IR 05000400/1992009
| ML18010A680 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/30/1992 |
| From: | Boland A, Bryan Parker, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18010A679 | List: |
| References | |
| 50-400-92-09, 50-400-92-9, NUDOCS 9207140125 | |
| Download: ML18010A680 (32) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 JUL O2 1992 Report No.:
50-400/92-09 Licensee:
Carolina Power and Light Company P. 0.
Box 1551
.
Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Shearon Harris License No.:
NPF-63 Inspection Conducted:
June 1-5, 1992 Inspectors:
A. T.
o nd D te Signed B. A.
r
& sa 9'z D te Signed Approved by:
D t S3.gned J
.
o t
,
Ch3.ef acilitie Radiation Protection Section Radiolog'l Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection of the licensee's radiation control (RC) program involved review of health physics (HP)
activities including program organization and staffing, self-assessment programs, internal and external exposure monitoring and assessments, radioactive material and contamination controls, operational controls, and ALARA program implementation.
In addition, actions related to previously identified open and enforcement items and receipt of selected Information Notices (INs) were reviewed.
Results:
The recent RC group organizational changes did not appear to adversely impact overall program implementation, and the level of RC staffing was adequate to support routine plant activities.
The licensee's internal and external exposure control programs were effective with all exposures within 10 CFR Part 20 limits.
Identified program strengths included contamination control and 9207l40i25
'920702 PDR ADOCK 05000400
overall housekeeping practices, the Radiation Monitoring System (RMS), and the technician continuing training program.
A weakness associated with the adequacy of leak testing for certain sealed sources was identified.
Overall, the licensee's RC program functioned adequately to protect, the health and safety of-plant workers.
The following.non-cited violation (NCV) was identified.
Licensee-identified violation for the failure to perform adequate leak testing of Fe-55 sealed sources used in alloy analyzers.
NCV of Technical Specifications (TSs) 4.7.9.1 and 2 with licensee corrective actions completed prior to the end of the onsite inspectio REPORT DETAILS Persons Contacted Licensee Employees M. Boone, Radiation Control Supervisor S. Brown, Health Physicist D. Cornett, Radiation Control Supervisor
- J. Cribb, Manager, Quality Control
- J. Floyd, Senior Specialist, AIdQ&
- C. Gibson, Manager, Program and Procedure
- C. Hinnant, General Manager
- Harris Plant J. Kiser, Manager, Radiation Control Operations
- S. Mabe, Project Engineer, Nuclear Assessment
- J. McKay, Manager, Engineering/Technical Support
- Project Assessment
- B. Meyer, Manager, Environmental and Radiation Control (E~RC)
- J. Morris, Manager, Instrument and Control/Electrical Maintenance
- J. Moyer, Manager, Project Assessment
- J. Nevill, Manager, Technical Support
- C. Olexik, Manager, Regulatory Compliance A. Poland, Manager, E&RC Support
- A. Powell, Manager, Harris Training
- F. Reck, Supervisor, Radiation Control
- G. Simmons, Specialist, Technical Training R. Thompson, Dosimetry Supervisor
- D. Tibbits, Manager, Shift Operations
- *L. Woods, Manager, System Engineering Other licensee employees contacted included engineers, technicians, and office personnel.
Nuclear Regulatory Commission
- M. Shannon, Resident Inspector
- Attended June 5,
1992, Exit Meeting Organization and Staffing (83750)
The inspector reviewed and discussed with licensee representatives changes made to the health physics organization since the last inspection of this area
'conducted May 6-10, 1991, and documented in Inspection Report (IR) -50-400/91-10.
Cognizant licensee personnel stated the structure of the Environmental and Radiation Control (ETC) group had been'changed to add the position of Manager, Environmental and Chemistry (E&C), who reported to the Manager, EERC.
Under the new organization, the two EEC Supervisors reported to the Manager, EEC rather than directly to the Manager, E&RC.
In addition, the Technical,
-Supervisors reported to the Manager, E&C rather than directly to the Manager, ESRC.
In addition, the Technical, Procedural, and Administrative Support group for ERC was separated from RC and was responsible to the Manager, ESC.
The inspector was also informed that recent changes to the RC group had been implemented; however, the changes were primarily related to staf f reassignments.
Several changes were made in technician and specialist assignments and a new ALARA Specialist (former Supervisor, Operations)
and Supervisor, RC Operations (former HP Specialist)
were designated.
The inspector noted that the changes resulted in the loss of a staff member in the ALARA group who was transferred to RC Operations.
However, the inspector was informed that this individual continues to provide an ALARA outage planning function within the Operations group.
In addition, the responsibility for all Fuel Handling Building HP activities was centralized into one group.
The inspector.
noted that personnel were adequately.transitioning into their new positions and were provided adequate turnover support.
