IR 05000335/1987015
| ML17221A309 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/27/1987 |
| From: | Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17221A308 | List: |
| References | |
| 50-335-87-15, 50-389-87-14, NUDOCS 8708070174 | |
| Download: ML17221A309 (16) | |
Text
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+**y4 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 DUL 30 1987 Report Nos.:
50-335/87-15 and 50-389/87-14 Licensee:
Florida Power and Light Company 9250 Mest Flagler Street Miami, FL 33102 Docket Nos.:
50-335 and 50-389 Facility Name:
St. Lucie 1 and
Inspection Conducted:
June 29 - July 2, 1987 License Nos.:
C.
.
assett te ne Accompanying Personnel:
M. T. Lauer Approved by:
ose, ectso re Division of Radiati n Safety and Safeguards 7 ~~/
ate gne SUMMARY Scope:
This was a routine, unannounced inspection in the area of radiation protection including:
organization and management controls; training and qualifications; external exposure control; control of radioactive material, contamination surveys and monitoring; facilities and equipment; the program for maintaining exposures as low as reasonably achievable (ALARA) and allegation followup.
Results:
No violations or deviations were identified.
870807017m S70730 PDR ADOCK 05000335 Q
REPORT DETAILS Persons Contacted Licensee Employees
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- R.
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- J
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- L
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- S
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- H.
- R
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- B
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- K.
- M.
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J. Boissy, Plant Manager Sipos, Services Manager W. Paduano, Manager of Nuclear Energy Services (Juno)
B. Harper, Superintendent of guality Assurance J. Barrow, Fire Protection Supervisor A. Pell, Technical Staff Supervisor G. Roos, guality Control Supervisor W. Pearce, Operations Supervisor F. Buchanan, Health Physics Supervisor G. Crider, Outage Management Supervisor F. Leppla, Instrumentation and Control Supervisor G. Brain, Independent Safety Engineering Group Supervisor L. Burton, Reliability Maintenance Supervisor M. Mercer, Health Physics Technical Supervisor M. McCullers, Health Physics Operations Supervisor E. Cox, Chemistry Supervisor M. Parks, guality Assurance Supervisor H. Stroud, Training Supervisor K. Anderson, Reactor Engineering Engineer W. Payne, Health Physics ALARA Supervisor J. Snyder, Technical Staff Engineer B. Somers, Health Physics Radioactive Waste Coordinator Justine, Purchasing Agent C. Haithcox, Health Physics Radioactive Waste Assistant Coordinator J. Gould, Corporate Health Physics J. Stoner, Corporate Health Physics DeBock, Training Supervisor R. Baker, Health Physics Administrative Supervisor L. Large, Health Physics Assistant Operations Supervisor E. Pugh, Health Physics Instrument Supervisor Other licensee employees contacted included engineers, technicians, security force members, and office personnel.
"Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on July 2, 1987, with those persons indicated in Paragraph 1 above.'he licensee acknowledged the inspection'indings and took no exceptions.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio.
Licensee Action on Previous Enforcement Matters (92702)
(Closed)
Violation (50-335/389/87-04-02)
Failure to label containers of radioactive material.
The inspector reviewed the licensee's response dated April 27, 1987, and verified that the corrective actions in the response had been implemented.
(Closed) Violation (50-335/398/87-04-04)
Failure to perform surveys on the underneath side of transport vehicles as required by Department of Transportation (DOT) regulations.
The inspector reviewed the licensee's
'esponse dated April 27, 1987, and verified that the corrective actions specified in the response had been implemented.
4.
Organization and Management Controls (83722)
a.
Organization The licensee is required by Technical Specification 6.2.2 to implement the facility organization specified in TS Figure 6.2-2.
The responsibilities, authority, and other management controls.
necessary for establishing and maintaining a health physics program for the facility were outlined in Chapters
and 13 of the Final Safety Analysis Report (FSAR).
Technical Specification 6.5. 1 specified the composition of the Facility Review Group (FRG)
and outlined its functions and authorities.
Regulatory Guide 1.8 also specified certain functions and responsibilities of the Radiation Protection Manager (RPM).
The inspector reviewed the plant organization with the RPM to determine the degree of support received from other members of management and the lines of authority and communication.
