IR 05000261/1995015
| ML14181A717 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/28/1995 |
| From: | Rankin W, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14181A716 | List: |
| References | |
| 50-261-95-15, NUDOCS 9507140232 | |
| Download: ML14181A717 (12) | |
Text
igB REGo4 UNITED STATES REGo NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900 ATLANTA, GEORGIA 30323-0199 June 30, 1995 Report No.:
50-261/95-15 Licensee:
Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:
50-261 License No.:
DPR-23 Facility Name: Robinson Inspection Conducted: May 30 - June 1995 Inspector:(-
A______________
F. N. Wright ate gigned Approved by J
/ :- :
f W. H. Rankin, Chief ate igned Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope This special announced inspection reviewed the adequacy of the licensee's occupational radiation protection program during extended outages. The inspection consisted of selected examinations of procedures and representatives records, interviews with personnel, and observation of activities in progress. The inspection included an examination of audits and corrective actions; radiological exposure controls; training and qualifications; control of radioactive material and radiological surveys; and ALARA activitie Results:
The radiation protection program continued to be effective in protecting the health and safety of the plant workers and the public. External and internal exposures were maintained within regulatory limits. The identification and documentation of problems concerning radiation protection activities by the Nuclear Assessment Department and the Environmental and Radiation Control
.
staff was considered a program strength. The collective dose received during 9507140232 950630 PDR ADOCK 05000261
the refueling outage 16 was the lowest in the licensee's history. Increased upper management involvement in the ALARA program activities was considered an ALARA program improvement, however, additional management attention is needed to facilitate additional collective dose reductions. One non-cited violation was identified concerning inadequate security of a locked high radiation area door (Paragraph 4).
REPORT DETAILS Persons Contacted Licensee Employees
- A. Carley, Manager, Communications
- A. Cheatham, Director, Corporate Health Physics
- R. Crook, Senior Specialist, Licensing/Regulatory Programs
- J. Henderson, Principal Specialist, Nuclear Assessment Department
- C. Hinnant, Robinson Site Vice President
- R. Krich, Manager, Regulatory Affairs
- J. Moyer, Manager, Nuclear Assessment Department W. Ritchie, Senior Specialist, Environment & Radiation Control
- D. Taylor, Controller
- R. Warden, Manager, Plant Support
- T. Wilkerson, Manager, Environment & Radiation Control
- D. Young, Plant General Manager Other licensee employees contacted during the inspection included technicians, maintenance and administrative personne Nuclear Regulatory Commission
- C. Ogle, Resident Inspector
- W. Orders, Senior Resident Inspector
- W. Rankin, Section Chief, Facilities Radiation Protection, Region II
- Attended June 2, 1995 Exit Meeting Abbreviations Acronyms used throughout this report are defined in the last paragrap.
Audits and Appraisals (83729)
Audits and appraisals were reviewed to determine the adequacy of the licensee's ability to identify problems and take effective corrective actio CFR 20.1101(c) requires that the licensee periodically review the RP program content and implementation at least annuall The licensee's independent audits and appraisals in the radiation control area consisted of formal audits per TS requirements. A qualified auditor with significant HP and chemistry qualifications and experience was assigned to the station to conduct the licensee's TS audit activitie The NAD staff had not conducted an audit in the RP program area since the last inspection conducted January 9-12, 1995, and documented in IR 95-02. However, the NAD staff had conducted an assessment of the effectiveness of the Outage Organization in the RFO 16 which reviewed
and addressed certain RP and ALARA issues. The assessment was conducted during the period of May 1-12, 1995, and was documented in Draft Audit Report R-OM-95-02. Since the report had not been issued corrective actions for audit findings were not completed or reviewed by the inspecto The licensee had established a self-assessment program requiring the various station departments develop a procedure for conducting self assessments. The program was a few years old and the E&RC group had developed a procedure for conducting the reviews. The inspector reviewed E&RC-014, "Environmental and Radiation Control Self Assessment Program," Rev. 4, dated March 17, 1995. The goals of the self assessment program were to:
recognize and correct program weaknesses; optimize resources; improve work standards; improve communications and to increase management involvement in programs. The suggested frequency for a self assessment was one per quarter year. The inspector determined that the E&RC group had continued to exceed the minimum assessment requirements and had completed numerous self assessments in 1995. The licensee also documented reviews of activities in progress, reviews of documentation, and tours made by the staff and staff supervision in Observation Reports. The Observation Reports document good practices, problems and non-compliance issues. The licensee had documented approximately 92 Observation Reports between April and June of 1995. The inspector noted that the E&RC department was very capable of identifying problems and very open to documenting identified deficiencies or weaknesses to cause appropriate corrective actions. The E&RC staff also did a good job evaluating problems, trending issues and looking for the root causes necessary to make corrective actions to prevent their recurrence. In general, E&RC personnel demonstrated a good understanding of corrective action processes. The NAD and E&RC staff's ability to identify issues for corrective action and to determine root causes was considered a program strengt No violations or deviations were identifie.
