IR 05000400/1994016
| ML18011A568 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/19/1994 |
| From: | Wade Loo, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18011A567 | List: |
| References | |
| 50-400-94-16, NUDOCS 9409020037 | |
| Download: ML18011A568 (19) | |
Text
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~4 P0 C0 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 303234199 Report No.:
50-400/94-16 AU8 gg t@
Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Shearon Harris Inspection Conducted:
July 25-29, 1994 License No.:
NPF-63 Inspector:
W.
.
Loo Date S gned Approved by:
W.
H. Rankin, Chief D te igned Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, announced inspection was conducted in the area of occupational radiation safety and included an examination of:
audits and appraisals, changes to organization and staffing, training and qualifications of personnel, external and internal exposure control, control of radioactive materials and contamination, surveys and monitoring, and program for maintaining occupational exposures As Low As Reasonably Achievable (ALARA).
Results:
Based on interviews with licensee personnel, records review, and observations of work activities in progress, the inspector found that the radiation protection program continued to adequately protect the health and safety of occupational radiation workers.
External and internal exposures were maintained within regulatory and the licensee's administrative limits.
The ALARA program continued to be effective in implementing dose reduction initiatives.
One non-cited violation (NCV) was identified by the inspector for failure of an individual to follow Radiation Control procedures prior to exiting the radiation control area (Paragraph 10.d).
9409020037 940822 PDR ADQCK 05000400 Q
REPORT DETAILS 1.
Persons Contacted Licensee Employees N. Bertrand, Specialist, Support Training (ST)
- H. Boone, Supervisor, Radiation Control (RC)
P. Christopherson, Specialist, ST
- A. Cornett, Supervisor, RC
- J. Donahue, Plant General Manager D. England, Specialist, ST
- D. HcCarthy, Manager, Regulatory Affairs
- C. Neuschaefer, Manager, RC H. Parker, ALARA Specialist, RC
"A. Poland, Manager, Environmental and Radiation Control (E&RC) Support
- B. Pruty, Manager, Licensing and Regulatory Programs (LRP)
D. Stih, Specialist, RC
- H. Wallace, Senior Specialist, LRP
- B. White, Manager, EERC E. Willis, Supervisor, RC Other licensee employees contacted during the inspection included technicians, maintenance personnel and administrative personnel.
Nuclear Regulatory Commission D. Roberts, Resident Inspector
- J. Tedrow, Senior Resident Inspector
- Attended July 29, 1994 Exit Meeting Abbreviations used throughout this report are defined in the last paragraph.
2.
Audits and Appraisals (83750)
CFR 20. 1101(c) requires that the licensee periodically (at least annually) review the RP program content and implementation.
'a ~
Assessments Through discussions between licensee representatives and the inspector and a review of records, the inspector determined that a
RC audit had not been conducted since the last inspection.
Through further discussions with licensee representatives and a
review of records, the inspector determined that at the time of the inspection, the licensee had recently completed a Pre-INPO Evaluation to include an assessment of RC as discussed in Paragraph 1 b.
Corrective Actions The inspector reviewed the licensee's program for self-identifying and correcting deficiencies and weaknesses related to the RC program.
Specifically, the inspector reviewed ACFRs related to the RC area and noted that since the last inspection the licensee had initiated numerous ACFRs related to the RC program.
For those selected ACFRs reviewed by the inspector several trends or indicators of RC problems were noted to include activities associated with RF05 such as inadequate or incorrect radiological postings, obtaining nasal smears and performing isotopic analysis for individuals with facial contaminations, and radiation worker practices.
The inspector reviewed these selected ACFRs and noted that the licensee was still in the process of reviewing these ACFRs and implementing corrective actions.
The inspector informed licensee representatives that the implementation of these corrective actions would be reviewed during future inspections to verify their effectiveness.
During further review of selected ACFRs, the inspector noted one incident involving a locked HRA door as discussed in Paragraph 10.
For other selected ACFRs reviewed at the time of the inspection, reports were properly documented and corrective actions were timely.
No violations or deviations were identified in this area.
3.
Changes (83750)
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Organization and Personnel The inspector reviewed and discussed with licensee representatives changes made to the RC organization since the last NRC inspection of this area conducted March 28 to April 1, 1994, and documented in IR 50-400/94-07, dated April 29, 1994.
