IR 05000302/1981027
| ML20039D271 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/07/1981 |
| From: | Hosey C, Jonathon Puckett NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20039D261 | List: |
| References | |
| 50-302-81-27, NUDOCS 8112310478 | |
| Download: ML20039D271 (8) | |
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'o-UNITED STATES F
j NUCLEAR REGULATORY COMMISSION L3 REGION ll
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101 MARlETT A ST., N.W., SUITE 3100
ATLANTA, GEORGIA 30303
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Report No. 50-302/81-27 Licensee:
Florida Power Corporation P. O. Box 14042, Mail Stop C-4 St. Petersburg, FL 33733 Facility Name:
Crystal River 3 Docket No. 50-302 License No. DPR-72 Inspection at Crystal Riv Fl o,rida Y8
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N Inspector:
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g i. Puckett a > S gned
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Approved byl 7[ D
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~C. M. Hosdy,%cting Sec{ ion Chief
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Technical Inspection Branch Engineering and Technical Inspection Division SUMMARY Inspection on November 16-20, 1981 Areas Inspected This routine, unannounced inspection involved 46.5 inspector-hours on site in the area of radiation protection, refueling health physics coverage, respiratory protection, and radiation work permits.
Results
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Of the 4 areas inspected, no violations or deviations were identified.
8112310478 81121I PDR ADOCK 05000302 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- D. C. Poole, Nuclear Plant Manager
- J. Cooper, NQA QS Manager
- M. Mann, Nuclear Compliance Auditor
- J. Dillon, Nuclear Plant Engineer
- G. Boldt, Technical Serving Supt.
- C, Brown, Nuclear Compliance Supt.
- G. Patrissi, Nuclear Fire Pretection Specialist
- K. Wilson, Nuclear Licensing Specialist
- J. Cunos, Nuclear Technical Training Specialist
- J. Pelham, Corporate Security Specialist
- G. D. Perkins, Plant Health Physicist
- K. F. Lancaster, Sr. Quality Program Auditor
- D. H. Smith, Nuclear Security & Special Projects Supt.
Other licensee employees contacted included 45 construction craftsmen, 6 technicians, 2 security force members, and 1 office person.
Other Organizations
- E. W. Ford, Consultant N.U.S. Corp.
- T. Stetka
- Attended exit interview
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2.
Exit Interview The inspection scope and findings were summarized on November 20, 1981, with those persons indicated in pa"; graph 1 above.
The inspector stated that the status of the radiation protection program at Crystal River 3 had shown considerable improvement as outlined in these details.
The plant manager acknowledged this observation and noted that work in the area of radiation protection required constant effort and that Florida Power Corporation was committed to r eovide that effor _________ _. _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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3.
Licensee Action on Previous Inspection Findings a.
79-24-01 (INF), Closed: The inspector has noted a heightened surveil-lance regarding posting and labeling on the part of the licensee. The corrective actions taken appear adequate to minimize this type of occurrance in the future, b.
79-35-03 (UNR), Closed:
Procedure documentation inadequacy.
The inspector has noted during investigation of several off normal events that documentation by the licensee is normally complete, accurate, and
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appropriate in the area of Chem / Rad, c.
79-46-02 (UNR), Closed:
Licensee to followup Gilbert Engineering report on rad waste disposal sy s tem., The Gilbert Engineering report indicated that no modifications to the rad waste disposal system were required.
This event has not reoccurred and the licensee feels no further action is necessary.
The inspector determined that the pre-cipitating event is presently unlikely due to current operating practice.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Health Physics Appraisal and Other Followup Items a.
79-FI-04 (IFI), Closed: Followup on bulletin 79-19; packaging of low level radioactive waste. This item was reviewed in inspection report 50-302/79-54. Since that time appropriate training has been given and retraining is required by the licensee's training program.
b.
79-FI-06 (IFI), Closed: Followup IE Circular 79-21. The licensee has examined potential release paths and taken appropriate. action in this regard.
c.
80-BU-10 (IFI), Open:
IE Bulletin 80-10, Contamination of non-radio-active system and resulting potential for unmonitored, uncontrolled release of radioactivity to environment.
Review of licensee records of 10 CFR 50.59(a) reviews reveals that the plant stormdrain system was not addressed. The licensee has been notified.
d.
80-15-02 (IFI), Closed: Training program revisions. The licensee has completely revised the employee training program. The training period has been expanded to three (3) days and addresses all of the points mentioned in the Health Physics appraisal.
e.
80-25-04 (IFI), Closed:
In-dapth performance audits.
In-depth per-formance audits are now performed by QC.
The inspector examined the program and determined it was adequately performed by both in-house and corporate personnel.
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80-25-12 (IFI), Closed:
Simplified presentation of indiYidual expo-sure data.
A printout is now sent to various departments with a
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simplified presentation of data.
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80-25-25 (IFI) Closed: Use of maintenance repair form, for respf ators.