Training and Qualifications of Personnel (83729)
This area was reviewed to determine the adequacy of the qualifications of contract HPTs utilized in RFO 1 The inspector reviewed the qualifications and training records for randomly selected contract HPTs working at the Robinson site during the RFO 1 The licensee utilized approximately 39 contract senior HPT No junior HPTs were utilized. The inspector reviewed ERC Procedure ERC-012, "Transient Health Physics Personnel Training and Qualification Program," Rev. 8, dated April 27, 1995. The procedure provided guidelines for the selection, in-processing, training and qualification and documentation of contract HPT The inspector found all contract HPTs met the licensee's minimum qualifications for experience and had completed site training requirements specified by the licensee's procedures. No concerns with the qualifications of contact HPTs were identifie No violations or deviations were identifie.
Radiological Exposure Controls (83729)
This area was reviewed to evaluate the licensee's control of work activities in the RC CFR 20.1502(a) requires each licensee to monitor occupational exposure to radiation and supply and require the use of individual monitoring devices to demonstrate compliance with the radiation exposure limits described in 10 CFR Part 2 DADs and the licensee's dose tracking system were used to monitor daily personnel radiation exposures. The inspector observed personnel utilizing the dosimeters and tracking system appropriately. During tours of the RCA, the inspector noted that personnel were also wearing DADs and TLDs properly. Based on direct observation, discussion, and review of records, the inspector determined that personnel dosimeters were being effectively utilize CFR 20.1201(a) requires each licensee to control the occupational dose to individual adults, except for planned special exposures under 10 CFR 20.1206, to the following dose limits:
(1) An annual limit, which is the more limiting of:
(i) The total effective dose equivalent being equal to 5 rems; or (ii) The sum of the deep-dose equivalent and the committed dose equivalent to any individual organ or tissue other than the lens of the eye being equal to 50 rems; and (2) The annual limits to the lens of the eye, to the skin, and to the extremities, which are:
(i) An eye dose equivalent of 15 rems; and (ii) A shallow-dose equivalent of 50 rems to the skin or to any extremit The inspector reviewed and discussed with licensee representatives external exposures for plant and contract personne The licensee reported the following individual doses were the highest doses received in 1994 and through the inspection in 1995. All exposures were well within the regulatory limit *
Highest Individual Exposures (mRem)
Year DDE TEDE LDE CEDE SDEWB SDEME DRP 1994 896 896 896 None 2,082 1,101 1,292 1995 1,164 1,164 1,164
14,533 2,341 14,300 The inspector reviewed administrative controls of external and internal exposure controls and verified that the controls met the applicable regulatory requirements and were designed to maintain exposures ALAR The inspector reviewed various RWPs utilized to control work during the RFO and noted radiological controls appeared appropriate for described task and radiological condition During tours of the plant, the inspector noted that the licensee's postings for radiation, HRAs, LHRAs, VHRAs, radioactive material areas, and contaminated areas were adequat CFR Part 20.1601 establishes the controls for access to HRAs. These controls are established for radiation areas greater than 100 mrem per hour. Paragraph (a) of 10 CFR 20.1601 states, the licensee shall ensure that each entrance or access point to a HRA has one or more of the features described in that paragraph. A common control in commercial nuclear power facilities is described as item (3) in Paragraph (a).
