IR 05000348/1990014
| ML20044B125 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/29/1990 |
| From: | Potter J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20044B124 | List: |
| References | |
| 50-348-90-14, 50-364-90-14, NUDOCS 9007170346 | |
| Download: ML20044B125 (10) | |
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WUCLEAR REGULATORY COMMISslON i
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101 MARIETT A STRE ET. N.W.
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Report Nos.: 50-348/90-14 and 50-364/90-14
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QJ Licensee: Alabama Power Company
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600 North 18th Street
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. Docket'Nos.:
50-348 and 50-364 License Hos.:' NPF-2 and NPF-8
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F cility Name:
Farley 1 and 2 l
Inspection Conducted:
June 11-15, 1990
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Inspector:
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Approved by:
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Facilities Radiation Protection Section Emergency Presaredness and Radiological
Protection 3 ranch
Division of Radiction Safety and Safeguards j
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SUMMARY
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This routine, unannounced inspection of radiation protection program activities
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included reviews of organization and nanagement controls, audits and corrective r
- action, internal and external occupational. radiation exposure, radiological i
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surveys and control of radioactive material, as low as reasonably achievable J
(ALARA) program, training and qualifications, and licensee action on previous
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inspection findings.
y Results:
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L, The licensee's' radiation protection staff appears to be generally effective in
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. protecting the health and' safety of the occupational radiation workers.
-Management support for the radiological protection program was evidenced by l
management's approval for additional radiation protection staff positions, staff position upgrades, and acquisition of a. modern personnel dosimetry -
monitoring system with real time dose monitoring and access contrcl functions.
' Within the scope of the review, no violations or oeviations were identified.
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9007170346 900702 PDR ADOCK 05000348
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REPORT DETAILS
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Persons Contacted
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Licensee Employees L
- S. Fulmer, Supervisor, Safety Audit and Engineering Review l:
- D. Graves, Health Physics Sector Supervisor
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- N. Maddox, SenicP Plant Instructor, Technical Training F
- M. Mitchell, Radioactive Waste Health Physics' Supervisor
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- D. Morey, General Plant Manager
- C, Nesbitt, Technical Manager
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P. Patton, Plant Health Physicist Other licensee employees contacted during this inspection included technicians and administrative personnel.
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NuclearRegulatoryCommission(NRC)
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- G. Maxwell, Senior Resident Inspector
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- Attended exit interview held June 15, 1990 2.
Occupational Exposure (83750)
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a.
Organization and Management Controls
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The inspector reviewed the licensee's organization and staffing of the in-plant radiation protection organization. The review was made g
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with respect to Technical Specification (TS) 6.2.
The inspector evaluated the licensee's performance in the area by discussing the organization and staffing levels with cognizant -
personnel and reviewing organization charts. The inspector reviewed the following matters:
Changes in the licensee's organization and staffing levels;
. Licensee's routine and outage work planning procc,ses and radiological interfaces in task preparations; and
Licensee's outage organization and management controls for oversight of outage work activities.
The following was noted:
The licensee had recently-approved 10 new radiation protection staff positions in it's 1991 operating budget that included;
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Five Health Physics (HP) Technicians to be assigned to the HP
Supervisor.
Three Nuclear Specialist to be assigned to the Plant Health
Physicist-ALARA, ne Nt Nar Specialist to be assigned to the Radioa:tive Weste
Supers or, and 1 i senior Specialist to be assigned to the Superintendent of
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With the exception of the Senior Specialist and the three ALARA Nuclear Specialists, the licensee planned to fill the positions es
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soon as possible. The licensee planned to fill the remaining positions in 1991.
The licensee also upgraded the Radioactive Waste Supervisor and the Radiation Protection Manager (RPM) positions. The RPM position was upgraded from the HP Su >ervisor to the Superintendent of HP. The Radioactive Waste Superv'sor's title did not change.
During outages, the licensee contracts approximately 65 senior HPs,
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20 junior HPs, and 9 dosimetry technicians to support outage activities. The licensee also brings in approximately 10-15 decontamination personnel to support the HP staff in decontamination, cleanup, shielding, and other activities as needed. The inspector determined that the licentee had budgeted additional HP personnel resources in 1991, to support resistance temperature detector (RTD)
removals on Unit 1.
