IR 05000302/1986026
| ML20214M710 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/20/1986 |
| From: | Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20214M669 | List: |
| References | |
| 50-302-86-26, NUDOCS 8609110238 | |
| Download: ML20214M710 (11) | |
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p Kit UNITED STATES o
NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET,N.W.
- c ATLANTA, GEORGIA 30323
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Report No.: 50-302/86-26 Licensee:
Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Docket No.: 50-302 License No.: DPR-72 Facility Name: Crystal River 3 Inspection Con cted: July 21-1986
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Inspector: [///a A
P - 2 0 - 8 (o W. T.~E60per p
Date Signed Approved by:
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.M.H6se~y,SectfonChief Date Signed Division of Radiation Safety and' Safeguards SUMMARY ~
Scope:
This routine, unannounced inspection involved a review of the licensee's health physics organization and management controls, internal dosimetry, the licensee's program for maintaining exposures as low as reasonably achievable (ALARA), transportation of radioactivt. material, control of radioactive materials, surveys and monitoring and external exposure control.
Resul ts: Three violations were identified:
(1) failure of an individual to have a radiation monitoring device in his possession which continuously indicates the radiation dose rate while in a high radiation area, (2) failure to perform an adequate alpha radiation evaluation, and (3) failure to brace a shipment of LSA radioactive material to prevent a shift of lading during transportation.
8609110238 860902 PDR ADOCK 05000302 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- V. R. Roppel, Technical Support Manager B. J. Hickle, Operations Manager
- K. R. Wilson, Manager, Site Nuclear Licensing
- M. S. Mann, Nuclear Compliance Specialist
- W. L. Rossfeld, Nuclear Compliance Manager
- P. J. Skramstad, Nuclear Chem / Rad Superintendent
- P. D. Breedlove, Nuclear Records Management
- V. A. Hernandez, Senior Nuclear Quality Assurance Specialist
- R. T. Wittman, Nuclear Operations Superintendent
- J. Albondi, Manager, Site Nuclear Support
- J. C. Smith, Nuclear Compliance Specialist
- R. Clark, Radiation Protection Manager
- A. Kazemfar, ALARA Specialist
- E. Welch, Nuclear Plant Engineering Superintendent
- C. Brown, Outage Manager
- G. A. Becker, Manager, Site Nuclear Engineering Services
- E. W. Ford, Operating Experience Specialist G. R. Clymer, Nuclear Waste Manager S. E. Chapin, Nuclear Waste Supervisor M. Siapno, Health Physics Supervisor D. A. Van Oosterwyk, Health Physics Supervisor R. Browning, Health Physics Supervisor W. P. Ellsberry, Nuclear Operations Training Supervisor Other licensee employees contacted included six technicians, three security force members and five office personnel.
NRC Resident Inspectors
- J. Stetka, Senior Resident Inspector
- J. Tedrow, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on July 25, 1986, with those persons indicated in Paragraph 1 above. The licensee was informed of three apparent violations involving the evaluation of the presence of smearable and airborne alpha radiation in the facility (Paragraph 8), the presence of personnel in high radiation areas without the required radiation survey instrument (Paragraph 9), and the release of tools from the Radiation Control Area without an adequate contamination survey (Paragraph 8).
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The inspector also discussed an unresolved item * pertaining to air sampling and a radioactive material uptake by one worker during reactor cavity decontamination on February 28, 1986. A licensee representative stated that the information would be forwarded to the inspector after a search of the document control files.
In a telephone conversation between the Region II office and licensee management on August 19, 1986, the licensee was informed of an additional violation concerning the bracing of drums in LSA Shipment-0686-061-A (Paragraph 7).
The licensee was also informed that the unresolved item related to a radioactive material uptake on February 28, 1986 was closed based on the review of the documents provided by the licensee subsequent to the inspection and that the apparent violation for contaminated tools outside the RCA has been evaluated and determined to be a licensee identified violation in accordance with 10 CFR 2, Appendix C.
Licensee management acknowledged the inspection findings and took no exceptions.
3.
Licensee Action on Previous Enforcement Matters (92702)
(Closed) Violation (50-302/85-41-02), Failure to barricade and post a high radiation area.
The inspector reviewed and verified the corrective actions as stated in Florida Power Corporation letter dated March 16, 1986.
(Closed) Violation (50-302/85-41-03), Failure to adhere to the requirements of procedure to wear protective clothing established on a RWP.
The inspector reviewed and verified the corrective actions as stated in Florida Power Corporation letter dated March 16, 1986.
