IR 05000335/1991023
| ML17223B399 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/16/1991 |
| From: | Pharr E, Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17223B398 | List: |
| References | |
| 50-335-91-23, 50-389-91-23, NUDOCS 9201140030 | |
| Download: ML17223B399 (13) | |
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UNITED STATES NUCLEAR REGULATORY COMMiSSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Repor t Nos.:
.50-335/91-23 and 50-389/91-23 Licensee:
Florida Power and Light Company 9250 West.Flagler Street Miami, FL 33102 Docket Nos.:
50-335 and 50-389 Facility Name:
St. Lucie 1 and
Inspection Conducted:
November 18-22, 1991
'nspectors:
o trs ge,.
License Nos,.:
DPR-67 and NPF-16 rz./Z~ gr ate Ss ned t
z 'Iz l.
bat S
ne Approved by:
J.
P. Potty', Section Chief Facilities/Radiation Protection Section Radiological Protection and Emergency Preparedness Section Division of Radiation Safety and Safeguards SUMMARY
/4/5 g Da e
igned Scope:
This unannounced.
inspection of radiation review of the licensee's organization and qualifications, external exposure control, radioactive materials and contamination, maintaining occupational exposures ALARA.
we'e reviewed.
Results:
protection activities included a
management controls, training and internal exposure control, control of surveys and monitoring, and In addition, Information Notices hithin the scope of the inspection, no violations or deviations were'dentified.
The radiation protection (RP)
program functioned adequately to protect the health of occupational radiation workers and to promote the safe use of radioactive materials.
MIanagement and staff were motivated and involved in activities to reduce personnel exposure.
9201140030 911216 PDR ADOCK. 05000335
REPORT DETAILS Persons Contacted Licensee Employees
- G. Boissy, Plant Manager
- H. Buchanan, Health Physics Supervisor
- C. Burton, Operations Superintendent
- R. Church, Chairman, ISEG
- K. Craig, Steam Generator Supervisor (ESI)
- J. Danek, Corporate Health Physics
- B. Dawson, Maintenance Supervisor
- J. Dyer, Supervisor, Maintenance guality Control
- R. Englmeier, Site guality Manager
- A. Flowers, Mechanical Maintenance Engineering
- B. Frechette, Chemistry -Supervisor
- J. Fulford, Materials Performance Supervisor
- J. Geiger, Vice President, Nuclear Assurance
- L. Jacobus, Health Physics ALARA Coordinator
- K. Mayhew, ISI Coordinator
- R. McCullers, Health Physics Operations Supervisor
- L. McLaughlin, Plant Licensing Manager
~A. Menocal, Mechanical Maintenance Department Head
- L. motley, Supervisor, Code Programs
- D. Nowakowski, NDE Section (ESI/JPN)
- T. Roberts, Nuclear Engineer
- T. Ware, Technical Training Supervisor
- D. West, Technical Department Supervisor
- D Wolf, Site Engineering Supervisor Other licensee employees contacted during this inspection included craftsmen, technicians, and office personnel.
Nuclear. Regulatory Commission
- S. Elrod, Senior Resident Inspector
- C. Ogle, Project Engineer
- M. Scott, Resident Inspector
- Attended November 22, 1991 Exit meeting
Occupational Exposure During Extended Outages (83729)
a.
Organization and Management Controls The inspector'eviewed and discussed with the licensee representatives the RP organization and staffing levels and verified that no changes had been made since the previous inspection conducted from November 5-9, 1990.
The inspector noted that RP staff members were knowledgeable and actively involved in activities to reduce personnel exposure.'he inspector reviewed the licensee s program for self-identification of weaknesses related to the radiation protection program and the
'appropriateness of corrective action taken.
The inspector noted that since January 1,
1991 only eight Radiological Event Reports (RERs)
had been written and each involved skin contaminations.
b.
Audits and Appraisals The inspector reviewed the licensee's program of self-assessment to determine the effectiveness in contributing to the prevention of problems'n radiological controls.
Three elements of this program reviewed in depth, included licensee audits,, surveillances, and RERs.
In reviewing audits the inspector found that corporate health physics does not perform a formal assessment of the plant radiation protection (RP)
program.
However, plant quality assurance does conduct a performance monitoring audit of RP.
The inspector reviewed the following audits:
gSL-OPS-90-759, dated October 31, 1990, Monitoring and Test Equipment gSL-OPS-90-772, dated November 16, 1990, Performance Monitoring-October gSL-OPS-91-791, dated February 21, 1991, Performance Monitoring-January (}SL-OPS-91-803, dated April. 3, 1991, Performance Monitoring - March gSL-OPS-91-809, dated April 30, 1991, Performance Monitoring - April gSL-OPS-91-820, dated July 31, 1991, Performance Monitoring - July gSL-OPS-91-894, dated September 4,.
