IR 05000348/1989008
| ML20246N979 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/11/1989 |
| From: | Gloersen W, Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20246N978 | List: |
| References | |
| 50-348-89-08, 50-348-89-8, 50-364-89-08, 50-364-89-8, IEIN-88-032, IEIN-88-034, IEIN-88-063, IEIN-88-101, IEIN-88-32, IEIN-88-34, IEIN-88-63, NUDOCS 8905220050 | |
| Download: ML20246N979 (12) | |
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UNITED STATES j,,,Lh? " ~ * * jo NUCLEAR REGULATORY COMMISSION REG 60N 11 p
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ATLANTA, GEORGt A 30323
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Wh'i 21989
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< Report Nos.: 50-348/89-08, 50-364/89-08 Licensee: Alabama Power Company 600 North 18th Street-L Birmingham,~AL. 35291-0400 l
Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility.Name:
Farley 1 and 2 Inspection Conducted: Ap il-14, 1989 Inspectors:////h
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Date Signed
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Approved.by:
f J. 7. Potter, Chief Dbtd Signed Facilities and Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope This routine, unannounced inspection was conducted in the areas of occupational exposure, shipping, transportation, solid waste, and licensee responses to Information Notices.
Results In the areas inspected, violations or deviations were not identified.
The licensee's radiation protection program appeared to be adequate in the areas covered during the inspection. A positive licensee initiative was noted in the area of new equipment acquisition.
In early 1989, the licensee purchased a Nuclear Data rapid counting stand-up whole body counter and three Canberra gamma spectroscopy. systems for the health physics laboratory, radiochemistry
. laboratory, and training center.
The licensee was pursuing several dose reduction initiatives slated for the near term (1989), intermediate term-(1990-1991), and long term implementation.
The licensee's collective dose for 1988 was belov the national average for the same time period for a pressurized water reactor.
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REPORT DETAILS I
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1.
Persons Contacted
Licensee Employees J. Bouillon, Dosimetry Foremer W. Boyd, Radwaste Technician (
- S. Casey, Supervisor, System Performance
- G. Dykes, Auditor, Safety Audit and Engineering Review (SAER)
P. Farnsworth, Supervisor, Radwaste D. Grissette, Supetvisor, Chemistry and Environmental
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- R. Hill, Assistant General Manager, Plan Operations
- D. Morey, General Manager, Nuclear Plant
- M. Mitchell, Supervisor, Health Physics
- C. Nesbitt, Technical Manager
- J. Osterholtz, Operations Manager
- P. Patton, Plant Health Physicist
- M. Pilcher, Auditor, SAER
- J. Thomas, Maintenance Manager Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, technicians, and administrative personnel.
NRC Resident Inspector
- W. Miller
- Attended exit interview 2.
External Exposure Control and Dosimetry (83724)
a.
Personnel Monitoring Devices 10 CFR 20.202 requires each licensee to supply appropMate personnel monitoring devices to specific individuals and requires the use of such equipment.
During tours of the Unit 2 Reactor Building, the Auxiliary Building, and other areas of the Radiologically Controlled Area (RCA), the inspectors observed workers wearing thermoluminescent dosimeters (TLDs) and pocket ion chambers (PICS) as required.
The inspector also reviewed the comparison between the monthly collective TLD and PIC readings from June 1988 to March 1989.
The data are l
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summarized below:
Table 1 Month PIC (person-rem)
TLD (person-rem)
Ratio (PIC/TLD)
6/88'
9.57 9.57 1.00 7/88 5.55 7.32 0.76 8/88 5.71 5.40 1.06 9/88 6.85 6.99 0.98 10/88 4.81 4.87 0.99 11/88 10.55 10.18 1.04 12/88
~6.15 6.71 0.92 1/89 4.07 4.78 0.85 2/89 3.01 1.86 1.62 3/90 58.81 62.33 0.94 The inspectors noted that, in general, there was good correlation between the collective PIC and TLD readings.
The inspectors also reviewed personnel exposure histories from January 1, 1989 to April 13, 1989, and the licensee's quarterly exposure history report.
Out of a total of 1801 badged individuals, the highest individual dose for last quarter was 1,070 mrem.
Additionally, the inspectors observed that the Engineering Department (including contractors)
received 44.19 person-rem which was the highest collective dose for any department during calender year 1989.
Most of this dose was attributed to performing inservice inspection work.