Item (3) prescribes, entry ways that are locked, except during periods when access to the areas is required, with positive control over each individual entr CFR 20.1601(c) states, that a licensee may apply to the Commission for approval of alternative methods for controlling access to HRAs. The licensee's TS, Section 6.13, "High Radiation Area" described the licensee's alternative methods for controlling access to HRAs that have been approved by the Commissio TS 6.13.1 stated the requirements for entering any HRA, in which the intensity of radiation is less than 1,000 mrem per hour. TS 6.1 stated that the requirements of TS 6.13.1 above shall apply to each HRA in which the intensity of radiation is greater than 1,000 mrem/hr at 30 centimeters from the radiation source or from any surface penetrated by the radiation, but less than 500 rad/hour at 1 meter from the radiation source or from any surface penetrated by the radiation. In addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Operations Shift Supervisor on duty and or the Radiation Control.Superviso Licensee procedure AP-031, "Administrative Controls For Entry Into Locked High and Very high radiation Areas," Rev. 20, dated April 21, 1995, defined a LHRA as:
"A high radiation area accessible to individuals in which radiation levels could result in an individual receiving a dose equivalent in excess of 1,000 mrem in any one hour at
- 30 centimeters from the radiation source or from any surface the radiation penetrates. A LHRA shall be personally manned or common keyed to prevent unauthorized access."
During a tour of containment on May 30, 1995, an NRC resident inspector noted that a chain securing a door into a LHRA was sufficiently loose to permit an individual's access between the edge of the door and the boundary wal The "C" RCP Bay was posted and controlled as a LHR The door with the gap separated the "B" and "C" RCP Bays. The resident inspector reported the finding to HP personne The HP staff found the door secured with a LHRA padlock passing through the ends of a chain link which passed through the door and door frame. When the door was pulled outward a gap of 9.75 inches was observed between the door and the fram Licensee personnel corrected the problem by pulling the chain snug and passing lock through the chain links closest to the door and frame. The inspector stated that failure to secure an entry into a LHRA to prevent unauthorized access was a violation of the licensee's TSs. This failure constitutes a violation of minor safety significance and is being treated as a NCV, consistent with Section IV of the NRC Enforcement Polic NCV 50-261/95-15-01:
Failure to secure access into a LHRA to prevent unauthorized acces *
Licensee representatives at the exit dissented with the inspector's findings and referenced Regulatory Guide 8.38, "Control Of Access To High and Very High Radiation Areas at Nuclear Power Plants."
The licensee contended that the barrier for the "C" RCP Bay, a LHRA, was sufficient to prevent inadvertent access. The licensee also pointed out that there were specific procedures addressing the requirements and controls for entering LHRAs and training was provided to radiation workers describing the requirements for entering a LHRA which met the guidance of the regulatory guide. The inspector acknowledged the licensee's dissenting comments and indicated the issue would be subject to further NRC management revie No deviations were identifie.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83729)
This area was reviewed to determine whether the licensee's control of radioactive materials and contamination met applicable regulatory and procedure requirement CFR 20.1501(a) requires each licensee to make or cause to be made such surveys as (1)