No violations or deviations were identified, b.
Audits and Corrective Actions The inspector reviewed the licensee's audits of the radiation protection and radioactive waste programs and the licensee's corrective actions for identified problems. The review was made with respect to TS 6.5.2.8 requirements. Audits.
The inspector also reviewed the experience and qualifications of the lead auditor performing the radioactive waste and radiation protection audits.
The inspector evaluated the the licensee's performance in the above
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areas by reviewing documents and by discussing the areas with
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cogni: ant personnel.
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The following was noted:
The licensee was performing audits of the radiation protection and radicactive waste programs in accordance with TS requirements;
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The audit checklists were detailed and addread licensee j
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commitments and requirenents; The' lead auditor for the audits had radiation protection and
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radioactive waste program experience, possessed a degree in
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physics, and was qualified as an auditor in accordance with the
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p requirenents of ANSI N45.2.23-1978, Noncompliances of requirements were documented in the licensee's
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I corrective action tracking system; and Corrective actions for identified' problems in the reviewed
audits appeared to be appropriate and timely.
i No violations or deviations were identified, c.
External Exposure Controls
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The inspector reviewed the licensee's external exposure control
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program.. The review was made with respect to the following L
requirenents:
i 10 CFR 20.101, Radiation Dose Standards for Individuals in
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l Restricted Areas;
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10 CFR 20.201, Surveys; 10 CFR 20.202, Personnel Monitoring;
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10 CFR 20.203, Caution Signs, Labels, Signals, and Controls;
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10 CFR 20.401, Records of Surveys, Radiation Monitoring, and
Disposal;
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- TS 6.8, Procedures and Programs; and
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The following areas were reviewed and discussed with licensee personnel:
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Proposed changes to the licensee's ' personnel radiation dose tracking system; and Control of radiation, high radiation, and exclusion areas.
- Evaluation of the licensee's performance in this area was based on i
observations during plant tours, discussions with licensee personnel, and review of licensee documentation.
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The following was noted:
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During the inspection the licensee authorized the surchase of a real-time access control, personnel dose track'ng, and monitoring system. The system included digital personnel radiation dosimeters and a network of reader stations throughout the facility to collect personnel exposure information stored in the individual dosimeters.
The dosimeters would provide the wearer with continuous indications of personnel radiation-exposure and radiation exposure dose rates. The monitors also had the capability to alert the wearer when exposure or exposure dose rates reached a preset limit.. The readers would transfer the personnel exposure information from the personnel dosimeters to a central computer for personnel exposure tracking and access i
control purposes. The licensee planned to install 21 readers for the dosimeters at radiological control area (RCA) entrances and exits and other areas as needed.
The licensee plans to have the initial system tested and ready for use by October 1990.
The inspector reviewed the licensee's access control procedures
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for accessing radiation, high radiation, and exclusion areas.
The licensee defined a high radiation area as an area where whole body radiation exposure levels exceeded 100 millirem per hour (mrem /hr)andanexclusionareawherewholebodyradiation exposure levels exceed 1,000 mrem /hr. In a previous NRC inspection, a Notice of Violation (NOV) was issued for a licensee identified violation concerning failure to access high radiation and exclusions areas in accordance with licensee TS requirements. The inspector determined that the licensee's corrective actions for the identified violation had been completed. The corrective action included, suspension and retraining for the involved individual and training sessions on high radiation and exclusion area access requirements for the licensee's staff. In addition, the licensee rep (orted thatstop sign)
human-factored postings using a red, octagonal formatforexclusionareasandayellow,trangular(yieldsign)
i for high radiation areas had been designed and ordered. The inspedor observed the use of the new signs and determined that the 'icensee had revised radiation protection general employee traiiiing programs to define their use. The inspector determined that the signs, which were significantly different than the common rectangular warning signs with descriptive hazard inserts, met the requirements of 10 CFR 20,203.
- The inspector determined that selected radiation and high radiation areas inspected and surveyed by the inspector appeared to be properly posted as required by 10 CFR 20.203.
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The inspector reviewed selected radiation work permits and
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determined that the licensee appeared to be using adequate radiation protection controls for reviewed task.
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No violations or deviations were identified, d.
