IR 05000335/1993013
| ML17228A174 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/14/1993 |
| From: | Bryan Parker, Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17228A173 | List: |
| References | |
| 50-335-93-13, 50-389-93-13, NUDOCS 9306020190 | |
| Download: ML17228A174 (8) | |
Text
~gg RE0I, Mp C
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 11 101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 MAY I 7
[993 Report Nos.:
50-335/93-13 and 50-389/93-13 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, Fl 33102 Docket Nos.:
50-335 and 50-389 Facility Name:
St.
Lucie Units
and
Inspection Conducted:
April 19-23, 1993 Inspectors:
R.
B. Shortridge B.
Parker License Nos.:
/
Sl~
7>
Da e signed Date Signed Approved b
.
S ig W.
H. Rankin, Chief Da e S gned Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This was a routine, announced inspection of the Radiation Protection (RP)
program and included a review of organization and management controls, training and qualification, external exposure control, internal exposure control, control of radioactive material, surveys and monitoring, the program to maintain occupational exposure As Low As Reasonably Achievable (ALARA) and followup of previously identified items.
Results:
Within the areas inspected, no violations or deviations were identified.
Radiological performance on jobs inside containment was good.
Based on observation of outage work, records review, and interviews with management and staff, the inspector determined that the RP program was implemented'sing high standards and was effective in protecting the health and safety of the public.
v~
9SObo o
050003>5 pDR ADQCK 0 pDR
REPORT DETAILS 1,
Persons Contacted
- G
- H.
- C
- L
- J
- J
- J
- J
- J L.
- L
- R.
- L
- H.
- K.
- T Boissy, Plant General Manager Buchanan, Superintendent, Health Physics Burton, Manager, Operations Croteau, Training Specialist Danek, Corporate Health Physics Dyer, Supervisor, guality Control Englmeier, Site guality Manager Geiger, Vice President Nuclear Assurance Holt, Engineer, Licensing Jacobus, ALARA Coordinator, Health Physics Large, Supervisor, Health Physics McCull'ens, Operations, Supervisor, Health Physics NcLaughlin, Manager, Licensing'ercer, Technical Supervisor, Health Physics Payne, Supervisor, Health Physics Ware, Supervisor, Technical Training 2.
Other licensee employees contacted during this inspection included technical and administrative personnel.
Nuclear Regulatory Commission
". S. Elrod, Senior Resident Inspector
+W. Rankin, Chief, Facilities Radiation Protection Section N. Scott, Resident Inspector
- Attended Exit Interview held on April 23, 1993 Organization and Management Controls (83729)
a 4 Organization The inspector reviewed and discussed with licensee representatives the Radiation Protection (RP) organization, staffing levels and lines of authority as they relate to the RP program and verified that the licensee had not made organizational changes which would adversely affect the ability to control radiation exposures and radioactive material.
b.
Management Controls The inspector reviewed other guality Assurance (gA) audits and Radiological Deficiency Reports (RDRs),
key documents used by management in maintaining RP program oversight/control, including:
gSL-OPS-92-878, Health Physics Department Audit, dated July 15, 1992;
gSL-OPS-92-913, Performance Monitoring Report for December 1992, dated January 15, 1993; gSL-OPS-93-06, Performance Monitoring Report for February 1993, dated March 11, 1993; and gSL-OPS-93-10, Performance Monitoring Report for March 1993, dated April 16, 1993.
The audits focused on specific RP activities and in general centered on compliance with established procedural requirements.
All items identified as requiring resolution appeared to have been corrected in a timely manner.
No violations or deviations were -identified.
Training and gualification (83729)
The inspector discussed continuing training and the training of contract health physics (HP) technicians with licensee training representatives.
The inspector learned that to date in 1993, the licensee had not been able to conduct continuing training in the classroom for licensee or contract HP technicians due to back-to-back outages during the first part of the year.
However, all required'training completion dates were being met.'n addition to site specific training, general employee training, and procedures training during initial site training, the licensee provided on-the-job (OJT) training in ten separate areas which included all facets of duties that a junior HP technician would be expected to encounter.
The inspector, reviewed the training for the 37 junior HP technicians onsite to support the outage and noted that approximately 80-90 percent was completed.
Licensee training representatives further stated that of the 30 licensee HP technicians, 17 had passed the certification for the National Registry for Radiation Protection Technologists (NRRPT).
During the program review, the inspector noted that the planned continuing training cirriculum for 1993 did not contain systems training for HP technicians with emphasis on the radiological hazards, precautions, and limitations of that particular system.
The licensee indicated that they would consider including this in their cirriculum when the training committee next met.
The inspector observed an OJT training session for two senior contract HP technicians on calibration of digital alarming dosimeters (DADs) and telemetric DADs.
The OJT training module required the task to be performed and consisted of the calibration of DADs equipped with telemetric capabilities.
The calibration involved the use of a robotic calibrator.
The students performed the OJT training without any problems.
