IR 05000302/1993029
| ML20059B308 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/17/1993 |
| From: | Rankin W, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059B298 | List: |
| References | |
| 50-302-93-29, NUDOCS 9401040076 | |
| Download: ML20059B308 (18) | |
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M UNITED STATES k nog %
NUCLEAR REGULATORY COMMISSION j
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.4 REGION fl
,5-E 101 MARIETTA STFtEET, N.W., SUITE 2900
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ATLANTA, GEORGIA 303210199
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DEC 2 3 093-Report No.:
50-302/93-29 Licensee:
Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Docket No.:
50-302 License No.:
Facility Name:
Crystal River 3
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Inspection Conducted: November 29 - December 3, 1993, and telephone discussions conducted on December 14, 1993-Inspector: hu Ob
/2//4/93 E. D. Testa, P. E.
Date Signed Accompanying Personnel:
P. Knapp M
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/7 /7 Approved by:
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W. H. Rankin, P. E., Chief Date' Sigded facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection of the licensee's radiation protection (RP) program involved the review of RP activities including:
self-assessments; changes to the program; outage planning and preparation; training and qualifications; external and internal exposure controls; control of radioactive materials and contamination surveys / monitoring; and maintaining occupational exposure As Low As Reasonably Achievable (ALARA).
Results:
Based on interviews with licensee ~ management, supervisors, personnel from station departments, and records review,_the inspector found the RP program to be adequately managed. Organizational changes were noted within the ChemRad-program; however, the' results could not be assessed due to their recent implementation. Internal and external. exposure control programs were effectively implemented with all' exposures within-10 CFR 20 limits.
Implementation of the revised 10 CFR 20 was accomplished on October 1,1993, and review of procedures and the training program determinad that appropriate 9401040076 931223 PDR ADOCK 05000302 O
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incorporation of the new requirements had occurred. The General Employee (GET)
Computer Based Training -(CBT), ALARA Lab (practical factors demonstration),
ALARA Generic Simulator and 10 CFR 19/20/50 Audit Matrix were considered program strengths (Paragraph 4).
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The following'non-cited violations (NCVs) were identified:
NCV 50-302/93-29-01:
Inadequate Security Procedure (Paragraph 3.a).
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NCV 50-302/93-29/02:
Failure to follow Radiation Protection Procedure
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RSP 101 (Paragraphs 3.b, c, and e) with three ' examples.
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NCV 50-302/93-29-03:
Failure to follow Technical Specification 5.12.1 (Paragraph 3.d).
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REPORT DETAILS
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Persons Contacted
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l Licensee Employees
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- J. Alberdi, Manager, Nuclear Plant Operations
- J. Baumgardner, Senior Nuclear Quality Auditor
- G. Becker, Manager, Site Nuclear Engineering Services
- G. Bold, Vice President, Nuclear Production
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- J. Campbell, Nuclear Security
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- R. Davis, Maintenance Manager
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- M. Fitzgerald, Supervisor, Nuclear Plant Systems Engineering
- J. Frijouf, Nuclear Regulatory Specialist
- E. Froats, Manager,,uclear Compliance
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- S. Garry, Corporate Health Physicist
- B. Hickle, Director, Nuclear Plant Operations
- S. Johnson, Manager, Chemistry and Radiation Protection
- W. Lagger, Health Physics Supervisor
- S. Mansfield, Nuclear Team Instructor
- W. Marshall, Manager, Nuclear Plant Operations i
- A. Miller, Integrated Scheduling
- B. Moore, Manager, Scheduling
- J. Newman, ALARA Specialist
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- W. Rossfeld, Manager, Site Nuclear Services
- R. Trentham, Health Physics Technician
- R. Widell, Director Nuclear Operations Site Support
- D. Wilder, Radiation Protection Manager Other licensee employees contacted during the inspection included technicians, maintenance personnel, and administrative personnel.
