IR 05000335/1989019
| ML17223A314 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/29/1989 |
| From: | Potter J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17223A312 | List: |
| References | |
| 50-335-89-19, 50-389-89-19, NUDOCS 8909130043 | |
| Download: ML17223A314 (11) | |
Text
e ~s ASCII,
UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.IN.
ATLANTA,GEORGIA 30323
<<P 0< n@
Report Nos.:
50-335/89-19 and 50-389/89-19 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miamt, FL 33102 Docket Nos.:
50-335 and 50-389 Facility Name:
St. Lucie 1 and
License Nos.:
DPR-67 and NPF-16 Inspection Conducted:
July 31 - August 4, 1989 Inspector:
F.
N. Wrig Approved by:
otter, C se Faci ities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards Mac art S'e te S gne SUMMARY Scope:
This routine, unannounced inspection of radiation protection activities included a
review of the licensee's organization and management controls; training; internal and external exposure controls; surveys, monitorinq, and control of radioactive material; the as low as reasonably achievable (ALARA)
program; solid radioactive waste; transportation; and followup of previously identified items.
Results:
No violations or deviations were identified.
3909130043 890901 P:.
PDR ADOCK 05000335
REPORT DETAILS Persons Contacted Licensee Employees
- A. Bailey, guality Assurance Supervisor
- J. Barrow, Operations Superintendent
- G. Boissy, Plant Manager
- E. Burgess, guality Improvement Program R. Church, Independent Safety Evaluation Group
- L. Croteau, Training Supervisor
- J. Danek, Corporate Health Physics B. Dawson, Maintenance Superintendent M. Groom, Instructor, Development Specialist D. Haithcox, Radwaste Health Physics J. Harper, guality Assurance L. Jacobus, Health Physics ALARA Coordinator B. Johnson, Health Physics Administrative Supervisor
- L. Large, Assistant Health Physics Operations Supervisor
- D. Lowens, guality Assurance
- R. McCullers, Health Physics Operations Supervisor
- H. Mercer, Health Physics Technical Supervisor
- J. Oyer, guality Control
- R. Parks, Backfit Manager
- R. Riha, Power Plant Engineering
- C. Swiatek, Technical Staff Engineer
- D. West, Technical Supervisor
- C. Wilson, Mechanical Maintenance Supervisor
- C. Wood, Outage Management
- G. Wood, Reliability Maintenance
- E. Wunderlich, Reactor Engineering Other licensee employees contacted during this inspection included technicians and office personnel.
Nuclear Regulatory Commission
- S. Elrod, SRI
~Attended exit interview Organization and Management Controls The inspector reviewed the licensee's organization staffing levels and lines of authority as they related to radiation protection and verified that the licensee had not made organizational changes which would adversely affect the ability to control radiation exposures and radioactive materia In a previous NRC inspection performed in January 1989, the inspector reviewed a
licensee Performance Honitoring Audit -
November, gSL-OPS-88-637, which identified a problem with processing health physics (HP) documentation.
As described.-in the audit report, quality assurance gA records substantiating completion of HP activities were not being completed, reviewed, and submitted for storage in a timely manner.
In the 89-01 report, the inspector reported that the audit finding appeared to be a violation for failure to follow licensee procedures, in that, routine activity check-off sheets were not being completed, reviewed, and submitted for storage in a timely manner.
At the time of the inspection, the licensee's radiation protection staff had not yet responded to the audit finding and the item was made an unresolved item (URI) 50-335/89-01-01 to be reviewed in a following inspection.
Licensee management took steps to correct the problem and implement corrective action which was not fully implemented until May 1989.
Corrective action included:
Requiring documents to be reviewed by the HP Shift Supervisor on a
"shiftly" basis to ensure documentation is adequate and timely.
Cross checks of documentation with work assignments
.
Purchasing fireproof file cabinets for interim storage gA records.
Transfer of completed documents to quality control on a daily basis.
Review of routine checkoff sheets by HP Operations Supervisor.
The licensee's gA group verified that records were being reviewed as required by procedure and were properly stored and maintained.
The gA staff closed the finding in May 1989.
Licensee representatives reported that the changes made in the document review procedures and improved management review had improved the quality of survey documentation.
The inspector reviewed the licensee s corrective actions and closed the item.
No violations or deviations were identified.
Training and gualifications The inspector policies, and discussed the verified that program.
reviewed changes in the licensee's training program, goals relating to the radiat'ion protection program and changes with licensee representatives.
The inspector the changes should not adversely affect the licensee's
CFR 19.12 requires the licensee to instruct all individuals working in or frequenting any portion of the restricted area in the health protection problems associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposures, and in the purposes and functions of protective devices employed, applicable provisions of
Commission Regulations, individual responsibilities
'and the availability of radiation exposure data.
In a
previous inspection conducted in January 1989, the inspector identified a program weakness in the licensee's general employee training (GET) program.
The licensee was utilizing vendor personnel to provide radiation protection training to workers.
The inspector determined that the licensee's training program for the vendor radiation protection trainer was not procedurally addressed and licensee management was informed that a review of the licensee's radiation protection GET for vendor instructions would be reviewed during a future inspection to assess the effectiveness of the existing program.