(Closed) Violation (50-302/86-11-01), Failure to perform adequate surveys to evaluate releases of airborne radioactivity.
The inspector reviewed and verified the corrective actions as stated in Florida Power Corporation letter dated March 14, 1986.
4.
Organization and Management Controls (83722)
The inspector reviewed the licensee's staffing levels and lines of authority as they related to the health physics and radioactive waste staffs.
The licensee currently employs thirty-five ANSI qualified health physics technicians (HPT), of which eighteen are contract technicians. The licensee also employs. four lead HPTs, five assistant HPTs and five decontamination technicians.
The Health Physics staffing level appeared adequate for a single unit PWR.
The inspector reviewed recent changes to the licensee's Radiological Safety Incident Report (RSIR) system which involved trending of deficiencies within
- An unresolved item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviation.
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five categories. The inspector selectively reviewed RSIRs written'since the change and it appeared, from the records reviewed, that RSIR items were being adequately tracked until completed. The inspector stated that in some cases, the corrective actions taken as a result of the radiation safety violations did not appear to address the root cause of the violation,- but rather were specific to a single individual, i.e., employee counseling.
A licensee representative stated that the licensee was limited as to the actions that could be taken due to the union contractual requirements for multiple levels of disciplinary action.
The inspector stated that notwithstanding contractual requirements, identification and correction of the root causes of violations should be addressed by the licensee.
The inspector discussed, with the Operations Manager, action the licensee was taking to provide increased management attention in the area of health physics.
The actions included:
Stationing of a security guard at the RCA frisking stations to monitor exit frisking, whole body frisking monitors have been evaluated and the order for those monitors was pending, elevated severity of the penalties associated with non-compliance of plant policies and procedures, establishment of supervisory goals in performance evaluations, establishment of a radiological safety committee, incorporation of radiation safety items into shop safety meetings, improvement of the RSIR program, established a management review board for ' non-compliances,
" fire-side chats" established on radiation safety topics, rewriting of HP procedures and implementation of the radiation safety concern / suggestion form and safety incentive program.
The inspector selectively reviewed the topics discussed during the inspection.
The inspector stated that the security guards observed at RCA frisking stations did not appear attentive to personnel performing frisks.
The inspector did not observe the guards correcting personnel on poor frisking practices. Licensee management stated that four Eber11ne model PCM-1 personnel monitors are approved for purchase and should be onsite within six months.
The management review board for non-compliances meets to discuss either significant radiation safety violations, or to discuss repeat violations involving the same individual.
The inspector reviewed the minutes of two management review board meetings and determined that the actions taken by the board appeared adequate.
No violation or deviations were identified.
5.
Internal Exposure Control and Assessment (83725)
The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403 and 20.405 to control uptakes of radioactive material, assess such uptakes and keep records of and make reports of such uptakes.
During tours of the plant, the inspector observed the use of temporary ventilation systems and containment enclosures in the hot machine shop and at the decontamination
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pit in the auxiliary building and discussed its use with the respiratory
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protection supervisor.
The inspector also discussed respirator issue and maintenance with licensee representatives.
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The instrument air system was used by the licensee for breathing air
purposes, and was routinely sampled by the licensee to insure it met Grade D L
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quality criteria.
When an instrument air line was used for breathing air purposes, a five stage filter was ettached to the manifold to provide further purification.
The inspector discussed the locations of the instrument air compressors with licensee representatives and verified that the compressors did not have an inert gas backup which would maintain system pressure in the ' event of a compressor failure.
In the event a failure occurred, the service air system would provide backup system pressurization.
The service air system was also routinely sampled to insure Grade D quality criterion was met.
Respirator repair after cleaning was performed -by onsite respiratory maintenance technicians who were trained by the vendor.
The technicians were qualified to perform mairtenance on all respiratory protection devices
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and were also trained for repairs through the first stage of air line or self contained breathing apparatus regulators.
The licensee performed maintenance on regulators on a two year cycle.
On February 28, 1986, post-hydrolasing cleanup operations were being conducted in the reactor building.
The inspector reviewed RSIR number 86-110 which documented an airborne event in the containment. Two building servicemen accompanied two HPTs into the reactor cavity in preparation for the application of.strippable paint.
Trash, wet herculite and nylon bags were double bagged and stored in the cavity.
This initial entry required the use of full face respirators and air sampling in the cavity was
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performed.