Nuclear Regulatory Commission b
- R. Butcher, Senior Resident Inspector
- T. Cooper, Resident Inspector
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- Attended December 3, 1993 Exit Meeting 2.
Organization and Staffing (83729)
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The inspector reviewed and discussed with licensee representatives l
changes made to the Radiation Control (RC) organization since the last l
inspection of this area conducted March-28 - April 2, 1993, and documented in Inspection Report (IR) 50-302/93-08. _ Effective November IS,1993, several organizational changes in the Chemistry / Radiation ChemRad Organization were implemented. The changes involved both the departmental structure and functional assignments. In-addition, several positions were transferred from Nuclear Operations
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Site Support to the ChemRad organization. The changes were designed to
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Health Physics (HP) organization has one ChemRad Manager, one Radiation Protection (RP) Manager, five specialists, one Senior Rad Engineer, three Chief HP Technicians, and 27 HP Technicians.
Implementation of
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the new organization was still underway during this inspection. The major apparent changes were found to be two less HP technicians and one less Chief HP Technician. Because of the recent implementation of the new ChemRad organization, results of the new organization could not be
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assessed at this time.
No violation:: or deviations were identified.
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3.
Audits and Appraisals (83729)
The inspector reviewed the licensee's self assessment program for identification and correction of radiological deficiencies.
The inspector reviewed the following Problem Reports (prs):
a.
PR 93-0234 A licensee employee was exiting the Protected Area the evening of October 6, 1993, and the Gamma 60 monitor in the guardhouse alarmed. There were 10-15 people attempting to exit at that time.
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The Security Officers called the HP office. ' The HP technician.
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found the monitor in a " logic lockup." Personnel were released and the monitor was reset. On October 7, 1993, the Florida Power Corporation (FPC) employee was again exiting the Protected Aree for lunch when the monitor again went off. This time the Secur ty Officers were able to determine what individual was responsible for causing the monitor to alarm.
It was subsequently determine that the individual recently had undergone a medical procedure using radioactive Thallium.
Technical Specification (TS) 6.8 requires that procedures for Security Plan implementation and personnel radiation protection shall be established, implemented and maintained. Security Procedure SS-201, Section 4.4, Item 5 states that security officers are to operate the exit turnstile ensuring that personnel have successfully cleared the portal radiation monitor and turned
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in their badges.
Post Order #1006, Revision (Rev.) 4, provides general requirements for processing persons exiting the plant and use of exit portal radiation monitors.
The licensee, at the time of the problem, performed a root cause analysis. As a result of the analysis, changes to the Post Order and information signs for personnel with medically administered
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radioisotopes and training for the guards on the event have already been completed. The licensee was informed that-the inadequate security procedure was a violation of TS 6.8. However,
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1 based on the minor safety significance and the licensee's prompt a
corrective actions, this issue would be considered non-cited because the criteria specified in Section VII.B of the Enforcement
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Policy were met (NCV 50-302/93-29-01),
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PR 93-0253 i
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Licensee Nuclear Mechanics were preparing to breach an Industrial l
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Cooling (CI) system pipe _(WR315217) identified as an l
Administrative Radiologically Controlled Area (RCA) per RSP-101.
i In accordance with Radiation Work Permit.(RWP) 93-0004
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instructions, the mechanics contacted the HP office prior _to work.
An HP technician was dispatched to the work location. The HP
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noted that a milling machine was-hooked up in preparation to
breach the pipe. The HP also identified a " hot spot" (0.3 mrem /hr i
and informed the mechanics. The HP-technician requested the i
mechanics to. contact the HP office when they breached the' system.
- Approximately one half hour later when milling was sufficient to.
- 1 breach the pipe the HP technician returned to the work area and-i sampled the water that was coming out' of the small opening that.