Current Harris RC staffing included approximately
technicians allocated to the RC organization.
At the time of the onsite inspection, the inspector was informed that one technician position was vacant.
Licensee representatives stated that no permanent contractor technicians were maintained on staff to support routine activities; however, two such technicians had been hired to replace two staff technicians who were reassigned to a-.
procedural development project for the revised
CFR Part 20.
All of the other supervisory and staff positions allocated tc the RC group were filled.
Overall, the inspector did not note any concerns regarding the RC organization and staffing.
The staffing appeared stable, and the personnel and organizational changes did not appear to adversely impact the conduct of routine RC activities.
No violations or deviations were identified.
Radiation Protection Training (83750)
CFR 19.12 requires, in part, that the licensee instruct all individuals working in or frequenting any portion of a restricted area in the health protection aspects associated with exposure to radioactive material or radiation; in precautions or procedures to minimize exposure; in the purpose and function of protection devices employed; in the applicable provisions of the Commission regulations; in the
individual's responsibilities; and in the availability of radiation exposure data.
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Contract Technician Training Licensee Procedure ERC-104, Contract EERC Personnel Qualifications and Training, Revision (Rev.)
3, describes the requirements for verifying and documenting the qualifications and training of contract personnel with radiation control responsibilities.
The inspector discussed with licensee representatives=
the process for qualifying and training contract RC technicians for the job functions they were expected to perform.
The licensee had established minimum work experience and educational requirements for each classification of RC contractor.
The program provided for formalized resume review and verification by an EERC evaluator as well as completion of required procedural review and demonstrated knowledge of required qualification tasks.
The inspector noted that proper performance of surveys was required to be directly observed by an ETC evaluator.
In addition, long term or returning contract technicians were required to requalify on tasks every two years'he inspector reviewed the resumes for the two contract RC technicians employed onsite at the time of the inspection and verified compliance with ANSI 3.1, 1981 requirements.
Review of training documentation for these contractors verified successful completion of the required reading and applicable qualification tasks.
The licensee's program for RC contract technician training and qualification was considered adequate with no concerns no'ted.
/
No violations or deviations were identified.
b.
Technician Continuing Training Training Instruction 114, dated August 1985, outlines the licensee's program for continuing training.
The inspector noted that the program was designed to provide training on procedural changes, plant modifications, industry events, and other health physics related topics.
An exam grade of 80 percent was required to demonstrate an understanding of the material presented.
Training personnel stated that they were informed of potential topics through the licensee's Dissemination of Information Program as well as recommendations directly from the RC staff.
The inspector was informed that continuing training was conducted on a quarterly basis, with the exception of outage periods, with attendance being required for all technicians and first -line supervisors.
Review of 1991 and 1992 c'ourse documentation noted that the training included such topics as industry events, NRC Information Notices, recent enforcement actions, industrial safety, Emergency Plan implementation, new instrumentation, procedure revisions, and plant systems overviews.
Examples of the systems addressed in training were the residual heat removal system, containment sprays, and incore/excore detectors.
In addition, the inspector noted that several field/hands-on training sessions had also been provided on field monitoring and SCBA use.
Overall, the inspector found the continuing training program to be comprehensive.
The inspector was also informed that 13 of the licensee's technicians had received certification from the National Registry for Radiation Protection Technologists.
No violations or deviations were identified.
4.
Self-Assessment Program (83750)
TS 6.5.4.1 requires audits of the facility to be performed by the Nuclear Assessment Department (NAD) encompassing conformance of facility operation to the. provisions contained within the TS and applicable license conditions at least once per 12 months and the Process Control Program (PCP)
and implementing procedures at least once per 24 months.
The inspector reviewed the most recent NAD audit of the RC program conducted March 23-27, 1992, and documented in Report No. H-ERC-92-01.
Supporting documentation indicated that the audit included a review of the EERC organization, self-assessment program, ALARA, training, posting/labelling, dosimetry, instrumentation, and respiratory protection as well as the Process Control Program, the Offsite Dose Calculation Manual, and the chemistry, environmental and effluent programs.
In particular, the inspector noted that the audit included performance reviews of various RC activities during the course of the audit.
Overall, the audit appeared sufficient in scope to address the major RC program areas, and related documentation was improved over the 1991 audit of this area.
Discussions with licensee representatives and a review of the observation data base revealed that few E&RC activities were reviewed between the required audits.
The inspector
was informed that the E&RC position within the NAD organization had been vacant for sometime and that actions to fillthe position have been ongoing.
~ At the time of the onsite inspection, the licensee stated that interim arrangements had been approved to provide onsite E&RC support part-time until the position could be filled '-
permanently.
At the exit, the inspector discussed with licensee management the importance of filling this position to increase program observation and foster program improvements.