The remaining collective dose by work group in decreasing order was as follows:
(1) Maintenance Department - 18.07 person-rem; (2) Health Physics Department - 13.68 person-rem; and (3) Operations Department
- 10.85 person-rem.
b.
Radiologically Controlled Areas 10 CFR 20,203 specifies posting and control requirements for i
radiation areas, high radiation areas, airborne radioactivity areas, and radioactive material areas.
During tours of the RCAs, the inspectors reviewed the licensee's posting and control of radiation; high radiation, airborne radioactivity, and radioactive material areas.
The inspectors also performed independent radiation surveys and verified locked high radiation doors in the Auxiliary Building were properly maintained.
The inspector verified that radiation levels were consistent with area postings.
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c.
Control of High Radiation Areas l
In 1988, inspectors responded to an event at the plant that had a l
high potential for personnel over exposure to radiation. One of the l
inspection findings was control of high radiation areas.
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Specification (TS) 6.12 requires that areas with dose rates exceeding 1,000 millit em/hr at 18 inches be barricaded and/or locked.
However, the TS allowed that if areas in containment could not reasonably have barricades or locks installed, then rope barriers and flashing warning lights could be used to denote very high radiation areas.
Investigation of the event showed that rope barricades and flashing warning lights were being widely used in the Auxiliary Building in lieu of locking these areas. A review of licensee corrective actions to the event showed good progress by the licensee in installing physical barrier with locks or locking existing doors to the areas in the Auxiliary Building with radiation levels greater than 1,000 mr/hr at 18 inches.
However, during tours of Unit 2 containment, the inspectors noted that the Non-Regenerative Heat Ext. hanger (NRHX) was posted with physical rope barriers and a flashing warning light to denote a high radiation area with dose rates of 1,200 mr/hr at 18 inches. The inspectors noted that one proposal to build a block wall with a lockable gate was not approved.
Licensee representatives stated T. hat a proposal was being developed to install a physical barrier that was lockable but this was slated for installation during refueling cycle eight.
The inspectors discussed the need for approved access control of this area and the NRHX in Unit 1 before the next refueling outage.
The licensee committed to the NRC during the inspection that appropriate temporary fencing material with a gate and locks, if access was required to this area, would be installed.in Unit 1 and Unit 2 during the next refueling outage. The inspectors stated that. licensee actions to properly barricade and lock, if access is required, the NRHX in Units 1 and 2 would be reviewed in a subsequent inspection and would be tracked by the NRC as an Inspector Followup Item (IFI) (50-348/89-08-01 and
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50-364/89-08-01).
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d.
Exposure Controls The inspectors discussed exposure controls with licensee
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representatives.
The licensee stated that plans are to install a
computerized access system in 1990 that will keep a current account I
of personnel dose.
The system will utilize electronic reading
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dosimeters capable of alarming at a pre-set accumulated dose or a pre-determined dose rate.
During tours of the RCA, the inspectors observed fuel shuffle, steam generator tube plugging, and sludge lancing operations.
Exposure controls such as time keeping for steam generator workers and multi-badging were in accordance with procedure requirements.
No vic1ations or deviations were identified.
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3.
Internal Exposure Control (83750)
a.
Engineering Controls 10 CFR 20.103(b)(1) requires that the licensee use process or other engineering controls to the extent practicable to limit concentrations of radioactive materials in the air to levels below those which delimit an airborne radioactivity area as defined 'in-20,203(d)(1)(ii).
During plant tours, the inspectors observed various engineering controls employed to limit concentrations of airborne radioactive materials.
These controls included the use of temporary ventilation systems, containment enclosures, and high efficiency particulate air (HEPA) filter units.
10 CFR 20.103(a) establishes the limits for exposure to individuals to concentrations of radioactive materials in air in restricted areas.
The inspectors determined that during calender year 1989, individuals working at the licensee's facility had not exceeded two MPC-hours for an eight hour period or ten MPC-hours in seven consecutive days.
For an individual inhaling a quantity of radioactive. material in a restricted area, the licensee established an administrative limit of 28 MPC-hours per week.
b.
Whole Body Counter 10 CFR 20.103(a) requires the licensee to perform appropriate bicassays to detect and assess intakes of radioactivity.
The licensee's administrative limits were described in FNP-0-DOS-300, Operation and Calibration of EG&G Ortec Whole Body Counters, Revision 1 March 17, 1989, which allowed release of an individual if any radioisotopes detected do not exceed three per cent maximum permissible organ burden (MP0B).
Additionally, FNP-0-DOS-300 requires an individual to be recounted to confirm results if any radioisotope is detected at or above one percent MP0B.