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had been made. Counting with a "Frisker" the sample did not
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indicate any activity above background. The mechanics continued
milling, enlarging the hole (6-8 inch slit) until water flow
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caused them to stop. The HP technician waited for_the water to
I stop flowing and when it did not, told the mechanics.to contact the HP office when it stopped. The HP technician proceeded to the j
chemistry area and' asked a chemistry technician if the CI system had any contamination and was told that the system contained-
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hydrazine which could be a health hazard. The HP technician
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promptly returned to the work area and informed the responsible l
supervisor of the health hazard. The discussion also' included
radiological concerns and it was stated that there were none for.
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the water. The HP technician left and continued to work other
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tasks while waiting to be called for.another survey of the pipe.
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The mechanics, believing that there were no further radiological j
concerns, proceeded to work which included tasks under a separate
Work Request (WR) that did not require a RWP. The next day-
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(November 17, 1993 around 10:00 a.m.) the same HP technician was
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conducting a routine walkthrough and returned to the work location
where he saw the pipe cut up and lying in the area without any RCA-
indications.
He smeared the pipe but could not verify it was >300
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dpm/100cm due to background fluctuations. After lunch the HP
technician counted the smears on an MS-2 and determined the pipe
was contaminated. He immediately went back to the work location-
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to identify the material and area as an RCA, but found out the i"
pipe had been removed from CR-3's restricted area..The pipe removal, from the restricted area, was done in accordance with the i
WR that did not require an RWP. All materials were' immediately i
located and returned to the RCA. A follow-up investigation-l determined that no personnel were contaminated, there was no internal depositions, no contamination to the environment, and no
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contamination of any surfaces contacted by the pipe. An RWP was initiated for the remaining work and appropriate radiological l
controls established. As a result of the event, the work controls i
systems were changed to automatically require an RWP when work is
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being performed on systems considered to be Administrative RCAs.
A root cause analysis was performed on this event and recommended corrective action were either in place or underway.
TS 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of
10 CFR Part 20 and shall be approved, maintained, and adhered to i
for all operations involving personnel radiation exposure.
Chemistry and Radiation Protection Procedure RSP-101, Basic
Radiological Safety Information and Instructions for Radiation
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Workers, Rev. 17, dated February 11, 1993, Section 3.1.17.1 states that no radioactive material is permitted outside the RCA, except
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items which are conditionally released, under HP escort, or
authorized radioactive material shipments.
i The licensee was informed that failure to follow the procedure was
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a violation of TS 6.11. However, based on the minor safety
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significance and the licensee's prompt corrective actions, this issue would be considered non-cited because the criteria specified in Section VII.B of the Enforcement Policy were met (NCV 50-302/93-29-02) (first example).
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PR 93-0174 On June 29, 1993, at approximately 11:00 a.m., an individual
entered the reactor building without assuring he was properly signed in on an RWP.
Interviews were conducted with personnel involved in this event and applicable records were reviewed.
The following information was provided as a result of the investigation.
Records reviewed indicated the following regarding the entry:
The individual attended a pre-job briefing on June 29, 1993.
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Proper Dose Rate equipment was checked-out by the individual
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on June 29, 1993.
The individual had adequate dose margin for the task.
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Entry into the RCA was not electronically entered via RDMS.
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The individual has used RDMS on a regular basis; eight times
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since May 1993.
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The inspector reviewed interviews with the individual and the applicable HP personnel.
Results of the review indicated the following:
The individual was cognizant of the radiological and
industrial conditions inside the reactor building and the requirements of RWP 93-0097 as a result of his conducting the pre-job briefing for the work on WS-23-LT.
The individual stopped at the RDMS terminal to sign-in and
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the computer screen indicated that he was not authorized for RWP-0097 and needed to contact the HP desk. He went to the desk and indicated he could not log into RDMS and needed to check with the HP.
It was not clear to the HP at the desk that the individual was communicating a problem with RDMS authorization.
(NOTE:
It is normal practice for individuals to check-in at the HP desk prior to entry). The HP at the desk asked what job he was going to work on and then checked the HP pre-job briefing form to assure the individual had attended the pre-job. The HP then informed the individual that he needed to get a mini-rad, check with the HP at the Reactor Building personnel hatch, and it was okay for him to proceed.