Internal Exposure Control A review of the licensee's respiratory protection program was made w;th rn oect to requirements specified in 10 CFR 20.103(c). Exposure of Individuals to Concentrations of Radioactive Materials in Air in L
Restricted Areas.
The inspector evaluated the licensee's respiratory protection by i
reviewing documents and by discussing the following aspects of the program with cognizant pe sonnel:
Respiratory protection training;
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Respirator fit testing; c
Respirator wearer qualification and verification procedures;
Internal assessment procedures;
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Respirator cleanliness, maintenance, and repairs;
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Breathing air sources and quality for supplied air respirators;
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Respiratory protection program records.
The licensee's respiratory protection program appeared to be generally effective. The licensee collected a nasal smear for radioactivity analysis for every respirator wearer following use.
s Nasal smears having positive radioactive measurements of approximately' 200 disintegrations per minute (dpm) required a investigation and followup bioassays to determine internal exposures.
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The licensee had two positive nasal smear measurements since January 1989, and the bioassays for those two measurements indicated intakes less than 3 percent of the maximum permissible organ burden (MP0B).
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No violations or deviations were identified.
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Control of Radioactive Materials and Contamination, Surveys, and
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Monitoring The inspector reviewed licensee's controls for radioactive
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contamination and surveys. The review was of the following
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requirements:
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10 CFR 20,201, Surveys;
10 CFR 20.105, Permissible Levels of Radiation in Unrestricted Areas; and
10 CFR 20.401, Records of Surveys, Radiation Monit(ving, and Disposal.
- Evaluation of the licensee's performance in this area was based on observations and radiological surveys made durir.g plant tours, discussions with licensee representatives, end review of documentation. The following areas were reviewed and discussed with
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licensee personnel:
Calibration of portable survey instrumentation;
Personnel contamination trends;
Selected radiation and contaminated survey procedures; and
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Radiation, contamination and airborne radioactivity surveys made during the inspection.
The following was noted:
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Reviewed plant procedures, which defined the licensee's i
radiological survey and monitoring program, were consistent with regulations, TSs and good HP practices.
- Reviewed calibration records, for select (.d neutron, gamma, beta,
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portable radioactive survey instruments and air samplers used during the inspection, werc in order. The instruments had been calibrated at frequencies specified by licensee procedures and were adequately documented showing calibration with sources and standards traceable to national standards.
The following perNnnel contamination trends were noted during the inspection:
The licensee documents personnel contaminations at or above r
5,000 dpm/100 cm. The licensee had 105 personnel contaminations in 1989, of which 49 were skin and 56 were clothing contaminations. At the time of the inspection, the licensee had 12 personnel contaminations in 1990, of which I was skin and 11 were clothing contaminations. The licensee's goal for 1990 was less than 65, combined.
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The licensee classifies particles having activities greater than
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25,000 dpm as hot particles and utilizes VARSKIN to calculate l
personnel exposures from them. The licensee had 37 hot particles
in 1989, of which 12 were skin and 27 were clothing
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contaminations. At the time of the inspection the licensee had i
6 hot particles for 1990. All 6 were found on clothing. None of the 1990 hot particle exposures resulted in skin dose
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modifications.
- The licensee has a scheduled refueling outage on Unit 2 during
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the fall of 1990 and personnel contaminations are expected to increase during the outage. At the time the inspection, no adverse trends of personnel contaminations trends were detected.
- During the inspectiot, appoximately 6.6 percent of the
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l licensee's recoverable contaminated floor space (8,765 ftr) was
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contaminated.
The licensee's recoverable area did not include areas having whole body radiation dose rates exceeding 1,000 mrem /hr.
No violations or deviations were identified, f.
Program for Maintaining Exposures As low As Reasonably Achievable
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l 10 CFR 20.1(c) states that persons engaged in activities under
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l licenses issued by the NRC should make every reasonable effort to maintain radiation exposures a 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 a, Nuclear Power Stations will be ALARA, and c
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' Regulatory Guide 8.10, Operating. Philosophy for Maintaining Occupational Radiation Exposures ALARA.
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The inspector :eviewed the licensee's ALARA program policies and
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li procedures, selected records, and discussed the following program areas with licensee personnel:
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'ALARA goals;
ALARA planning and preparation for upcoming outage work;
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Plant ALARA Committe* activities; and
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Status of ALARA dose reduction initiatives.