The inspector reviewed the licensee's internal program for identifying and correcting deficiencies related to the control of radioactive material.
Radiation safety deficiencies and improvement items were identified using the Feedba'ck and Adverse Condition Report (ACR) reporting.
systems depending on the severity, with the latter being of the greater significance.
Review of selected Feedback Reports and ACRs pertaining to the RC group noted that corrective actions were implemented as appropriate.
However, the inspector noted that the licensee was not trending the root causes associated with Feedback Reports in order to formulate an assessment of adverse performance or programmatic weaknesses.
In addition, the inspector noted that closure of Feedback Reports was not always timely with numerous 1991 and several 1990 and 1989 reports remaining open.
The licensee had identified the need for improvements in the trending and closure timeliness of Feedback Reports, and, at the time of the onsite inspection, actions were underway to complete actions on old Feedback Reports.
Further, a revision to Procedure ERC-201, E&RC Feedback Report, was underway which was to include improved guidance on the processing and disposition of reports including the identification and trending of root causes.
Based on 'the licensee's ongoing actions to strengthen this aspect of the self-assessment program, the inspector informed the licensee that the related NRC open item would be closed.
However, the satisfactory completion of ongoing improvement actions would be evaluated during a future inspection.
No violations or deviations were identified.
External Exposure Controls (83750)
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CFR 20.101 requires that no licensee possess, use, or transfer licensed material in such a manner as to cause any individual in a 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 truck, active blood forming organs, lens of the eyes, or gonads; 18.75 rem to
the hands, forearms, feet and ankles; and 7.5 rem to the skin of the whole body.
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Personnel Dosimetry
CFR 20.202 requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipment.
CFR 20.202(c)
requires that dosimeters used to comply with 10 CFR 20.202(a)
shall be processed and evaluated by a processor accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for the types of radiation for which the individual is monitored.
The inspector reviewed and discussed with licensee representatives the overall personnel dosimetry program.
Thermoluminescent dosimeters (TLDs) were not issued to all individuals, but only to those individuals who entered the licensee's radiological controlled area (RCA)
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TLDs were exchanged and read on a quarterly basis and were stored with employee identification badges on the racks at the main plant entrance/security checkpoint.
During quarterly exchanges, health physics personnel checked the RCA entry records and, for those employees who had not entered the RCA during the previous quarter, their TLD was removed.
TLDs issued to visitors were checked every two weeks and pulled from the racks as necessary.
The routine checks were made to limit the number of active TLDs to those of individuals who "routinely" entered the RCA.
In addition to TLDs, the licensee also provided self-reading pocket dosimeters (SRPDs)
to plant personnel and instructions on their utilization.
SRPDs were response-checked annually.
During tours of the plant, the inspector observed workers properly wearing appropriate personnel monitoring devices.
The inspector verified that the licensee was certified in all eight NVLAP dosimetry categories and was
'accredited as a processor through October 1992.
Corporate Health Physics was responsible for maintenance of the TLD program and each plant within the utility, including Harris, processed its own dosimetry and maintained dose records in a central (corporate)
database, RIMS.
Approximately 850 and 1450 TLDs were "read" each quarter during non-outage and outage periods,
respectively.
Maximum doses measured in millirem at the Harris site were as follows:
~19 1
~1
(as of June 3)
Whole body
.
1784 Upper extremity 1892 Lower extremity 1061 659 459
Discussions with licensee representatives revealed that implementation of digital alarming dosimeters was being'lanned.
At the time of the onsite inspection, the licensee had not finalized the system to be purchased; however, an implementation date of 1993 was anticipated.
The inspector noted that the addition of this equipment would be an enhancement to the dosimetry pro'gram.
10. CFR 20.101(b)(3)
requires the licensee to determine an individual's accumulated occupational dose to the whole body on an Form NRC-4 or equivalent record prior to permitting the individual to exceed the limits of 20.101(a).
Discussions with licensee representatives and a review of selected records indicated that Form NRC-4 equivalent information was obtained from monitored individuals prior to initiating radiation work.
No violations or deviations-were identified.
Dose Extensions and Exposure Investigations Dose extensions were reviewed by the inspector and were found to be controlled by the licensee with approval required from varying levels of licensee management depending upon the magnitude of the extension.
Extensions were only granted if the requesting individual was expected to receive significant dose from an upcoming job and less than 350 millirem (mrem)
remained in the individual's quarterly dose bank.
The licensee's administrative limit with a Form NRC-4 on file was 1250 mrem.
Approximately 102 dose extensions were granted in 1991 with the majority of them associated with Refueling Outage Three (RFO-3) for steam generator and other high dose workers.
The majority of dose extensions granted by the licensee were from the 1250 mrem whole body limit to 1800 mrem.