The individual indicated he thought, when told by the HP it
was okay to proceed, they had taken care of the log-in for him.
The HP thought the individual was checking-in with him as
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required by the RWP for entry.
This appeared to clearly be a miscommunication problem.
TS 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
Chemistry and Radiation Protection Procedure RSP-101, Basic Radiological Safety Information and Instructions for Radiation Workers, dated October-1, 1993, provides instructions to radiation workers.
The licensee was informed that failure to follow the procedure was a violation of TS 6.11.
The licensee performed a root cause analysis and actions on the recommendations were either complete or nearing completion. Based on the minor safety significance and the licensee's prompt corrective actions, this issue would be considered non-cited because the criteria specified in Section VII.B of the Enforcement Policy were met (NCV 50-302/93-29-02) (second example).
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PR 93-0166 On June 15,-1993, an individual entered the Auxiliary Building Triangle Room without a dose rate meter or alarming dosimeter.
The Triangle Room is posted as a High Radiation Area (HRA).
l This individual logged on to RWP 93-0018 prior to entering the
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RCA, but did not comply with the below listed RWP requirements:
" Contact HP office prior to RCA entries for current survey data;"
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" Follow all posted radiological instructions;" and " Dose rate instrument, alarming dosimeter, or HP escort required to enter a posted High Radiation Area."
To enter the area the individual crossed a step-off pad and passed.
l through a swing gate.
A radiological posting affixed to the swing i
area provided the following information: "High Radiation Area;"
" Survey Instrument Required for Entry;" and " Contaminated Area."
A subsequent HP investigation determined that the highest dose
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rate in the areas traversed was 7 mrem /hr. No other HRAs were entered.
Exit Personal Ionization Chamber (PIC) reading for the entire RCA entry was O mrem. The individual was a contract employee performing work for nuclear engineering and has been badged as a CR-3 Radiation Worker since September 14, 1992. The individual was denied access to the licensee's protected area pending resolution of action closure items. The meetings and actions necessary to complete closure of the event have taken
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place. The licensee performed a root cause analysis of the event and has taken the necessary corrective action.
TS 6.12.1, High Radiation Area states that in lieu of the " control device" or " alarm signal" required by Paragraph 20.203(c)(2) of 10 CFR 20, a HRA in which the intensity of radiation is greater
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than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded
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and conspicuously posted as a HRA and entrance thereto shall be controlled by'the issuance of a RWP and any group of individuals permitted to enter such areas shall be provided with one or more of the following:
A radiation monitoring device which continuously indicates
the radiation dose rate in the area, or An integrating alarming dosimeter which alarms when a preset
integrated dose or dose rate is received, or An individual qualified in HPPs with a radiation dose rate
monitoring device, who is responsible for providing positive control over activities in the area and who performs periodic radiation surveillarice at the frequency specified in the RWP.
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The licensee was informed that failure to follow the requirements
was a violation of TS 6.12.1.
However, based on the minor safety significance and the licensee's prompt corrective actions, this
issue would be considered non-cited because the criteria specified
in Section VII.B of the Enforcement Policy were met i'
(NCV 50-302/93-29-03).
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PR 93-0172
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On June 22, 1993, during performance of HPP-202 two examples of
altered radioactive materials tags were discovered.
In both cases
the tags had been placed on locked tool boxes during a previous performance of this procedure. The HP performing the procedure surveyed the octside of the tool boxes and affixed a radioactive
materials tag bearing the survey results and the special
instructions, " Contact HP prior to opening." The purpose of the
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special instructions was to notify HP so that the contents could
be surveyed prior to use.
r On June 22, 1993, it was found that these instructions had been
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marked through and the tool boxes were not locked. HP had not i
been contacted, had not surveyed the contents of the boxes, and i
did not make the alteration to the radioactive materials tags.