The following was noted:
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The 1990 collective personnel radiation exposure goal was 374 person-rem. The licensee had one refueling outage scheduled for the Unit 2 end of cycle (E0C) 7 in the fall of 1990. The licensee's estimated exposure for the Unit 2 outage was 283
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person-rem. As of June 10 1990, the licensee's collective personnel exposure was 37.6 person-rem.
- The major expected dose centributor for the Unit 2 refueling outage was steam generator work. The licensee plans to do 100 percent eddy current testing on all steam generators and plug tubes as necessary. The licensee estimated that those activities could result in exposure of 80 person-rem. The licensee was preparing to sleeve tubes if necessary. However, dose estimates for that work were not included in the outage exposure estimate.
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The licensee plans to improve the effectiveness of the plant ALARA program in 1991, with the three newly created ALARA Nuclear-Specialists. During previous outages, the ALARA coordinator utilized selected plant HP technicians to administer and monitor ALARA program objectives. The licensee also plans to improve ALARA work planning with one of the ALARA Specialist working closely with site work planners.
No violations or deviations were identified.
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TrainingandQualifications(83723)
The inspector reviewed the licensee's training policies for vendor HP technicians. The inspector also reviewea the licensee's own program by reviewing documents and by discussing the areas with cognizant personnel.
The following was noted:
Vendor HP technicians were required to pass a written examination of i
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' basic HP principles to demonstrate a working knowledge of the discipline complete " Qualification Records" that demonstrated a working knowledge of licensee policy and procedures.
In a previous inspection, a training program weakness for vendor HPs was identified. Vendor HP technicians, interviewed by the inspector, were unaware of specific industry events related to the activities that they were monitoring. The inspector determined that vendor HP technicians were not receiving training on industry events related to radiation protection problems. The licensee agreed to evaluate the finding and an inspector followup item (IFI) was identified.
During the followup of the IFI, the inspector determined that the lictimee routes incoming radiation protection information concerning industry
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events to the plant HP staff. Vendor HP's were added to the routing j
list when they were on site. The licensee reported that " lessons
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learned," from industry events may not have been presented to vendor HPs as IE Notices or event information, if they were not on site when
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the reviews were made by plant personnel. However, the licensee
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reported that any revisions made to operating procedures addressing
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" lessons' learned" were reviewed by the vendor HPs. The licensee reported that the vendor HPs may not have been aware of the specific industry events that may have caused revisions to licensee policies or procedures.
The inspector. determined that the licensee was e
r creating a rehding file concerning industry events that would be part
of the vendor HP qualification and orientation program. The inspector reported that Ir! 50 346f;;9-28-02 would be closed.
No violations or deviations were identified.
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LicenseeActionsonPreviousInspectionFindings(92701,92702)
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(Closed) Violation, 50-348, 364/89-28-01:
Access G ntrols For High Radiation Areas.
The violation concerned the unauthorized entry of a contract worker
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into a high radiation and exclusion area.
The licensee response dated December 28, 1989, was considered acceptable by Region II. The
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licensee stated that the violation was caused by singular personnel
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error, in that, a worker was inattentive to health physics postings
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on and around a steam generator platform. The licensee's corrective action included suspending the worker, requiring the worker to repeat
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initial radiation worker training, and training sessions for plant workers on entry requirements for high radiation and exclusion areas.
The inspector reviewed the licensee's corrective actions and verified
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that the corrective actions had been completed. Additional program
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enhancements are discussed in Paragraph 2.
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(Closed) IFI. 50-348, 364/89-28-02:
Reviews of Industry Events for Vendor HP Technicians.
The item concerned the_ licensee's training program for vendor HP
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technicians. During a previous inspection the inspector determined
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that the vendor HP technicians were not receiving training on industry events related to radiation protection problems. The inspector determined that the licensee was addressing the program weakness (See Paragraph 3) and reported that the IFI would be closed.
-5. Exit Interview
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The inspection scope and findings were summarized on June 15, 1990, with
those persons indicated in Paragraph 1. The ins 3ector described the areas inspected and reported that the licensee's rad'ation protection program appeared to be effective h protecting the health and safety of the occupational radiation wor m. Dissenting comments were not received from
the licensee. Proprietary fuformation is not contained in this report.
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