IR 05000302/1990002
| ML20006E543 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/07/1990 |
| From: | Gloersen W, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20006E539 | List: |
| References | |
| 50-302-90-02, 50-302-90-2, IEIN-89-047, IEIN-89-47, NUDOCS 9002230532 | |
| Download: ML20006E543 (10) | |
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UNITED STATES -
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- NUCLEAR REGULATORY COMMISSION
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' Report No.::. 50-302/90-02
'Y censee: Florida Power Corporation Y
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3201:34th Street,. South cm St. Petersburg. FL 33733
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Docket'No.: 50-302 License No.: DPR-72'
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. Facility Name:- Crystal River 3-j
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' Inspection Cond c e -
ar 1 -19, 1990
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"V Inspector:'
W. V Groersen Dfe[ Signed.
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Accompanying Pe
..P. Potter
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Jkf'. Potter, ' Chief D/tpSigned Facilities Radiation Protection Section
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Emergency Preparedness and Radiological
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Protection Branch Division of Radiation Safety and Safeguards
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'4 SUMMARY Scope:-
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tThis-routine, unannounced inspection was conducted in the areas of occupational radioactive safety; transpornation of radioactive materials; followup on
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. previous-inspector identified items; and followup' on' Information Notices.
u, Results:
Based upon results of interviews with licensee management, supervision, health i
physics technicians; review of records, inspector observations; and health l-physics personnel knowledge of functions and' responsibilities regardino
department operations.
The inspector found the radiation protection, solid j
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waste,:and transportation of radioactive materials program to be adeciuately L.
managed.and controlled.
It-appeared that adequate management involvement was
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provided to support the Radiation Protection Program. Two non-cited violations L
were identified in the areas of waste shipment manifest documentation and documentation of engineering elevation for DOT Specification 7A Type A u
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9002230532 900208
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PDR ADOCK 05000302
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REPORT DETAILS
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Persons ~ Contacted
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- Licensee Employees.
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- G. Clymer, Nuclear Waste Manager j
B. Colt, ALARA Specialist
- S. Garry, Corporate Health Physicist j
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- J. Gilbert. Nuclear Waste Supervisor
- B. Hickle, Manager. Nuclear Plant Operations
- S. Johnson, Manager, Site Nuclear Services j
- A. Kazemfar, Supervisor, Radiological' Support Services j
- T. Mosley, Nuclear Waste Supervisor
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.j S. Lashbrook Instrument Supervisor i
- J. Roberts, Assistant Nuclear Chemistry and Radiation Protection
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Superintendent-
- S. Robinson, Nuclear Chemistry and Radiation Protection Superintendent
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- W. Rossfeld, Manager, Nuclear Compliance
- D. Wilder, Radiation Protection Manager J
- M. Williams, Nuclear Regulatory Specialist Other. licensee employees contacted during this inspection included j
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engineers, operators, technicians, and administrative personnel.
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NRC Resident Inspectors
- W. Bradford, RI
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- P. Holmes-Ray SRI
- Attended exit interview
2.
-AuditsandAppraisals(83750)
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Technical Specification (TS) 6.5.2.9 requires that audits of facility-I activities be performed under the coanizance of the Nuclear General Review Committee (NGRC), including the following:
(1) the conformance of facility operation to provisions contained within the TSs and applicable license conditions at least once per 12 months; (2) the Offsite Dose Calculation Manual (ODCM) and implementing procedures at least once per 24 months; and (3) the process control program and implementing procedures for solidification of radioactive wastes at least once per 24 months.
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The inspector reviewed Audit Report 89-08-CREW (Chemistry, Radiation Protection, and Environmental Waste) conducted during the period of August 14-September 1, 1989.
The audit included a review of radwaste shipments and documentation, the Process Control Program, the ALARA and Radiation Protection programs, and followup of activities associated with previously-identified audit findings and concerns. The audit findings had
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no major safety problems; however, the findings as well as.the required
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. corrective actions were being tracked by the responsible party.
The inspector. also. reviewed radiation controlled area (RCA) walk-through inspections conducted periodically. in -1989 by the Corporate Health Physicist.
The walk-through inspections were documented in memo formate to the Radiological Support Services Supervisor, with copies sent to appropriate manaaers in the Radiation Protection Organization.
In general,' the walk-throughs identified items of substance related to the
. Radiation Protection Program, however, it did not appear that formal mechanisms were in place to effect corrective actions for deficiencies noted.
No violations or deviations were identified.
3.
Changes (83750)
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The inspector reviewed the licensee's Radiation Protection Program to determine if any major changes occurred since the last inspection in
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oraanization, personnel, facilities, equipment, programs and procedu' es.
r It was observed that no significant changes occurred in the licensee's Radiation Protection Organization.