If the results of the recount confirm that whole body count results are greater than three percent MP0B, then the technician is required to notify the Health Physics (HP) Foreman via DOS Form 994.
After a review of selected whole body count reports for the first quarter of 1989, it was observed that no administrative limits had been exceeded.
During the first quarter of 1989, the licensee had acquired a new rapid counting stand-up whole body counting unit (Nuclear Data 2000)
which was located at the Emergency Operations Facility (E0F).
Additionally, the licensee has one EG&G Ortec Chair geometry whole body counter located in the Auxiliary Building and another locbted in the EOF.
These counters were equipped with germanium detectors. At the time of this inspection, the counting unit in the E0F was not operational.
The licensee's stand-up unit provided rapid screening capabilities and also the capability to quantify the body burden of radioactive materials, but it only provided crude activity
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localization capabilities.
The licensee stated that in cases where such additional information is needed or that when one percent MP0B was exceeded, the individual would be recounted on one of the chair geometry whole body counting units.
The inspector reviewed FNP-0-00S-307, Operation and Standardization of the Nuclear Data Stand-up Whole Body Counter, Revision 0, March 2, 1989.
A review of the operating routine for the whole body counter facility showed that the licensee was performing quality control (QC)
checks that are normally recommended by the vendor. The daily checks included background verification, checks on the count rate from a standard source, and full-width-at-half-maximum (FWHM) checks. After reviewing FNP-0-DOS-307, the inspectors identified some weaknesses in the quality control portion of the procedure. Some of the weaknesses included the following:
Lack of guidance on actions to take when the stand-up whole body count failed the daily QC parameters check.
Key QC parameters (FWHM, count rate) were not plotted.
QC parameter check frequency was not specified.
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Control limits for the standard check source were not decx corrected.
After. reviewing the weaknesses, the licensee took prompt action and revised the procedure by the conclusion of the inspection.
The inspectors also reviewed the initial calibration records of the stand-up whole body counter. The initial calibration was part of the
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Site Acceptance Test for the stand-up whole body counting system, dated February 8, 1989.
The review included an examination of the energy calibration, efficiency determination, and minimum detectable activity calculations.
The calibration records appeared to be in order.
Additionally, the inspectors reviewed FNP-0-DOS-300, Operation and Calibrations of the EG&G Ortec Whole Body Counters, Revision 1, March 17,1989, and the daily QC parameter checks for the Ortec counters.
The inspectors noted that the control limits for the standard source count rate check should be established on the same cycle as when the efficiency determination is made.
Presently, the licensee reestablished the control limits monthly. The inspectors and licensee representatives discussed the advantage of establishing the control limits over a longer time period than one month, primarily to detect electronic drifts in the linear amplifier or analog-to-digital converter failures.
The licensee acknowledged the inspectors'
comments.
No violations or deviations were identified.
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4.
Control of Radioactive Materials and Contamination, Surveys and Monitoring (83750)
The licensee was required by 10 CFR 20.201(b) and 20.401 to perform surveys and to maintain records of such surveys necessary to show i
compliance with regulatory limits.
During plant tours, the inspectors performed surveys in unrestricted areas J
of the plant and in RCAs outside of the Auxiliary Building. Based on the survey results, the inspectors determined that the program for releasing material to unrestricted areas was satisfactory and that radioactive material in RCAs outside of the Auxiliary Building was properly labeled and controlled.
The inspectors also examined the licensee's radiation detection instrumentation and verified that all instruments observed were in current calibration.
No violations or deviations were identified.
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Program for Maintaining Radiation Doses As Low As Reasonably Achievable
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(ALARA)(83528)
10 CFR 20.1(c) specifies that licensees should implement programs to maintain workers' doses ALARA.
Other recommended elements of an ALARA program are contained in Regulatory Guides 8.8 and 8.10.
a.
Modified Chemistry Program To reduce out of core source term, the licensee implemented a modified chemistry program in 1986.
Licensee representatives stated that their objective was to keep crud in the reactor coolant system in suspension by increasing coolant pH, thereby increasing the letdown system. clean up capabilities.
In addition to the modified chemistry program, the licensee also performs a hydrogen peroxide addition prior to each refueling to introduce a crud burst.
The licensee stated that prior January 1985, the hydrogen peroxide operation was performed for the entire reactor coolant system with the system solid.
