IR 05000302/1982006

IE Insp Rept 50-302/82-06 on 820316-19.Noncompliance Noted:Leak Test Performed on Pu-239 Calibr Source Counted on Instrument Accurate for Beta or Gamma Detection Only

ML20054K295
Person / Time
Site:	Crystal River
Issue date:	04/07/1982
From:	Barr K, Kahle J, Jonathon Puckett NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20054K251	List: IR 05000302/1982006 ML20054K250 ML20054K266 ML20054K271 ML20054K289
References
50-302-82-06, 50-302-82-6, NUDOCS 8207010402
Download: ML20054K295 (9)

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i 8 k UNITED STATES 8 N NUCLEAR REGULATORY COMMISSION i

$ E REGION 11 l o # 101 MARIETTA ST., N.W., SUITE 3100 k d ATLANTA, GEORGIA 303o3

...o Report No. 50-302/82-06 l Licensee: Florida Power Corporation P. O. Box 14042, Mail Stop C-4 St. Petersburg, Florida 33733 Facility Name: Crystal River 3 Docket No. 50-302 License No. DPR-72 Inspection at Crystal River, Florida Inspectors: h_M. Puc ett

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Technical Inspection Branch Division of Engineering and Technical Programs SUMMARY Inspection on March 16-19, 1982 Areas Inspected This routine, unannounced inspection involved 60 inspector-hours on site in the areas of radiological protection procedures, instruments and equipment, exposure control, internal exposure, posting, labeling and control, surveys, and radiation protection supervisio Results Of the seven areas inspected, no violations or deviations were identified in six areas; one item of noncompliance was found in one area (Failure to follow proce-dures for control of radioactivity for limiting materials released to the environ-ment and limiting personnel exposure),

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REPORT DETAILS Persons Contacted Licensee Employees

• G. H. Ruszala, Chem-Rad Prot. Mg * Lander, Maintenance Superintendent

• W. Johnson, Nuclear Operations En *B. P. Komara, Nuclear Compliance Auditor

• F. Cranfield, Health Physics Supervisor G. D. Perkins, Plant Health Physicist Other licensee employees contacted included eight technician NRC Resident Inspector

• T. Stetka

• B. Smith

• Attended exit interview Exit Interview The inspection scope and findings were summarized on March 19, 1982, with those persons indicated in paragraph 1 above. Licensee representatives acknowledged the violation regarding procedural complianc . Licensee Action on Previous Inspection Findings Not inspecte . Unresolved Items Unresolved items were not identified during this inspectio . Tour of Turbine and Auxiliary Buildings On March 16, 1982, the inspectors, in the company of a licensee representa-tive, conducted a tour of the turbine and auxiliary building In the turbine building the inspectors surveyed an area set aside for the packaging and processing of ion exchange resin prior to shipment for burial as radioactive waste. The resin is used in the condensate system to remove radioactive and other contaminants and, as a result of very small primary to secondary leakage of radioactively conta'minated water in the steam genera-tors, is slightly radioactive. The inspectors observed that the area was properly posted as required by 10 CFR 20.203 and confirmed the licensee's surveys by independent measurement of radiation dose rate _

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The inspectors also measured radiation dose rates in the secondary system sampling area, an area sometimes found to be radioactively contaminated due to steam generator leakage. Due to the very small amount of steam generator leakage and coincident low levels of radioactivity present in the primary

system, no measurable levels of radioactivity or significant radiation dose were found in this area when surveyed by the inspector Upon entering the auxiliary building, one of the inspectors was required, due to his not having previously visited the Crystal River facility, to complete several forms unique to this plant. When a licensee representative was questioned about the utility of these forms, the following explanation was provided: contractors (non-utility employed workers) had previously found that by representing certain of their employees os casual visitors, they could circumvent the radiation worker training repairements mandated by the plant technical specifications, section By .he extra form for visitors, which by design requires review by the plant manager, attention of higher levels of plant management has been brought to bear on the misuse of the visitor designation and this practice has been curtaile The unde-niable efficiency of this remedy forbode further comment by the inspector In the radiochemistry laboratory the inspectors noted an Eberline AMS-2 continuous air monitor in use to monitor levels of airborne radioactivity concentrations. Affixed to a panel below the monitor was a log sheet