It appeared that the licensee was adequately-staffed to manage the normal operations for the one unit site.
The licensee's Radiation Protection Oraanization consisted of 23 health physics technicians (HPTs) (six vacancies), two assistant HPTs, four chief HPTs (one vacancy), four health physics (HP) supervisors, and the Radiation Protection Manager (RPM).
The RPM reported to-the Nuclear Chemistry and Radiation Protection Superintendent who, in turn, reported r
y directly to Nuclear Plant Operations Manager.
In preparation-for the upcoming refueling outage, the licensee plans to supplement its radiation protection staff with approximately 106 contract HPTs.
Normally, the licensee will employ approximately 75 contract HPTs to supplement the staff.
However, the licensee anticipates that extra HP coverage will be needed during this outage to cover the installation of the steam generator (SG) nozzle dams and reactor coolant pump shaf t inspections.
The licensee was in the process of making extensive modifications to the RCA access control point.
The modifications were necessary for better control of individual inaress to and egress from the RCA.
In addition, the licensee was in the process of insta111na a computerized radiation
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work permit (RWP) trackino system for improved control and monitoring of individual and task dose.
The licensee had also purchased four additional Eberline PCM-1Bs for placement at the main exit of the RCA.
l The equipment purchase for improved and more efficient techniques to monitor and control personnel contamination was considered a program improvement.
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,No violations or deviations were identified.
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4.
PlanningandPreparation(83750)
The inspector discussed with licensee' representatives outage planning and
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management. support for radiation protection planning..As mentioned in Paragraph'3 of this inspection report,. management, supported the Radiation Protection Organization by authorizing the increase.of -its HP staff by
- l 7'E 93-Senior HPTs and 13. lead HPTs.
Included in the discussion was the total collective dose budget for the refueling outage, the most significant j
dose intensive jobs planned for the outage and HP pre-planning.
The licensee had. budgeted 322 man-rem for refuel outage number 7.
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following were the most dose-intensive jobs planned by the. licensee:
J Steam generator eddy current testing 16.0 man-rem
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Steam generator nozzle dam installation / removal 25.0 man-rem
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Contro1~ rod drive mechanism: remove / clean inspect / replace 20.0 man-rem
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Reactor coolant pump ID refurbishment 35.0 man-rem
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Scaffolding assemble / disassemble-18.0 man-rem
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The HP department was budgeted 32.0 man-rem for job coverage and.
surveillance.- The inspector reviewed a HP outage plannina document for refuel number 7 (no title, no date).
The plan consisted of'a detailed '
outline. of HP activities for:
(1) refueling; (2) preventative and component maintenance; (3) in-service inspections; (4) special maintenance (boron' corrosion inspections); (5) radwaste; and (6) surveillances.
The plan also provided useful information on pre-outage preparations, surveys and postings, equipment history, HP coverage stratecies, time allocation, responsibilities, work instructions, and radiological considerations.
It was-apparent after reviewing this document, that the licensee incorporated i
experience from and lessons learned during previous outages to aid in improving performance.-
' No violations or deviations were identified.
5.
Radiation Source and Field Control (83750)
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The inspector discussed with licensee representatives methods of reducing out-of-core radiation sources and fields to reduce occupational radiation exposure at Crystal River 3.
The licensee was considering the use of hydrogen peroxide to chemically decontaminate the primary system especially since chemical decontamination is one of the most ('
cost-effective ways to reduce doses to occupational workers f:
(NUREG/CR-5158, Worldwide Activities on the Reduction of Occupational
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Exposure at Nuclear Power Plants," June 1988).
At the' time of this inspection, the licensee was still in the advanced planning stage and was i
in the process of procedural development.
The licensee's experience in
using this chemical decontamination process will be reviewed durina a subsequent inspection. The licensee had also planned to install SG nozzle y'
dam. rings (two per SG), during refuel number 7 to facilitate the
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installation and subsequent removal of SG nozzle dams during future
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f refueling outages.
The dose reduction initiatives _ discussed above were
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considered as ALARA program improvements.
.No violations or deviations were identified.
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-Shipping-of low-Level Wastes for Disposal and Transportation (83750)
10 CFR 71.5 requires' that_ licensees who transport licensed material l
outside the confines of its plant or other place of use, or who deliver h
licensed material to a carrier for transport.- shall comply with the
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- applicable requirements of the ' regulation appropriate to the mode of
- transport of the Department of Transportation (DOT) in 49 CFR Parts 170-i through 189.