-i A review of records for this event identified that there were no internal uptakes, personnel contaminations, or personnel dose
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associated with this event.
TS 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
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Chemistry and Radiation Protection Procedure RSP-101, Basic Radiological Safety Information and Instructions for Radiation Workers, dated October 1, 1993, provides instructions to radiation workers.
The licensee was informed that failure to follow the procedure was a violation of TS 6.11.
However, based on the minor safety significance and the licensee's prompt corrective actions, this issue would be considered non-cited because the criteria specified in Section VII.B of the Enforcement Policy were met (NCV 50-302/93-29-02) (third example).
Five non-cited licensee identified violations were found in this area.
4.
Radiation Protection Training (83729)
10 CFR 19.12 requires, in part, that the licensee instruct all individuals working in or frequenting any portion of a restricted area in the health protection aspects associated with exposure to radioactive material or radiation; in precautions or procedures to minimize
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exposure; in the purpose and function of protection devices employed; in the applicable provisions of the Commission regulations; in the individual's responsibilities; and in the availability of radiation exposure data.
The inspector reviewed the following procedures:
HPP-306, Occupational Radiation Exposure Calculations, Rev. 4,
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dated October 1, 1993 HPP-302, Operational Dosimetry, Rev. 4, dated October 1,1993
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HPP-214, Very High Radiation Area Controls, Rev. O, dated
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October 1, 1993 AI-1500, Conduct of Chemistry and Radiation Protection Department,
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Rev. 23, dated October 11, 1993 AI-400B, Originating New Procedures, Rev. 9, dated December 14,
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1992 AI-407, Administrative Instructions, Rev. 5, dated December 1,
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1992 RSP-101, Basic Radiological Safety Information and Instructions
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for Radiation Workers, dated October 1, 1993 Revised 10 CFR 20 Implementing Matrix
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The inspector determined that instruction provided to individuals working in or frequenting a restricted area was being provided with the health protection aspects associated with exposure o radioactive material or radiation. The inspector reviewed the oomputer Based
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Training (CBT) General Employee Training (GET) that was implemented and used for the revised 10 CFR 20 and found it to be well prepared, user friendly and provided the necessary elements for instruction on the revised 10 CFR 20 implementation. This was considered a program strength. The inspector reviewed the Generic ALARA Simulator and found that it had been updated and the lesson plans used to provide the training enabled the workers to obtain " hands on" training experiences.
The inspector attended an ALARA Lab (practical factor demonstration)
training class which is designed to familiarize the radiation worker in the following areas: RWPs, pre-job briefings, signing onto an RWP, to don and doff protective clothing and ALARA work practices. The inspector determined that the training was effective and that the plant tour pointed out' postings and radworker requirements.
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lesson plans for ST-Il74 titled, " Revision to 10 CFR 20", Rev. O, dated i
May 18, 1993, and the Audit Matrix were reviewed and found to contain the necessary elements for implementation of the revised 10 CFR 20. The inspector reviewed the audit material and found the Audit Matrix a
valuable reference book for employee use.
No violations or deviations were identified in this area.
5.
External Exposure Controls (837D)
j 10 CFR 20.1201(a),(b),(c),(d),(e), and (f) requires that the licensee
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shall control the occupational dose to individual adults to annual limits specified.
a.
Personnel Dosimetry
10 CFR 20.1502(a) requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipment.
10 CFR 20.1501(c) requires that dosimeters used to comply with
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10 CFR 20.1502(a) shall be processed and evaluated by a processor accredited by the National Voluntary Laboratory Accreditation Program (NYLAP) for the types of radiation for which the individual is monitored.
The i m pector selectively reviewed the licensee's dosimetry program to ensure the licensee was meeting the monitoring requirements of new 10 CFR Part 20. During tours of the plant, the inspector observed proper use of thermoluminescent dosimeters (TLDs) and PICS.
i No violations or deviations were identified in this area.