The maximum extensions granted were from the 1250 mrem limit to 2400 mrem.
In 1992, as of June 5,
no
extensions, were given for the year.
A review of selected records by the inspector revealed no concerns.
The inspector was informed that personnel exposure investigations were conducted following any abnormal occurrence involving personnel exposure or dosimetry.
For example, approximately 60 TLDs were lost in 1991 (approximately 41 were subsequently recovered)
and
TLDs were lost in 1'992, prompting licensee evaluations
.to estimate the doses incurred.
The inspector reviewed selected records involving lost dosimetry and no concerns were noted.
Dose estimates were appropriately assigned based upon previous known doses and pocket dosimeter readings.
No violations or deviations were identified.
Internal Exposure Controls (83750)
CFR 20.103(a)(1)
states that no licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a
quantity of radioactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />,per week for 13 weeks at uniform concentrations of radioactive material in air specified in Appendix B, Table 1, Column 1.
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Respiratory Protection
CFR 20.103(c)(2)
permits the licensee to maintain and to implement a respiratory protective program that includes, at a minimum:
air sampling to identify the hazard; surveys and bioassays to evaluate the actual exposures; written procedures to select, fit, and maintain respirators,'ritten procedures regarding supervision and training of personnel and issuance of records; and determination by a physician prior to the use of respirators, that the 'individual.user is physically able to use respiratory protective equipment.
The inspector reviewed and discussed with licensee representatives the program for the issue, use, decontamination, repair, and storage of respirators.
After use, the licensee cleaned and decontaminated respirators as well as performed a.100 percent test of seal integrity using atomized corn oil.
Any respirator failing the leak test was re-inspected, repaired and retested or removed from service.
Following successful maintenance, each respirator was bagged, dated, and tracked by computer through the RIMS syste Respirators had a 30-day shelf-life before re-inspection was required.
During a tour of the respiratory equipment facility, the inspector noted that all full-face respirators available for issuance were segregated, stored, individually bagged, and labelled
'as. required.
Further, the inspector noted that all respirators were issued using the RIMS system.
The system included appropriate controls to ensure that respirators were not issued if they exceeded the 30-day shelf-life or if the individual was not fully qualified for the particular respirator requested.
The inspector reviewed records for selected employees who had signed in on RWP 92-0163 for work associated with RTD manifold repair conducted during the 1992 mini-outage.
The inspector verified that each worker had successfully completed General Employee Training (GET), training, fit testing, and medical qualification for the use of respiratory equipment in accordance with appropriate requirements.
No violations or deviations were identified.
Breathing Air Quality
CFR 20, Appendix A, Footnote (d), requires adequate respirable air. of the quality and quantity in accordance with NIOSH/MSHA certification described in
CFR Part 11 to be provided for atmosphere-supplying respirators.
CFR 11.121 requires that compressed, gaseous breathing air meets the applicable minimum grade requirements for Type 1 gaseous air set forth in the Compressed Gas Association (CGA) Commodity Specification for Air, G-7.1 (Grade D or higher quality).
The inspector reviewed and discussed with licensee representatives the program for testing and qualifying breathing air as Grade D.
Licensee Health Physics Procedure HPP-308, Rev.
6, detailed the methodology and acceptance criteria for certifying breathing air sources
- the plant air system, SCBA refill equipment, portable air compressors, and compressed gas cylinders.
The frequency of certification for Grade D established by procedure was once per calendar quarter, or prior to each use.
The inspector noted that the licensee's acceptance criteria for Grade D was consistent with the CGA Commodity Specifications for Air, G-7.1, dated 198 The breathing air 'systems implemented by the licensee consisted of bottled air and a portable plant-developed compressor air line system, used on. an as'eeded basis.
Further, the licensee informed the inspector that the plant instrument air system was no longer used to supply breathing air since the inadvertent contamination of the system with approximately
gallohs of RCS water (IR 50-400/89-29).
Discussions with licensee representatives and review of applicable documentation revealed that the licensee conducted testing of the SCBA refill system on a quarterly basis.
Although Grade D air was required, the quality of the air typically met that of Grade E air.
The inspector noted that the portable breathing air system was last tested in March 1991 prior to its use in RFO-3 to support steam generator work activities.
Licensee representatives stated that the system had not been used since that time, and therefore, had not been routinely tested.
The inspector noted that, other than SCBA, the licensee did not maintain an immediately available breathing air system.
To utilize breathing air for work requiring air supplied hoods, the licensee must ready the equipment as well as recertify the quality of breathing air prior to use.
No violations or deviations were identified.
Whole Body Counting
CFR 20.103 (a) (3) requires, in part, that the licensee, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment, of individual intakes for radioactivity by exposed individuals.