The inspector reviewed the qualifications of the vendor providing radiation protection GET and determined that the licensee had provided and documented training similar to that provided to licensee trainers.
During the inspection, the licensee issued Revision
to Administrative Procedure No. 5735, Instructor Training Program, to allow vendor instructors to receive the General Instructional Certification for vendors completing the site Initial Instructor Development Program.
The program includes instructional topics on various training,skills and techniques used in preparation and presentation of training subjects.
The inspector closed the inspector followup item (IFI).
During an inspection conducted in March 1989, the inspector determined that the licensee was utilizing vendor personnel to support the station's administrative dosimetry group during outages.
The dosimetry section operates the whole body counter, determines personnel exposure histories, and issues dosimetry to radiation workers.
The inspector determined that the licensee was using dosimetry training modules, developed for the utilities staff, in training the vendor workers.
However, the licensee was not maintaining training records for contract dosimetry personnel.
The licensee agreed to revise training procedures to describe the licensee's method for documenting the vendor dosimetry personnel training.
A review of the licensee's procedures for documenting vendor dosimetry personnel training was made an IFI.
The inspector reviewed licensee procedure TDI-33, Health Physics Administrative Training Program, Revision 4.
The licensee had prepared a training index for each dosimetry contractor which defined the required training modules for each worker based upon assigned duties.
The inspector closed the IFI.
No violations or deviations were identified.
External Exposure Control and Personnel Dosimetry Technical Specification (TS) 6.8 requires the licensee to have written procedures, including the use of radiation work permits (RWPs).
The inspector reviewed plant procedure HP-1, Radiation Work Permits, which provided detailed instructions on the preparation and processing of RWP The inspector reviewed selected RMPs for appropriateness of the radiation protection requirements based on work scope, location, and conditions.
During tours of the plant, the inspector observed the adherence of plant workers to the RWP requirements and discussed the RWP requirements with plant workers at the job site.
The inspector discussed the planning and preparation for the upcoming outage with licensee representatives.
Specific areas discussed included increases in staffing, special training, equipment and supplies, HP involvement in outage planning, licensee control over HP technicians, and dose reduction methods to be employed.
CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material.
Additional requirements for control of high radiation areas are contained in TS 6.12.
During tours of the plant, the inspector reviewed the licensee's posting and control of radiation areas, radioactive material areas, and the labeling of radioactive material.
CFR 20.202 requires each licensee to supply appropriate personnel monitoring equipment to specific individuals and require the use of such equipment.
During tours of the plant, the inspector observed workers wearing appropriate personnel monitoring devices.
No violations or deviations were identified.
5.
Internal Exposure Control A.
Air Sampling
CFR 20. 103(a)
establishes the limits for exposure of individuals to concentrations of radioactive material in air in restricted areas.
This section also required that suitable measurements of concentrations of radioactivity materials in air be performed to detect and evaluated the airborne radioactivity in restricted areas and that appropriate bioassays be performed to detect and assess individual intakes of radioactivity.
The inspector reviewed selected results of general inplant air samples taken during July and August 1989, and the results of air samples taken to support work authorized by specific RMPs.
B.
Respiratory Protection Equipment 10 CFR 20. 103(b)
requires that when it is impracticable to apply process or engineering controls to limit contcentration of radioactive material in air below 25 percent of the concentration specified in Appendix B, Table 1, Column 1, other precautionary measures should be used to maintain the intake of radioactive material by any individual within seven consecutive days as far below 40 MPC-hrs as is reasonbly achievable.
By review of records, observation and disucssion with
licensee representatives, the inspector evaluated the licensee's respiratory protection program, including training, medical qualifications, MPC-hr controls, quality of breathing air, and the use, decontamination, repair,.and storage of respirators.
No violations or deviations were identified.
6.
Surveys, Monitoring, and Control of Radioactive Material
CFR 20.201(b)
requires each licensee to make to cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be present.
The inspector reviewed the plant procedures which established the licensee's radiological survey and monitoring program and verified that the procedures were consistent with regulations, TSs, and good HP practices.
The inspector reviewed selected records of radiation and contamination surveys performed during the period of July and August 1989, and discussed the survey results with licensee representatives.
During tours of the plant, the inspector observed HP technicians performing radiation and contamination surveys.
The inspector performed independent radiation and loose surface contamination surveys in the Auxiliary Buildings and verified that the areas where properly posted.
The inspector reviewed the dose curves for radioactive sources and verified that the test and calibration equipment utilized to calibrate radiation survey instrumentation was traceable to National institute of Standards and Technology (NIST) standards.
The inspector reviewed the calibration records for selected radiation survey instruments and verified that instruments were calibrated in accordance with licensee procedures and properly documented.
The inspector noted that the licensee was continuing to reduce the volume of stored radioactive material onsite.
The licensee has spent considerble effort to reduce radioactive material storage areas in number and size.
During 1989, the licensee has reduced radioactive material storage areas by sorting out reusable equipment and material from radioactive waste and increasing disposal of the radioactive waste.
