedures for a contaminated vacuum cleaner servicing was identifie.

Surveys, Monitoring, and Control of Radioactive Material (83729) Contamination Monitoring Event PLP-031, Contamination Monitoring Program for Personnel/Personnel Effects, Rev. 5, dated January 1, 1991, in step 3.1.2 requires that workers perform a whole body.frisk at the nearest.frisking station immediately upon existing a high contamination are On June 1, 1992, during tours of the RCA, the inspector observed three workers in modesty clothing apparently exiting the spent fuel pit. The inspector further noted that the three workers bypassed a remote frisking station established to monitor workers exiting the spent fuel pit. Upon observing the workers bypass the frisking station, the inspector proceeded to the spen fuel pit area to ascertain if a closer frisker existe However, security door access was denied so the inspector verified later that there was no closer frisker and that 95-98 percent of the area inside the

spent fuel pit door was posted as a high contamination area. The inspector also noted that an earlier NAD assessment recorded observations of several instances of personnel failing to frisk at the nearest frisker (paragraph 2).

The inspector informed the licensee that the failure to perform a frisk at the nearest frisking station following exit from a high contaminated area was an apparent violation of TS 6.5.1.1.1 (50-261/92-17-02).

Subsequently, the licensee inquired if the inspector actually observed the workers exiting the spent fuel pit or in fact a highly contaminated area. The inspector stated that he assumed the workers to have been in the area since it appeared to be their only purpose for being in such a remote area (up 6 or 7 flights of stairs with no other work area nearby).

The licensee asked the inspectors to provide the time of occurrence, which the inspectors did, and stated that they would interview the workers to establish if the incident in fact occurred as stated by the inspecto One violation of TS 6.5.1.1.1 for failure to follow

procedures for frisking properly was identifie Control of Radioactive Materials Following discussions with licensee representatives, the inspector was informed that as of May 31, 1992 the RCA contaminate area averaged approximately 3287 square feet (ft

), year-to-date, which included three outage months. The inspector was infofmed that the goal for 1992 was 2000 contaminated ft During discussions with licensee representatives, the inspector was informed that during the period from January 1, 1992 to May 31, 1992 the licensee had recorded a total of 99 contamination events, surpassing the projected goal.for the period of 8 The licensee informed the inspector that the 1992 annual goal of 130 contamination events was still achievabl No violations or deviations were identifie.

Plant Tours (83729)

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 materia *

During tours of the RCA the inspector observed several areas where the postings appeared inconsisten In one area in the Hot Machine Shop a step off pad was used as a partial barrier to a high radiation area. The inspector informed the licensee that the NRC position for this type of area was to have a barrier which required manipulation by the entrant in order to access. A contract RC technician made a subsequent tour with the inspector to observe the are Later in the shift the RC operations supervisor informed the inspector that the high radiation area was dismantled since a subsequent survey indicated the area not to be a high radiation area at al The licensee corrected the posting deficiencie During a tour of the CV the inspectors noted while on the upper level of the CV, that workers were routinely performing tasks around and over an empty reactor cavity without safety belts. Approximately 50 percent of the reactor cavity was without hand or guard rails. Workers were noted to sit on the inside of the guard rail and operate ropes and tool bags to raise and lower light loads of hand tools into the cavity. This was considered significant since the reactor cavity was without water and is approximately 30-40 feet deep. The.inspector located a supervisor inside containment and notified him of the observance. Personnel were noted to properly wear safety belts after the problem was made known to managemen No violations or deviations were identifie.