Licensee Procedure HPP-251, Personnel Decontamination and Documentation of'ontamination Events, Rev.
5, requires that special whole body counts be performed for contamination events at or near the facial area.
The inspector reviewed selected Feedback Reports for the period January 1 through June 1,
1992, detailing individuals reported to have positive facial contamination.
For all the reviewed cases, special whole body counts were conducted in accordance with procedural guidance, and no positive measurements were reported.
The inspector was informed by licensee representatives that no positive internal contaminations due to
licensed activities had been identified thus far in 1992.
For calendar year 1991, approximately 2341 whole body counts were. performed, and seven individuals were
- identified with positive whole body analyses.
Discussions with licensee personnel indicated that only two of'the positive counts were associated with licensee activities 'while the remainder were attributed to medical treatment, uptake from wild meat, or positive baseline/incoming counts.
Review of the two positive counts indicated that the maximum intake was estimated at approximately 6 Maximum Permissible Airborne Concentration
- hours (MPC,-hrs).
Based on the above, the inspector concluded that no internal contamination in excess of the 40 MPC,-hr control limit requiring an evaluation had been identified for calendar year 1991 or year-to-date in 1992.
No violations or deviations were identified.
Instrumentation Since the previous inspection of this area in May 1991, the inspector noted that the licensee had implemented a
new Fast Scan stand-up geometry whole body counter.
Licensee dosimetry personnel stated that the new counter was primarily used for routine analysis, and that any additional analysis would be performed using the chair geometry counter.
The licensee required annual calibration of the whole body counting systems.
The inspector verified that the Fast Scan was calibrated in November 1991 when it was placed into service, and the chair geometry counter was last calibrated in December 1991.
The inspector also discussed the licensee's whole body counter intercomparison program.
The program involved a quarterly comparison of a vendor supplied isotope mix which was then counted in a phantom using the licensee's chair and stand-up counters.
The results were compared with the vendor's to determine the relative bias and precision of the measurements.
Review of the first quarter 1992 comparison study results indicated that both counters performed within the established acceptance criteria for the various isotopes utilized.
No concerns were noted regarding the maintenance of the whole body counters, and the inspector considered the intercomparison program to be a positive licensee initiative.
No violations or deviations were identifie Operational and Administrative Controls (83750)
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Radiation Work Permits (RWPs)
The inspector reviewed selected routine and special RWPs for adequacy of the radiation protection requirements based on work scope, location, and conditions.
The RWPs associated with the 1992 mini-outage, as well as the associated pre-job briefin'gs, properly addressed radiological concerns.
Pre-job AZdQV. reviews contained appropriate ALtQ&
recommendations, and the inspector verified that
. workers attended pre-job briefings.
The inspector noted that post job reviews were performed and included identification of lessons learned.
Xn addition, the inspector also evaluated the RWPs associated with June 3,
1992, containment entry to conduct maintenance on the containment airlock.
The RWP requirements and HP support activities (i.e. surveys, and dose tracking)
appeared appropriate.
During the inspection the inspector was informed that the licensee had recently implemented a new method for RCA access and RWP sign-in.
The system provided for self-issuance of SRPDs and computerized RWP login by each worker.
RCA access was granted as long as the worker had reviewed and signed the current revision of the RWP, otherwise RCA access was denied pending review and sign-off on the current RWP.
Licensee representatives stated that cross-checks were performed daily to ensure personnel were appropriately implementing the computerized system.
The inspector observed workers properly using the computerized system during the onsite inspection.
No concerns were noted.
The inspector found the licensee's program for RWP implementation to adequately address radiological protection concerns, and to provide for proper control measures.
b.
No violations or deviation's were identified.
Termination Reports
CFR 20. 408 (b) and
CFR 20. 409 (b) require that the licensee make a report to the Commission, and notify the individual involved, of the radiation exposure of each individual who has terminated employment.
The report is to be furnished within "30 days after the individual's exposure is determined by the licensee or 90 days after the date of termination of employment or work assignment, whichever is earlie ~
V
One of the features of the centralized database, RIMS, was to provide termination information.
The licensee provided lists of terminating individuals and their termination dates to the corporate dosimetry department which, in turn, obtained the required information from RIMS and furnished termination letters to the individuals.
The inspector discussed the termination process with licensee representatives and reviewed selected termination letters.
No concerns were identified with the contents or timeliness of the letters or the licensee's methods.
No violations or deviations were identified.
Control of Radiative Material and Contamination, Surveys, and Monitoring (83750)
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Surveys
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 radiological hazards that-may be present.
The inspector noted that the licensee had established a
routine survey program in accordance with approved procedures.
Review of selected survey documentation indicated that periodic surveys were performed at the established frequency.
