IR 05000302/1987039

Insp Rept 50-302/87-39 on 871116-20.Violation Noted.Major Areas Inspected:External & Internal Exposure Control, Surveys,Monitoring & Control of Radioactive Matl,Alara, Transportation of Radioactive Matls & Solid Radwaste Mgt

ML20237F061
Person / Time
Site:	Crystal River
Issue date:	12/16/1987
From:	Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237F033	List: IR 05000302/1987039 ML20237F030 ML20237F045
References
50-302-87-39, IEIN-87-031, IEIN-87-037, IEIN-87-31, IEIN-87-37, NUDOCS 8712290333
Download: ML20237F061 (11)

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NUCLEAR REGULATORY COMMISSION REGION 11 101 MARIETTA ST., g %/ ATLANTA, GEORGIA 30323

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Report No.: 50-302/87-39 Licensee: Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Facility Name: Crystal River ,

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Docket'No.: 50-302 License No.: DRP-72 Inspectior Conducted: ) November 16-20, 1987 Inspector: %

T. R. Collins ND //-// 4 [ P l Date Signed

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Approved by: !\

C. M. Hosey, Secti$n Chief

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Date Signed Division of Radiation Safety and Safeguards SUMMARY l

This routine, unannounced inspection was conducted in the areas of

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Scope:

external exposure control, internal exposure control, surveys, monitoring and control of radioactive material, transportation of radioactive materials, solid radioactive waste management, licensee's program for maintaining occupational exposures as low as reasonably achievable (ALARA), training and qualifications, organization and management controls, and followup on IE Information Notice Results: One violation was identified - failure to properly solidify liquid waste transported for burial.

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8712290333Og2M02 PDR ADOCK O PDR G

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S REPORT DETAILS Persons Contacted Licensee Employees

• J. Alberdi, Assistant Director, Nuclear Plant Operations

• B. J. Hickle, Manager, Nuclear Plant Operations

• L. Rossfeld, Manager, Nuclear Compliance

• J. Lander, Manager, Nuclear Maintenance and Outage

• S. L. Robinson, Superintendent, Nuclear Chemistry and Radiation Protection

• D. T. Wilder, Manager, Radiation Protection G. R. Clymer, Manager, Nuclear Waste

• S. B. Syllens, Supervisor, Nuclear Electrical Instrument and Control

• B. Roberts, Supervisor, Nuclear Waste D. A. Van 00sterwyk, Supervisor, Health Physics R. J. Browning, Supervisor, Health Physics A. Kazemfar, Supervisor, Nuclear Support Services S. L. Lashbrook, Supervisor, Health Physics W. J. Lagger, Supervisor, Health Physics M. M. Siapno, Supervisor, Health Physics S. Horvath, ALARA Specialist

• M. S. Mann, Nuclear Compliance Specialist

• J. L. Buchner, Nuclear Compliance Specialist Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security office members, and office personne Other Organization Applied Radiological Control, Inc. (ARC)

Nuclear Regulatory Commission T. Stetka, Senior Resident Inspector

• J. Tedrow, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were sunmarized on November 20, 1987, with those persons indicated in Paragraph 1 abov The inspector described the areas inspected and discussed in detail the apparent violation for failure to properly sol'idify liquid waste with cement and transported for burial (Paragraph 8). In regard to the hot particle event that occurred on the evening of November 20, 1987, the inspector informed the licensee that additional information would be necessary when their investigation of these event had been completed (Paragraph 4). On l

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December 14 and 15,1987, telephone conversations with your Radiation Protection Manager, Chemical and Health Physics Superintendent, Babcock and, Wilcox (B&W) onsite representative and B&W, Inc. Lynchburg, VA, the inspector was informed that an exposure of 953 millirem would be assigned to the individual involved with the hot particl After further conversation with representatives at B&W, Inc. Lynchburg, VA the inspector was informed that additional surveys of the individual's home, automobile and clothes, were performed by B&W radiation protection personnel, and no radioactivity was found. B&W representatives informed the inspector that the B&W, Inc. Apollo, PA facility was evaluating this event with

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information provided by Crystal River (CR-3) to assign an occupational exposure for the individual in question for the period of time while not assigned at CR-3. This information will ' be documented by B&W, Inc. ,