Since the last inspection the licensee had appointed a new Radiation Control
.Hanager.
This individual had previously been in the Nuclear Assessment Department as the ER&C Focus Lead.
Based on a review of his experience in the area of HP, the inspector determined that the new appointee met the qualification requirements specified in the licensee's policies and procedures to include TSs.
The inspector noted that the licensee continued to maintain a
RC staff of approximately 45 to include RC supervisors, RC specialists, RC technicians, dosimetry technicians, and clerical staff.
At the time of the onsite inspection, the inspector was informed that the RC technician position which had been vacant since the last inspection would not be filled due to licensee reorganization.
Overall, the inspector did not note any concerns regarding the RC organization and staffing.
The RC organization and staffing levels continued to be appropriate, appeared stable and functioning adequately to support ongoing RC activities.
The
personnel changes noted by the inspector at the time of the inspection did not appear to adversely impact the conduct of RC activities.
No violations or deviations were identified in this area.
b.
Policies and Procedures The inspector reviewed selected RC policies and procedures and discussed those records with licensee representatives.
Through those discussions and reviews of selected records, the inspector independently verified that the licensee made numerous revisions to policies and procedures to ensure compliance to NRC regulations.
No violations or deviations were identified in this area.
Planning and Preparation (83750)
Based on discussions between the inspector and licensee representatives, the inspector was informed that the licensee planned to schedule a
RFO in the Fall of 1995, lasting approximately 38 days.
Licensee representatives stated that an exposure goal for RF06 had not been.
established; however, the licensee planned to set a goal less than the exposure for RF05 which was approximately 195 person-rem.
In addition, the licensee projected that the most dose intensive activities to be conducted would involve removal of the reactor coolant pumps, work on the permanent cavity seal ring, and work associated with a stuck cavity head tension stud.
At the time of the inspection, licensee representatives had not begun the process of finalizing dose goals, estimates and details for accomplishing ALARA initiatives to be conducted during RF06.
The inspector informed licensee representatives that these issues would be reviewed during future inspections.
No violations or deviations were identified in this area.
5.
Training and gualifications of Personnel (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.
'a ~
General Employee Training f
The inspector discussed with licensee representatives and reviewed the licensee's program for providing RC training to licensee employees.
Through those discussions and reviews of selected
lesson plans the inspector noted that GET was divided into two levels.
Level I entitled "Plant Access" was for all licensee employees lasting approximately one day.
This session included topics such as fitness for duty, plant organization and administration, nuclear power plant overview, industrial safety, fire protection, quality program, plant security, emergency response/preparedness, and radiological orientation.
In addition, individuals were administered a 50 question exam requiring a
passing grade of 80 percent.
Level II entitled "Radiation Worker" was for individuals who entered radiologically controlled and contaminated areas.
This session lasted approximately one and a
half days and individuals were administered a 50 question written exam requiring a passing grade of 80 percent.
In addition to the written exam, the individuals would have to take a practical or
"hands on" exam demonstrating that they were knowledgeable in RP principles and practices requiring a passing grade of 80 percent.
In the event an individual did not pass the Level I or II exam and practical that individual would have to take the entire course again.
Through discussions between the inspector and licensee representatives and a review of selected training records, the inspector noted that for annual retraining licensee employees would review two videotapes, one entitled "guality Check... It Works" and one regarding the use of the licensee's electronic alarming dosimeters.
Individuals would then be given a study period and take a 50 question written exam requiring a passing grade of 80 percent.
Through further discussions with licensee training representatives, the inspector was informed that the licensee was completing a computer based training program for annual retraining.
The licensee planned to implement this program within the next few months as a pilot program to see how effective it would work for individuals who required GET Level I and II retraining.
The inspector informed licensee representatives that this CBT would be reviewed during future inspections.
No violations or deviations were identified in this area.,
RC Technician Continuing Training The inspector discussed and reviewed the RC continuing training program with licensee representatives.
Through those discussions and review of selected training records, the inspector noted that the licensee had conducted an RC Peer Panel Meeting since the last inspection.
During this meeting, RC training representatives reviewed the training needs and topics to be discussed for the third quarter of 1994.
Upon review of the RC training needs, the licensee determined that the topics to be covered would include an RC Manager review of training related ACFRs and post-outage critique, soft skills training for team building, environmental monitoring with hands-on training, interpretation of gamma scan printout, a review of bloodborne pathogens, and radiological
controls for use at area hospitals.
