IR 05000348/1989028
| ML19332E955 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/27/1989 |
| From: | Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19332E942 | List: |
| References | |
| 50-348-89-28, 50-364-89-28, NUDOCS 8912130194 | |
| Download: ML19332E955 (8) | |
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UNITED STATES -
NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET,N.W '
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ATLANT A, GEORGI A 30323 b
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DEC 011989
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t Report Nos.: 50-348/89-28 and 50-364/89-28-Licensee: Alabama Power Company 600 North 18th Street
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Birmingham, AL 35291-0400-l Docket Nos.:- 50-348, 50-364 License Nos.: NPF-2, NPF-8 Facility Name: ~ Farley 1 and 2 Inspection Conducted:- October 2-6, 1989
/5.MML e,/i7/ff Inspector:
R.-B. Shortridge Date Sighed '
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Accompanying Person e P. Potter Approved by:
// #7 f J. p Potter, Chief.
Date Sigried Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch
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' Division of Radiation Safety and Safeguards
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SUMMARY Scope:
This routine, unannounced inspection of the radiation protection program included a-review of occupational exposure, shipping and transportation, and licensee action on previous inspection findings.
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Results:
In the areas -inspected, an unresolved item was reclassified as an apparent'
violation.
The apparent violation concerned the unauthorized entry of a contract worker into a high radiation area and an exclusion area.
The-inspection also found that contract health physics (HP) technicians were not
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receiving training on industry events related to radiation protection problems.
The licensee agreed to evaluate this finding.
The licensee's radiation protection (RP) program during extended outages appears to be effective in
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protecting the health and safety of the occupational radiation worker.
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REPORT DETAILS i
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Persons Contacted
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Licensee Employees
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- S. Casey, Supervisor, System Performance
- L. Enfinger, Manager, Plant Administration
- P. Farnsworth, Supervisor, Radwaste
- S. Fulmer, Supervisor, Safety Audit and Engineering Review
- R. Hill,' Assistant General Manager, Plant Operations
- M. Mitchell, Plant Supervisor, Health Physics and Radwaste
- D. Morey, General Manager, Plant
' *C. Nesbitt, Manager, Technical
- J. Osterholtz, Manager Operattuns
- R. Rogers Supervisor, Computer Services
- J. Thomas, Manager, Maintenance
- L. Williams, Manager-Training I
Other licensee employees contacted during this inspection included craftsmen, engineers, technicians, and administrative personnel.
Nuclear Regulatory Commission
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- P. Balmain Region II, Project Engineer L
- G. Maxwell, Senior Resident Inspector l
- J. Potter, Chief, Facilities Radiation Protection Section
- Attended exit interview l-2.
Occupational Exposure (83750)
l-The licensee shut the Unit I reactor down on September 22, 1989, for a l
l routine refueling outage scheduled for 46 days.
Significant work planned l-for the end of cycle 9 included Steam Generator Eddy Current Testing.
L Sludge Lancing, Pulse Cleaning, and Reactor Coolant Pump "A" Rotor repair.
L The inspector reviewed the organization, staffing level, and lines of l --
authority as they related to the refueling outage RP program.
The inspector verified that the licensee had not made organizational changes
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which would adversely affect the ability to control occupational radiation l
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Through observations of work in the Auxiliary Building and containment, the inspector determined that the licensee had adequate resources to provide radiological job coverage for -the outage work.
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supplement the licensee's staff for the refueling outage. 90 contract HP technicians were utilized to provide additional outage support.
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External Exposure Control The inspector observed steam generator (S/G) eddy current operations in Unit 1.
HP utilized computer generated time sheets that
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calculated stay times based on radiation levels.in the S/G and on the S/G platform.
To minimize personnel dose, the operation was performed using robotics and video cameras.
During the tour of Unit F
1 containment on October 10, 1989, the inspector performed a survey of radiation, high radiation, and exclusion areas and determined that all areas were properly posted.
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The inspector noted that inside-the containment bio-shield wall on the 105 ft elevation, the entire area was posted as a high radiation area.
Inside this area there were other areas posted as high radiation areas.
Workers entering containment were required to present a containment outage pass to the HP control point prior to starting work.- The pass signifies that the worker has notified HP, prior to entering containment, of the work to be performed, and has received pertinent HP instructions.
When HP at the containment control point receives the pass, the worker is briefed on any.
additional exposure control / ALARA requirements and taken to the jobsite where HP surveys the area and informs the worker of dose rates in the specific area.
If work is' performed in.a high radiation area. HP is required by. Technical Specification (TS) to provide periodic surveillance at a frequency specified by facility HP E
supervision. The inspector observed work in high radiation areas and exclusion areas (very high radiation areas) for a period of two days
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and noted that all workers were using the containment outage passes I
as required, and when questioned,- knew the dose rates in their L
specific work area.