It appeared that the support required to implement and maintain an effective radiation protection program was in place.
b.
Staffing Technical Specification 6.2.2 also specified the minimum staffing for the plant.
FSAR Chapters
and 13 further outlined details on staffing.
The inspector reviewed the radiation control organization with the RPM and other licensee representatives.
The RPM indicated a
new position was to be added to the health physics organization in 1988.
The new position of Contamination Control Coordinator, which had functionally already been filled, was helping the licensee reduce and maintain better control over contaminated areas in the facility.
The subjects of the attrition rate, use of contractors health physics technicians (HPTs)
personnel qualifications and actual versus authorized staffing levels were also discussed.
At the time of the inspection, thirty-six health physics technical positions were authorized; one remained to be filled.
In addition, two contractor
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HPTs were being utilized to augment the licensee's health physics staff in support of post-outage cleanup and other operations.
Controls The inspector reviewed the licensee's Radiological Incident Reports for 1987.
The reports were to be written after:
1) unplanned personnel exposure, 2) suspected or confirmed internal deposition of radioactive material, 3) personnel contamination, or 4) any condition
'or spill in excess of specified limits.
The system appeared to be functioning as intended and problems were being investigated and corrected as'equired.
No violations or deviations were identified.
5.
Training and gualifications (83723)
a ~
b.
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Radiation Worker Training The licensee is required by 10 CFR 19. 12 to provide basic radiation protection training to workers.
Regulatory Guides 8.13, 8.27 and 8.29 outlined topics that should be included in such training.
Chapters 12 and 13 of the FSAR contain further commitments regarding training.
The inspector discussed the initial general employee radiation protection training (GET) with GET Training personnel and reviewed the course outline and lesson plans.
The inspector verified that the lesson plans addressed radiological health and safety industrial safety, plant controlled access areas, and security procedures.
The GET also included a practical factors section with hands-on protective clothing and equipment instruction.
Selected training records of plant personnel were also reviewed.
Health Physics Technician Training The inspector discussed the training program for FP&L HPTs and contractor HPTs and verified the FP8L KPT training program had been accredited by the Institute for Nuclear Power Operations (INPO) on July 24, 1986.
Health Physics Supervisor gualification The licensee is required by Technical Specification 6.3 to ensure that each member of the facility staff meets or exceeds the minimum qualifications of the American National Standard ANSI/ANS 3.1-1978 for comparable positions.
The inspector reviewed resumes of selected health physics supervisory personnel and verified that the individuals met the qualification requirements.
No violations or deviations were identifie.
External Exposure Control and Dosimetry (83724)
a ~
Use of Dosimeters and Postings The licensee is required by 10 CFR 19.13, 20.101, 20.102, 20.201(b),
20.202, 20.401, 20.403, 20.405, 20.407, and 20.408 to maintain workers'oses below specified levels and to keep records of and make reports of exposures.
.The licensee is also required by 10 CFR 20.203 and Technical Specification 6.12 to post specified areas and to control access to plant areas.
FSAR Chapter 12 also contains commitments regarding dosimetry and dose control.
During observation of work in the plant, the inspector noted the wearing of thermoluminescent dosimeters (TLDs)
and self-reading pocket dosimeters (SRPDs)
by workers as required.
During plant tours, the inspector also observed the posting of areas and made independent radiation measurements using NRC equipment to assure proper postings.
The inspector checked the security of the locks at four locked high radiation areas and observed posted survey results.
b.
Dosimetry Results and Administrative Controls The inspector reviewed the Form NRC-5 equivalent printout showing exposures through June 30, 1987, and verified that the radiation doses recorded were within the limits of 10 CFR 20.101.
To ensure the licensee's quarterly administrative limit of 2500 mr was not
'xceeded, the licensee required consecutively higher tiers of supervision to approve dose extensions with the Plant General Manager having approval authority for whole body exposrue up to three rem during a calendar quarter.
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d.
Radiation Work Permits (RWPs)
The licensee used standing RWPs to cover work of ongoing nature such as surveillance tours and operations inspections.
Specific work was governed by special RWPs which were requested to control jobs of shorter duration.
The inspector reviewed selected standing and special RWPs posted at the entrance to the radiation control area (RCA).
Hot Particle Exposure Control The licensee had begun a program to control excessive skin exposures due to hot particles of radioactive material.