The plastic bags were subsequently removed from the cavity via rope from the refuel floor and stored in a posted high radiation area. The air samples collected during work within the cavity did not indicate an airborne problem during this work evolution; however, routine air samples collected on the 164 foot and 180 foot elevations of the containment indicated increased airborne radioactivity in excess of 25 percent of a maximum' permissible concentration (MPC) as defined in 10 CFR 20, Appendix B, Table 1, Column 1.
A licensee evaluation of the event indicated a suspected air flow reversal caused contaminated air to move out of the reactor cavity and into the upper elevations of containment. At the time of this incident, the building serviceman located at the reactor cavity railing was not wearing respiratory protective equipment and that individual was subsequently sent for a whole body count. At the time of the exit interview on July 25, 1986, the magnitude of the exposure was not known.
The dosimetry supervisor subsequettly provided the inspector with whole body count data after the exit interview. The inspector also reviewed air sample data provided to the inspector by mail on August 12, 1986.
The inspector subsequently calculated a radioactive material uptake equivalent to 0.29 MPC-hours based upon whole body count data.
The licensee calculated the radioactive material uptake related to this incident to be equivalent to 0.12 MPC-hours.
The licensee was not required by 10 CFR 20.103(a)(3) to maintain records of exposures less than 2 MPC-hours in a day. This item was initially identified as an unresolved item in the exit interview, but after the inspector's review of the whole body count and air sample data, the inspector stated in a telephone conversation with licensee management on August 19, 1986, that this item was close.
6.
ALARA (83728)
During tours of the plant, the inspector interviewed licensee personnel on their knowledge of ALARA and the methods each individual used to minimize his exposure.
Each individual appeared to have adequecte knowledge of ALARA principles and methods.
The projected radiation dose for the year as of January 1986, was 30 man-rem. However, an unscheduled reactor coolant pump outage resulted in a revision to that estimate.
The revised projected dose for the year was 350 man-rem.
Cumulative dose for 1986 thru June 30, 1986, was 313 man-rem as measured by TLD.
7.
Transportation of Radioactive Materials (86721)
The inspector reviewed the licensee's program for the transportation of radioactive waste including the procedures for selection of packaging; preparation of waste for shipment; and marking, placarding and labeling and monitoring for radiation and contamination.
A licensee representative stated that the procedures are updated when required to incorporate revisions to the regulations.
The inspector reviewed the licensee's transportation procedures and verified the procedures were consistent with applicable regulations.
The inspector reviewed a Type C radioactive waste shipment made by the licensee during the week of July 14-21, 1986, which consisted of letdown filters in high integrity containers.
The inspector discussed the shipment with licensee representatives and reviewed the sampling methods used to determine the radionuclides on the filters and the curie content of the containers.
The licensee used a portion of plant procedure WP-101, Packaging, Storing and Shipping of Radioactive Waste, which dealt with the subject determinations in compacted solid waste.
The licensee representative stated that a procedure detailing more specific handling instructions for letdown filters was in the process of being developed. The inspector determined that the procedure in use appeared to be adequate. The inspector stated that the new procedure for the handling of letdr 1 filters was an inspector followup item and would be reviewed during a tucure inspection (50-302/86-26-01).
The inspector discussed a warning communication mailed to the licensee by the State of South Carolina Department of Health and Environmental Control on June 11, 1986, which detailed concerns related to Radioactive Waste Shipment No. 0686-061-A.
The communication detailed two infractions:
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Drums in this shipment were found to have bulging lids which constitute damaged drums. This is contrary to the requirements of Condition 61 of S.C.
Radioactive Material License 097, Amendment 41.
Irregular packaging of this nature also limits stacking of the drums, therefore, utilizing additional trench spac _
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b.
Although blocking and bracing was provided, some of the drums in the rear of the van underwent a shift of lading, contrary to the requirements of 49 CFR 173.425(b)(6).
Additional bracing should have
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been provided to secure all drums.
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49 CFR 173.425(b) exempts LSA materials consigned as exclusive use from the packaging requirements of 49 CFR 173.412.
The inspector determined that since no breach of package integrity occured and there were no loss of package contents even though the packages were deformed, item (a) of the warning communication would not be considered a violation of 49 CFR 173.425 in that the package met the strong, tight package criteria.
10 CFR 71.5 prohibits transport of any licensed material outside the confines of a plant or other place of use, or delivery of licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Transportation in 49 CFR 170-189.
49 CFR 173.425(b)(6) requires that exclusive use shipments of low specific activity (LSA) material must be braced so as to prevent shifting of lading, under conditions normally incident to transportation.
t On June 5,1986, at the Barnwell waste burial facility, a State of South Carolina inspector found that several drums of compacted waste near the rear of the van had undergone a shift of lading during transportation of LSA exclusive use Shipment Number 0686-061-A.