may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be presen During tours of the plant, the inspector noted that portable radiation detectors, air samplers, and friskers and contamination monitors had current calibration stickers and had been source-checked as require The inspector also reviewed selected records of special radiation and contamination surveys performed during the current RFO and discussed the survey results with licensee representatives. During tours of the plant, the inspector independently verified radiation and contamination levels in selected areas of the Auxiliary, waste processing, and fuel handling buildings. No concerns with the adequacy or frequency of the radiological survey activities were identifie The inspector reviewed HPP-007, "Handling and Storage of Contaminated and Radioactive Materials," Rev. 13, dated March 18, 1995. HPP-007 provided instructions for the handling and storage of contaminated/
radioactive material containers, equipment and tools in accordance with the regulations of 10 CFR Part 2 During tours of the licensee's RCA, the inspector observed weaknesses in the licensee's control of contaminated materia The inspector observed that a group of 55 gallon containers in the yard did not have lids tightly secured. Many of the containers were dented or had some corrosion evident. The inspector inquired about the contents of the drums and learned that they contained sand utilized to pad a laydown area for the containment equipment hatch. The sand had been used during previous RFOs and the ongoing RFO 16. According to licensee personnel the drums had been filled with the sand for several days and the drums were to be moved to a radioactive material storage warehouse location on site for the next RFO. The licensee reported the sand was slightly contaminated with corrosion products at a concentration of approximately 1.0 E-7 microcuries. The containers were exempt from labeling requirements of 10 CFR 20.1904 based on the concentrations reported by the license The licensee's procedures required containers of radioactive material in quantities less than the quantities listed in Appendix C to 10 CFR 20 be marked with the maximum contact radiation level and the associated date of survey. The procedures also required the dose rates recorded on labels be posted as less than 5.0 mrem/hr whenever low dose rates below 5.0 mrem/hr were observed. The inspector noted that all of the containers had a radiation survey information written on the drums. The inspector surveyed the containers and verified that the dose rates marked on the drums were accurate. However, many of the containers had old survey dates such as 1993 indicated on the containers while they had actually been emptied and refilled since those dates. The inspector reported to licensee management that additional attention to containers of contaminated materials located in the yard was neede While the licensee did not meet the annual PCE goals during the period of 1992 through 1994, the licensee did see decreasing trend in the numbers of PCEs occurring during that period. At the time of the inspection, the number of PCEs occurring during the RFO 16 were RFO 15 totals and the outage goa *
Personnel Contamination Events Year Annual Outage Skin Clothing Respirators ActuaT Goal Days Actual' Goal Used 1992 177 130 126
117 RFO 14
117 NA
64 3,700 Forced
27 NA
22 1993 141 130 109
93 RFO 15
87
30
1,400 Forced
19 NA
11 1994
<12
.61
9
Forced
13 NA
11 Forced
4 NA
4 Forced
1 NA
1 19953
135
24
10 RFO 16
53 100
29
'In some cases 1 PCE included a skin and a clothing contaminatio PCEs is number of PCE's per 1,000 RWP Entries 31995 data through May 27 No violations or deviations were identifie.
Maintaining Occupational Exposures ALARA (83729)
This area was reviewed to determine whether the licensee was establishing and tracking ALARA goals and objectives and to evaluate the effectiveness of those activitie CFR 20.1101(b) requires that the licensee use, to the extent practicable, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members of the public that are ALAR The licensee has continued to reduce collective dose in recent year The 1994 collective dose was the lowest in the sites histor Effective ALARA preparations and plant availability were major contributors to collective dose reductions in 1994. As a result, the licensee's three year-collective dose average dropped in 1994 from about 294 person rem/unit (1991-1993) to about 251 person rem/unit (1992 1994).
