IR 05000348/1993023
| ML20059K826 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/10/1993 |
| From: | Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059K789 | List: |
| References | |
| 50-348-93-23, 50-364-93-23, NUDOCS 9311160210 | |
| Download: ML20059K826 (8) | |
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o UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET, N.W., SUITE 2930
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Report Nos.: 50-348/93-23 and 50-364/93-23 Licensee:
Southern Nuclear Operating Company, Inc.
600 North 18th Street Birmingham, AL 35291-0400 DocLet Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility Name:
Farley 1 and 2 i
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Inspection Conducted: October 12-15 1993
_ //!/o 73 Inspector:
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R. B. Shortr'idge~ ~
d-Da(e Sign ~ed
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Approved by: [ d? [4)
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W. H. Rankin, Chief /
Da/eSigned Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection was conducted in the area' of occupational radiation exposure.
Specific areas examined included: organization and management controls, audits and appraisals, external exposure control, internal exposure control, control of radioactive material' and contamination,
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surveys and monitoring, and maintaining occupational exposures As low As
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Reasonably Achievable (ALARA).
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Results:
The Radiation Protection (RP) technician staff appeared knowledgeable and well
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trained. The licensee continued to implement effective internal and external
exposure programs with all exposures less than 10 CFR Part 20 limits.
t Contamination control and overall housekeeping practices were also considered
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adequate.
Licensee efforts in the performance of ALARA initiatives was
determined by the inspector to be a program strength in meeting ALARA goals.
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In the areas inspected, no violations were identified.
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9311160210 931110 PDR ADOCK 05000348 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- W. Bayne, Supervisor, Safety Audit Engineering and Review (SAER)
- G. Bouler, Health Physics Foreman
- C. Buck, Technical Manager D. Griffin, Shift Supervisor, Health Physics P. Harlos, SAER, Auditor
- R. Hill, General Plant Manager
- M. Mitchell, Superintendent, Health Physics
- R. Livingston, Engineering Supervisor
- M. Stinson, Assistant General Plant Manager J. Walden, Operations Supervisor, Health Physics Other licensee employees contacted during this inspection included-craftsmen, engineers, operators, mechanics, recurity force members, technicians, and administrative personnel.
Nuclear Regulatory Commission
- M. Morgan, Resident Inspector
- Attended exit interview 2.
Organization and Management Controls (83729)
Technical Specification (TS) 6.2.1 details, in part, the establishment of onsite and offsite organizations for unit operation and requires that the lines of authority, responsibility, and communication be established and defined for the highest levels through intermediate levels to and including all operating organization positions.
The inspector reviewed changes made to the licensee's RP organization since the last NRC inspection of this area during July 12-16, 1993, and documented in Inspection Report No. 50-348,364/93-16. Cognizant licensee representatives stated that the overall reporting chain and management structure for the RP program has remained unchanged.
The health physics (HP) staff consist of approximately 46 personnel.
The inspector discussed with licensee representatives the planned staffing for the Unit 2 Refueling Outage - 9 (U2RFO-9) scheduled that began on September 24, 1993.
Licensee representatives stated that approximately 24 junior and 70 senior contractor technicians were brought in to supplement the plant organization during the outage.
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Based on discussions with licensee representatives and observctions of activities in progress, no concerns were identified regarding the assignment of contract personnel or the licensee's organizatien and
staffing which appeared adequate to support ongoing activities.
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No violations or deviations were identified.
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Audits and Appraisals (83729)
l TS 6.5.2.8 requires audits of facility activities to be conducted under i
the fianager, Safety Audit and Engineering Review (SAER) encompassing the
conformance of facility operation to the provisions contained within the
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TS and applicable license conditions at least once per 12 months.
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The inspector reviewed the most recent comprehensive audit of the RP program conducted June 7 through July 22, 1993. Audit SAER-WP-02, Radiological Controls, fulfilled the TS required fret,uency for such audits.
Based on : review of the licensee audits and the associated checklists used by SAER to evaluate the RP Program, the inspector
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determined that the audits were detailed and were sufficient in scope to include the major radiation protection functional areas. No issues similar to the current inspection findings were noted.
Non-compliances as well as areas for improvement (i.e., " comments" in the audit reports)
were documented, reported to licensee management, and tracked for
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completion of corrective actions. The inspectors noted that actions on selected deficient areas were both appropriate and timely.
No violations or deviations were identified.
4.
External Exposure Control (83729)
10 CFR 20.101 requires that no licensee shall possess, use, or transfer i
licensed material in such a manner as to cause any individual in a
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restricted area to receive in any period of one calendar quarter a total occupational dose in excess of 1.25 rem to the whole body, head and trunk, active blood forming organs, lens of the eyes, or gonads;
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18.75 rem to the hands and forearms, feet and ankles; and 7.5 rem to the skin of the whole body.
10 CFR 20.202(a) requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such
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i equipment.
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During tours of the plant, the inspector observed personnel wearing appropriate monitoring devices on the location of the body as specified
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by procedures.
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No violations or deviations were identified.