This effort included an investigation of dry-clean methods for protective clothing
,
laundering; requiring frequent protective clothing changes during long duration jobs, and increasing HPT awareness of the hot particle contamination potential.
The inspector reviewed the licensee's investigation and dose assessment for a hot particle contamination event which occured on March 9, 1987, and resulted in a skin exposure
of 6.417 rem.
The individual was working in the reactor cavity on the reactor head at the time.
The licensee estimated that the particle, which was located on the back of the neck, remained on the individual for approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> before detection and removal.
Characterization of the particle was thorough and included radioanalysis by an independent laboratory whose results were within 10% or less agreement with licensee's data.
These analyses indicate that the particle was an activation product with a total activity of
.735 uCi.
The licensee used Loviengers beta point equation to determine the skin dose averaged over one square centimeter (cm').
No violations or deviations were identified.
7.
Control of Radioactive Materials and Contamination, Surveys and Monitoring (83726)
a ~
b.
Surveys The licensee is required by
CFR 20.201(b)
and 20.401 to perform surveys and to maintain records of such surveys necessary to show compliance with regulatory limits.
Survey methods and instrumentation were outlined in FSAR Chapter 12, while Technical Specifications 6.8 and 6.11 provided requirements for adherence to written procedures.
During plant tours, the inspector examined radiation levels and contamination surveys results outside selected rooms and cubicles.
The inspector performed independent radiation level surveys of selected areas and compared them with licensee survey results.
Frisking During tours of the plant, the inspector observed the exit of workers and movement of materials from the RCA to the clean ar eas to determine if proper frisking was performed by workers and proper fixed and transferable contamination surveys were being performed on materials.
The inspector determined that frisking and material release surveys were adequate.
c.
Instrumentation During tours of the facility, the inspector observed the use of survey instruments by radiation control personnel.
The inspector examined calibration stickers on radiation protection instruments in use and at various storage locations.
Instrument use appeared to be in accordance with standard practice and all instruments examined had been calibrate d.
Caution Signs, Labels and Controls
CFR 20.203(f) requires that each container of licensed radioactive material bear a
durable, clearly visible label identifying the contents when quantities of radioactive material exceeded those specified in Appendix C.
During plant tours, the inspector verified that containers of radioactive material were labeled as required and that proper controls were established.
No violations or deviations were identified.
8.
Facilities and Equipment (83727)
FSAR Chapters
and 2 specified plant layout and radiation protection facilities and equipment.
During plant tours, the inspector observed personnel traffic patterns in Units 1 and 2 Reactor Auxiliary buildings and in the RCA.
The inspector reviewed the use and intended operation of the personnel decontamination facilities in each unit and observed the operation of the laundry facilities in each auxiliary building.
The use of temporary shielding was discussed with licensee representatives and the use of ventilated enclosures was observed.
The inspector discussed housekeeping with the licensee and noted that a
'large amount of radioactive waste and a
number of used sets of protective clothing were being stored.
The licensee indicated that the protective clothing were awaiting shipment-to a vendor laundry facility for cleaning and the waste was to be shipped to another vendor for supercompaction.
No violations or deviations were identified.
9.
Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA)
(83728)
'a ~
ALARA Program
CFR 20. 1(c) specifies that licensees should implement programs to maintain workers'ose ALARA.
Other recomnended elements of an ALARA program are contained in Regulatory Guides 8.8 and 8.10.
Chapter
of the two units'SARs also contains licensee commitments regarding worker ALARA programs.
The inspector reviewed the ALARA procedure and program with licensee representatives.
The ALARA procedure required an ALARA review for each job, the type and depth mandated by the radiological safety aspects of the work to be performed.
Post-job reviews were only completed for major work efforts and were performed by the ALARA Review Board.
The Board, composed of plant department heads and contractor project leaders, met quarterly to consider methods of dose reduction, especially as related to outage b.
Goals and Objectives The licensee indicated that the man-rem goal for'986 had been 540 while actual accumulated exposure, as measured by TLD, totaled 469 man-rem.
The man-rem projection for 1987 was 982 man-rem while a goal of a
ten percent reduction, or 884 man-rem, had been established.