Current surveys were maintained on file in the Health Physics Office.
To-supplement the routine surveys the licensee maintained a computerized monitoring system, RMS, which provided remote indication of various effluent, area, and accident radiation monitors in the Health Physics Office.
The system included the capability for acquiring immediate radiological status and various trended information, as well as a monitor alarming function.
The licensee stated that the system was utilized to identify changes in radiological conditions and to assess needed changes in the routine survey program.
The inspector found the system to be sophisticated and a strength of the licensee's program.
Review of the April 1992 HP and Chemistry Trending Report revealed a significant reduction in the number of "hot spots" tracked by the licensee.
The inspector was informed that the reduction was due to a change in the hot spot criteria from 100 mR/hr contact and
times area radiation levels to 300 mR/hr contact.
Licensee representatives stated that the change was
implemented to provide consistency with the other Carolina Power and Light plants.
During facility tours, the inspector independently verified radiation levels at various Auxiliary Building, Waste Processing Building, and other RCA locations.
The inspector noted in all cases, areas were posted and safeguarded in accordance with the radiation hazards present.
In particular, the inspector observed that locked high radiation areas (LHRAs) were appropriately controlled, and in many cases, certain HRAs and radiation areas were controlled and locked by RC to prevent unnecessary access.
No violations or deviations were identified.
Personnel and Area Contamination The licensee maintained approximately 460,000 square (ft ) of floor space as radiologically controlled.
As of June 4,
1991, the licensee tracked approximately 1774 ft of recoverable space as contaminated which equated to less than one percent contaminated floor space.
During tours of the RCA the inspector observed a clean. plant as well as good housekeeping and contamination control practices.
In 1991, the licensee experienced approximately 131 personnel contamination events (PCEs).
Of those,
were skin contaminations and 96 were clothing contaminations.
As of May 8, 1992, 4 skin and
clothing PCEs had occurred during the year.
The licensee's goals for 1991 and 1992 were the same,
skin and 100 clothing PCEs, and were based on past performance during one-outage years.
Review of the licensee's hot particle log revealed that most particles were found as a result of a PCE; however, a few were discovered while frisking trash or performing area surveys.
If possible, the particles were analyzed for isotopic content and either stored for reference or properly disposed.
The maximum particle activities found by the licensee were 40,000 net counts per minute (ncpm)
and 2,000 ncpm in 1991 and 1992, respectively.
Based on the above, the inspector determined that the licensee was adequately controlling contamination at its source.
No violations or deviations were identifie Leak Testing of Radioactive Sealed Sources TS 4.7.9.1 and 2 require that sealed sources containing radioactive material be leak tested at least once per
months, and that the test method have a detection sensitivity of at least 0.005 microcuries per test sample.
The inspector discussed with licensee representatives a
recently identified issue regarding the adequacy leaking testing for iron-55 (Fe-55)
sealed sources.
The licensee maintained two alloy analyzers each containing approximately 5 millicuries of Fe-55.
The sources had been entered into the licensee's source inventory and maintenance program and had been leak tested at the required 6-month frequency.
However, the methodology employed by the licensee to analyze the smears, gas flow proportional counting, was not adequate to measure the low energy X-rays associated with the Fe-55 decay.
Specifically, the licensee identified that the test method did not have the 0.005 microcurie detection sensitivity required by TSs.
Upon identification during a routine sealed source surveillance in November 1991, the licensee initiated and completed the following corrective actions:
(1)
the responsibility for analysis of Fe-55 smears was transferred to the Harris Energy and Environmental Center which had the capability for liquid scintillation counting; (2)
incorporation of appropriate changes to procedure RST-010, Leak Source Accountability, Revision 6; and (3)
training of the technician staff on the procedural changes.
The inspector identified the failure to perform adequate leak testing of Fe-55 sealed sources as a
violation of TSs 4.7.9.1 and 2 requirements (Violation 50-400/92-09-01).
However, because the licensee's efforts in identifying and correcting the apparent violation were adequate and the criteria specified in Section V.G.1 of the NRC Enforcement Policy were met, the inspector informed licensee representatives that the violation would not be cited.
One licensee-identified, non-cited violation for the failure to adequately leak'est certain sealed sources was identified.
Radiation Detection and Survey Instrumentation During facility tours, the inspector noted that in-use survey instrumentation, whole body friskers, and
continuous air monitors were operable and displayed current calibration stickers.
In addition, the inspector noted that source checks of instrumentation were performed at the. required frequency.
'o violations or deviations were identified.
Program for Maintaining Exposures As Low As Reasonable Achievable (ALARA) (83750)
CFR 20.1(c) states that persons engaged in activities under licenses issued. by the NRC should make every reasonable effort to maintain radiation exposures as low as reasonably achievable.