10 CFR 20.311(b) requires that each shipment of radioactive' waste to a licensed land disposal facility be accompanied by a sh,ipment manifest and also specifies the required entries on the manifest.
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10 CFR 20.311(d) requires, in part, that any generating licensee who.
transfers waste to a licensed waste processor who treats or repackages waste shall co:miy with the requirements of 10 CFR 20.311(b) and (c).
The inspector reviewed selected records of radioactive waste and materials
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shipments ~ rnade during 1989 and January 1990.
The shipping manifests examined, for shipments made directly to a licensed land disposal facility (Barnwell); were prepared consistent with 49 CFR requirements.
The-radiation and contamination survey results were within the limits specified for the mode of transport and shipment classification and the
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shipping documents were being completed and maintained as required.
In 1989,'the licensee had begun making shipments directly to a licensed waste processor (Scientific Ecology Group) (SEG). for processing and supercompaction of non-compacted waste. The inspector observed that in at
'least'three circumstances, the shipment manifests were not completed in accordance with the requirements of 10 CFR 20.311 (b). Specifically, the licensee failed to identify clearly on the shipment manifest the waste classification.
The problem was the licensee considered the shipments to the licensed waste processor as radioactive materials shipments and therefore considered the shipment manifest requirements of 20.311(b) not applicabic.
10 CFR 20,311(a) states that the purpose of the requirements of Paragraph 20.311 was to control transfers of radioactive waste intended for disposal at a land disposal facility and establish a manifest tracking system and supplement existing requirements concernina transfers and
. recordkeeping for such wastes.
The material shipped to SEG had no commercial value and was intended for disposal at Barnwell. The inspector informed licensee representatives that failure to include the waste classification on the shipment manifest was a violation of 10 CFR 20.311(b); however, this NRC identified violation is not being cited because the criteria specified in Section V. A. of the NRC Enforcement Policy were satisfied (Non-cited Violation)
(NCV:
50-302/90-02-01).* The licensee initiated appropriate corrective action before the end of this inspection by submitting Waste Procedure WP-101,
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" Package.: Storage, and Shipping of Radioactive Material" for revision, m
The revision was to include a requirement that all shipments of materials to. a' waste processor will include a shipment. manifest.
The licensee
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comitted to have-this-procedure revised and approved as soon as practicable following this inspection.
The inspector also reviewed the shipping papers and' documents associated
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with a. DOT Specification 7A Type A shipment (5hipment No. 90-3, j
January' 17,1990).
.The licensee was shipping a thermoluminescent dosimeter (TLD) calibrator conteining 0.5 millicuries of Sr-90 back to the
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During-the records review, the inspector observed that the
' licensee failed to maintain on file documentation of testing, engineerino evaluations, or comparative data showing that the container marked as DOT Specification 7A Type A met the requirements of that package
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This failure was - identified as a ' violation of
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49 CFR.173.415(a).
49 CFR 173.415(a) requires that each shipper of.a DOT-
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Specification 7A package must maintain on file for at'least one year after
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the latest shipment a complete documentation of tests and an engineering s
evaluation or comparative data showino that the construction methods, packaging design, and materials of construction comply with that specification.- This.NRC identified violation is not beino cited because-
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the criteria specified in Section V.A. of the NRC Enforcement Policy were
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satisfied (NCV:
50-302/90-02-02).
The licensee initiated. appropriate corrective action before the termination of this inspection ~ by contacting the package manufacturer (Container Products Corporation) and requesting a
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full report of the results of the engineering analysis and comparative analysis.
At the exit meeting, the licensee committed to obtain this
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report from the package manufacturer as soon as practicable following this inspection.
To prevent recurrence, the licensee initiated a procedure revision to WP-102, " Radioactive Shipment Certificates of Compliance "
Revision 14. March 29,1987, to include a requirement to have all the
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necessary Certificate of Compliance paperwork in niace before packace acceptance or shipment.
49 CFR 173.421 excepts up to 0.4 mci of Sr-90 in normal or special form fron, specification packaging. The inspector had no.
's further concerns.
Two NCVs were identified.
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Radiological Incident Reporting (83750)
The inspector reviewed a sample of 1989 radiological occurrence reports to
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determine if programmatic problems exist and if licensee-identified deficiencies were properly addressed.
Most of the reports reviewed dealt with personnel contamination due to gas leaks in the Auxiliary Building from pre / post filter change outs.
The inspector noted that one personnel contamination event (PCE) involved a HPT who left the site with identified, isolated, and contained spots of contamination on his hands
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L and left forearm and subsequently returned to the site with additional contamination identified on the individual's upper chest and lower hack.