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indicating the frequency of change of the fixed filter collection medi The log sheet in current use was a hand-drawn replacement of the form normally used and the frequency of filter change was irregular and varied from one to three weeks. The most recent change of filter was March 15, the day prior to the inspection. The inspector requested that the sample results from the filter analysis be produced by the licensee. A search of the records by licensee representatives produced no result. The inspector noted also that the AMS-2 strip-chart recorder had not been replenished with the required pressure-sensitive chart paper. This element of the device's design could provide warning of an abnormal situation in the radiochemistry laboratory by indication of an upward trend in airborne contamination levels before reaching the alarm setpoint on the machine. It was noted by the inspectors that the alarm was set to sound at approximately four times background levels normally experienced in the room. Thus, the alarm could be expected to sound well before the maximum permissible concentration levels (MPC) requiring special controls would be reache When questioned by the inspectors regarding the intent of placing an AMS-2 monitor in the laboratory, the plant Health Physics supervisor stated that i the monitor resulted from a concern that some event could unexpectedly occur in the lab which could cause a transient high airborne radioactive material concentration and the monitor would provide warning of such an event. He stated that the laboratory fume hoods were installed to ensure 100 LFM flow into the hoods (as recommended by National Bureau of Standards Handbook 52 for hoods in use with radioactive material) and that this airflow was monitored by appropriate instrumentatio ._ _ - . _ _ _ _ _ , _

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3 Chemistry and Radiation Protection Procedure RP-202, " Radiological Surveys",

paragraph 2.1 notes that routine radiological surveys are normally performed at a given frequenc A cardex file in the Health Physics Operations-offices is used to denote specific routine survey frequencies and requires that all operating AMS-2 continuous air monitors have their filters changed weekl Contrary to the above, the AMS-2 located in the Radiochemistry laboratory was found to have had its filter changed on 3-15-82 and 2-22-82, an elapsed time of greater than the one week required by the procedur _

(Violation 50-302/82-06-01)

The inspector stated that it was apparent an evaluation of the hazards to workers due to the presence of radioactive materials had been performed as required by 10 CFR 20.201. Although this requirement had been met, the requirement for procedural adherence was not me During the inspection of the auxiliary building the inspectors checked the function of the locks on doors or gates (these locks are required by Techni-cal Specification 6.12). All gates in accessible areas were properly locked j and could not be easily defeated. The inspector concluded that this require-ment was satisfied.

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Proper posting of radiation areas and high radiation areas as required by 10 CFR 20.203 was confirmed by independent measurement of radiation levels in the auxiliary building. No discrepancies were noted by the inspector The inspectors observed that the licensee uses metal boxes to ship, for burial as radioactive waste, items which cannot be compacted into Speci-l fication 0.0.T.17-H 55 gallon arums. The metal boxes are placed in the

, vicinity of the drum compactor and receive items which are presumed to be

! radioactively contaminated. The inspectors observed on March 16, 1982,

a metal box, approximately 1/2 full of items which were removed from the

' compaction area, some of which bore " radioactive material" tape. The box was not marked in any way to indicate the hazard present. Procedure

, RP-217, Section 2.2.1, states that the Chem-Rad Section will affix a

! " Radioactive Material" tag to the container or survey the container and

! mark as required. This is a violation of Procedure RP-21 (Violation

! 50-302/82-06-01)

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On March 16, 1982 a drum from Southern Space,- marked H-9, containing laundered bubble hoods comprising a total of .007 millicuries of radio-activity according to a shipping manifest found inside the drum had not been properly surveyed. Subsequent survey revealed the contents to be less than plant unconditional release limits. This is a violation of the procedural requirement for a survey. (50-302/82-06-01)

Contrary to the above, no notification of Chem-Rad took place for the items mentioned above. (Violation 50-302/82-06-01)