Apollo, PA. facility and reported to Region I, NRC Office, King of Prussia, P B&W plans to retrieve the hot particle at CR-3 and similar hot particles from the Apollo facility and send them to B&W Lynchburg Research Center (LRC), Lynchburg, VA for analytical analyses to determine the origin of the hot particles, if possibl Regional NRC Offices were to be notified when these analyses were complet Licensee management acknowledged the inspection findings and took no exceptions. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . External Exposure Control (83724) Control of Radiological Control Area During tours of the Reactor Building (containment) and auxiliary buildings, the inspector reviewed the licensee's posting and control of radiation areas, airborne radioactivity areas, contaminated areas, radioactive material areas and the labeling of radioactive material During a tour of the spent fuel pool area (Auxiliary Building, Elevation 164'), the inspector observed an area posted as a contaminated area and a flashing light was activated as c warning devic This device is normally used in containment to warn personnel that radiation levels inside a high radiation area that cannot be locked are in excess of 1,000 mR/h The inspector questioned a licensee management representative why this area was not posted as a high radiation area as required by Technical Specification (TS) 6.12.1. The inspector was informed by the -

licensee management representative that this area was previously posted as a high radiation area and it was their intent to control this area in such a manner. However, the signs had been removed because posting the area as a high radiation area created confusion for personnel. The inspector was informed that the radiation levels on the end of several ropes to which were attached approximately i

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' eighteen in-core detectors submerged the spent fuel pool, were up .to 22,000 R/hr. General area dose rates in accessible areas of the spent fuel pool, as measured by the inspector, were up to 5 mR/h The access to the spent fuel pool area, Elevation 164', was posted as l

.a-radiation area as required by 10 CFR 20.20 Technical Specification 6.12.1 specifies that any area in which the intensity of radiation is greater than 1,000 mR/hr should be posted as a high radiation area and locked' doors shall be provided to

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prevent' unauthorized entry into such areas. Additionally, individual

. areas that are accessible' to personnel, with radiation levels .such that a major portion of the body could receive in one hour a dose in excess of 1,000 mrem, and that are located within large areas such as the Reactor Building where no enclosure exists for purposes of locking and no enclosure can be reasonably constructed around the individual area, .shall be roped off and: conspicuously posted, and a

' flashing light shall be activated as a warning devic The inspector determined through discussions that the' licensee had -

intended to post 'this area as a high radiation area and use a flashing light as a warning device, since no enclosure could be reasonably constructed around the area to control access. The licensee immediately posted the access to the posted controlled area as a 'high radiation area and moved the flashing -light closer to the ropes to which the in-core detectors were attached. Each individual rope was tagged with a' Radioactive Material Log indicating radiation levels at.the end of the rop 'After further review and discussion with NRC RegionLII ' management .

representatives, the inspector informed licensee representatives that since the : intensity of radiation (22,000 R/hr) was not accessible to personnel this area was not required to be posted as a high radiation area'even though the licensee's intent was to control this areas as suc The inspector reviewed the:11censee's General Employee Training (GET)

lesson plans to assure that appropriate training was provided to personnel providing instruction on the use of flashing lights. In regard to high radiation areas, GET lesson plans stated that if an areas exists where dose rates exceed 1 R/hr a flashing light or locked gate will be used to warn the workers of this condition. The inspector interviewed several plant workers to determine if they were aware of the use of flashing light The workers interviewed informed the inspector that the use of flashing lights were used to warn personnel that high radiation levels may exis The inspector also reviewed selected administrative control procedures that delineated certain activities that were performed periodically by different groups in the spent fuel pool area to verify what controls the licensee had established to warn personnel of specific radiological concerns within the spent fuel pool. During

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i the review of the administrative control procedures the inspector noted that the procedures did not address safety precautions or establish specific hold points that required personnel to contact health physics personnel to obtain a radiological evaluation- of the conditions that may be.present. Licensee management representatives informed- the inspector that they wou?d review these administrative control procedures and revise them as necessary to incorporate safety precautions and hold points as appropriate to have radiological conditions evaluated as specific tasks are performed. Licensee review of the administrative control procedures will be considered an Inspector Followup Item and will be . reviewed during future inspections (50-302/87-39-02).

No violations or deviations were identifie Hot Particle Control The inspector reviewed the licensee's methods for the detection and control of high specific activity radioactive particles (hot particles). Based on this review, the inspector concluded that the licensee's apparently successful hot particle control program was due to addressing the cause of hot particles and not the symptom Contamination containments and monitoring were the primary means of hot particle contro Health physics technicians received specific training in the detection of hot particles on both equipment and personne Techniques for contamination containment and detection included the use of different types of containment, ventilation, the use of sticky pads, and instruction in the types of instruments best suited for detection. Also instruction was given in identification and retention of the particle when detecte On November 19, 1987, the licensee discovered that a contractor employee while exiting the Radiation Control Area (RCA) was determined to have a hot particle lodged in one leg of his trouser The licensee confiscated the hot particle and determined it to be !