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On July 1,1989, a HPT who had been involved with changing a prefilter on a makeup pump became contaminated on'his left forearm and eventually his
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The area of contamination on the individual's left forearm was approximately 3 cm.
Radioactive material removed from the area of
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contamination was analyzed and a distribution of nuclides similar to that
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found in the licensee's reactor coolant system was identified.
Initially.
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it^was believed that the HPT may have had an uptake of radioactive gas during -the pref 11ter change since there had been several gas leaks in various areas of-the Auxiliary Building, Whole body count results were '
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inconclusive.
After the whole body count, several attempts to oecontaminate the individual were made.
It was later decided by the site physician that the individual's skin was too irritated for further
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decontamination.
The contaminated area of the forearm was wrapped in plastic and gloves were placed on the hands to induce sweating. After a whole body frisk by both an RM-14 probe and a PCM-1B whole body frisker.
was performed, the individual was released fonn the site. Survey results indicated approximately 2.000 cpm on the forearm and 500 cpm on the
fingers.
On July 3,1989, whole body frisks were - performed and additional contaminated areas were identified on the individual's upper chest and back.
Leeching from the HPT's forearm was suspected as the source of the additional contamination.
The Site RPM directed HPTs to perform contamination surveys of the individual's home and car.
The following three items in the individual's home were identified as containir.q radioactive material:
(1) pocket-ion chamber 300 cpm);
(2) Saran Wrap from the contaminated arm (100 cpm); and (3)(one pair of underwear (2,000 cpm). An Operations Report (89-0164) was written on July
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4, 1989 to document the discovery of radioactive material in an
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uncontrolled area.
The licensee performed skin dose calculations using
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VARSKIN and made the following assumptions:
(1) contamination was from handling the Teletector which came into contact with the prefilter; and (2) irradiation time of 9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The licensee calculated a skin dose of 0.387 rem. The inspector had no further concerns regarding this issue.
No violations or deviations were identified.
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FacilityStatistics(83750)
The inspector reviewed the facility's goals and results with regard to the total annual collective dose, contaminated floor space, and personnel contamination for 1989.
The 1989 station collective dose was l
217 person-rem.
Approximately 157 person-rem was accumulated during the reactor coolant pump 1A outage durino the period March-May 1989.
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l licensee was well within its 1989 goal of 250 person-rem. Since 1987, the station's three year ending average collective dose has been decreasing.
The three year ending averaoes for the period 1987-1989 were:
587 person-rem. 356 person-rem, and 271 person-rem, respectively.
The inspector also observed that number of PCEs for 1989 (78 PCEs) increased
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from the previous year (47 PCEs).
This increase was not unusual, since the licensee experienced more outage days in 1989 and, obviously, the probability of PCE increases during outace periods.
The inspector observed no apparent trends in the number of PCE reports generated since 1986. The inspector also reviewed the licensee's contaminated floor space control and reduction program. Since 1985, the licensee has significantly l
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I reduced the contaminated floor space (excluding the Reactor Building).
From 1985-1989, the year ending contaminated floor space was: 20.750 fte;
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13.500 ftr; g,900 fte; 7.800 fte; and 7.400 f tr. respectively.
The licensee maintains a total area of approximately 90.000 ftt.
No violations or deviations were identified.
9.
Infomation Notices (92701)
l The inspector detemired that the following Information Notice (IH) had
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been received by the licensee, reviewed for applicability, distributed to apprnpriate personnel, and that action as appropriate was taken or
scheduled:
Potential problems with worn or distorted hose clamps on i
self-contained breathing apparatus.
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10. Action on Previously Identified Inspector Followup Items (IFIs) (92701)
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(Closed) IFI 50-302/88-33-02:
Resources in the ALARA Organization
were not adequate to have an effective dose reduction program.
The l
inspector reviewed the response to this IFl which was identified in a special NRC ALARA assessment in a letter to the NRC dated February 10. 1989.
In response to this item. the licensee perfomed an ALARA seli-assessment which was conducted durina the Fall of 1989. and documented in a memo dated December 6, 1989. -The self-assessment did I
not reconnend a permanent increate in staffing to supplement ALARA resources, but did recommend that the ALARA related work planning load be spread to line personnel, work planners. HP planners. job sponsors. first-line supervisors. HP Supervisors, and HPTs.
It also
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.reconmended that ALARA implenentation for field operations be the responsibility of the first-line supervisor, craft personnel, and HP
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Supervisors; and that ALARA program management should remain the
responsibility of the ALARA Specialist and the ALARA Conmiittee. Each of the recommendations identified an individual responsibic for implementation.