1991, Performance Monitoring-August
'dditionally, the inspector reviewed 58 surveillances of the RP program performed by site quality control personnel and eight RERs performed in 1991.
All eight of the RERs were written for personnel contamination events which duplicated the effort for
c ~
reporting since the licensee also issues personnel contamination event reports for each personnel contamination.
Based on =the review, the inspector noted in only one audit and one surveillance were there findings of substance.
Overall, the RER system was not used comprehensively and the audit arid surveillance programs were not fully developed.
The inspector was not able to determine management oversight, root cause determination, timeliness of correction, or problem trending; all critical elements in a program to ensure that problems, both programmatic and compliance based, are being identified and corrected when the Region-based radiation specialists are not
.on site.
This item was discussed with plant management at the exit and the licensee acknowledged the NRC's concern.
Training and gualifications Technical Specification (TS) 6.3 states that each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS-3. 1-1978 as endorsed by Regulatory Guide 1.8, September 1975.
e d.
ANSI/ANS-'3. 1-1978, Section 4.5.2 requires that technicians have three years of working experience in their speciality of which one 'year should be related technical training.
The inspector noted that the licensee had contracted with 90 technicians to provide HP support during the current outage.
The inspector was informed that 55 of the contract HP technicians were ANSI 3. 1 qualified.
The remaining 35 contract technicians only provided HP support while under the auspices of an ANSI qualified technician.
The inspector reviewed selected ANSI qualified contract technician's resumes and verified compliance with ANSI 3. 1 requirements.
External Exposure Control
CFR 20. 101 requires that no licensee shall possess, use or transfer licensed material in such a
manner as to cause any individual in a restricted area to receive in any period of one
.calendar quarter a total occupational dose in excess of 1.25 rems to the whole body; head and trunk; active blood forming organs; lens of the eyes; or gonads; 18.75 rems to the hands and forearms; feet and ankles; and 7.5 rems to the skin of the whole body.
(1)
Multibadge/Extremity Exposure Monitoring The inspector reviewed the RP program guidance for conducting multibadge exposure monitoring for workers involved with Radiation Work Permit (RWP)
1407, Installation of Nozzle Dam (2)
Health Physics Procedure, HP-112, Nultibadging, revision (Rev. 7), dated 10/22/91, requires HP supervision to establish multibadging and dosimetry requirements for applicable RWPs.
From review of selected contract outage worker records, the inspector verified that procedural requirements were met for multibadging the workers.
The inspector also verified that the doses assigned to each worker were for the maximum whole body and extremity doses
[1349 milliRem (mRem)
and 1048 mRem, respectivelyj, for those involved in the installation of steam generator nozzle dams.
Skin Dose Evaluation Procedure HP-72, Determination of Dose to the Skin from Skin Contamination, Rev.
5, dated 2/20/90 provides guidance for determining beta dose from skin contamination.
Any skin contamination in excess of.25,000 disintegrations per minute-hours (DPN-hrs) is required to be evaluated to determine if the contamination is in the form of a hot particle.
Skin dose calculations conducted from January 1,
1991, until the time of the onsite inspection were reviewed and discussed with cognizant licensee representatives.
The inspector noted that for all events involving hot particles, skin. dose evaluations were initiated as required by HP-72.
The maximum skin exposure assigned to an individual was 931 mRem from a hot particle.
Internal'xposure Control Program Implementation
CFR 20. 103(a)(1)
states that no licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a
quantity,, of radioactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for
hours per week for 13 weeks at uniform concentrations -of radioactive material in air specified in
CFR Part 20, Appendix B, Table 1, Column l.
CFR 20.103(a)(3)
requires that for purposes of determining compliance with the requirements of this se'ction, the licensee must use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas, and in addition, as appropriate, measure radioactivity in the body, measure radioactivity excreted from the body, or any combination of such measurements a's may be necessary for the timely detection and assessment of individual intakes of radioactivity by exposed individual (2)
HP Procedure, HP-35, Bioassay Program, Rev.
7, dated 9/21/90 states that each radiation worker shall have a baseline or entrance bioassay and upon termination of assignment. should have an exit bioassay.
In addition the procedure states that radiation workers should submit to at least one whole body count per year.
The inspector verified that'elected contract personnel involved in,current outage activities had received baseline whole body counts following assignment to the site.
The inspector also reviewed and verified completion of annual whole body counts for'elected RP personnel.
Further,'from review of the selected whole body analysis records the inspector noted that no positive-whole body analyses'were identified.
I For those records reviewed the inspector noted the resul,ts of
.
the licensee's internal'ssessment efforts.
No exposures in excess of the
Maximum Permissible Concentration
- hours
'MPC-hrs) control measure had occurred since January 1,
1991.