The inspector noted that the licensee had previously encountered a problem with the calibrator in that the software caused the calibrator, when -in the automatic mode, to set the DAD >uch that it reported two times the actual dose.
The inspector reviewed the licensee's technical report and noted that the software problem had
still not been corrected.
The licensee indicated that the software problem would be fixed and that no other problems were anticipated as long as the calibrator was operated in the manual mode.
No violations or deviations were identified.
External Exposure Control (83729)
CFR 20.202 requires each licensee to supply appropriate personnel monitoring equipment to specific individuals and requires the use of such equipment.
CFR 20.203 specifies the posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactivity areas,
- and radioactive material areas.
Additional requirements for control of high radiation areas are contained as Technical Specification (TS) 6. 12.
During tours of the Auxiliary Building and Unit 1 containment to observe outage RP activities; the inspector noted that all personnel were wearing personnel dosimetry as required.
All postings and labeling in the radiologically controlled area (RCA) of the plant were'as required by 10 CFR Part
a'nd the site procedures.
The inspector performed radiation and contamination surveys in Unit 1.containment and various areas within the RCA and noted that the results did not differ from the licensee-performed/posted surveys.
The inspector reviewed the administrative control for high radiation area keys.
TS 6. 12.2, in part, requires that areas accessible to personnel with high radiation levels such that a major portion of the body could receive in one hour a dose greater than 1000 millirem per hour (mrem/hr)
be provided with locked doors to prevent unauthorized entry, and the keys maintained under the administrative control of the shift foremen on duty and/or health physics supervision.
A review of
. th'e locked high radiation area (LHRA) logs showed that over the 1992-1993 period for both units, personnel complied well with LHRA key check out and return requirements.
I.
The inspector monitored the radiological operations performed during the repair of a two-inch valve (VO-2030) located in the Unit 1 containment, 18 foot elevation, in the Regenerative Heat Exchanger Room, a
LHRA.
Radiological requirements for the job were established by Radiation Work Permit (RWP)
No.
1323, Unit 1 Regenerative Heat Exchanger Valve, Repair.
General area radiation levels averaged 500 mrem/hr with a maximum general area reading of 900 mrem/hr.
Several feet away, a dose rate of 3,000 mrem/hr was noted.
Surface contamination levels in the area ranged from 80,000 to 300,000 disintegrations per minute per 100 square centimeters (dpm/100 cm').
Maintenance personnel had performed a mockup of the valve repair under simulated radiological conditions and estimated the repair to take 15-20 minutes, depending on the problem.
To ensure maximum control over the exposure, the licensee utilized telemetric DADs for the job.
In addition, closed circuit television was
used to enhance HP coverage and maximize communications.
The inspector observed the operations and noted that all aspects were carried out using good dose reduction techniques.
The valve repair was performed for approximately 120 mrem total and all radiological aspects of the job were performed well.
The inspector also monitored the radiological operations performed during additional valve repairs on the 18 and 23 foot elevations.
This work was performed under RWP Nos.
1323 and 1341.
This job involved setting a liquid nitrogen freeze seal on the incoming and outgoing legs around the valves, draining the isolated section, conducting the repairs, releasing the freeze, and verifying the repair was complete.
The inspector attended the pre-job briefing and observed the work in progress at various stages.
The entire job was completed for approximately 260 mrem.
Good radiological controls and techniques were observed throughout the job and no problems were noted.
No violations or deviations were identified.
Internal Exposure Control (83729)
CFR 20. 103(b)(1) requires that the licensee use process or other engineering controls to the extent practicable to limit concentrations of radioactive'aterials in the air to levels below those which delimit an airborne radioactivity area as defined in 20.203(d)(1)(ii).
CFR 20. 103(c)(2) permits the licensee to maintain and implement a
respiratory protective program that includes; at a minimum:
air sampling to identify the hazard; surveys and bioassays to evaluate the actual exposures; written procedures to select, fit, and maintain respirators; written procedures regarding supervision and training of personnel and issuance of records; and determination by a physician prior to the use of respirators, that the individual user is physically able to use respiratory protective equipment.
The inspector reviewed portions of the licensee's respirator training, fit-testing and medical qualification programs.
Selected records for individuals associated with the jobs discussed in Paragraph 4 were reviewed and no problems were noted.
The licensee informed the inspector that some adjustments were made to the fit-test booth, which helped increase the overall pass rate from approximately 80 percent to 90 percent.
Three attempts were allowed per individual to pass the fit-test, which is quantitative in nature.
In addition, the inspector was informed that, as part of the approval process to use bubblehoods, a
fit-test had to be at least attempted.
The inspector noted that the licensee had completed new facilities for respirator and camera maintenance.
This new area should help streamline the activities involved in repairing self-contained breathiag apparatus (SCBAs)
and other respiratory protection equipment, as well as combine
the storage areas for spare parts, tools, etc.