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Internal Exposure Control (83729)
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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
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and airborne radioactivity area as defined in 10 CFR 20.203(d)(1)(ii).
l The inspector noted that the licensee continues to use effective i
engineering controls and to minimize the use of respiratory equipment.
The inspector observed that the number of facial contaminations (FCs)
appeared excessive in that the licensee reported five FCs on the lith outage day, four FCs on the 15th outage day.
In all, the inspector noted since the start of the outage the_ licensee had 16 personnel
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contamination events (PCEs). Ten of the 15 were NSSS vendor personnel.
Of the nine facial contaminations the licensee indicated that they were the result of reducing respiratory requirements for S/G work. The inspector noted that face shields and/or surgical mask worn in place of respirators also contributed to the facial contaminations. Workers inadvertantly adjusted the items and subsequently became contamination on the face. The inspector interviewed the Radiation Protection Manager (RPM) and NSSS vendor site supervisor and found that the licensee was working with the vendor, but the vendor had not implemented their ALARA program which may have had a positive effect on reducing facial PCEs.
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The licensee and vendor met and both agreed on proposed corrective actions to reduce the trend in facial contaminations. The inspector learned that for jobs where respirators previously were worn for the same amount of time on the job, a savings 33 percent in external exposure was realized by not wearing the respirator.
No internal
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contaminations were reported on any of the nine FCs.
No violations or deviations were identified.
6.
Control of Radioactive Material and Contamination, Surveys and Monitoring (83729)
The licensee is required by 10 CFR 20.201(b), 20.401, and 20.403 to
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perform surveys and to maintain records of such surveys necessary to show compliance with regulatory limits.
j The inspector reviewed licensee contamination surveys and performed contamination surveys to verify the licensee results. No discrepancies i
were identified. During tours, the inspector noted that all radiation protection instrumentation was within current calibration except for a high volume air sampler described in Paragraph c.
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Posting and Labeling i
During tours of the Unit 2 Containment, Auxiliary Building, Radwaste Building, and selected outside radioactive material storage areas, the inspector noted that radioactive material areas were appropriately posted and containers labeled in accordance with licensee procedures.
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b.
TS 6.12.1 required, in part,_that each High Radiation Area (HRA)
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with radiation levels greater than or equal to 100 mrem /hr but
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less than or equal to 1000 mrem /hr be barricaded and conspicuously posted as a HRA.
In addition, any individual or group of _
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individuals permitted to enter such areas are to be provided with
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or accompanied by a radiation monitoring device which continuously
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indicates the radiation dose rate in the area or a radiation
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monitoring device which continuously integrates the dose rate in the area, or an individual qualified in radiation protection
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procedures with a radiation dose rate monitoring device.
During tours of the Auxiliary Building and the Radwaste Building, i
the inspector noted that all HRAs and locked HRAs were locked and/or posted, as required. The inspector performed indeoendent
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radiation surveys at the boundaries of selected HRAs and locked HRAs verifying licensee survey results. The licensee's posting of
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the affected areas was conservative and appropriate.
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No violations or deviations were identified.
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c.
Radiation Detection and Survey Instrumentation
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During facility tours, the inspector noted that survey I
instrumentation and continuous air monitors in use within the
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radioloigically controlled area (RCA) were operable and displayed current calibration stickers with one exception. ~ The inspector
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found a high volume air sampler attached to a grating guard rail
on the 129 foot elevation of the Unit 2 containment that went out
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of calibration on March 2, 1903.
The inspector notified the i
roving health physics technician (HPT) of the discrepancy and the HPT immediately took the air sampler out of service.
The licensee reviewed air sample records and found that this particular instrument had been used seven times in a three day period, by five different HPTs.
In performing calibration on the instrument the as found data was within the calibration tolerances and needed no adjustments. The licensee determined that the instrument was removed from the instrument impound locker by
mistake a week before the discovery and that improving
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communication with the HP staff would be the corrective actions to i
preclude recurrence.
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The inspector further noted an adequate number of survey instruments were available for use, and background radiation levels at personnel survey locatiors were observed to be *.in the licensee's procedural limits.
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During facility tours, the inspector independently verified
radiation and/or contamination levels in selected areas of the i
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l Material Storage Areas.
- I The inspector reviewed the licensee's program to control contamination at its source. The inspector noted that 7.25 percent of RCA or 10,049 square feet (ft ) of the 137,663 fta
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total RCA is contaminated [this figure is unadjusted). The licensee experienced a total of 54 PCEs through October 14, 1993.
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The licensee has determined that approximately 7,359 square. feet of contaminated floor space in the RCA is not feasible from a dose savings stand point to decontaminate.
No violations or deviations were identified.
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Maintaining Occupational Exposures As low As Reasonable Achievable
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(ALARA) (83729)
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10 CFR 20.l(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain
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radiation exposures as low as reasonably achievable.
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Regulatory Guedes 8.8 and 8.10 provide information relevant to attaining goals and objectives for planning and cperating light water reactors and
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provide general philosophy acceptable to the NRC as a necessary basis for a program of maintaining occupacional exposures as low as reasonably achievable (ALARA).