However, to prevent the introduction of crud from the core region to the steam generators, pressurizer and remainder of d
the system, the licensee performs the operation with the reactor coolant level at the mid-plane of the reactor vessel nozzles.
The licensee stated that after the Unit 1 seventh refueling cycle and Unit 2 fourth refueling cycle a modified chemistry program was initiated by adjusting the lithium / boron ratio and increasing the reactor coolant pH within the steam generator owner's group band from 6.6 to 6.9.
Radiation levels in Unit 1 steam generators were basically the same when the steam generator channel heads were surveyed during the eighth refueling but the radiation levels dropped by 41 percent in Unit 2 steam generator. The significant decrease in steam generator channel head radiation levels from 14.0 rem /hr to 8.25 rem /hr averages was attributed to the modified chemistry
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program.
However, the licensee stated that failure of Unit 1 steam generators to show the same reduction in radiation levels may have been attributed to the partial removal of the passivation layer in the reactor coolant system during the shot peening activities of the steam generators.
The inspectors reviewed the sixth refueling radiation level data from the Unit 2 steam generators and noted that radiation levels had increased to levels prior to implementation of the modified chemistry program and in some areas significantly above the levels noted during the fourth refueling cycle. Also, data from the hydrogen peroxide addition revealed that 934 curies of cobalt 58 was removed during system letdown.
The inspector noted that the activity removed during the sixth forced hydrogen peroxide addition had increased by more than 35 percent over other hydrogen peroxide additions.
The licensee stated that a significant amount of collective dose was expended removing shot from the steam generators (from previous shot peening activities) and that they suspected that residual shot may have been responsible for the significant increase in activity removed from the system. The licensee suspected the shot peening had removed the passivation layer in the system and that may have been responsible for the increased radiation levels in the steam generator channel heads.
Licensee representatives informed the inspectors that a safety evaluation had been performed and that they had received permission to increase system pH to levels above the steam generator owners group band during the next operative cycle.
b.
Dose Reduction Initiatives Licensee representatives in discussion with the inspectors, stated
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that a number of dose reducing initiatives were slated for near term (1989), intermediate team (1990-91), and long term implementation.
The following is a listing of some initiatives in each category:
(1) Near Term Implement a modified chemistry program with elevated pH above the steam generator owners group band to reduce out of core source term.
Install ultrafilter cartridges to reduce the radioactivity in selec ted plant systems.
Evaluate improvements to the ALARA Suggestion Program and possible incentives for participating.
Upgrade valve packing program to reduce leakage and maintenance.
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Implement formal ALARA classroom training for selected radworkers.
Install a steam generator channel head mock-up.
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Intermediate Term Change grid strap material on fuel assemblies from low j
cobalt inconel to zircalloy.
Develop a program to replace NSSS stellite seat valves with low cobalt seat valves.
Train work crews to perform limited radiation protection coverage.
(3) long Term Remove resistance thermocouple detectors and associated inanifolds.
Evaluate joining the ad hoc committee on full system chemical decontamination with fuel in the vessels.
Upgrade the movable incore detector to reduce system moving parts and increase system reliability.
The licensee stated that a reactor head shield was installed for outage operations in 1988, and had resulted in reducing dose rates by a factor of 10.
c.
ALARA Suggestion Program The inspectors reviewed ALARA Committee Meeting minutes for 1988 and 1989, and determined the ALARA Committee was involved in all elements of a comprehensive dose reduction program.
However, the inspectors noted that for several years the ALARA Committee had carried an action item to improve the ALARA Suggestion Program by providing incentives to workers to increase participation in the program.
Records showed that in 1987,1988, and 1989 there were 9, 4 and 7 ALARA suggestions submitted, respectively.
Licensee representatives stated that dose reducing suggestions were received through surveys of radworkers in continuing training but increased participation in the ALARA Suggestion Program was needed.
d.
Goals and Objectives The person-rem goal for both outages in 1989 was 771 person-rem. To l
date, the licensee has expended 137 person-rem compared with a projected expenditure of 293 person-rem.
The ALARA group representatives stated that additional work scope may be increased
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when steam generator plugs are inspected.
The licensee plans to manually install :26 plugs in suspect steam generator tube plugs with an additional 42 plug to plug installations by robotics.
An additional 109 plug to plug installations may be required.
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Based on a review. of radiological data by the inspectors, improvements were noted in the reduction of personnel contaminations.
The licensee defined c contamination as an activity level grea.er than or egual to 1,000 dpm/100 cm2 The licensee had a goal of less than 200 personnel contamination events in 1989. To date there have been six skin contaminations and nine clothing contaminations.