6. Led Testing of Sealed Sources The inspector examined the records of the semi-annual leak test performed on

! all sealed sources in the licensee's possessio The licensee's records i indicated 100 sealed sources had been checked. The inspector indicated that the number of sources appears to be higher than actually required. Radia-tion Protection Manager stated that an evaluation of the need for so many sources would be performed and those not required would be properly disposed of as radioactive wast Chemistry and Radiation Protection Procedure RP-101, Radiation Protection Manual, section 6.3, Sealed sources, requires all licensee's sealed sources, such as calibration sources, to be leak tested at six months interval The inspector noted that the leak test performed in January,1982, on source

1. 55, a 0.03 uCi Pu239 calibration source, was counted on an instrument accurate for beta or gamma detection only. Smears to detect Pu239 leakage require counting with an alpha sensitive radiation detecto (Violation 50-302/82-06-01)

7. Procedural Compliance Technical Specification 6.8 requires written procedures to be established, implemented, and maintained for activities recommended in Appendix "A" of Regulatory Guide 1.33, November 197 Section G of Appendix "A" describes Procedures for Control of Radioactivity (for limiting materials released to the environment and limiting personnel exposure).

The inspector reviewed the licensee's inspection history of the past tw years (1980, 1981) in the area of health physics with the licensee's Radia-tion Protection Manage The inspector observed that much progress has been made in the process of bringing the programs for personnel protection against radiation and radio-active material into - compliance with the applicable regulations. The inspector stated that recent inspections indicate the procedural accom-plishment of program goals has been substantially complete The inspector suggested to the licensee that the next step in the licensee's overall management of the changes recommended by the Health Physics

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Appraisal (50-302/80-25) would appear to be ensuring prompt and complete procedural compliance by all plant radiation workers as well as Chem-Rad technician The Radiation Protection Manager stated that he was aware of the problems in this area and was taking steps to emphasize the role of middle level super-vision in ensuring procedural complianc . Calibration of Instruments RP-206, Radiation Protection Calibration Procedures, section 2.2.1, states that each instrument will have a calibration data sticker noting the cali-bration due date and requires the instrument to be cycled for calibration on or before the calibration due date has expire On March 18, 1982, an Eberline Ion Chamber Instrument, R0-2, SN1215, was found by the inspector to bear a tag with a calibration due date of March 6, 1982, which had been in use past that date for surveys used to satisfy the requirements of 10 CFR 2 The licensee's Radiation Protection Manager stated that the due date intended was understood by his employees to mean the last day of the noted month rather than the specific day date noted on the ta The inspector stated that the procedure, RP-206, should be changed to show that inten The inspector further noted that since this was the only instance noted of an out-of calibration instrument, and that the operation of the instrument was shown to be proper, this event would be treated as an isolated occur-rence, not worthy of citation, due to the difference in procedure interpre-tation. (This item is an Inspector Followup Item 50-302/82-06-02)

9. Radiation Protection Operations Office Functioning (RWP Office)

The inspector observed the routine operation of the Radiation Work Permit (RWP) of fic RWP's 82-0182, 82-0186, and 82-0170 were reviewed for adequacy of protective measures taken by or required by the Chem-Rad Department -for the performance of work in the plant. In each case, technicians performing air samples, dose surveys, or other surveillance, were questioned as to the technique used and the methods used to determine need for the surveillanc One minor problem was noted in the use of the licensee's respirator issue log. When a respirator is required by a radiation work permit, the ir.dividual to be protected is issued the appropriate device and it is logged along with his name and the RWP being worke The licensee's log for equipment issue failed to discriminate between a particulate filter or airline supplied air when the Scott full-face respirator was issued. Hence by default, the protection factor for the filter must be used for calculation of inhaled radioactive material rather than the much higher factor allowed for supplied air. Because the default

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value would be used, this is a conservative approach and results in individuals being afforded rather more protection than indicated by the lo When the inspector requested the licensee produce copies of the RWP used for a special reactor containment entry on March 5,1982, the paperwork appeared i to be incomplete. The dose addendum sheet for RWP 82-0170 could not be produced until the next day.

The two preceding items are regarded by the inspector as being indicative of i a continuing problem regarding record keepin This problem was first j brought to the licensee's attention during the Health Physics Appraisal and i has been evident since that time. (See NRC Inspection Reports 50-302/80-25;

) 81-08, and 81-27).