HP personnel stated that the approximate doubling of 1987's projection relative to 1986's actual accumulated exposure was due to the planned Unit 1 and Unit 2 refueling outages.
In 1986, only Unit 2 had an outage which routinely results in less man-rem totals than Unit
outages.
As of June 30, 1987, exposure expenditure was at 620 man-rem, well below the projection of 691 for mid-year.
No violations or deviations were identified.
10.
Audits (83726, 84722)
The inspector reviewed audits of the radiation protection and radwaste programs conducted from November 17, 1986 to date.
Extent of audits, qualifications of auditors, and adequacy of corrective actions were reviewed.
Four guality Assurance (gA) audits of the RP and radwaste programs were conducted during this period.
gA Audit gSL-OPS-87-530, Area Radiation Monitoring System, dated June 10, 1987 gA Audit gSL-OPS-86-491, Chem-Nuclear Services, Inc.,
dated January 13, 1987 gA Audit gSL-OPS-86-482, PSL Health Physics and Solid Radioactive Waste Program, dated November 24, 1986 gAS-HP-88-1, Corporate Health Physics, dated November 17, 1986 The depth of the audits and qualifications of the auditors appeared to be adequate.
No violations or deviations were identified.
11.
Allegation Followup (99014)
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(Rlt-87-A.0034)
In March 1987, after working in containment (apparently Unit 1),
the alleger left the area and returned a short time later.
The alleger was denied re-entry into containment by Health Physics personnel due to elevated levels of airborne iodine.
As a result, the NRC was requested to inquire about the alleger's exposure to airborne iodin Discussion The inspector reviewed all log entries of the licensee's Air Sample Log Book from the beginning of'he Unit I outage, which began February 7, 1987, through the first week in March.
It was noted that, upon initial entry, elevated radioactive iodine levels were found at all elevations inside the containment building.
After approximately sixteen -hours, the iodine concentration had dropped below one maximum permissible concentration
{MPC) and was generally below twenty-five percent of the MPC.
Throughout the outage there were various work evolutions that created elevated levels of radioactive iodine in specific areas of the containment.
Initial radioactive iodine concentrations in the specific areas ranged from 0.81 times MPC to 25 times MPC.
Generally, the radioactive iodine concentrations in the areas during work ranged from 25 percent MPC to 5 times MPC.
Through discussions with licensee personnel it was noted that, on certain occasions, the airborne levels of radioactive iodine concentration would
'have restricted access to specific areas.
At levels above
.25 MPC, respiratory protection was required.
At levels above I MPC, only selected individuals were allowed to enter the area to perform specific tasks.
For those jobs with airborne levels anticipated to be greater than I MPC
{i.e., opening the steam generators and installing ventilation), wet suits and air-supplied bubble hood respiratory protection were required.
Individual exposures were also tracked by the licensee and no one received in excess of 40 MPC-hours in a seven consecutive day working period.
~Fi ndi n The allegation was partially substantiated in that there were occasions when worker access to the containment building or certain areas therein were restricted due to elevated concentrations of iodine.
Because the alleger was anonymous, the individual's specific exposure records could not be reviewed.
However, based 'on the record reviews delineated above, no indication was found of any exposure to radioactive iodine in excess of regulatory limits.
No violations or deviations were identified.
Facility Statistics a.
Solid Wastes During 1986, the licensee made 27 shipments of radioactive waste consisting of 16,225 cubic feet of waste containing 2134 curies of radioactivity.
This year to date,
shipments had been made consisting of 3,995 cubic feet of waste containing a total of 652 curies of radioactivit b.
Contaminated Area The licensee began tracking square footage of contaminated area of the plant on February 1, 1986.
At that time 46,565 square feet or approximately 35%
was contaminated.
As of June 30, 1987, 16,550 square feet or 14.7%
remained under contamination control.
Neither reactor building was included in this inventory.
The licensee indicated that the reduction in square footage of contaminated areas was a priority"item and was receiving a great deal of management attention and expenditure of manpower.
c.
Personnel Contamination During 1986, there were 176 skin and -83 clothing contaminations resulting from a total of 227 contamination events.
To date during 1987, 200 skin and 144 clothing contaminations had resulted from a total 320 contamination events.
The licensee indicated that the increase was due mainly to the recent Unit 1 outage.
No violations or deviations were identified.