Collective Personnel Exposure (Person-Rem)
Year Annual Dose Outage Outage Dose Outage Dates Actual Goal Actual Goal 1992 352 420 RFO 14 298 377 03/28/92 to 06/24/92 Forced
<1 NA 07/10/92 to 07/12/92 Forced
NA 08/22/92 to 09/24/92 1993 337 325 RFO 15 254 225 09/11/93 to 11/13/93 Forced
NA 11/17/93 to 12/31/93 1994
58 Forced
NA 01/01/94 to 02/11/94 Forced
NA 02/18/94 to 03/21/94 Forced
<1 NA 08/02/94 to 08/06/94 1995 176*
172 RFO 16 151 135 04/28/95 to 06/03/95
- 1995 exposure data as of June 1 The licensee established challenging outage goals based on previous performance The licensee's lowest collective dose for a RFO had been 254 person-rem in RFO 1 The licensee's collective dose goal for RFO 16 was 135 person-rem significantly below the previous lo The actual collective RFO dose on June 2, 1995, was 155 person-rem and the licensee was still in the later stages of the RF However, it appeared that the RFO 16 collective dose would be the lowest in the history of the facility and significantly below the previous low collective dose for a RF The licensee's 1995 annual collective dose goal was 172 person-re The licensee exceeded the annual collective dose goal near the end of the inspection with the additional outage dos The inspector reviewed the dose estimates for work plans exceeding dose goals with the ALARA Coordinato There were various problem Work effort estimates were underestimated, schedule pushes impacting decontamination and clean-up efforts resulting in higher than anticipated radiation levels, additional personnel added to work crews for training, emergent work and rework were a few of the reasons dose estimates were exceede Licensee representatives acknowledged better efforts to define and limit work scopes and estimate actual work efforts (hours) were needed to continue dose reduction The licensee was considering the use of an automated system that would closely track work effort (hours) to very specific task (work orders) which would provide information for more accurate dose estimates and permit closer ALARA assessments for the smaller task component The most significant change in the ALARA program was the installation of the highest levels of site management on the ALARA Committee. The ALARA coordinator reported the change had brought significant attention to ALARA needs and had resulted in recent program improvements. The ALARA coordinator reported ALARA committee was conducting stronger reviews of ALARA plans and at a lower leve The ALARA Committee reviewed tasks having collective dose total greater than 5 person-rem verses the previous 10 person-rem threshol *
The licensee continued to increased the use of remote monitoring equipment, video cameras and telemetric dosimetry, during RFO 1 The ALARA Coordinator reported that more lead shielding was installed quicker and earlier than in previous outages due to increased engineering support for load analysis work prior to the start of the outage. Licensee representatives reported approximately 5 to 10 person-rem was saved with the increased shieldin The inspector reported to licensee management that additional management attention was needed to improve accuracy of task dose estimate process, better control emergent work and reduce source terms to facilitate additional collective dose reductions. Overall, the licensee appeared to be advancing the effectiveness of the site's ALARA progra No violations or deviations were identifie.
Exit Meeting The inspection scope and findings were summarized on June 2, 1995, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed below. Dissenting comments were received from the licensee. Licensee representatives disagreed with the violation stating the intent of the TS requirements was to prevent inadvertent access into LHRA and that the conditions observed by the inspector would have prevented inadvertent access. The inspector noted the licensee's position and discussed it with Region II staf Upon Region II review the violation was confirmed. However, due to the minor radiological safety significance of the specific event the decision was made to identify the violation as a NCV. The licensee was notified of the decision by telephone on June 28, 1995. Proprietary information is not contained in this repor Type Item Number Status Description and Reference NCV 50-261-01 Open Failure to secure an entrance into a locked high radiation area in such a manner to prevent unauthorized entry (Paragraph 4). Index of Acronyms and Abbreviations Used in this Report ALARA As Low As Reasonably Achievable CEDE Committed Effective Dose Equivalent CFR Code of Federal Regulations CP&L Carolina Power & Light DDE Deep Dose Equivalent dpm Disintegration Per Minute DRP Discrete Radioactive Particle E&RC Environmental and Radiation Control HPP Health Physics Procedure HPT Health Physics Technician HRA High Radiation Area
IR
Inspection Report
Lens Dose Equivalent
LHRA Locked High Radiation Area
mrem Milli-Roentgen Equivalent Man
NAD
Nuclear Assessment Department
Non-Cited Violation
NRC
Nuclear Regulatory Commission
Reactor Coolant Pump
Re-Fueling Outage
Radiation Protection
Radiation Work Permit
SDEME Shallow Dose Equivalent, Maximum Extremitie SDEWB Shallow Dose Equivalent, Whole Body
TEDE Total Effective Dose Equivalent
Thermoluminescent Dosimeter
TS
Technical Specification
VHRA Very High Radiation Area