TS 6.12.1 requires that each high radiation area in which the intensity is greater 100 mrem /hr but less than 1,000 mrem /hr shall be controlled by issuance of a radiation work permit (RWP) and be accompanied by one or more of the ' following:
(a) a radiation monitoring device that continuously indicates dose in the area, (b) a
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L radiation monitoring device that continuously integrates dose and alarms at a pre-set point; or (c) a HP technician with a radiation monitoring device that provides positive control over activities in the area and provides surveillance and surveys at a frequency designated by the facility HP supervisor.
TS 6.8.1 requires that written procedures be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33.
Paragraph 7.e. recommends that the licensee have procedures for access to radiation areas. Licensee procedure, FNP-0-M-001, Health Physics Manual, Section 4.1.1.7, requires an individual to know and follow tha requirements of the RWP used to control work.
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i 10 CFR 19.12 requires in part that all individuals working in or frequenting any portion of a restricted area shall be instructed in precautions to minimize exposure, and in the purposes and functions
'of protective devices employed; and shall be instructed in, and instructed to observe, to the extent within the workers control, the applicable provisions of Commission regulations and licenses for the protection'of personnel from exposures to radiation or radioactive materials occurring in such areas.
The extent of these instructions shall be. commernsurate with potential radiological health protection problems in the restricted area.
On October 5,1989, a contract worker was observed on a closed circuit television monitor by a HP technician at the 105 foot-elevation, Unit -1 containment control point, to enter a-high radiation area and and proceed to an exclusion area without-authorization.
The HP technician responded immediately to the exclusion area and found the worker standing on the ladder leading to the "A" S/G platform.
HP took appropriate actions and removed the
. worker from the area. The contract worker was assigned to perform in service inspection weld buffing on the A-loop safety injection piping support.
The HP supervisor briefed the contract workers' foreman that radiation levels at the job site-were 200-500 mrem /hr and that intermittent job coverage would be provided.
When the contract worker completed work on one side of the pipe hanger at SI-R116, he realized that he could not safely cross over to the'other side of the i
pipe. He noticed a temporary ladder that he could use located inside j
of the lower "A" S/G tent.
He descended to the 105 foot elevation
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and proceed to enter the' tent and ascended half way up the ladder.
I The entrance to the tent was posted as a high radiation area, airborne area, respirator required,- contaminated area, hot particle area, and to contact HP for entry.
The temporary ladder leading to l
the S/G platform was posted as an exclusion area on the fourth rung and a flashing red light was attached to the third rung of the ladder.
The workers dose for the entry was determined to be less j
than 5 mrem for the one minute entry.
In a critique of the event, the contract worker stated that he was wearing a respirator and did not see the high radiation area posting, exclusion area posting, or the flashing red light that was posted as l
an ' added precaution to denote an exclusion area (an area where radiation levels are greater than 1,000 mrem /hr at 12-18 inches).
The inspector attended the critique and noted that several problems were discussed that may have contributed to the event. The critique revealed that the foreman discussed the job with HP prior to entry of the worker into containment, but did not relay information on the adjacent high radiation area to worker.
Also, that the worker did not notify HP prior to starting the job. Although this violation of I
high radiation area / exclusion area access requirements and HP
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procedure requirements was identified by the licensee, the inspector noted that similar violations were cited in December 1987 (Inspection
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Report - (IR) No. 50-348. 364/88-02), and May 1989 (IR No. 50-348, 364/89-13).. A review of the exclusion area access requirement l
violation (December 87) showed the following similarities with this
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event.
The workers involved in both events did not sufficiently understand the definition or significance of exclusion areas, and did not _ heed a flashing red light although in each event a worker passed over a flashing red light.
The permanent corrective action taken to I
prevent recurrence of the December 1987 exclusion area violation, in l
part 'was to incorporate specific training on exclusion areas into i
radiation worker training and retraining.
However, the j
training / retraining was not adequate to prevent recurrence.
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Therefore, this event could reasonably be expected to have been
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prevented by the licensee's corrective action and credit for licensee'
q self-identification and correction is not appropriate under
10 CFR Part 2,. Appendix C, section V. G.
Since the investigation and
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corrective actions were _ in progress.on the day the inspector j
completed this inspection, this event was considered an unresolved
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item.
After a review of the licensee's investigation and previous
violations, the -inspector notified the plant HP Supervisor on
October 11, 1989, by telephone, that the failure of a contact worker to understand and comply with high radiation / exclusion area l
requirements was an apparent violation of 10 CFR 19.12 and TS 6.12.1
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(50-348,364/89-28-01).
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Training
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The inspector observed HP technician time keeping and monitoring of l'
S/G work and inquired if they were aware of any industry events that related to inadequate radiological controls of S/G work. -None of the j
technicians (approximately 5-7) were aware of any industry events
regarding S/G HP coverage.
The inspector investigated further and
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found that HP safety meetings and training - included problems concerning inadequate radiological protection of-workers in the l
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In discussions with the plant HP Supervisor and HP
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l Training Supervisor, the inspector was informed that the licensee's
l training program did not include training for contractor HP technicians in this area and that some industry events and Information Notices (ins) were not routed for training for inclusion into the training program in a timely manner.