The Radiation Protection Manager stated that the development of a compu-terized record system for the Chem-Rad Department was proceeding apace and that the required hardware had been installed on site. Cables were being installed and the system implemented with as much diligence as possible. It 3 was apparent to the inspector that this problem area had been addressed on a i temporary' basis. A new form for tracking surveys was in use, for example, but work remains to be done to resolve these problems. The licensee acknow-j ledged the inspector's concerns.

! An important part of the functioning of the Health Physics Department at a facility is the relationship between Chem-Rad technicians and the workers

! they are charged to protec The inspector observed that workers were l

greeted courteously and their problems or concerns dealt with promptly.

10. External Exposure Control

I Procedures

The inspector examined the following licensee procedures

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l RP-101 Radiation Protection Manual j RP-201 Personnel Exposure Documentation l RP-206 Radiation Protection Instrumentation Calibration Procedures

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i RP-213 Quality Test of Direct Reading Pocket Dosimeter RP-216 Health Physics - Vendor Services Spike Program RP-229 Extremity Dosimetry Program i Several areas in the procedures were discussed with licensee _repre-

sentatives for clarification and detail. It was apparent that the

procedures had been revised and reviewed since the health physics

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appraisal inspection in June 1980. The inspector had no further questions regarding these procedures.

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7' Radiation Detection Devices TLD radiation detection devices are issued on a monthly basis to all workers and visitors 1who enter the radiation control area (RCA).

Eberline contractor services are used with provisions _ for onsite

- readout during outages. The inspector verified that the licensee had implemented a program for determining extremity and skin-exposures and that the program was functioning. Self reading-pocket dosimeters are issued to all individuals entering the RCA. Dose estimates are main-tained on a daily basis with control documentation to maintain radia-tion doses within the licensee's prescribed limit of 300 mrem per wee The 300 mrem limit may be exceeded with radiation protection and plant management approval. Daily computer printouts are provided which give-individuals' margin between the 10 CFR 20 quarterly dose limit and the individual's estimate TLD and pocket dosimeter dose. The printouts are posted at the entrance to the RCA and are available to radiation protection personnel for review and approval of radiation work permit The inspector had no further question Records The inspector examined the radiation exposure records for 1981 and January 1982. The records showed no exposures greater than 3 rem in a quarter or 5 rem for 1981. There were no significant exposure during January 198 Where quarterly exposures exceeded 1.25 rem, _the inspector verified that Form NRC-4 information was maintained in the individuals radiation exposure files. The inspector verified that the 10 CFR 20 limits for skin _and extremity doses had not been exceede No violations were identifie Exposure To Minors Licensee representatives explained the system for controlling exposure to individuals under 18 years of age. The individual's birth date and age are placed on the licensee's dosimetry request form when dosimetry service is established. The computer program uses this information when computing the margin exposure. Licensee representatives stated that currently there were no individuals under 18 years of age on the dosimetry program. A cursory examination of the records and files confirmed this statement. The inspector had no further question Quality Control Licensee representatives explained their system for preparing spiked dosimeters and blanks (background radiation). Two fictitious individuals are maintained constantly plus a licensee representative wears a duplicate TLD at all times. If'the contractor results for the two spikes or the duplicate TLD vary more than 20 percent of the known exposure or the individuals recorded dose then investigative and corrective measures are taken. The inspector had no further question r ,

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f. Dosimeter Calibrations Licensee representatives explained the pocket dosimeter calibration procedur Dosimeters are calibrated at a six month interval .

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A record is maintained for each dosimeter. The accepted calibration date is placed on each dosimeter. An examination of dosimeters- and the records showed that the calibrations were being performed as require The inspector had no further question g. TLD and Pocket Dosimeter Correlations The licensee uses a computer program to compare TLD and pocket dosi-meter results. If results are greater than 100 mrem and vary by more than 25 percent, an evaluation is made to determine which is the true dos If the dosimeter result is used a letter is issued to the contractor for changing the exposure records and reports to reflect the pocket dosimeter results. The inspector verified that the evaluations had been performed and the corresponding dose records had been update The inspector had no further question h. Reports The inspector verified that the annual and termination reports were issued in accordance with 10 CFR 20.407 and 10 CFR 20.40 No viola-tions were identifie .