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Whole Body Exposure The inspector discussed the cumulative whole body exposures for
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plant and contractor employees.
Licensee representatives stated
and the inspector indMr.dently confirmed that all whole body.
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exposures assigned sinc 0 the previous NRC inspection of this area l
were within 10 P R 20 liidts. Through November 30, 1993 the site
whole body dose was 58.481 person-rem. The October.and November
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doses had not been corrected from the PIC readings. The licensee-
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had not granted any administrative dose extensions as of
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December 3,1993.
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No violations or deviations were identified in this area.
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Planned Special Exposures l
10 CFR 20.1206 permits the licensee to authorize an adult worker.
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the doses received under the limits.specified in 10 CFR 20.1201 provided that certain conditions are satisfied. Such exposures cannot exceed the dose limits in 10 CFR 20.1201(a) in any year or five times the annual dose limits during an individual's lifetime.
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The inspector reviewed the licensee's procedure HPP-217 titled,
" Planned Special Exposures," Rev. O, dated October 1, 1993.
The procedure provides an acceptable authorization process, that could be used in exceptional circumstances, which would allow an adult occupational worker to receive a dose in addition to and accounted for separately from the individual's routine occupational dose limits.
No violations or deviations were identified in this area.
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d.
Notices to Workers I
10 CFR 19.11(a) and (b) require, in part, that the licensee post current copies of 10 CFR 19, 20, the license, license conditions, documents incorporated into the license, license amendments and
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operating procedures, or that a licensee post a notice describing these documents and where they may be examined.
10 CFR 19.ll(d) requires that a licensee post NRC Form-3, Notice to Employees.
Sufficient copies of the required forms are to be posted to permit licensee workers to observe them on their way to
or from licensee activity locations.
During the inspection, the inspector verified that NRC Form-3 was l
posted properly at various plant locations permitting adequate
worker access.
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No violations or deviations were identified in this area.
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Control of Radioactive Material and (entamination, Surveys, and
Monitoring (83729)
i 10 CFR 20.1501(a). requires each licensee to make or cause to be made f
such surveys as (1) may be necessary for the licensee to comply with the
regulations and (2)'are reasonable under the circumstances to evaluate
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the extent of radiological hazards that may be present.
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Posting and Labeling
I 10 CFR 20.1904(a) requires, in part, each container.of licensed material containing greater than Appendix C quantities to bear a durable, clearly visible label identifying the radioactive contents and providing sufficient information to permit
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individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
During tours of the Auxiliary Building, Turbine Building, Spent Fuel Storage Building, Radioactive Waste Processing Building, and various radioactive material storage locations, the inspector
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independently verified that selected radioactive material areas were appropriately posted and that selected containers were labeled consistent with regulatory requirements.
No violations or deviations were identified in this area.
b.
Personnel and Area Contamination i
The licensee maintained approximately 2453 square feet (ft') of floor space as contaminated as of the date of this inspection.
This represented approximately 2.6 percent of the RCA. The total Personal Contamination Events (PCEs) for the year to date were 126 of which 44 were skin and 82 were clothing. The licensee uses
100 counts above background to define PCEs. The inspector i
selectively and independently reviewed the licensee's Personnel Skin and Clothing Contamination Index and the follow-up and resolution of a sample of these events. The inspector determined that the licensee's follow-up actions were appropriate.
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During a tour of the Auxiliary Building, the inspector noted the recently resurfaced floors. The resurfaced floor made the plant look extremely clean and the new surfaces increased the brightness
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in the areas for worker safety and the coatings provide a surface more easily decontaminated.
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During plant tours, the inspector observed adequate housekeeping and contamination control practices. The inspector observed
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handling, packaging, and surveying of contaminated equipment for movement and ~ judged the work evaluations satisfactory.
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No violations or deviations were identified in this area.
c.
15 6.12.1 requires, in part, that each HRA with radiation levels greater than cr equal to 100 mrem /hr but less than or eoual to 1000 mrem /hr be barricaded and conspicuously posted as a HRA.