In addition, the licensee was going to include a session on internal dose calculations and presentation techniques to minimize the apprehension level of plant workers who have been potentially contaminated.
.Through further discussions and reviews, the inspector noted that the licensee had tentatively scheduled topics for the fourth quarter of 1994 to include radiation monitoring system review, surrogate tour operation, response checks on instrumentation, systems review for spent resin sluicing and filter backwash, emergency response to a cask accident, set-up and operation of video/audio/teledose system, survey map creation with use of computer programs, hazardous waste, and mechanical valve operation overview.
No violations or deviations were identified in this area.
The inspector noted that at the time of the inspection the licensee's GET and RC Continuing training programs appeared to contain appropriate radiation protection topics with knowledgeable, experienced and qualified training representatives.
External Exposure Controls (83750)
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Administrative Controls for External Exposures
CFR 20.1201(a)
requires each licensee to control the occupational dose to individual adults, except for planned special exposures under
CFR 20. 1206, to the following dose limits:
(1)
An annual limit, which is the more limiting of:
(i)
The TEDE being equal to 5 rems; or (ii)
The sum of the deep-dose equivalent and the committed dose equivalent to any individual organ or tissue other than the lens of the eye being equal to 50 rems; and (2)
The annual limits to the lens of the eye, to the skin, and to the extremities, which are:
(i)
An eye dose equivalent of 15 rems; and (ii) A shallow-dose equivalent of 50 rems to the skin or to any extremity.
The inspector reviewed external exposure records and discussed those records with licensee representatives for selected plant and contract personnel for the year 1994 to date.
The inspector noted that for those selected individuals the maximum year to date exposure for 1994 was 1297 mrem (TEDE).
The inspector noted that the licensee had not granted any exposure extensions since January 1,
1994.
The inspector concluded that for those selected exposure records reviewed, the licensee monitored external exposures adequately and all were within 10 CFR Part 20 limits.
No violations or deviations were identified in this are Exposure to Skin Procedure No. HPP-251,
"Personnel Decontamination and Documentation of Contamination Events,"
Rev. 6, Change No. 2, dated April 9, 1994, provides instructions for decontaminating personnel and their personal clothing, and for documenting contamination events.
The inspector reviewed selected cases of skin contaminations requiring the performance of dose assessment for the year 1994 to present.
From the records reviewed, a maximum skin dose of 452 millirem was assigned for an individual who was working on the reactor head seal ring during RF05.
Based on those reviews of dose assessment records, the inspector determined that the licensee's followup surveys and assessment activities for the selected cases were in accordance with approved procedures.
No violations or deviations were identified in this area.
Personnel Dosimetry
CFR 20. 1502(a) requires each licensee to monitor occupational exposure to radiation and supply and require the use of individual monitoring devices for:
(1)
Adults likely to receive, in one year from sources external to the body, a dose in excess of 10 percent of the limits in
CFR 20.1201(a);
(2)
Hinors and declared pregnant women likely to receive, in one year for sources external to the body, a dose in excess of 10 percent of any of the applicable limits of 10 CFR 20. 1207 or 10 CFR 20.1208; and (3)
Individuals entering a high or very HRA.
The inspector selectively reviewed the licensee's dosimetry program and noted that the licensee continued to provide thermoluminescent dosimeters to individuals requiring personnel monitoring.
The licensee used the TLD for primary monitoring and utilized electronic alarming dosimeters for secondary monitoring.
Personnel TLDs were read quarterly and the results served as the official dose record.
EADs were read upon exiting the RCA and served as a means for tracking individual's cumulative exposure on a day-to-day basis.
During tours of the plant, the inspector observed proper use of TLDs and EADs by licensee employees and contractors.
In addition, through a review of records and discussions with licensee representatives, the inspector noted that the licensee's personnel dosimetry program was NVLAP accredited in all eight categorie Through discussions with licensee representatives and a review of dosimetry records, the inspector was informed that the licensee was considering the use of EADs for primary monitoring.
At the time of the inspection the licensee utilized approximately 800 TLDs.
The licensee estimated that approximately 300 TLDs would be required for individuals who routinely worked in areas where exposure to radiation would be observed with the exception of outages if EADs were used for primary monitoring.