Altinough this item is considered closed. final implementation of this recommendation will be reviewed durino
subsequent inspections, b.
(Closed) IF150-302/88-33-03:
The RWP program lacks a formal hold program to review the status of jobs approaching or exceedina exposure estimates.
In a letter from FPC to NRC dated February 10 1989. part of the licensee's response to this ALARA finding was to assess how the RWP hold program could be fomalized through procedures and policies.
The inpector reviewed Administrative Instruction. AI-1600 ALAPA Program Manual. Revision 7. dated January 26, 1990, and noted that ALARA hold points were described in Section 4.7.
The rmcedure authorized either the ALARA Specialist or the HP Supervisoi
'i halt any job evolution for the following two cases:
(1) the is arded job dose exceeds 110 percent of the estimated dose budnet for the evolution; and (2) changing conditions
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r or scope cf work will prevent successful achievement of the established dose budget.
Additionally, a nemo from the Director.
Nuclear Plant Operations to Job Sponsors and First-Line Supervisors dated March 23, 1989, detailed the hP staff and ALARA Specialist's
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responsibility to initiate ALARA " holds" if during the job the actual doses are approaching or exceeding the dose estimate.
This item is considered closed.
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(Closed)
IFl 50-302/88-33-04:
It is not evident that FPC has an effective audit program that identifies ALARA problems. _ In response to this item, the Corporate Health Physicist of the licensee's Site
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Nuclear. Services Department conducted an ALARA program self-assessment during the Fall of 1989, and documented the final recomendation for the ALARA assessnent in a memo dated December 8,
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1989. Thirteen areas were reviewed and an action responsibility list i
identifying personnel to take the lead in implenenting each recomendation was noted.
Some of the areas assessed included:
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ALARA Policy and managenent; data management; job reviews; design reviews, dose tracking; rework tracking; and ALARA training for engineers.
In general, the audit was detailed enough to provide a thorough assessment of the ALARA program.
This item is considered closed.
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(Closed) IFI 50-302/88-33-05:
Person-hour estimates used for dose projections for specific tasks are overly conservative.
The inspector reviewed the licensee's response to this item, which was identified during the NRC ALARA assessment, in a letter from FPC to
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NRC dated February 10, 1989.
The licensee indicated that mechanisms
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were being evaluated to separate person-hours expected in radiation areas versus person-hours for the total job. The inspector observed that Al-1600. ALARA Program Manual, provided guidance for the Nuclear Integrated Plannina Department, Job Sponsors, and First-Line Supervisors to provide accurate person-hour estimates for tasks and
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evolutions in a radiation field. This item is considered closed.
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(Closed) IFI 50-302/88-33-07:
Consider ALARA effects from operating with defective fuel.
The inspector reviewed the licensee's response to this item, which was identified during the NRC ALARA Assessment, in a letter from FPC to NRC dated February 10, 1989.
The licensee stated that programs and guidelines were in place that address operation with failed fuel and that additional actions were in the development stage when the NRC assessment took place.
Since the above nentioned letter was written, the licensee performed an evaluation of the impact of failed fuel on plant operation, dated May 24, 1989.
The evaluation was in response to an INP0 Significant Event Report (01-89).
The licensee incorporated the applicable recomendation into Performance Monitorina Guidelines (PMGs).
PMG-2, Reactor and Fuel Integrity Performance Monitoring, Revision 2 dated September 20, 1989, was revised to include more specific guidance regarding activities, responsibilities, and actions for responding to fuel failures. This item is considered closed.
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Exit Meeting
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The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on January 19, 1990.
The inspector sunmarized the scope and findings of the inspection, including the NCVs.
The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee did not identify any such-documents-or processes as proprietary.
Dissentina coments were not received from the licensee.
Item Number Description and Reference 50 302/90-02-01 NCY - Failure to ioentify clearly on
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the shipment manifest (of material i
shipped to SEG in 1989) the waste classification as required by 10CFR20.311(b)(Paragraph 6).
50-302/90-02-02 NCV - Failure to maintain on file documentation of-engineering evaluations showing that a DOT
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Specification 7A Type A package net the
appropriate requirements as required by 49 CFR 173.415(a) (Paragraph 6).
During the exit meeti n'a, licensee representatives indicated that Revision 7 to Administrative-Instruction. AI-1600. ALARA Program Manual, would be completed as soon as practicable and sent to the Region II office so that the IFIs identified during the NRC ALARA assessment (88-33-02, 88-33-03, and 88-33-05) could be closed.
AI-1600 was received and reviewed by the NRC on January 29, 1990. The items referred to above were considered closed, i
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