In-addition, any individual or group of individuals permitted to
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l enter such areas are to be provided with or accompanied by a radiation monitoring device which continuously indicates the radiation dose rate in the area or a radiation monitoring device which continuously integrates the dose rate in-the area, or an
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individual qualified in radiation protection procedures with a radiation dose rate monitoring device.
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i During tours of the Auxiliary Building, Turbine Building, and Radioactive Waste Processing Building, the inspector noted that all HRAs and locked HRAs were locked and/or posted, as required.
No violations or deviations were identified in this area.
d.
Radiation Detection and Survey Instrumentation
During facility tours, the inspector noted that survey
instrumentation and continuous air monitors in use within the RCA were operable and displayed current calibration stickers. The i
inspector further noted an adequate number of survey instruments were available for use, and backgrount' radiation levels at personnel survey locations were observad to be within the
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licensee's procedural limit of 300 counts per minute (cpm).
- No violations or deviations were identified in this area.
e.
Independent Surveys During facility tours, the inspector independently verified contamination levels in the Auxiliary Building, Turbine Building,
Radioactive Waste Processing Building areas, and other radioactive material storage areas including the Low Level _ Waste Storage
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Building.
No violations or deviations were identified in this area.
7.
Program for Maintaining Exposures As Low As Reasonably Achievable (83729)
10 CFR 20.1101(b) states that the licensee shall use to the extent
practical, procedures and engineering controls based upon sound radiation protection procedures to achieve occupational doses to members i
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of the public that are as low as reasonably achievable (ALARA).
Regulatory Guides 8.8 and 8.10 provide information relevant to attaining goals and objectives for planning and operating light water. reactors and provide general philosophy acceptable to the NRC as a necessary basis for a program of maintaining occupational exposures ALARA.-
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During the inspection, the inspector reviewed and di< cussed'with cognizant licensee representatives ALARA program initiatives and
' mplementation for 1993 year-to-date. The inspector reviewed and i
discussed the report titled, "ALARA Considerations for Crystal River Unit 3," Rev. 1, dated October 11, 1993, and faund that it contained the basic elements needed to implement an effective ALARA program.
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The inspector selectively reviewed the following ALARA initiatives:
Mockup use
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Chemical Decontaminations of Systems
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Temporary Shielding
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Valve Cobalt Elimination Program
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The inspector reviewed a listing of active RWPs for the period January 1,1993 to December 2,1993, and found the actual person-rem was
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consistently controlled below the estimated person-rem.
r The inspector reviewed the Crystal River Unit 3 9M (mid-Cycle) outage Report which detailed the major work activities and personnel doses associated with the outage. The outage began on March 4, 1993, and was completed on April 26, 1993, for an outage duration of 54 days. Three projects of significant radiological concern were discussed. They were identified as the RB Flood Plane MAR, the RV insulation repair, and the installation of the permanent refuel cavity seal plate. The final outage dose was 44.118 person-rem. The outage goal had been established at 90 person-rem. The average dose per day for the 9M Outage was 0.86 rem / day. This value was lower than experienced in past outages, and was 50 percent of the 1.64 rem / day experienced in the ORF (Refuel)
outage. The low average was the result of a combination of factors of a generally " light" scope of significant dose work and reduced dose rates encountered in the Reactor Building. The report discusses the exposure y
reduction techniques, problems encountered, and new equipment evaluations. The report provides a useful historical record, which should be valuable for planning for future outages.
No violations or deviations were identified in this area.
S.
Internal Exposure Control (83729)
10 CFR 20.1204 (a)(3) requires, in part, that the licensee, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
The inspector reviewed the licensee's bioassay program, which is implemented under the following procedures HPP-323 titled, "In-Vitro Bioassay", Rev. 2, dated October 1,1993, and'HPP-322 titled, "Wholebody Counting System Calibration," Rev. 3, dated September 15, 1988.