As of October 23, 1981, the use of respirator repalf forms ha been required by RP-102. The inspector observed the J;rms in use aring this inspection.
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80-25-26 (IFI) Closed: Documentation of filter repl'acemdntion building air supply. Procedure RP-102 has required the specified $ cumentation as of October 23, 1931.
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80-25-31 (IFI), Open: Development of an acceptable records system for health physics. A review of the HP records system was conducted by the licensee's contractor (General Physics) as _part of an evaluation of recordkeeping in the facility.
The report wa2 received; in February,:
s 1981.
The licensee has reviewed all personnel exposure records tc, verify completeness, procedures have been changed to reflect the ws concerns expressed in the appraisal report.
The, inspector state (
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that more work was required in this area 'to ensure an acceptable
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program was in place and the licensee concurredJ e
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j 80-25-36 (IFI) Closed:
Recommendations f for streng'thisI.Ofo% routine
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surveillance program. The licensee presently performs dally contami-nation surveys in the HP lunch room. The scrap pile and other areas outside the protected area are surveyed monthly.
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The Plant Health Physicist stated that mutual use of equipmmt and
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personnel between the nuclear plant and the adjaceiit fossil plants.is
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not a normal occurrance at his site.
Also, a phystral barrieE completely surrounds the nuclear plant thus preventing any inadvertent _
j unsupervised transfer of materials between the plantg. For these
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reasons he did not feel a periodic survoy of the fossil plant.s tQ'
warranted.
The inspector agreed that the likelihoqd of transfge;cf
.m contaminated items to the fossil plant was low ane,-thabiNn the
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professional judgement of the licensee the suggested suivey wa'dedy
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needed then an appropriate evaluation, as required by 10 CFR 20.201, l
had been performed.
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80-25-38 (IFI) Open:
Incorporation of ANSI N-323-1978 ir,to plant calibration procedures (See item 80-25-43 discussed belos)?
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80-25-43 (IFI), Open:
Calibration facility and training for cali-bration technicians.
The licensee has established a new calibration i
facility in the turbine building.
Although the training of techni-cians in all areas has been upgraded, the concern expressed in the-appraisal has not been specifically addressed.
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80-Q-45 (IFI) Open:
Real Time ton;puting system for ALARAcconcerns.
The licensee's new HP4000 lystem, to be working by mid 1%2 vill
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address this concern.
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40-25-47 (IFI), Closed:
Recommended changes tc, procedure.
The inspector reviewed the recommended change and licensee ' actions on each.
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In almost every case the recommended change had been> incorporated or
",g appropriately resolved.
The exception deals with ^ the inclusion of ANSI, N-323-1978 in instrument calibration prochdures and is-carried s
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[77'n pfesantly under IFI 30-25-38.
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The inspecky wasjadedtp look into concerns expressed by an employee c. -
d7 M{A,Sp5cifically,'the Y6nceq$ i'a work in the radiation conti)lled area.
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ofre subcontfact'or'engdg A as that employees had been instructed to Yec 1 **repa fil inside the reacto Nbuilding during periods that their presence a
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is not required for specihc work functions.
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NJ,("When this c'oncern was firs (yevealed to the inspector he' telephoned the
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y ins), ructions, expressed it a letter, was ch,nslistent iwith traintaining K.,..
,s personnel radiation exposure As Low As Reasonably Achievable (ALARA).
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He further stated that he regarded h y.h underst'anding by the workers
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as,very unfortunate and would takeestep Q o correct their misapprehen--
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When the inspector, during the coursef of this in'..'ection, inquired
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about the actions taken, the licensee representative stated that a
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meeting had been held wherein the plant's ALARA policy was explained
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and the use of established low bqckground " waiting" areas in the
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reactor building was recommended to the workers for those times when it
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fG was impractica'l to exit the^ building prior to resuming work.
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radiation levels by actual measurement.
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The stathd urpose of requiring workeri to stay in the reactor building
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was:
"Due to inefficiencies experienced with taking breaks and to
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reduce thg-volume of profective clothing used...".
Each exit / entry
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Ds from the reactor building would result in one full set of protective
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clothinf be'ing sent to the laundry. Aside from the monetary - expense t-involved, this would result (if the exit was unnecessary) in the
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,Q generation af a discrete amount of liquid radioative waste due to the
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wash. The licensee clso stated that the nature of the job involved
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work area each time" caused undesirable delays in the progress of the s
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-The inspector stated that each of these reasons were valid so long as the overriding philosophy of ALARA was taken into consideration. He further suggested that the problems experienced were likely due.to poor communication.
On November 17, 1981, the inspector was informed by the licensee that four workers had quit their jobs and left the plant. No definitive reason for their action could 'be ascertained.
The inspector, after
. consultation with the licensee, held a meeting with about 40 of the workers to:
1) determine 'if any of their concerns fell within the purview of the NRC, and 2) provide information to the workers regarding the licensee's responsibility to inform workers in accordance with 10 CFR 19.