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Dose Goals and Outage Planning, The collective dose goal for 1992 was established at 215 person-rem and distributed as follows:
Normal Operations, 20 person-rem; Outages/Special Projects, 165 person-rem; Spent Fuel Program, 15 person-rem; and Steam Generator Life Extension, 15 person-rem.
As of June 4,
1992, 26 person-rem had been expended of which approximately 8 person-rem was associated with the 1992 mini-outage.
For 1991, the licensee expended 226 person-rem as compared to a goal of 210 person-rem with the overage primarily being attributed to outage/special project activities.
The inspector reviewed and discussed with cognizant licensee representatives the ALAf&final assessment for RFO-3 (March 16
- May 22, 1991).
The exposure goal for the outage was approximately 170 person-rem.
The actual exposure incurred was approximately 189 person-rem, 1$ percent above the goal.
The licensee attributed the increased dose to outage scope growth and unplanned work primarily related to RHR mechanical seal and RTD manifold valve leak repairs.
The highest dose job during the outage was steam generator shot'eening with approximately 41 person-rem expended.
Overall, for the 67 day outage, dose expended was commensurate with work performed.
At the time= of the onsite inspection, the licensee had initiated planning for the fall 1992 RF0-4.
Significant activities planned for the outage included steam generator tube pulls and pressurizer hanger installation.
The inspector was informed that RC technician outage assignments had already been made to facilitate. job planning and preparation activities.
A particular initiative targeted for the outage was to reduce the dose associated with scaffolding.
At the
time of the inspection, the licensee was evaluating quick disconnect scaffolding as well as methods to better control scaffolding use/reuse.
The inspector was also informed that RFO-4 outage scope had been frozen on May 1 unless approval was obtained from the Plant General Manager.
Changes less than 60 days prior to the outage were required to be approved by the Site Vice President.
Dose Reduction Activities For RFO-3 the licensee implemented a controlled, chemical shutdown which consisted of early boration and subsequent removal of corrosion products by letdown demineralization.
For the outage, the licensee calculated that approximately 591 Curies of activity were removed.
Subsequent outage surveys of the steam generator channel head found that radiation levels remained stable with respect to previous outages, rather than increasing as predicted if early boration had not been implemented.
The licensee also attempted early boration for the 1992 mini-outage; however, because the RTD repair work was unexpectedly completed in Mode 4, the licensee did not enter Mode 5 and, thus, activity removal was not completed.
As a result, dose rates in many areas near and around the RHR system have increased, many of which required posting as high radiation areas.
However, based on the success during RF0-3, the licensee planned to continue to employ this dose reduction technique during future outages.
The inspector reviewed and discussed the licensee's Dose Reduction Plan, dated September 1990, and currently under revision.
The Plan established a long term dose goal of 130 person-rem to be achieved by 1995.
Review of the Plan's elements revealed that progress had been made on several of the items including implementation of early boration, control of outage scope growth, and planned RTD bypass manifold removal during, RFO-5.
Other items such as ultrafiltration, robotics, and stellite reduction were in the planning stage The inspector encouraged continued pursuit of the stated Dose Reduction Plan initiatives.
The inspector reviewed the activities of the ALARA Subcommittee.
The Subcommittee cons'isted of representatives from the major plant functional units and was chaired by the ALARA Specialist.
The inspector was informed that recently a representative from the fuels group was added to the Subcommittee.
The Subcommittee met once per month and attendance by the
various groups was good.
Review of the meeting minutes for 1991 and 1992 noted that the Subcommittee typically evaluated AIdQ& suggestions, ALARA action items, dose goals, and special topics such as the Dose Reduction Plan, outage lessons learned, and review of jobs with doses greater than 25 rem.
Regarding the latter, the inspector noted that only 1-2 jobs per outage normally met'the review threshold, and those were normally infrequently performed tasks (i.e. shot peening).
The inspector discussed with licensee representatives the potential dose savings benefits associated with ALARA Subcommittee review of lower dose, more repetitive jobs.
The licensee indicated that the issue would be examined.
C.
Licensee Awareness and Involvement The inspector reviewed the licensee's program for worker awareness and involvement in the ALMA Program.
The inspector noted that the license had established, an ALMA suggestion program.
The program included incentives for the submission of dose reduction suggestions as well as the achievement of job and unit dose goals.
Since the establishment of incentives in 1991, the number of AIBA suggestions submitted has increased.
As of June 1,
1992, 41 ALARA suggestions had been submitted as compared to 63 in 1991 and 3 in 1990's of May 1, 1992, 35 suggestions remained open.
Discussions with licensee representatives revealed that implementation of a new incentive program was being considered to improve the quality of suggestions submitted.
The new program would include cash awards for suggestions rather than accumulation of points (ALMAbucks) for prizes.