Plant Access (83729)

10 CFR 50.70(b)(3) states that the licensee or construction permit holder shall afford any NRC resident inspector assigned to the site, or other NRC inspectors identified by the Regional Administrator as likely to inspect the facility, immediate, unfettered access, equivalent to access provided regular plant employees, following prior identification.and.compliance with applicable access.control measures for security, radiological protection, and personnel safet On June 1, 1992, the inspector arrived onsite at approximately 1230 hours0.0142 days <br />0.342 hours <br />0.00203 weeks <br />4.68015e-4 months <br />. The inspector processed. into the site and attended a site entrance meeting with licensee management. During initial tours of the auxiliary building the inspector experienced access difficulties which lead to several inquiries by the security force. The inspector was later denied access when attempting to enter the spent fuel pi The inspector exited the protected area to discuss with security personnel the cause for the delays and the refusal for access to the spent fuel pit are *

Security personnel stated that the inspectors' P-3 form, Attachment 7.1 to RNP procedure, Access Request Authorization, did not request entry to -the spent fuel pit, new fuel area, or CV. The security personnel further stated that usually the resident inspector made.arrangements for entry to these areas for regional inspectors. The inspector was informed that there were 20 areas on the access list and that their computer system could only allow access to 15 of those areas at one time. The security personnel then authorized the inspectors to all areas except the CASS and SASS but were not inclined to authorize access to area 2 The inspector requested explanation as to where and what area 20 was and why access was not routinely granted to NRC regional inspector Following discussions with the E&RC manager, the inspector was informed that area 20 was security door 32A and was reserved for NRC resident inspectors and operations personnel as it was a short cut from the auxiliary building, through the open turbine building, to the control room. The inspector was further informed that personnel utilizing security door 32A were required to have dosimetry and to be on a special RWP. The E&RC manager informed the inspector that if access to this area was needed it could be authorized. The inspector explained that the occasion may arise that in the process of observing work or a worker the inspector may need this access. The E&RC manager authorized the regional inspectors access. The inspector requested that NRC inspectors' site specific access training be revised to inform inspectors of the 15 area maximum access of the licensee's system and that inspectors be made aware that in order to gain access to the other 5 areas then the inspector must specifically request that security grant them the needed acces The inspector reviewed site HP procedures and noted that PLP-016, Radiation Work Permit Program, Rev. 11, dated March 26, 1992, step 5.3.2 stated that exit from the RCA through security door 32A was allowed for operations personnel routinely and E&RC personnel in an emergenc The inspector also reviewed the FSAR for information on the RCA. H. B. Robinson's Updated FSAR, Amendment No. 6, in Facilities and Access Provisions, step 12.5.2.4 states that entry to and exit from the RCA is through the designated access control points only, with reference to Figure 12.5.2 2. The inspector reviewed the figure and noted that RCA entry and exit points were not specifically shown as such, and that the area with security door 32A was not shown on the figure at al The inspector was informed by licensing/compliance personnel that the subject figure in the FSAR had not been updated since 196 During a June 10, 1992 teleconference between the inspectors, other NRC representatives, and licensee representatives, the licensee

committed, following NRC request, to updating step 12.5. and/or the referenced Figure 12.5.2-2 during the next routine revision of the FSA In addition, the inspector informed RC management that there were no radiological postings on security door 32A to make personnel aware the door was a RCA exit and that as a minimum personnel must frisk prior to exiting. Prior to the end of the onsite inspection the requirement to frisk before exiting and a RCA boundary posting was added to the doo No violations or deviations were identifie.

Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA) (83729)

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 achievabl The inspector reviewed the licensee's program to maintain occupational exposure ALARA. During discussions with licensee representatives the inspector was informed that the total collective radiation exposure for 1992, through May 31, based on the sum of first quarter thermoluminescent dosimeter (TLD) readings and second quarter, to date, Self Reading Pocket Dosimeters (SRPDs), was approximately 288 person-rem. On day 67 of a 70 day scheduled outage, the licensee had accumulated approximately 90 percent of the 318 person-rem outage exposure goa The licensee's collective radiation exposure goal for 1992 was 420 person rem, with a stretch (preferred) goal of 350 person-re The inspector discussed with licensee representatives several successful outage jobs and dose reduction initiatives which had contributed to the licensee successfully maintaining, to date, their outage exposure goal. Licensee representatives attributed much the success, particularly of some first time jobs, to extensive use of mockups and training, experienced work crews, and RC technicians dedicated solely to a particular job. As well, the licensee was successful with recently purchased remote cameras and the surrogate video tour system for preventing unnecessary time in high dose areas, thereby reducing personnel exposur Licensee representatives also discussed enhanced personnel awareness of the correlation between outage duration and exposure, thereby contributing to better planning, less emergent work, and better outage management support. Also beneficial in maintaining outage exposures ALARA was the successful second application of the Reactor Coolant System (RCS) Shutdown Chemistry Control Progra Licensee data indicated that approximately 834 Curies (Ci)