The inspector stated that the failure to brace LSA exclusive use Shipment Number 0686-061-A to prevent shifting of lading was an apparent violation of 10 CFR 71.5 (50-302/86-26-02).
The licensee's corrective actions addressing the infractions identified by the State of South Carolina were not complete at the time of the inspection.
The licensee had made a response to the State of South Carolina, which the State found to be unacceptable.
The licensee was in the process of formulating an additional response at the time of the inspection.
8.
Control of Radioactive Materials and Contamination, Surveys and Monitoring (83526)
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On July 7,1986, Region II was notified by the licensee that they had discovered contaminated tools outside the radiation control area and outside
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the protected area.
In discussions with licensee representatives, the inspector determined that a licensee contractor had discovered a welding torch in the contractor tool trailer outside the protected area with what appeared to be the remains of a radioactive material sticker attached to it.
A survey of the torch performed by health physics indicated fixed contamination of 1000 dpm per the area under the probe (AUP).
Additional surveys performed by the licensee identified a total of approximately 50 tools which were found in offsite tool trailers, the cold machine shop, Instrumentation and Control (I&C) shop and Electrical Maintenance shop.
The problem was discussed at a licensee Management Review Board meeting on July 7, 1986.
A nonconforming operation report (NCOR) was also written on
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July 8, 1986.
The licensee's immediate corrective actions included weekly routine surveys of the contractor's tool trailer, discussion of the RSIR and radioactive material control at staff meetings and radiological safety committee meetings, evaluations of state of the art monitoring equipment and evaluation of the process of monitoring and release of material from the RCA through the planned decontamination facility.
The Management Review Board reconvened on July 24, 1986, and detemined that the following additional long term corrective actions would be taken:
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Development of a tool control program.
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Provide a low background monitoring area.
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Submit a proposal to plant management for an RCA entry monitor (person).
At the time of the inspection, the corrective actions completed were:
surveys of other areas with a potential for containing contaminated tools, scheduling of those areas for weekly surveys, and staff discussions of the incident.
Although the licensee's procedures require tools and equipment to be surveyed by a HPT, discussions with licensee representatives indicated that personnel who exited the RCA may have been surveying their own tools and equipment.
Licensee management stated that they were unaware that this practice was occurring and that this would be investigated.
Technical Specification 6.8.1.a required written procedures to be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, November 1972.
Regulatory Guide 1.33(G)(5)(c) recommended procedures for surveys and monitoring.
Plant Procedure HPP-202, Radiological Surveys, outlined the criteria for performance and documentation of surveys.
The licensee was informed that the failure to conduct an adequate survey of materials being released from the RCA for unrestricted use would normally be considered a violation of Technical Specification 6.8.1.a.
However, the NRC Enforcement Policy, 10 CFR 2, Appendix C, 1986, states that a Notice of Violation will generally not be issued for violations identified by the licensee, if (1)
it was identified by the licensee; (2)
it fits in Severity Level IV or V; (3)
it was reported, if required; (4)
it was or will be corrected, including measures to prevent recurrence, within a reasonable time; and (5)
it was not a violation that could reasonably be expected to have been prevented by the licensee's corrective actions for a previous violation.
The inspector stated that this apparent violation met the criteria specified in 10 CFR 2, Appendix C and would be considered licensee identified.
The inspector stated that the implementation of the yet completed long term corrective actions was an inspector followup item and would be reviewed during future inspections (50-302/86-26-03).
Licensee Procedure HPP-202, Radiological Surveys, provided the guidelines, instructions and requirements pertaining to the performance and
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documentation of radiological surveys.
Section 2.6.8.1 detailed the survey requirements for the unconditional release of tools, equipment and material from the RCA.
Section 3.5.2 further outlined the survey methods to be used for unconditional release from the RCA.
The inspector stated that the procedural guidance provided in HPP-202 was not consistent with the guidance provided in IE Information Notice (IEN) 85-92 and IE Circular (IEC) 81-07.
The inspector stated that the licensee should review the information in the procedure in light of the information provided in the IEN and IEC.
During the review of the licensee's survey and contamination control programs, the inspector noted that the licensee had identified alpha emitting radionuclides on the smear and air samples.
The inspector discussed the alpha survey program with licensee representatives and found that the alpha radiation was found, for the most part, in primary system components such as steam generator channel heads, filter housings and reactor coolant pump impellers.
