IR 05000400/1989029
| ML18009A295 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/28/1989 |
| From: | Potter J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18009A294 | List: |
| References | |
| 50-400-89-29, NUDOCS 8912130401 | |
| Download: ML18009A295 (8) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-400/89-29 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 Conduct d
ctober 30 through November 3, 1989 Inspector: F.. lri t Approved by:
J
. Pot er, C ref Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and SafeguardsI'a e
cygne
/i Da e
i ned SUMMARY Scope:
This unannounced 'nspection of the licensee's radiation protection program included a review of:
organization and management controls; training and qualifications; internal and external exposure controls; and control of radioactive material, contamination, and surveys.
Results:
No programmatic weaknesses were identified in the radiation protection program and no violations or deviations were identified.
In general, the licensee's radiation protection program for outages appears to be effective in protecting the health and safety of the occupational radiation worker.
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REPORT DETAILS Persons Contacted Licensee Employees A. Boone, Radiation Control Foreman, Operations
- J. Brown, Senior Specialist, guality Assurance
- J. Collins, Manager, Operations D. Elkins, Radiation Control foreman, Radioactive Materi J. Floyd, Radiation Control Foreman, Operations
- G. Forehand, Manager, guality Control/guality Assurance
- J. Hammond, Manager, Onsite Nuclear Safety
"C. Hinnant, Plant General Manager
- J. Kiser, Supervisor, Radiation Control
- B. Morgan, Senior Specialist, Radiation Control-ALARA A. Poland, Project Specialist, Radiation Control F. Reck, Radiation Control Foreman, Operations Support
- R. Richey, Manager, Harris Nuclear Project
- J. Sipp, Manager, Environmental and Radiation Control
- D. Tibbitts, Director, Regulatory Compliance
- R. Van Metre, Manager, Technical Services
- M. Wallace, Senior Specialist, Regulatory Compliance al s/Dosimetry Other licensee employees contacted during this inspection included technicians and maintenance personnel.
Nuclear Regulatory Commission N. Shannon, Resident Inspector J. Tedrow, Senior Resident Inspector
- Attended exit interview Organization and Management Controls The inspector reviewed the health physics (HP)
outage organization, staffing levels, and lines of authority as they related to radiation protection program
'requirements.
The licensee appeared to have established adequate controls for monitoring and controlling the outage work.
The licensee had set up two major control points at the primary radiological control area (RCA) entrance.
One for the Containment Building and another for the rest-of the facility.
Each of the control points was manned with senior licensee HP personnel.
The licensee was able to monitor. the scope and activity of work at each control point and assign radiological control resources accordingly.
At the containment access control point, the licensee was utilizing a status board that showed the number of-workers in the containment by job and location.
The board allowed the coordinator, or others, to quickly assess the work
activity in the containment building.
The board also showed the area assignment of HP personnel for containment work coverage.
The status" board appeared to be an effective tool in the management of radiological protection resources.
No violations or deviations were identified.
Training and gualifications During a previous NRC inspection, the inspector determined that licensee procedure ERC-104, Contract EKRC Technician gualification and Training, dated June 1989, did not describe how training and work experience assessments would be made.
The licensee was informed that a vendor HP qualifications and training would be reviewed later as inspector follow-up item (IFI) 89-23-03.
The inspector reviewed the qualifications of selected vendor HP technicians onsite to supplement the plant HP staff.
The qualifications of the personnel reviewed appeared to be adequate to meet license's Technical Specification (TS)
commitments.
The inspector also determined, through interviews with HP foremen and a review of licensee records, that the vendor HP technician's procedural training varied and depended upon work assignment.
The inspector did not identify any problems with the training provided.
However, the licensee's written procedures did not clearly specify or document how the licensee was accomplishing training objectives or assessing vendor qualifications.
The licensee committed to revising the vendor HP training and qualification procedures to better define the qualification assessment process, minimum qualifications for each type of vendor employee, minimum training objectives for HP vendor personnel, and training and qualification record deposition.
The inspector stated that the previously identified IFI would remain open pending a
review of the revised HP vendor training and qualification procedure.
No violations or deviations were identified.
External Exposure Control; Surveys, Personnel Monitoring, and Control of Radioactive Material TS 6.8 through reference to Regulatory Guide 1.33, Revision 2, February 1978; requires written radiation protection procedures for access control to radiation areas including a radiation work permit system, radiation surveys, airborne radioactivity monitoring, contamination control, and personnel monitoring.
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 radioactive hazards that may be present.
The inspector reviewed selected records of radiation and contamination surveys performed during the inspection and discussed the survey results with licensee representatives.
During tours of the plant, the inspector
'
observed HP technicians performing radiation and contamination surveys.
The inspector observed HP personnel providing continuous job coverage throughout the licensee's containment building.
The inspector performed independent radiation and loose surface contamination surveys in the Containment, Auxiliary, and Radwaste Buildings and verified that the areas where properly posted.
CFR 20.203 specifies the posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactivity 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, airborne radioactivity areas, contamination areas, radioactive material areas, and the labeling of radioactive material.
No violations or deviations were identified.
5.
Internal Exposure Control a.
Airborne Radioactive Material Sampling
CFR 20.103(a)
establishes the limits for exposure of individuals to concentrations of radioactive material in air in restricted areas.
This section also requires that suitable measurements of concentrations of radioactive materials in air be performed to detect and evaluate the airborne radioactivity in restricted areas and that appropriate bioassays be performed to detect and assess individual intakes of radioactivity.
The inspector observed HP personnel taking routine and special air samples in support of outage activities.
The inspector reviewed selected results of air samples taken to support work authorized by specific radiation work permits (Rl(Ps).
No violations or deviations were identified.
b.