The licensee was still in the process of reviewing this issue although an estimated implementation date of July 1, 1995, was being considered.
The inspector informed licensee representatives that the implementation of this dosimetry program would be reviewed during future inspections.
No violations or deviations were identified in this area.
d.
Radiation Work Permits The inspector reviewed selected RWPs for appropriateness of the radiation protection requirements based on work scope, location, and conditions.
The inspector noted and reviewed initial survey results for initiation of special RWPs.
The inspector also noted that the RWPs were being appropriately initiated and terminated based on job scope.
For the RWPs reviewed, the inspector noted that radiological concerns were appropriately addressed in that appropriate protective clothing, respiratory protection, and dosimetry were required.
During facility tours, the inspector observed the adherence of plant workers to RWP requirements and discussed the RWP requirements with plant workers at the job site.
The inspector found the workers to be knowledgeable of RWP requirements and their responsibilities to comply with those requirements.
Furthermore, the inspector found the licensee's program for RWP implementation to adequately address radiological protection concerns, and to provide for proper control measures.
No violations or deviations were identified in this area.
e.
Posting and Labeling During tours of the plant and selected outside radioactive material storage areas, the inspector noted that the licensee's posting and control of radiation areas, HRAs, airborne radioactivity areas, contamination areas, and radioactive material areas was adequate.
No violations or deviations were identified in this area.
Internal Exposure Controls (83750)
CFR 20. 1204 states that for purposes of assessing dose used to determine compliance with occupational dose equivalent limits, the licensee, when required to monitor internal exposure, shall take
suitable and timely measurements of concentrations of radioactive materials in air, quantities of radionuclides in the body, quantities of radionuclides excreted from the body, or combinations of these measurements.
When specific information on the behavior of the material in an individual is known that information may be used to calculate the
.
CEDE.
CFR 20. 1502(b) requires each licensee to monitor the occupational intake of radioactive material by and assess the CEDE to:
(1)
Adults likely to receive, in one year, an intake in excess of 10 percent of the applicable ALI in Table 1, Columns 1 and 2 of Appendix B to
CFR 20. 1001-20.2401; and (2)
Minors and DPWs likely to receive, in one year, a committed effective dose equivalent in excess of 0.05 rem.
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b.
Respiratory Protection Through discussions with licensee representatives, the inspector determined that for the year 1994 to present, approximately 1,008 respirators had been used.
For the years 1993 and 1992, the licensee utilized approximately 583 and 2,221 respirators, respectively.
During 1993, the licensee did not conduct any scheduled outages while in 1992 the licensee conducted one scheduled outage and one non-scheduled mini outage.
In addition, for RF05 the licensee had utilized approximately 686 respirators while during RF04 the licensee utilized approximately 1,529 respirators.
Based on those reviews of selected records and discussions with licensee representatives, the inspector noted that the licensee continued to decrease the use of respirators from year to year and outage to outage.
The licensee indicated that they were continuing to decrease the use of respirators by not using respirators in those areas where respirators had been previously used.
As a result of decreased respirator use for RF05 the licensee observed an increase in facial personnel contamination events; however, the licensee did not observe any significant positive whole body counts during this period of time as discussed in Paragraphs 7.c and 10.d.
Based on those reviews and discussions with licensee representatives, the inspector determined that at the time of the inspection the licensee had made efforts to maintain TEDE exposures ALARA.
No violations or deviations were identified in this area.
Engineering Controls During discussions with licensee representatives, the inspector was informed that during RF05 the licensee made efforts to decrease respirator usage and expand engineering controls to limit airborne radioactivity concentrations to include the use of portable HEPA filtration units and vacuum lines on RTD pipe cut Based on those discussions and work activities associated with RF05, the inspector determined that at the time of the inspection the licensee's initiatives in reducing radiation exposures through decreased respirator usage and increased engineering controls during potential airborne radioactivity activities were adequate to maintain TEDE exposures ALARA.
No violations or deviations were identified in this area.
Whole Body Counting and Exposure Tracking
CFR 20. 1204 stated that for purposes of assessing dose used to determine compliance with occupational dose equivalent limits, the licensee, when required to monitor internal exposure, shall take suitable and timely measurements of concentrations of radioactive materials in air, quantities of radionuclides in the body, quantities of radionuclides excreted from the body, or combinations of these measurements.