During outage work on steam generators, airborne alpha concentrations were measured up to 40 times the MPC for unknown alpha radionuclides although the beta / gamma constituent of the air sample was the controlling MPC factor.
The licensee had been aware of the presence of alpha radiation for several years and in 1985, samples were sent to a vendor for an alpha spectroscopy analysis. The analysis indicated that the predominant isotopes were Plutonium-238, -239, and -240, Americium-241, and Curium 242 and 244.
A licensee representative stated that he did not feel that this analysis was indicative of the alpha distribution present in the plant, and as a result, the unknown alpha MPC of 6 E-13 microcuries per milliliter was still in use.
Prior to the latest revision of procedure HPP-202, Radiological Surveys, five percent of air and smear samples were analyzed for the presence of alpha radioactivity.
Revision 2 of HPP-202 was approved on January 3,1986, and deleted the requirement for routine analysis of smear and air samples for alpha radiation The procedure stated that analysis may be perfon..ed periodically under the direction of the Health Physics Supervisor and must be performed anytime alpha activity is suspected.
At the time of the inspection, the guidance provided to the HP staff was to discontinue alpha sample counting.
A licensee representative stated that the routine sampling for alpha was discontinued in an effort to try to delete non-useful activities from the HP program.
The representative stated that prior to the deletion of the alpha program, survey data was reviewed and it was detennined that, except for selected components, no alpha problems existed in the plant.
No formal project report supporting these conclusions or justifications was written by the licensee.
The inspector stated that, based upon a review of alpha survey data, the evaluation to delete the program appeared to be inadequate.
In discussions with the inspector, a licensee representative stated that he had determined that approximately thirty percent of the activity on a smear sample or air sample from the containment could be attributed to alpha radiation.
10 CFR 20.201(b) required the licensee to make or cause to be made such surveys as may be necessary for the licensee to comply with the regulations in the part and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Plant procedure HPP-202 was revised and approved on January 3,1986.
The revision deleted the
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requirement to count five percent of the air and smear samples for alpha.
For_ the period January 3,1986, through July 25, 1986, the licensee failed to perform routine surveys for alpha radiation even though it was known alpha contamination was present.
Personnel and equipment exiting the controlled area within containment were not routinely surveyed for alpha, nor were air and smear survey samples routinely evaluated or used to establish personnel protective measures for the alpha radioactivity that may have been present.
Failure of the licensee to evaluate the extent of the
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alpha radiation hazard present and the failure to conduct an alpha survey program was identified as an apparent violation of 10 CFR 20.201(b)
(50-302/86-26-04).
9.
External Occupational Exposure Control and Personnel Dosimetry (83524)
IE Inspection Report 50-302/86-06 issued on March 25, 1986, documented an instance of a worker being present in a high radiation area without a radiation monitoring device as required by TS 6.12.1.a.
The licensee's response to the Notice of Violation issued in the report stated that.the corrective action to prevent recurrence was complete and that the licensee
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was in full compliance as of January 29, 1986.
T. S. 6.12.1.a specified that in lieu of the " control device" or alarm signal" required by 10 CFR 20.203(c), a High Radiation Area in which the intensity of radiation is greater than 100 mrem / hour but less than 1000 mrem / hour shall be barricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by issuance of a Radiation Work Permit and any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area.
On February 18 and 19,1986, the licensee's RSIR system documented two cases of individuals present in the reactor cavity, a posted high radiation area, with dose rates greater than 100 mrem /hr, and did not possess the radiation monitoring device required by the TS.
The inspector stated that licensee identification of these violations was not applicable in accordance with criteria in 10 CFR 2, Appendix C in this case because the corrective actions detailed in response to violation 86-06-01 had not been sufficient to prevent a recurrence. The inspector stated that the entry of workers into a High Radiation area with dose rates greater than 100 mrem /hr, without a radiation monitoring device to indicate the dose rate in the area was an apparent violation of T. S. 6.12.1.a (50-302/86-26-05).
10. Facility Statistics Through June 1986, the collective radiation dose for the year was 314 man-rem as measured by TLD.
Through July 24, 1986, the licensee had
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generated 6,730 cubic feet (ft3) of solid radioactive waste, had shipped i
6,186 f t3 of waste containing 409 curies of activity and had 2,397 ft3 of waste stored onsite.
There had been 52 personnel contaminations for the
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year.
This number included skin, clothing and noble gas contaminations.
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The licensee maintained 10,300 square feet of the plant as contaminated which is a 50 percent reduction from the same time frame in 1985.
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