No violations or deviations were identified.
7.
Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA)
CFR 20. 1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures ALARA.
The recommended elements of an ALARA program
are contained in Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Station will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures ALARA.
The -licensee's 1989 ALARA goal was 514 person-rem.
Through the end of July 1989, the licensee had accumulated 433.6 person-rem and was 22 person-rem below the July target dose of 456 person-rem.
The licensee was on schedule to met ALARA dose goals despite an extended Unit 2 outage and an unplanned outage on Unit 1.
The Unit 2 outage was scheduled to last 68 days and included high dose work on steam generators, reactor coolant pump impleller, and nozzle replacement for resistance temperature dectors (RTDs)
on reactor coolant loops.
The licensee was on schedule to meet an outage goal of 344 person-rem on day 68, however, the outage lasted 89 days and an total of 364 person-rem was accumulated.
When the 1989 goal was set the licensee included 40 person rem for 20 days of unplanned outage activity.
The licensee had an 18 day outage to replace suspect steam generator tube plugs on the hot leg sides of the Unit 1 steam generators.
The licensee replaced 63 steam generator tube plugs and experienced equipment problems which caused the exposure to be about twice the expected at 113 person-rem.
The licensee plans to replace steam generator plugs on cold leg side during a 1990 refueling outage.
No violations or deviations were identified.
Solid Radioactive Waste The inspector reviewed the licensee's solid radioactive waste management program, including:
adequacy of implementing procedures to properly classify and characterize waste, prepared manifest, and mark packages, overall performance of the process control and quality assurance programs, and the adequacy of required records, reports, and notifications.
CFR 20.311 requires a licensee who transfers radioactive waste to a
land disposal facility to prepare all waste so that the waste is classified in accordance with
CFR 61.55 and meets the waste characteristic requirements of
CFR 61.56.
It.further establishes specific requirements for conducting a quality control program.
The inspector reviewed the methods used.by the licensee to assure that waste was properly classified, met the waste form and characteristic requirements of
CFR Part
and met the disposal site license conditions, and discussed the use of these methods with licensee representatives.
CFR 20.311 requires that the licensee maintain a tracking system for radioactive waste shipments to verify that shipments have been received without undue delay by the intended recipient.
The inspector reviewed selected manifests prepared for waste shipments made during 1989 to verify that a tracking system was being used to ensure that shipments arrived at the intended destination without undue dela The licensee has a radioactive waste quality improvement team which as identified numerous problems with the licensee's radioactive waste program.
In addressing the problems, the licensee has initiated several projects to improve the radioactive waste program including:
sorting and segregating clean and radioactive waste, increased radioactive waste compaction, and radioactive waste reduction activities.
As a result of the licensee's efforts, the licensee's control of radioactive material/radioactive waste program has improved in 1989.
No violations or deviations were identified.
Transportation of Radioactive Material 10 CFR 71.5 requires the licensees who transport licensed material outside the confines of its plant or other place of use, or who delivered licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts 170 through 189.
CFR 71.91 specifies the records that the licensee is required to maintain for each nonexempt shipment of radioactive material.
The inspector reviewed selected records of radioactive material shipments made in 1989, and verified that the licensee had maintained the records required by
CFR 71.91.
The inspector verified that the radioactive manifest reviewed had been properly completed.
The inspector reviewed plant procedures for the preparation, documentation, shipment, and receipt of radioactive material and verified that the procedures were consistent with regulations.
While reviewing the licensee s procedure HP-48, Activity Determined From Dose Rate From Containers, Revision 2, the inspector determined that the licensee's procedure included three methods for estimating the curie content of packages from measured exposure rates.
However, the procedure lacked sufficient criteria or guidance on when one method was preferred over another.
The licensee committed to revise the procedure to describe criteria or guidance to be utilized in selecting the:appropriate method.
The license also committed to improve the method:for documenting the appropriate calculations.
The inspector stated that the licensee's actions to upgrade procedures for estimating curie content from measured exposure rates would be tracked as an IFI (IFI 50-335/89-19-01).
No violations or deviations were identified.
Licensee Actions on Previously Identified Inspection Findings (Closed)
URI 50-335/89-01-01:
This item concerned the control and storage of HP records, a finding identified in licensee gA Audit 88-637.
The inspector reviewed licensee's corrective action and closed the item (Paragraph 2).
(Closed)
IFI 50-335/89-01-03:
Thi s itern concer ned the training requirements for general employee trainers (Paragraph 3).
(Closed)
IFI 50-335/89-08-01: 'his item concerned the documentation of training provided to vendor dosimetry technicians (Paragraph 3).
11.
Exit Interview The inspection scope and results were sumnarized on August 4, 1989, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection findings listed below.
Dissenting comments were not received from the licensee.
Proprietary information is not contained in this report.
Item Number Descri tion and Reference 50-335/89-19-01 IFI - Review the licensee's procedures for estimating radioactivity from measured exposure rates (Paragraph 9).
Licensee management was informed that a previous URI and two IFIs discussed in Paragraph 10 were closed during this inspection.