IR 05000400/1989010
| ML18005A952 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/08/1989 |
| From: | Potter J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005A951 | List: |
| References | |
| 50-400-89-10, NUDOCS 8906280115 | |
| Download: ML18005A952 (8) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 JONL p. 888 Report No.:
50-400/89-10 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris License No.:
NPF-63 Inspection Conducted:
May 22-26,
.1 89
?nspector:
.
~
~
rig Approved by:
J.
P.
tter, Chic Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards 4~S te Sign D t Signed SUMMARY Scope:
This routine, unannounced inspection of the licensee s radiation protection program consisted of a review in the areas of:
. organization and management controls; external and internal exposure control; control of radioactive material and contamination, surveys, and monitoring; and transportation of radioactive material.
The inspection also included a review of licensee actions concerning previous enforcement and inspector follow-up items.
Results:
The licensee has made changes in the health physics organization in order to improve the radiation protection program.
=- Management support of the radiation protection program is evident and appears to be adequate.
The licensee's
'radiation protection program appears to be functioning as necessary to protect the health and safety of the occupational radiation workers.
During the inspection, no weaknesses were noted in the areas of procedural compliance, compliance with Technical Specification requirements, or regulatory compliance.
890b280115 890b12 PDR ADOCK 05000400
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REPORT'DETAILS 1.
Persons Contacted Licensee Employees N. Boone, Radiation Monitoring System Foreman, Radiation Control
- J. Collins, Manager, Operations D. Elkins, Radioactive Waste Foreman, Radiation Control
- J. Floyd, Operations Foreman,'Radiation Control
- G. Forehand, Director, guality Assurance/guality Control
- C. Gibson, Plans and Programs
- J. Hammond, Director, Onsite Nuclear Safety
- A. Howe, Regulatory Compliance J. Kiser, Supervisor, Radiation Control
- B. Morgan, Senior Specialist, ALARA, Radiation Control Other licensee employees contacted during this inspection included engineers, technicians, and administrative personnel.
Nuclear Regulatory Commission W. Bradford, Senior Resident Inspector
- M. Shannon, Resident Inspector u
ll.
- Attended exit interview
,9)t DA 2.
Occupational Exposure Shipping and Transportation Organization and Management Controls (83750)
The inspector reviewed the licensee's organization staffing level and lines of authority as they relate to radiation protection and radioactive material control and verified that the licensee had not made organizational changes which would adversely affect the-..ability of the licensee to control radiation exposures and radioactive material.
The inspector discussed with the radiation protection management the type, methods of, and degree of interaction between plant groups.
--The.inspector attended a daily planning meeting in which planned radiological protection work activities were discussed.
The inspector reviewed licensee procedure Radiation Safety Violations, Revision 3, dated June 1988.
The procedure described the licensee's method for documenting, reviewing, resolving, and tracking violations. of the radiation protection program requirements.
The licensee had less than 40 radiation safety violations (RSVs)
in 1988 and, at the time of inspection, the licensee only had one RSV for 1989.
The licensee's program for identifying compliance problems appeared adequate in structure.
However, the low number of documented program violations was
questioned by the inspector.
The licensee reported that the low dose rates and few contamination problems'at the site had enabled the radiation protection staff to provide a lot of health physics (HP) coverage for most work activities and that the workers had not been allowed to deviate from program requirements.
The iyspector determined that most of the RSVs documented in 1988 occurred during the first refueling when work activity had increased.
The inspector determined that licensee management was aware of the radiation protection program violation and HP work load correlation.
Licensee Audits The inspector discussed the audit and surveillance program with licensee representatives in the areas. of radiation protection and transportation.
The inspector reviewed the following guality Assurance (gA).audit and surveillances:
Audit gAA/0022-88-04, Harris Nuclear Project Environmental and Radiological Control Program, July 1988 Surveillance 88-037, Radwaste Shipping, March 1989 Surveillance 88-071, Radiation Protection-Contamination Control, April 1988 Surveillance 88-77, Radiation Protection-Independent Radiation Survey, May 1988 Surveillance 88-90, Outage Control and Refueling/New Fuel Receipt/Storage, April-June 1988 Surveillance 88-111, Outage Control and Refueling/Refueling Activities, August-October 1988 Surveillance 88-113, Radiation Protection-Dosimetry, May-June 1988 Surveillance 88-182, Waste Management/Radwaste Shipping, Shipment 4-L14-195, June 1989 No violations or deviations were identified.
3.
Occupational Exposure Shipping and Transportion-External Occupational Exposure Control and Personnel Dosimetry (83750)
Technical Specification (TS) 6.11 requires the licensee to have written radiation protection procedures.
The inspector reviewed the following
'plant procedures:
Plant Program Procedure (PPP)-511, Radiation Control and Protection Program, Revision
Administrative Procedure (AP)-503, Entry into Radiological Areas, Revision
Health Physics Procedure (HPP)-020, Radiation Work Permits, Revision
The inspector reviewed selected active radiation work permits (RWPs) for appropriateness of the radiation protection requirements based on work scope, location, and conditions.
CFR 20.203 specifies the posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactive areas and radioactive material.
Additional requirements for control of high radiation areas are contained in TS 6.12.
During tours of the plant, the inspector reviewed the licensee's posting and control of radiation areas, high radiation areas, contaminated areas, radioactive material areas, and the labeling of radioactive material.
The inspector found areas were posted conservatively.
The inspector verified that posted high radiation areas were secured.
CFR 20.202 requires each licensee to supply appropriate personnel monitoring equipment to specific individuals and require the use of such equipment.