Cobalt-60 (Co-60), approximately .02 microcuries. After interview with the individual it was determined that he had not dressed out in protective clothing while in the RCA and had not been in any '

i contaminated controlled area since he had been onsite. The licensee went to the individual's residence and survey his home, automobile, and additional clothin While surveying the individual's clothes a s pair of socks was found to contain another hot particle of approximately .02 microcuries (Co-60). No other hot particles or radioactivity were detected. The licensee questioned the individual about his previous work assignment and location. It was determined that he had performed work on control rod drive mechanisms (CRDMs) at Babcock and Wilcox (B&W), Inc. Apollo, PA. The inspector suggested to the licensee that they should contact B&W at Apollo, PA to inform them of an apparent problem that may exist with hot particles from the CRDMs at their location. The licensee initiated a Radiological Safety Incident Report (RSIR) to document this event. The inspector I

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' informed' the licensee that this event was to be reviewed during a subsequent inspectio 'The inspector reviewed the licensee's administrative control procedures HPP-0306, Occupational Radiation Exposure Calculations, and HPP-0104, Personnel Monitoring and Decontamination, that address hot particle detection and control and method of calculation of skin dose in event. of a hot particle exposure. The licensee uses the

. computer code ~ VARSKIN to calculate skin exposure due to hot particles. Procedures used to control hot particles appeared to be adequate with respect to instructions, controls provided~ and the methodology used to calculate skin exposures due to hot particle No violations or deviations were identified.

, Surveys, Monitoring, and Control of Radioactive Material (83726)

a. . 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with

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the regulations and (2) are reasonab.le under the circumstances to evaluate the extent of' radiation hazards that may be presen During tours .of -the Radiological Controlled Area the inspector performed independent surveys of selected areas, equipment and containers and determined that the posted surveys of selected areas were adequat The inspector selectively reviewed radiological'

surveys for the period of October and November 1987, of.the Reactor Building (containment), steam generators and selected ~ areas throughout the Auxi_11ary Building and concluded that the licensee had performed surveys as required to evaluate the extent of the radiological hazards that may be presen Based on a review of radiation surveys performcd inside of Unit 3 steam generators the inspector noted that radiation levels were relatively high, approximately 30 R/hr at the highest location. The inspector discussed with licensee representatives if they had considered implementing a program to adjust pH controls in the reactor coolant to reduce radiation exposures in the steam '

generator The inspector was informed that the licensee was aware of adjusting pH controls of the reactor coolant to reduce radiation exposures, however, at the time of the inspection they had not pursued this change in pH controls of reactor coolant due to fuel warranty specifications. The licensee stated that they are planning to further evaluate this method of adjusting pH in reactor coolant to i reduce radiatior exposures to personne No violations or deviations were identifie The inspector observed that contaminated areas of the plant had been adequately controlled. However, since their present refueling outage began additional areas have been controlled as contaminated areas due i

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to the large scope of work being performe Of 28,836 square feet (ft2) of area trended for contamination controls,13,099 ft2 or approximately 45 percent of the area is controlled due to surface contamination. Prior to the present refueling outage only 22 percen of the RCA was controlled due to surface contamination. Through November 1987, the station has had 30 skin and clothing contaminations greater than 1,000 dpm, excluding noble gas contamination No violations or deviations were identifie . Internal Exposure Control and Assessment (83725)

10 CFR 20.103(a) establishes the limits for exposures of individuals to concentrations of radioactive materials in air in restricted areas. This section also requires that suitable measurements of concentrations of radioactive materials in air be performed to detect and evaluate the ,

airborne radioactivity in restricted areas and that appropriate bioassays be performed to detect and assess individual intakes of radioactivity. The inspector reviewed selective whole body count records for 1987. To date two people had organ burdens up to 3 percent. These personnel were i performing work inside the Reactor Building (containment) on CRDMs. These 1 personnel- were not provided respiratory protection equipment because of industrial safety concerns (high temperature) inside containmen However, the licensee tracked these individuals' uptake and assigned MPC-hrs appropriatel The licensee has instituted an effective program to reduce contamination levels on specific equipment resulting in a reduction in the use of rripiratory equipment by personnel. Results of data for 1987 for the same period during 1986 indicate that the licensee has reduced the total use of respirators by 11 percent. The licensee has determined that personnel can work more efficiently and reduce person-rem exposures when respiratory protection equipment can be eliminated either by decontamination efforts or engineering control No violations or deviations were identifie . Transportation (86721)