Further, the inspector was informed that the utility Great Idea
,Program had been recently revised to specify criteria for dose savings suggestions.
The inspector discussed ALSO'. training with licensee representatives.
The licensee stated-. that Corporate Engineering was provided ALARA training on the use of the ALKDesign Guide, NED-DG-001, on a quarterly basis; however, no specialized training, beyond GET, was provided to the plant staff.
Licensee representatives stated that ALARA training was being considered for incorporation into the upcoming Technical Support Manager Training.
The inspector noted that additional emphasis could be placed on ALA&
awareness training for plant workers.
No violations or deviations were identifie.
Followup on Previous Enforcement Actions (92702)
(Closed) Violation 50-400/90-15-01 Failure to properly secure radioactive materials'stored in an unrestr'icted area.
The inspector reviewed and verified implementation of corrective actions stated in the licensee's response dated October 2, 1990.
Review of licensee procedures PLP-511; Radiation Control and Protection Program, Rev.
6, and HPP-035, Posting and Barricading of Radiological Areas, Rev.
6, confirmed that the licensee had implemented appropriate procedural controls for radioactive material storage areas located outside of the Protected. Area.
In addition, tours of Warehouse 6 and other locations outside of the Protected Area noted ro examples of improperly stored radioactive.
material.
This item is considered closed.
11.
Followup on Open Items and Licensee Events (92701, 92700)
a.
Inspector Followup Items (IFIs)
1.
(Closed) IFI 50-400/89-23-01:
Implement a
formalized method for documenting procedural and regulatory HP violations.
The inspector reviewed
, the licensee's Feedback and ACR Reporting systems used to document RC deficiencies and improvement items.
As discussed in Paragraph 4 of this report, improvements were needed regarding the licensee's tracking and closure of identified items.
However, based on the licensee's ongoing corrective'ctions, in this area, this item is considered closed.
2.
(Closed) IFI 50-400/89-23-02:
Revise procedures to delineate the minimum qualification and training requirements for contractor HP personnel.
The inspector reviewed the licensee's program for training and qualification of contractor personnel as well as-verified implementation of the program for two contract technicians onsite at the time of the inspection.
As discussed in detail in Paragraph 3 of this report, the licensee's response to this NRC concern had been adequately addressed.
This item is considered closed.
b.
Licensee Event Reports (LERs)
.(Closed)
LER 91-020-00:
Failure to adequately test sealed sources resulting in TS violation.
The inspector reviewed the circumstances surrounding the identification and correction of the deficiencies associated with the leak testing and analysis for Fe-55 sealed sources.
As discussed in detail in Paragraph
of this report, the failure to adequately perform leaking testing was identified as a non-cited violation.
This LER is considered.closed.
c.
Information Notices (INs)
The inspector determined that the following INs had be received by the licensee and reviewed for applicability.
Importance of Proper Response to Self-Identified Violations by Licensees IN 90-08 Kr-85 Hazards from Decayed Fuel IN 90-33:
Sources of Unexpected Occupational Radiation Exposures at Spent Fuel Storage Pools IN 90-44:
Dose Rate Instruments Underresponding to
'Pure Radiation'Fields IN 90-47:
Unplanned Radiation Exposures to Personnel Extremities Due to Improper Handling of Potentially Highly Radioactive Sources IN 90-48:
Enforcement Policy for Hot Particle Exposures IN 88-63:
Supplement 1:
High Radiation Hazards from Irradiated Incore Detectors and Cables IN 91-36: Nuclear Plant Staff Working Hours IN 91-37:
Compressed Gas Cylinder Missile Hazard IN 88-63:
Supp1ement 2:
High Radiation Hazards from Irradiated Incore Detectors and Cables IN 91-76:
CFR Part 21 and 50.55(e)
Final Rules IN 92-25: Potential Weakness in Licensee Procedures for Loss of refueling Cavity Water IN 92-30: Falsification of Plant Records 12.
Exit Interview (83750, 92701, 92702)
The inspection scope and results were summarized on June 5,
1992, with those persons indicated in Paragraph 1 above.
The general program areas reviewed and the non-cited violation identified during this inspection and listed below were discussed in detail.
The inspector also noted that two
previously identified IFIs and a violation were reviewed and closed during the inspection.
Licensee representatives acknowledged the inspector's comments and no dissenting comments were received.
The licensee was informed that although proprietary information was reviewed during this inspection, but such material would not be included in the report.
Item Number 50-400/92-09-01 D seri tion'and Reference Non-Cited Violation:
Failure to perform adequate leak testing of certain sealed sources in accordance TSs 4.7.9.1 and 2.
Licensee corrective. actions completed prior to the end of the onsite inspection (Paragraph 8).
'