During tours of the plant, the inspector observed workers wearing appropriate personnel monitoring devices.
The licensee's dosimetry program is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) in all eight categories through October 1, 1990.
The inspector determined that the licensee was preparing to conduct an extremity thermoluminescent dosimeter (TLD) study in which the doses received on TLD finger rings would be compared to TLDs and ion chambers located on the wrist.
The purpose of the study is to provide a basis for the use of TLD finger rings.
The licensee's highest whole body exposure for the year was 225 millirem (mRem)
and the highest extremity exposure was 134 mRem.
The licensee's As Low As Reasonably Achievable (ALARA) goal for 1989 was 150 person-rem.
The licensee's total person-rem exposure for the facility was approximately 8 person-rem through April 30, 1989.
The licensee's ALARA person-rem goal for the outage was 100 person-rem.
The inspector reviewed selected dosimetry technical reports and the licensee's procedure for calculating and tracking Xexon (Xe)
133 beta dose.
No violations or deviations were identifie.
Occupational Exposure, Shipping and Transportation-Internal Exposure Control and Assessment (83750)
The licensee was required by 10 CFR 20. 103, 20.201(b),
20.401, 20.403, and 20.405 to control intakes of radioactive material, assess such =-intakes and keep records of and make reports of such intakes.
The inspector determined that the licensee had no persons with documented weekly intakes equivalent to those which would result if exposed to concentrations specified in Appendix B, Table 1, Column 1 for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.
The inspector reviewed licensee PPP-510, Respiratory Protection Program, Revision 2.
No violations or deviations were identified.
5.
Occupational Exposure, Shipping and Transportation Control of Radioactive Material, Surveys, and Monitoring (83750)
CFR 20.201(b)
requires each licensee to make or cause to be made such surveys as (1)
may be necessary for the licensee to comply with the regulations, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazard that may be present.
The inspector reviewed selected records of radiation, contamination and airborne radioactive material surveys performed during May 1989, and discussed the survey results with licensee representatives.
The inspector made independent radiation surveys and reviewed the results of radiation and contamination surveys throughout the facility.
The surveys reviewed by the inspector were current, the data was legible and appeared sufficient for assessing the general radiological hazards present.
The inspector reviewed the following licensee procedures:
Environmental and Radiation Control (ERC)
Management Manual-113, Control of Radiological Control Test Equipment, Revision
HPP-030, Control and Release of Equipment/Material from the Radiologically Controlled Area (RCA)/Restricted Area, Revision
HPP-060, Performance of Radiation and Contamination Surveys, Revision
HPP-035, Posting and Barricading of Radiological Areas, Revision 4 HPP-066, Collection and Analysis of Air Samples, Revision
HPP-404, Operation of Condenser R-Meter, Revision
HPP-507, Use and Certification of Neutron Sources, Revision
Survey Instrumentation Gal ibrati on-048, Certification of Gaoma Standards, Revision
The inspector reviewed the calibration records for the licensee's sources and test equipment utilized to calibrate radiation detection and measurement equipment.
The inspector determined that the licensee's radioactive calibration'ources and 'test equipment were being maintained as required by licensee procedures and traceable.to National Bureau of Standards.
No violations or deviations were identified.
6.
Occupational Exposure, Shipping, and Transportation (83750)
CFR 71-.5 requires that licensees who transport licensed material outside the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, 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 through 189.
The inspector reviewed selected records of radioactive waste and radioactive material shipments performed during 1989.
The shipping manifests examined were prepared consistent with 49 CFR requirements.
The radiation and contamination survey results were within the limits specified for the mode of transport and shipment classification.
The inspector observed the preparation and loading of a radioactive waste shipment and made independent radiation surveys to verify that the licensee's transport surveys were adequate.
A representative of the licensee's quality control department observed the loading and verified that the shipment was properly prepared.
No violations or deviations were identified.
7.
Licensee Actions on Previously Identified Inspection Findings (92701, 92702)
a
~
(Open)
50-400/88-28-01:
This item concerned TS 6. 12 requirements for entry into a high radiation area.
The corrective action includes the implementation of licensee controls during outages.
The licensee was reviewing methods to control personnel entries into high radiation areas during outages and had not decided on some program implementation details.
The inspector stated that the licensee's corrective action would be reviewed in a future inspection.
b.
(Open)
Inspection Follow-up Item (IFI) 50-400/88-28-03:
This item concerned the proper wearing of protective clothing in radiological controlled areas.
Due to the limited work activity in contaminated areas during the inspection, the.inspector stated that a larger
sample of licensee protective clothing compliance would be reviewed in a future inspection.
8.
Exit Interview a ~
Inspector Comments The inspection scope and findings were summarized on May 26, 1989, with those persons indicated in paragraph 1.
No new violations, deviations or IFIs were identified.
The inspector reported to management that the attitude of persons inter viewed was positive and that the licensee's staff had been informative, professional, and helpful.
The inspector also pointed out that housekeeping appeared to be good, that the quality assurance audit and surveillances were adequate and that management support of the radiation protection program appeared to be good.
b.
Previously Identified Inspection Findings The inspector discussed the status of previously identified items discussed in Paragraph 6 with licensee management and reported the following:
(1)
NOV 50-400/88-28-01 concerning requirements for entry into high radiation areas would be reviewed during a following inspection.
A portion of the licensee's corrective action is scheduled for implementation during the next refueling outage.
(2)
IFI 50-400/88-28-03 concerning proper wearing of protective clothing.
The inspector stated that additional observed compliance with protective clothing requirements was needed to close the item.
The inspector stated that the licensee's use of protective clothing would be reviewed in future inspection (
ry