The licensee was required by 10 CFR 71.5 to prepare shipments of radioactive materials in accordance with Department of Transportation regulations. The inspector reviewed recent changes to shipping procedures and records of shipments of radwaste for the months of October to November ,

198 The inspector verified that the licensee was a registered user of packages (C.0.Cs) used during 198 No violations or deviations were identified, i

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7 Solid Waste Program (84722)

10 CFR 20.311 requires a licensee who transfers radioactive waste to a land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.56. It further establishes

. specific requirements for conducting a quality control program and for maintaining a manifest tracking system for all shipment The inspector reviewed the following plant procedures for the packaging, classification and tracking of radioactive waste shipped to low-level waste burial facilities:

WP-101, Packaging, Storing, and Shipping of Radioactive Materials WP-102, Radioactive Shipment Certificates of Compliance WP-103, Estimation of the Curie Content of Packaged Radioactive Material WP-110, Radioactive Waste Disposal Data Requirements WP-301, Radioactive Waste Solidification and Process Control Program (PCP)

The inspector reviewed the methods used by the licensee to assure that waste was properly classified and met the waste form and characteristic requirement The inspector reviewed selected manifests prepared for waste shipments made during the period of September to November 1987, to verify that a tracking system was being used to insure that shipments arrived at the intended destination without undue dela The inspector discussed with a licensee representative the total solid radwaste shipped for burial during the years 1986 and 1987. Total volume shipped for 1986 was 12,864 ft3 containing 1,347 curies of activity as compared to 8,947 ft3 containing 340 curies of activity shipped through November 1987. The licensee's goal for 1987 for waste shipped for burial has been set at 12,324 ft3 The licensee has a seven year allocation of 86,268 ft3 with Chem Nuclear Systems, Inc. for burial of radwaste. The licensee has set an annual goal of 12,324 ft3 per year for seven years which is not to exceed a monthly goal of 1,027 ft3 10 CFR 61.56(b)(2) requires that liquid wastes or wastes containing liquid, must be converted into a fonn that contains as little free standing and noncorrosive liquid as is reasonably achievable, but in no case shall the liquid exceed 0.5% of the volume of the waste for waste

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On June 8, 1987, the licensee : shipped 22 55-gallon drums containing

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phosphoric acid sclidified with' cement to a land disposal. facility (Barnwell,SC). Radioactive Waste Shipment No. 0687-019-A was specified on the shipping manifest as Radioactive-Material low specific activity (LSA), n.o.s., UN 2912, described as liquid solidified with . cement, packaged . in steel drums. Upon inspection of one 55-gallon drum by an - I inspector from 'the State of South Carolina at the burial facility, it was found that one drum contained 1,585 milliliters-of liquid which failed to solidify per.the licensee's Process Control Progra The burial site is prohibited by the . State of South Carolina from-receiving unsolidified liquid waste and . consequently all 22 55-gallon drums were . returned to the licensee's facility. On June 15, 1987, the-State of South Carolina issued a violation to the licensee and a. civil-penalty of one .thousand dollars ($1,000).

When; notified of the . failure to solidify, the licensee dispatched representatives-to the burial ground to confirm the finding. To date, the licensee has not determined why the drum in question failed-to totally solidif The licensee has temporarily discontinued solidification process on site until.the cause of the failure of the waste to solidify have been determine Failure of the 55-gallon drum of waste to meet the waste characteristic requirements of 10 CFR 61.56(b)(2) in that it contained free liquid which exceeded 0.5% 'of the volume of waste for waste processed .to a stable form-was identified as . an apparent violation of 10 CFR 20.311(d)(1)

(50-302/87-39-01). Maintaining Occupational Exposures As low As Reasonably Achievable (ALARA)

(83728)

10 CFR 20.1(c) specifies 'that licensee's should implement programs to keep workers' doses as low as reasonably achievable. The recommended elements of.an ALARA program were contained in. Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Exposure at Nuclear Power Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for