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licensee had effectively used a warning ticket system to improve awareness of poor radiological work practices and other radiological deficiencies.
The inspectors noted that the contaminated square footage of the RCA in the plant had not improved in 1988.
In 1987, the licensee reported nine percent or 10,568 square feet (ft2) as contaminated and 10,913 fta in 1988.
To this point in the outage a total of 11,412 fte of the RCA was contaminated.
No violations or deviations were identified.
6.
Shipping and Transportation (83750)
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10 CFR 71.5 requires that licensees who transport licensed material outside the confines of its plant or other place of use shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 througn 139.
The inspectors reviewed selected portions of the following radioactive materials shipments (RMS) and radioactive waste shipments (RWS) made since March 1989:
Shipment Number Media RMS 89-04 Dewatered primary resin media to TMA/NORCAL Charcoal Samp le from Containment Purge Filtratior, it RMS 89-05 Charcoal Sample from Containment Purge Filtration Unit RMS 89-06 Filter Smears to TMA/NORCAL RWS 89-07 Hittman Resin, Hittman Charcoal RWS 89-06 Dewatered Bead Resin
RWS 89-05 Dewatered Primary Bead Resin
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.The inspectors examined the shipping manifests which were consistent with 49 CFR requirements.
Additionally, vehicle surveys, including radiation
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and contamination surveys, were within the-limits specified for the mode of transport and shipment classification and the shipping documents were being completed and inaintained as required. The licensee's last shipping violation occurred in May 1985.
Additionally, the inspectors reviewed the following audits conducted as part of the quality control program to ensure compliance with 10 CFR 61.55 and 10 CFR 61.56:
RWM, SAER-WP-20, conducted August 24 - October 2, 1987.
RWM, SAER-WP-31, Appendix A and B, conducted August 29 - October 18,
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RWS, 88-49, SAER-WP-21, Appendix A, conducted October 6-18, 1988.
The inspectors observed that the deficiencies and noncompliance identified in the audit reports were being tracked and were closed. The inspectors also reviewed management evaluations of the aforementioned audits which appeared to satisfy the requirements of 10 CFR 20.311(d)(3).
No violations or deviations were identified.
7.
Solid Waste (84750)
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10 CFR 20.311(d)(1) requires that licensees prepare all waste such that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements specified in 10 CFR 61.56.
The licensee is currently sampling and performing offiste isotopic analyses of waste streams annually, except when substantive operational changes may require special sampling.
FNP-0-RCP-809, Isotopic Characterization of Radioactive Waste Streams for Offsite Shipment; and/or Burial, Revision 7, September 1,1988, and FNP-0-RCP-820, Scaling Factor Utilization for Waste Classification, Revision 6 September 15, 1986, described the licensee's waste sampling, classification and characterization program.
The various waste streams that were sampled included:
dry active waste (DAW), resins, mechanical filters, tank l
sludge, steam generator sludge, liquids (prior to solidification), and l
oils.
In addition to the annual vendor analyses, the licensee performed
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key isotopic analyses on DAW quarterly and after each batch for the other waste streams noted above.
The licensee used a vendor-supplied computer program (WASTETRAK) which processed input information obtained from a package of waste to determine the package's waste classification and transportation type.
The program identified non-gamma emitters based on the scaling factors developed by the licensee for the particular waste stream from which the waste was i
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The program accounted for the generation of daughter products I
and calculated the activity contents as a function of time.
No violations or deviations were identified.
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Information Notices (92701)
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The inspectors 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
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scheduled:
Prompt Reporting to NRC of Significant Incidents Involving Radioactive Material IN 88-34: Nuclear Material Control and Accountability of Non-Fuel Special Nuclear Material at Power Reactors IN 88-63: High Radiation Hazards from Irradiated Incore Detectors and Cables IN 88-101:
Shipment of Contaminated Equipment Between Nuclear Power Stations 9.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)
at the. conclusion of the inspection on April 14, 1989.
The inspectors summarized the scope and findings of the inspection, including the IFI.
Additionally, licensee management made
- .a oral commitment to install an appropriate barricade around the non-regenerative heat exchanger area in both Units 1 and 2 containment during the next refueling outage.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors 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 Description and Reference 50-348, 364/89-08-01 IFI - Review licensee's actions on barricading and locking, if access is required, the non-regenerative heat exchanger area in the Units 1 and 2 containment (Paragraph 2.c).
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