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ALARA Initiatives The inspector reviewed and discussed with cognizant licensee representatives ALARA program implementation-and initiatives for U2RF0-9 and operations during non-outage periods. The licensee-has formulated an Exposure Reduction Plan by which FNP plans to
achieve their projected exposure goals through 1997. Some of j
these efforts specific to this outage included:
(1) increased use
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of temporary shielding based on engineering analyses; (2)
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increased use of video such as cameras and expanding the surrogate tour and including Unit 2 for briefing personnel; (3) improved teledosimetry and computer tracking usage to better monitor individual doses during specific high dose evolutica, (4) ordering
and scheduling replacement of valves containing stellite with non-stellite valves to reduce the cobalt source term in the plant; (5) chemical decontaminations of isolated systems; (6) use of
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water shields; (7) increased use of robotics-such as mini
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submarines used in pools and reactor vessels during inspections; l
(8) improved soft chemical shutdown procedures; (9) sub-micron
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filtration; (10) replacement of fuel bundles with inconnel fuel
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spacers rather than materials containing cobalt; (11) improved plant chemistry including elevated ph with Boron / Lithium
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Management, and (12) Nickel / Cobalt removal during plant startup.
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Other ALARA initiatives are being implemented or evaluated by the licensee for future use. The' licensee is actively pursuing the use of Zinc Injection during operation to reduce source term activity in the reactor plant piping. The licensee is evaluating
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installing the nozzle ports for the Zinc Injection during the next i
Refueling Outage.
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i The inspector reviewed selected ALARA Committee Meeting minutes l
held by the licensee to discuss performance indicators year to date, ALARA suggestions, assignment of action items, and completion of action items.
The inspector also reviewed ALARA
Committee Meeting attendance rosters and verified management involvement in the overall ALARA process. The inspector. discussed
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with cognizant licensee representatives FNP plans to improve ALARA
training and implement programs to increase ALARA awareness among workers.
In general, based on the above, the inspector found ALARA
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initiatives to be a program strength in support of ongoing operations and future dose reductions, particularly during outages.
b.
Collective HP Dose The inspector evaluated the Group Radiation Exposure i
Trending Report for collective station dose and noted that
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HP dose appeared high.
In comparison with Mechanical Maintenance, Operations, Modifications, and Systems Performance with respective person-rem of 14.6 (MM),
8.3 (OPS), 23.2 (PM), 31.3 (SP), HP with 19.5 appeared high.
Especially since all collective dose for waste and decontamination (14.6 person-rem) was not included in the HP
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number. The inspector discussed this with HP Management'who
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stated that they will review the observation and look for additional ways to minimize collective dose to the
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technicians. The in:pector noted during observation of in-plant HP operations that digital alarming dosimeters were in i
use but the utility had limited resources for closed circuit i
television and telemetric dosimetry.
Increased use of both-I were discussed as a remedy to the high HP collective dose l
currently occurring.
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c.
Steam Generator (SG) Bowl Washing
The inspector discussed one of the licensee's ALARA initiatives S/G bowl washing with ALARA personnel. The licensee stated that initially they expected a decrease in S/G bowl dose rates of between 10 and 15 percent. However, slightly less reduction was achieved.
In some areas dose
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rates increased. During the operation that was performed j
with a high pressure lance (pressure on the order of I
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9,000 psig) the Nuclear Steam Supply System (NSSS) vendor lost a hose fitting in the "B" intermediate loop area. The foreign material could not be located in the S/G bowl so the licensee drained the loop, cut out a 2-inch diameter ' valve in the intermediate loop and, performed retrieval successfully. The licensee estimated that one person-rem had been lost unnecessarily, but the valve had not been replaced yet. Dose rates in the area of the intermediate loop increased from 150 millirem per hour (mrem /hr) to 450 mrem /hr during the retrieval operation.
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Collective Dose The licensee's collective dose goal for the outage was adjusted downward and established at 250 person-rem. On day 13 of the scheduled 54 day outage the actual collective dose expended was 82 person-rem versus the87 person-rem projected for this point in the outage.
Also, 136.901 person-rem had been expended toward the annual ' goal of 337 person-rem.
No violations or deviations were identified.
8.
Review of Previously Identified Inspection Findings (92702)
(Closed) IFI 50-348/93-16-02: Review procedural changes to clarify requirements for taping vacuum cleaner nozzles and hoses.
During the inspection, the inspector observed that all vacuum cleaners used for radiological operations had contained nozzles and hoses.
Farley Nuclear Plant Procedure 0-RCP-843, Operation of the HAK0 Minuteman Vacuum Cleaner, Revision 1, dated October 8, 1993, was changed to require the containment of nozzles.
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Exit Meeting (83729)
At the conclusion of the inspection on October 15, 1993, an exit meeting _
was held with those licensee representatives indicated in Paragraph 1 of this report.
The inspector summarized the scope and findings of the inspection.
No violations, deviations, or weaknesses were identified.
The licensee did not indicate any of the information provided to the inspectors during the inspection as proprietary in nature. The inspector informed the liccnsee that IFI 93-16-02 had been reviewed by the inspector and closed.
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