Selected breathing air manifolds, SCBAs, and airline pressure gauges were checked by the inspector in numerous locations onsite and no problems were noted with the licensee's service, storage or calibration methods.
'I The licensee continued to have problems with pin-hole leaks developing in the aluminum neck area of SCBA air cylinders, causing the cylinders to fail.
This issue was thoroughly discussed in NRC Inspection Report No. 92-25.
The licensee plans to begin replacing the cylinders on an as-needed basis.
Thus far, there has been minimal impact. on the respiratory protection/emergency response capability due to the loss of approximately 25 percent of the licensee's inventory of air cylinders, as multiple backup units are routinely maintained.
The inspector noted that the licensee's increased use of engineering controls (tents, local HEPA units, etc.) coincided with a respirator reduction program that was implemented.
No problems were noted with the licensee's procedures and no trends relating respirator reduction to increased internal exposures have yet been noted.
No violations or deviation were identified.
Surveys, Honitoring, and Control of Radioactive Haterial (83729)
CFR 20.203 specifies the posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactivity, areas and radioactive material areas.
Additional controls for high radiation areas are contained in TS 6. 12.
During tours of the containment building and auxiliary building the inspector noted that all posting and labeling was in accordance with licensee procedures.
The inspector performed both radiation and contamination surveys to ascertain licensee performance in this area.
The inspector's survey results did not differ from the licensee postings and recorded surveys.
The inspector noted that the licensee had made improvements in locking certain high radiation areas.
New locking mechanisms had been fabricated for the reactor sump, drain tank.
The inspector reviewed personnel contamination events (PCEs)
and noted that the licensee had experienced a low number (28) to date for the year and 22 to date for the outage.
The inspector also reviewed skin dose assessments for significant skin contaminations, including hot particles.
No excessive skin doses occurred, the maximum being approximately 650 mrem.
No problems were noted with the licensee's procedures or methods.
No violations or deviations were identifie,
Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA) (83729)
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 Stations will be ALARA," and Regulatory Guide 8. 10,
"Operating Philosophy for Haintaining Occupational Radiation Exposures ALARA."
During a previous inspection, the inspector discussed specific aspects of the licensee's program to maintain occupational exposure ALARA with licensee representatives.
'he ALARA Coordinator demonstrated a robotic device in the reactor cavity that provided clear remote closed circuit television pictures, as well as, a capability to perform vacuuming operations.
The device was outfitted with two radiation detection devices capable of reading high radiation levels, Also, the licensee provided information on the in-pool filtration system for maintaining the quality, and clarity of reactor vessel cavity water.
The system was
- located in the pool and the high levels of radiation were -kept underwater during filter change out.
The licensee was unable to postulate a dose savings from these systems but stated that the robotic device saved significant exposure in performing remote inspections during reactor head disassembly/assembly and defueling operations.
Licensee representatives indicated that since the inspection in Nay 1992, two more robotic submarine-type cameras and an additional in-pool vacuum/filtration system had been purchased to further reduce co'Ilective dose.
The licensee indicated that new nozzle dam upgrades for Unit I for 1993 had been purchased and installed.
In the past, the licensee has had unnecessary exposures due to leaking nozzle dams.
In 1992 alone, seven person-rem was incurred due to three draindowns of the hot leg on "A" steam generator resulting from nozzle dam leaks.
During some previous outages, the nozzle dam installation and removal has resulted in as much as 20 person-rem.
The new nozzle dams for the hot leg and both cold legs were installed during this outage for. less than three person-rem, a
significant collective dose savings.
The licensee is planning to install a new permanent cavity seal ring during the outage scheduled for early 1994.
The seal ring will be neutron-shielded on the underside.
In addition to overall increased dose savings from shielding, the new component will help cut the installation time for shielding from four days to one and one-half days.
The licensee continued to use enhanced filtration to reduce the size of particles in the reactor coolant system (RCS).
Also, a list of valves containing stellite has been developed and actions were beiag implemented this outage to change out the valves as needed.
The reduction of cobalt in the RCS by replacement of valves with stellite
is planned to be performed according to established priorities where the most benefit could be realized.
The valve replacement project is expected to take approximately five years to complete.
The licensee established a collective dose goal of 600 person-rem for 1993.
This was to cover two major refuelinggmaintenance outages; however, collective dose through April 21, 1993, was approximately 430 person-rem with a major scope of work for this outage still to be completed.
Licensee representatives indicated that approximately 60 person-rem had been incurred during an unplanned outage in January-Harch of this year and that the outage scheduled for late 1993 had been rescheduled for early 1994; therefore, the licensee indicated that it was possible that the original collective dose goal could be met.
No violations or deviations were identified.
Exit Interview The inspection scope and findings were summarized on April 23, 1993, with those persons indicated in Paragraph 1.
The inspector noted that the RP program was aggressive in their quest for high standards and in using new technology and innovative ideas.
The inspector did not receive any proprietary information or dissenting comments from the licensee.