of activity was removed. This removal resulted in a 11 percent average reduction in general -area dose rates throughout the CV and the auxiliary buildin The inspector informed licensee representatives that their program to maintain worker exposures ALARA during outage activities appeared to be functioning adequatel 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:

10 CFR Part 21 and 50.55(e) Final Rules IN 92-25:

Potential Weakness in Licensee Procedures for Loss of Refueling Cavity Water IN 92-30:

Falsification of Plant Records 1 Licensee Actions on Previously Identified Inspector Findings (92701) (Closed) 50-261/90-25-04:

Evaluate the effectiveness of using ring TLDs versus wrist TLD During discussions with licensee representatives the inspector was informed that additional comparison data had been collected during the outage by placing TLD finger rings on selected individuals required to wear wrist TLDs. Tasks performed throughout the outage in which individuals were monitored with finger rings and wrist TLDs included various filter changes, an incore detector change-out, Waste Hold-Up Tank desludging, removal of cavity debris, removal, inspection, and replacement of a reactor nO" ring, and miscellaneous valve repairs. Following completion of modification 1064, Transfer Canal Upgrade, the data collection phase of the study will be complete. At that time the results will be analyzed by the CP&L Corporate Dosimetry staf Subsequent to the onsite inspection, the inspector informed licensee representatives that based on the actions completed that this item would be close However, the final analysis of the comparison data would be evaluated by NRC during a future inspectio (IFI 50-261/92-17-03)

16 (Open) Inspector Followup Item (IFI) 50-261/92-03-03, Evaluate the effectiveness of licensee corrective actions to prevent recurrence of an improperly latched control rod even On February 8, 1991, following reactor vessel head removal, the control rod drive shaft at core location C-7 was found not to be latched to its control rod assembly. ACR 91-099 was written for a documentation of the event -and to determine adequate corrective action(s).

This event did not place the plant in an unanalyzed condition nor was the condition outside the design basis as reported in ACR 91-09 However, the event was radiologically significant due to the exposure to radiation in resolving the problem. Based on resolution documentation of the ACR, the inspector noted that equipment failure did not occur, and extensions to resolve some equipment investigations were necessary. However, the licensee had not closed out the ACR as resolutions were not yet complet Therefore, this item will remain ope.

Exit Meeting The inspector met with licensee representatives, denoted in Paragraph 1, at the conclusion of the inspection on June 5, 199 The inspector summarized the scope and findings of the inspection, including four potential violation 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 During a subsequent teleconference between licensee representatives and NRC representatives, as denoted in paragraph 1, the inspector discussed the two apparent violations of TS 6.5.1.1.1. As well, the inspector informed licensee representatives that following regional.review and approval the two issues which were discussed during the onsite inspection as potential violations, training of contract personnel and the out of date FSAR, would be addressed in the inspection report rather as concerns (Paragraphs 3 and 10, respectively).

Licensee representatives acknowledged the inspector's comments and no dissenting comments were receive Item Number Description and Reference 50-261/92-17-01 Two examples of a NRC identified violation of TS 6.5.1.1.1 for failure to follow procedures for (1) requiring work

performed in the radiologically controlled area (RCA) be performed under the appropriate RWP -and (2) servicing contaminated HEPA vacuum cleaner (Paragraph 7)

50-261/92-17-02 NRC identified violation of TS 6.5.1. for the failure to follow procedures for requiring individuals exiting a highly contaminated area to perform a whole body frisk at the nearest frisking station. (Paragraph 8.a.)

50-261/92-17-03 Inspector Followup Item for the evaluation of the licensee's completed analysis of ring TLD and wrist TLD comparison dat (Paragraph 13.a)