< Maintaining Occupational Exposures ALAR The inspector discussed with licensee representatives, ALARA goals and objectives for 1987 and reviewed person-rem expended during the present refueling outage. The collective personnel exposure for 1987 is projected to be 350 person-rem. Presently, the plant is involved in a refueling and maintenance outag The station has expended 211 of 291 projected person-rem or 71 percent of their outage goal. The accumulated collective exposure to date for the year is.at 265 person-rem. The station expects to add an additional 40,000 man-hours to the outage which will probably exceed their projected person-rem for the outage of 291 person-re The' inspector reviewed Procedure Al-1600, ALARA Program, to determine when ALARA reviews were to be performed for specific tasks. The procedure

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requires an ALARA review to be performed on all tasks that are projected to be greater than one person-rem and an informal ALARA review for tasks projected to be between 0.5 and 1 person-rem. The inspector reviewed an ALARA review performed by the ALARA Committee for a core flood nozzle inspection inside the reactor core. This job has been projected to expend 778 person-rem worst cas Radiation levels are 10 R/hr in the core nozzle. The projected dose rates are an estimate since the reactor cavity is flooded and no surveys can be performed until the reactor cavity and core can be drained down to the core nozzles. The licensee is negotiating with appropriate NRC/NRR personnel to eliminate this core nozzle task due to ALARA concerns. The inspector informed licensee representatives that this task would be reviewed during a subsequent inspection if they are required to perform this tas No violations or deviations were identified.

10. Training and Qualifications (83723)

Technical Specification Section 6.4.1 states that a retraining and replacement training program for the facility staff shall be in accordance with ANSI N18.1-197 Paragraph 5 of ANSI N18.1 states that a training program shall be established which maintains the proficiency of the operating organization through periodic training exercises, instruction perieds, and review The inspector discussed the INP0 accreditation of the technician training program with a licensee management representative. The inspector was informed that they had received INP0 accreditation on October 23, 198 The licensee had scheduled their technicians to complete the technician training program on a 2 year cycle, however, the technicians were in a training capacity 20% of their available time. Due to the amount of time the technicians were spending in a training capacity the licensee changed the 2-year cycle to a 3-year cycle for completing the training progra The inspector asked a licensee management representative if they have a technician training program for contract health physics technicians. At this time the licensee provides a two day classroom training program in plant specifics for contract technicians, at the end of the training program an examination is given to determine that the technicians fully understand the contents of the training progra The inspector was informed that this program was implemented as necessary, however, at this time the program was not formalized. The inspector discussed with licensee management representative the formalization of this program to provide consistency with the instructions provided. Licensee management representatives stated that they would evaluate and formalize this training program as necessar ;

No violations or deviations were identifie I

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11.- Organization and Management Controls (83722)

l Organization The licensee is required by Technical _ Specification 6.2 to implement 4 the. . plant' organization . specified in Technical Specification L Figures 6.2-2.. The responsibilities, authorities, and other

! management- controls were further outlined in Chapters 12 and 13 of the Final Safety Analysis Report. TS 6.2 also s-of. the Plant Operations Review Committee -(PORC)pecified and outlined the the member functions and responsibilities to be assigned to the-Chemistry'and Health Physics Superintendent and radiation protection responsibilities to be assigned to the Radiation Protection Manage The inspector reviewed the plant: organization with the Radiation LProtection Manager to determine the degree of support received from management outside the Radiation Protection Department. It appeared that the support required to ' maintain and improve the radiation control program and solid waste management program was in plac No violations or deviations were identifie Staffing Technical Specification 6.3 specifies minimum plant staffin FSAR Chapters 12 and 13 also outline. further details .on staffin The inspector discussed authorized staffing levels versus current

. staffing levels withlthe Radiation Protection Manager. Due to the low attrition rate, staffing appeared to be adequate and consistent with authorized levels. Currently. . Radiation Protection staff consists of a- superintendent, manager, eight supervisors, eight chief health physics technicians-(ANSI N18.1-1971 qualified) and 11 health physics - technicians ( ANSI' N18.1-1971 qualified). Additionally, due to their present refueling outage the licensee has employed 75 contract senior HP technicians,14 junior HP technicians, four decon specialists, and 12 deconner No violations or deviations were identifie . IE Information Notices (IEN) (92717)

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The inspector determined that the following information notices had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or schedule IEN 87-31, Blocking, Bracing, and Securing of Radioactive Materials Packages in Transportation  ;

IEN 87-37, Control of Hot Particle Contamination at Nuclear Power Plants i

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