Respiratory Protection Program
CFR 20; 103(c)
permits the licensee to maintain and to implement a respiratory protection program that includes; at a
minimum:
air sampling to identify the hazards; surveys and bioassays to evaluate the actual exposures; written procedures
'o select, fit and maintain respirators; written procedures regarding supervision and training of personne'1 and issuance of records; and determination by a
physician prior'o use of respirators that the individual user is physically able to use respiratory protection equipment.
The inspector reviewed current respiratory protection program records to verify training, completion of medical physicals, and fit-testihg for selected RP staff personnel
'and contract personnel involved with nozzle dam installation activities.
For those records reviewed,
.the inspector verified that all personnel were trained to use respiratory protection equipment, fit-tested, and medically qualified in accordance with the regulations.
Surveys, Monitoring, and Control of Radioactive Material and Contamination,
CFR 20.201(b) requires a licensee to make or cause to be made such surveys as (I) may be necessary to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be presen.10 CFR 20.203 specifies the posting; labeling and control requirements for radiation,'irborne, and. radioactive material areas.
During tours of the Unit 1 containment and the auxiliary building for both units, the inspector examined licensee postings, labeling, and controls for radiation and high radiation areas.
The inspector observed good consistency for postings and labelings of radioactive material and good controls for radiation and high radiation areas.
The inspector performed both radiation and surface contamination surveys in the auxiliary building and radiation surveys in the Unit
containment building.
All surveys agreed with those taken by the licensee.
The inspector reviewed the licensee's program to control contamination at the source and noted the licensee posted as contaminated 10,161 square feet (ft') of the total 106,000 ft'f radiologically controlled area (RCA).
However, during operations the average contaminated area of the RCA is approximately 4,000 ft~.
To date in 1991 the licensee has experienced
personnel contaminations.
With a major portion of the outage completed> it appears that the goal of 167 personnel contaminations for 1991 will not be exceeded.
Licensee representatives stated that increased worker awareness, decontamination of areas, and daily cleanings of the aisleways have kept personnel contaminations low.
The inspector also'oted that the licensee had continued efforts to ship all radioactive waste off site and cleanup their backyard area.
The area has improved greatly in posting and appearance over the past several inspections.
g.
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 as low as reasonably achievable.
The recommended elements of an ALARA program are contained in Regulatory Guide 8.8,
"Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Stations will be ALARA," and Regulatory Guide 8. 10,
"Operating Philosophy for Maintaining Occupational Radiation Exposures ALARA."
Ongoing licensee operations during the week of the inspection included the completion of sludge lancing in steam generator (S/G)
"C" and eddy current testing in S/G
"A" and "B".
Maintenance was also in progress on pressurizer valves and S/G tube plugging.
At the time of the inspection, the licensee was seven person-rem over their projection, however, the outage completion date appeared to be ahead of schedule.
Site dose by thermoluminescent dosimeter readings through October showed a collective dose of 135 person-rem, well below the projected 178 person-re Based on a
review of data and discussions with licensee representatives, the inspector noted that the program to reduce hot spots was working well.'ince the start of the outage, the 30 existing hot spots had been reduced by flushing to 15.
Ultra filters had been installed to reduce the size of radioactive particles in the reactor coolant system.
Roughing filters are still used to cover the cavity drain during draining operations.
Routinely the several filter's used, read between
and 100 rem/hr, when removed.
This,has removed a significant amount of source term and subsequent water treatment for cavity drain effluent.
No violations or deviations were identified.
3.
Information Notices (92701)
. The inspector determined that the following Information Notices (INs)
had been received by the licensee, reviewed for applicability, distributed to appropriate personnel, and that action, as appropriate was taken or scheduled:
O 90-49: Stress Corrosion Cracking in PWR Steam Generator Tubes 90-50:
Minimization of Methane Gas in Plant Systems and Radwaste Shipping Containers 90-52:
Inadvertent Shipment of a
Radioactive Source in a
Container Thought to be Empty 90-63:
Management Attention to the Establishment and
'aintenance of a Nuclear Criticality Safety Pro'gram 88-63:
Supplement 1:
High Radiation Hazards from Irradiated Incore Detectors and Cables 90-66:
Incomplete Draining and Drying of Shipping Casks 90-75:
Denial of Access to Current Low-Level Radioactive Waste Disposal Facilities 90-81: Fitness-For-Duty 91-10:
Summary of Semi-Annual Program Performance Reports 91-35:
Labeling Requirements for Transporting Multi-Hazard Radioactive Materials 91-36:
Nuclear Plant Staff Working Hours
91-37:
Compressed Gas Cylinder Missile Hazard 91-49:
Enforcement of Safety Requirements for Radiographers 4.
Exit Meeting The inspector m'et with license representatives denoted in Paragraph 1 at the conclusion of the inspection on November 22, 1991.
The inspector summarized the scope and findings of the inspection and.did not receive any dissenting comments.
The licensee did not identify any materials reviewed by the inspectors as proprietary.