Process and Engineering Controls 10 CFR 20.103(b)
requires the licensee to use, process, or other engineering controls, to the extent practicable, to limit
.concentrations, of radioactive material in air to levels below that specified in Part 20, Appendix B, Table 1, Column
or limit
.concentrations, when averaged over the number of hours in any week during which individuals are in the area, to less than 25 percent of the specified concentrations.
The use of process and engineering controls to limit airborne radioactivity concentrations within ~ the licensee's containment building was discussed with licensee employees and the use of such controls was observed in the licensee's reactor vessel cavity and on,
The licensee was also utilizing containment enclosures inside the containment building to limit the spread of radioactive material.
No violations or deviations were identified.
Respiratory Protection
CFR 20.103(b)
requires that when it is.impractical to apply process or engineering controls to limit concentrations of radioactive material in air below 25 percent of the concentrations specified in Appendix B, Table 1, Column 1, other precautionary measures should be used to maintain the intake of radioactive material by any individual within seven consecutive days as far below 40 MPC-hours as is reasonably achievable.
The licensee utilizes supplied air respirator hoods as a method to maintain exposures to airborne radioactivity as low as is reasonably achievable (ALARA).
The licensee utilized the instrument air system as the source of breathable air for the supplied air hoods.
On October 30, 1989, in support of a local leak rate test, a licensee employee mistakenly connected instrument air to a vent valve in the letdown system instead of the charging system.
At the time of the event, the plant was in Mode 5, in a partially drained (mid-loop)
condition and the residual heal removal (RHR) system was providing core cooling while crosstied to the chemical volume control system for reactor coolant system (RCS) cleanup.
The letdown system was at a higher pressure than the instrument air system.
Consequently, RCS water was injected into the instrument air system when the vent valve was opened.
The connection allowed about 25 gallons of RCS to enter the instrument air system before the error was detected and vent valve closed.
The investigation on how the error occurred and the.
licensee's actions for system recovery and cleanup was addressed in another NRC report.
When the system became contaminated the,licensee did not have anyone utilizing supplied air respirators.
The site radiation protection staff was immediately notified that the air system'ad become contaminated.
The radiation protection supervisor suspended the use of instrument air for breathing air purposes and ensured all HP personnel were aware of the contamination problem.
A plant wide announcement was made to suspend any use of the instrument air system without HP support.
The licensee began the process of evaluating the extent of the contamination spread.
The contaminated water migrated through portions of the instrument
'ir system in the Containment, Auxiliary, and Radioactive Waste Processing Buildings..
The gross radioactivity measurements from collected samples showed the radioactivity in the range of 10E-2 micro curies per milliliter.
, Contamination of the instrument
air system eliminated it as a source of breathable air.,
When the contamination event occurred, the licensee was just a few hours away from entering the.steam generators for nozzle dam installation.
The steam generator jumpers had rehearsed respirators and needed a source of breathing air.
The licensee considered the use of bottled air in a
cascade system, but determined that such a system would not be
,
sufficient for supplying air to hood respirators.
The licensee also considered the use of tight fitting full face supplied air respirators and attempted a practice steam generator jump with the steam generator mockup.
The full face respirators significantly increase the difficulty and time in the simulated jumps.
The licensee was able to obtain and set up a portable breathing air compressor, two days after the event occurred.
However, the licensee was limited in the number of supplied air respirator connections that could be used with the portable breathing air compressor.
The inspector verified that the licensee sampled the temporary breathing air system for breathing air quality and observed the first use of the temporary system.
The licensee was still reviewing options for sources of breathing air when the inspection ended.
No violations or deviations were identified.
6.
Action on Previous Inspection Findings a ~
b.
(Open)
Violation 50-400/88-28-01:
Radiological Nonitoring for Persons Entering High Radiation Areas.
A previous inspection identified a violation of TS requirements for personnel entering high radiation areas without a HP escort or proper monitoring device to measure radiation dose rates.
In a licensee response dated November 17, 1988, the licensee reported that the Radiation Control Technicians were directed to question persons entering Containment Building to determine if they would be entering the secondary shield wall.
If workers needed to enter a high radiation area they were to be provided with an escort or appropriate
,personnel monitoring equipment.
To prevent recurrence of the violation, the licensee's November 17, 1988 response reported that during future outages, a similar positive control method would be utilized.
While this procedure was observed during the inspection, the inspector determined that the licensee had not documented the new policy in their written procedures.
The inspector reported to licensee management, that the licensee's'olicy should be specified in their directive documentation system.
Licensee management agreed to make procedure revisions as necessary.
The licensee did not specify a corrective action completion date at the exit meeting.
(Open)
IFI 50-400/89-23-02:
Vendor HP Technician Training and gualifications.
A previous inspection identified a lack of guidance in the licensee's procedures for verifying vendor HP qualifications and training
requirements.
The inspector made a review of vendor HP qualification and training records as an IFI.
The inspector reviewed the qualification and training records for selected vendor HP technicians and determined that they met the qualification requirements specified in the licensee's TS.
Licensee representatives committed to revising existing HP vendor training and qualification procedures to provide additional guidance (Paragraph 3).
The inspector reported to licensee management that the item would remain open pending a.review of the licensee procedures.
The licensee committed to complete the procedure revisions in February 1990.
7.
Exit Interview The inspection scope and results were summarized on November 3, 1989, with those persons indicated in Paragraph 1.
Dissenting comments were not received from the licensee.
Proprietary information is not contained in this report.
No new issues were identified during the inspection.
The inspector discussed the previously identified items, as in Paragraph
above, and the need for additional corrective action in order that the items could be closed.
Licensee management agreed to document existing policies associated with the items, in licensee procedures, so that the open items could be closed.