A licensee representative stated that these items would be evaluated for inclusion into training.
The inclusion of contractor HP technicians in training for industry (events would be tracked by the NRC as an Inspector Followou Item IFI) and would oe reviewed in subsequent inspections (50-348/89-28-02).
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Control of Radioactive Material During tours of Unit I containment and the Auxiliary Building, the inspector performed radiation and contamination surveys.
Surveys were also performed for radioactive material outside the radiological
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controlled area (RCA) of the plant.
No discrepancies were noted
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The inspector reviewed station RP goals for 1989.
The collective dose through September was 410 person-rem. This is 56 percent of the station goal of 772 ' person rem. The station's goal for Radiological-Incident Reports (RIRs) is less than 200 with the number of RIRs at.
122 through September.
In 1988, the licensee recorded 127 personnel contamination events (PCEs).
Through September 1989, the licensee has recorded 122 PCEs with the goal of less than 200 PCEs. The goal for' contaminated square feet (f tr) at the station is less than 10 percent of the total RCA of 132, 000 ft2 At the end of September 1989, the licensee reported approximately 13,000 fte or 10 percent of
the RCA was contaminated.
Licensee representatives stated that they expected to meet _ the 1989 goals in spite of having two refueling outages and one unscheduled mini outage in one year.
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Facilities The licensee recently completed facility modifications to the HP offices and control point egress from the RCA.
The modification involved the addition of a counting room in the immediate area of the
HP office and HP briefing room.
Four PCM-IBs have been relocated to
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the side of the HP office, that enhance monitoring of people exiting
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the area.
The modification has resulted in a better defined RCA
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boundary and better facilitates the movement of personnel ~through the area.
One violation and no deviations were identified.
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Shipping and Transportation of Radioactive Materials j
'10 CFR 71.5 requires that each licensee who transports licensed material
outside the confines of its plant or other place of use, or who delivers i
licensed material to a carrier for transport, shall comply with the i
applicable requirements of the regulations appropriate to the mode of
transport of the Department of Transportation (DOT) in 49 CFR Parts 170 j
through 189.
I The inspector observed two shipments of radioactive material during the inspection, a Reactor Coolant Pump -Rotor assembly and shipment of drums containino radioactive waste.
The inspector performed independent l
radiation surveys and verified that the radiation levels were within the
limits specified in 49 CFR.
The inspector reviewed the appropriate
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records for these shipments and discussed the shipments with licensee representatives.
The inspector determined by review that the procedures were adequate and verified that the procedures were consistent with
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regulations.
No violations or deviations were identified.
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ActiononPreviousInspectianf*ndings(92701)
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(Closed) VIO 50-348/B'J-13-01 and 50-364/89-13-01.
This violation invc'aved two separate, independent actions, where byproduct material
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was attached te United States currency by HP and waste and decon (W&D/ technicians to catch an alleged thief.
This use byproduct
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material was not authorized by any Farley licenses.
To correct this problem and to prevent future recurrence, the licensee's management conducted meetings with all HP and W&D
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i personnel emphasizing that the unauthorized use of byproduct material r
will not be tolerated.
S m tements were added to the Health Physics j
manual and training material precluding the unauthorized use of byproduct material.
The event was also added to general employee
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training and retraining. This item is closed.
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(Closed)VIO 50-348/89-13-02 and 50-364/89-13-01.
The violation occurred when a NRC resident inspector observed a worker entering an area posted as high radiation area without a
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required digital alarming dosimeter or a HP technician with a dose rate instrument.
This violation resulted from inadequate communication between operations and HP.
To prevent recurrences, a log was established by HP that utilizes and maintains a record of any authorized deviations i
from RWP requirements. This item is closed.
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(Closed) IFI 50-348/89-08-01.
This followup item was to review
licensee actions on providing a lockable barrier for the exclusion area around the Unit 1. Regenerative Heat Exchanger (RHX).
During the inspection, the inspector observed that the licensee had
erected a fence around the Unit 1 RHX and that the exclusion area was l
locked.
The licensee stated that a roof or top to the enclosure was
determined not to be needed. The inspector surveyed the barrier and found it properly posted. This item is closed.
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Exit Interviews l
l The inspection scope and findings were summarized on October 6. 1989. with those person indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below.
The licensee did not identify any of the materials provided to, or
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reviewed by, the inspector during the inspection proprietary.
The licensee was informed of the status of the items discussed in Paragraph 4.
i Item Number Description and Reference
50-348,364/89-28-01 VIO - A contract worker entered a high radiation area and exclusion area without HP authorization and without meetin TS requirements (Paragraph 2.c) g 50-348/89-28-02 IFI - Contractor HP technicians are not included in training on industry events regarding radiation protection problems (Paragraph 2.b)
The inspector notified M. Mitchell, Plant HP Supervisor, by telephone on October 11, 1989, that the unresolved item regarding the contract worker entering the high radiation area and exclusion area was considered a apparent violation of NRC regulatory requirements.
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