As a result of this meeting, a number of worker ccacerns were expressed to the inspector. The following describes each concun and its dispo-sition or resolution.
Concerns which were not within the area of responsibility of the NRC and posed no immediate threat to health were dealt with by the inspector recommending the-individt al contact the appropriate regulatory body outside the NRC.
Concerns:
1.
An item concerning the validity of the security background check performed by.the licensee was referred to the RII section having responsibility for this area.
2.
The workers expressed a concern that on at least one occasion when the reactor building was cleared for radiation protection pur-poses, the building evacuation alarm was not sounded.
The building was cleared by having Health Physics personnel direct the orderly clearance.
The licensee has written criteria for sounding the reactor building evacuation alarm in approved procedures. In those cases when these criteria are not met, the option to sound the alarm is still available to the reactor operator if he feels it necessary.
In the cases examined by the inspector the conditions in the reactor building did not warrant sounding. the alarm and the orderly and thus, less hazardous, me: hod used 'was adequate for personnel protection. A licensee representative stated that the reactor operator consults with the radiation protection group in making this decision. The inspector had no further questions.
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Workers expressed concern that on occasions where respi ratory protection is required for a job, cases occur where workers only a few feet from the work are not required to wear protective masks or other device.
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6-The inspector explained that the determinations made in these jobs are on a case-by-case basis and are founded on the radiation protection technician's knowledge of the job gained from experi-ence and consultation with supervision and workers; awareness of radiological conditions, samples taken at the_ specific job or-
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similar ones; and his training.
-The inspector also suggested to the workers that the measures taken by the licensee appeared effective because the bioassay results required of the licensee by 10 CFR 20.103(a)(2) to deter-mine the efficacy of his respiratory protection program indicated no significant uptake of radioactive materials in the history-of this facility.
4.
A question was posed regarding the recording of entry and exit times kept on radiation work permits. Specifically, workers were concerned that this information was used by the licensee only to monitor the worker's whereabouts.
The inspector explained that this information was important from a-radiological protection standpoint for two major reasons. _ First, an ALARA computer system used by the licensee uses time informa-tion to monitor the average rate of received dose for jobs - a valuable planning tool.
Second, in the ca:,e of lost personnel dosimetry, the duration of exposure becomes a very important variable in the required evaluation of personnel exposure.
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The inspector noted that other use'of the time information was the business of the licensee and fell outside the purview of the mission of the NRC.
5.
A question was raised concerning the adequacy of security coverage
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in the reactor building but no specific example of a problem was given. the inspector. This concern has been provided to the' RII
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security specialist.
6.
The workers, when questioned by the inspector, were unaware of the location of the NRC Resident inspector's office at the plant site.
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The inspector stated that concerns by workers could be brought to the NRC's attention and receive prompt action when appropriate, via this channel.of communication.
'The inspector obtained a set of large, reflective, adhesive letters spelling, "USNRC Resident Inspector" and applied these to-the side of the resident's trailer where they could be easily seen and read from the main entry to the site.
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Section 5.d of this report closes a previous inspection item.
concerning the. adequacy of the ' licensee's general employee training program. The licensee has indeed upgraded his training
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to meet both NRC specific requirements and the concerns expressed in the Health Physics appraisal.
The workers expressed a concern to the inspector that the training presently provided, while adequate or even excessive in its presentation of the theoretical aspects of radiation protection, erred by neglecting the practical, day-to-day aspects.
An example provided specified that although the various articles of protective clothing afforded for use by the workers were mentioned, the method of wearing them was left to be taught to the new worker by his more experienced fellows. The actual practice donning of protective clothing was not done during training.
Other concerns of this type were expressed by the workers. The inspector stated that although the licensee was meeting regulatory requirements, he would discuss with the licensee adding practical demonstration by the workers in donning and removing protective clothing and frisking to the training program.
8.
A final concern expressed by the workers was in the area of quality control of the work they performed.
This item, dealing with pipe restraints (snubbers) was turned over to the resident inspector fcr evaluation and resolui. ion.
b.
Contract Health Physics Technician Qualification The inspector examined the resumes of the refueling outage contract technicians and determined that all technicians performing in a respon-sible position met the requirements of ANSI N-18.1,1971 as required by the license's Technical Specifications. Approximately 50 records were examined.
The licensee has instituted a program of pre-employment testing for contract technicians inclu ing both a written examination and oral d
interviews. Upon completion of the testing, successful contractors are provided with plant-specific information, procedures, and orientation to enable them to properly perform at the facility. The inspector stated that this program was an excellent technique for obtaining quality workers.
c.
The licensee stated that negotiations are presently underway to limit permanent technician responsibilities to either radiochemistry or Health Physics in order to avoid dilution of an individual's experience and job familiarity. This re-definition of duties should, according to the licensee, provide more expertise in each of these areas.
The inspector agreed, and noted that current personnel assignres had been made for longer than usual terms, resulting in the beginc.ng of the realization of these benefits.