The inspector reviewed the most recent efficiency calibration.
In addition, the inspector reviewed the following related documents:
Canberra /RMC ABACOS-II Library 100 & 103
Canbet ra/RMC ABACOS-II Efficiency Calibration #2
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Canberra /RMC ABACOS-II Energy Calibration #3
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Routine bioassays were performed at initial employment, annually and at termination.
Special bioassays were performed as needed. No problems were found during a review of the procedures or of selected bioassay records.
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No violations or deviations were identified.
9.
Licensee Actions on Previously Identified Inspector Followup Items
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(IFIs) (92702)
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(Closed) Unresolved Item (URI) 50-302/93-08-01: Adequacy of
dosimetry program for assessing and assigning shallow dose to the
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extremities.
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The inspector reviewed the licensee closure material associated with this item including interoffice correspondence from R. J.
Browning to D. T. Wilder dated November 3, 1993. The subject of
the correspondence was " Ring Type TLD, Answers to NRC Questions."
The study performed by the licensee concluded that there was no need to correct the reported Ring TLD results for beta dose since.
work controls require the use of gloves and that personnel are not
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permitted to work on contaminated equipment bare handed. The'
t inspector verified the requirement for gloves on selected RWPs and
observed the use of gloves by maintenance workers. The inspector
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informed licensee representatives that the open item would be
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considered closed.
i b.
(Closed)' Inspector Follow-up Item (IFI) 50-302/93-08-02:
Data entry error associated with MPC,-hr assignments.
The inspector spot checked selected MPC,-hr assignments and
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determined the problem to be isolated. The implementation of the
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ravised 10 CFR 20 creates a moot issue in this area since airborne
activity will be tracked using Derived Air Concentration (DAC).
The inspector informed licensee representatives that the open item
would be considered closed.
10.
Licensee Actions Regarding Previous Enforcement Items i
a.
(Closed) Violation (VIO) 50-302/93-08-04:
Failure to follow HPP.
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RSP-101, Step 3.17.1.
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The inspector reviewed the Reply to a Notice of Violation dated i
July 1, 1993, and independently verified the licensee actions tc-l correct the violation and prevent its reoccurrence.
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(Closed) VIO 50-302/93-08-05:
Failure to follow Security
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Procedures and Post Orders.
The inspector reviewed the Reply to a Notice of Violation dated July 1,1993, and independently verified the licensee actions to correct the violation and prevent its reoccurrence.
11.
Exit Meeting (83729)
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The inspector met with licensee representatives indicated in Paragraph I at the conclusion of the inspection on December 3, 1993. The inspector summarized the scope and findings of the inspection. The inspector also discussed the likely information content of the inspectior. 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.
Dissenting comments were not received from the licensee.
Item Number Status Description and Reference 50-302/93-29-01 Closed NCV - Inadequate Security Procedure (Paragraph 3.a).
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50-302/93-29-02 Closed NCY - Failure to follow Radiation
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Protection Procedure RSP 101 (Paragraph 3.b) (first example).
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NCV - Failure to follow Radiation Protection Procedure RSP 101 (Paragraph 3.c) (second example).
NCV - Failure to follow Radiation Protection Procedure RSP 101 (Paragraph 3.e) (third example).
50-302/93-29-03 Closed NCV - Failure to follow TS 6.12.1
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(Paragraph 3.d).
50-302/93-08-01 Closed i cl - Adequacy _ of dosimetry program for assessing and assigning shallow i
dose to the extremities (Paragraph 9.a).
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50-302/93-08-02 Closed
.IFI - Data entry error associated with MPC,-hr assignments (Paragraph 9.b).
50-302/93-08-04 Closed VIO - f ailure to follow HPP RSP-101, Step 3.17.1 (Paragraph 10.a).
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50-302/93-08-05.
Closed VIO - Failure to follow Security Procedures and Post Orders (Paragraph 10.b).
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