When specific information on the behavior of the material in an individual is known, that
.information may be used to calculate the CEDE.
The inspector reviewed selected records of whole body counts performed by the licensee for the year 1994 to date.
Through those reviews of selected records.and discussions with licensee representatives, the inspector determined that for the year 1994 to date the licensee had conducted approximately 210 WBCs.
Of those WBCs the licensee did not observe any significant positive uptakes.
Although the licensee continued to reduce respirator usage and had an increase in facial PCEs no significant increase in positive WBCs was observed.
At the time of the inspection no concerns were noted by the inspector based on those review of selected records and discussions with licensee representatives.
No violations or deviations were identified in this area.
Planned Special Exposures (83750)
CFR 20. 1206 permits the licensee to authorize an adult worker to receive doses in addition to and accounted for separately from the doses received under the limits specified in 10 CFR 20. 1201 provided that certain conditions are satisfied.
Such exposures cannot exceed the dose limits in 10 CFR 20. 1201(a)
in any year or five times the annual dose limits during an individual's lifetime.
Section 6. 10 of the licensee's RCIIPH, Rev. 22.states the CPRL policy on planned special exposures.
Specifically, the utility states that it would not utilize the planned special exposure provisions of 10 CFR
Part 20 to allow individuals to receive dose in excess of annual dose limits.
Discussions with licensee personnel noted that in light of the policy no procedures had been developed at the Harris plant for implementation of this aspect of the new
CFR Part 20 regulations.
No violations or deviations were identified in this area. Dose to the Embryo/Fetus and Exposures of Declared Pregnant Women (83750)
CFR 20. 1208(a) requires that the dose to the embryo/fetus not exceed 500 mrem during the entire pregnancy due to occupational exposure of a DPW.
Section 6.3 of the RC&PH and Procedure RC-PD-07, entitled
"Embryo/Fetus Exposure Monitoring," detailed the licensee's program and policies regarding declaration of pregnancy as well as exposure monitoring and dose limits for the declared pregnant woman and embryo/fetus.
Through discussions with licensee representatives and a
review of dosimetry records, the inspector noted that for the year 1994 to date three women declared to be pregnant.
However, at the time of the inspection none of the three women were available for interview.
The inspector reviewed exposure records for the DPWs and verified that the licensee appropriately limited the individuals'ose in accordance with policies, procedures and NRC requirements.
No violations or deviations were identified in this area.
Control of Radioactive Material and Contamination, Surveys, and Honitoring (83750)
CFR 20. 1501(a) 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.
CFR 20. 1904(a) requires the licensee to ensure that each container of licensed material bears a durable, clearly visible label bearing the radiation symbol and the words "Caution, Radioactive Material," or
"Danger, Radioactive Material."
The label must also provide sufficient information (such as radionuclides present, and the estimate of the quantity of radioactivity, the kinds of materials and mass enrichment)
to permit individuals handling or using the containers, to take precautions to avoid or minimize exposures.
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Control of Radioactive Material During plant tours, the inspector observed adequate housekeeping and contamination control practices.
The inspector noted that the licensee's posting and control of radiation areas, HRAs, airborne radioactivity areas, contamination areas, radioactive material areas, and the labeling of radioactive material was adequate.
In addition, the inspector reviewed selected survey records and verified that the licensee was performing routine surveys of
radioactive materials areas and checks of labels on radioactive material containers stored in outside storage areas.
Furthermore, the inspector observed RCTs monitoring worker activities in their assigned locations, making radiation and contamination surveys and advising workers on appropriate radiological protection procedures.
No violations or deviations were identified in this area.
Surveys Procedure No. HPP-625, Rev.
1, Change No.
1, dated March 21, 1994, entitled "Performance of Radiological Surveys" provides instructions to implement the RC&PP requirements as established in the FSAR to establish minimum frequencies for performing routine radiological surveys, perform radiation, contamination and airborne surveys of accessible plant areas and materials, and the posting and barricading of appropriate areas.
The inspector reviewed selected records of routine and special radiation and contamination surveys performed=in 1994 and discussed the survey results with licensee representatives.
Evaluation of selected surveys posted at the RCA entrance found them to be current and appropriately documented.
During facility tours, the inspector noted that the surveys were found to be informative and consistent with the data maintained at the RWP office.
During tours of the plant, the inspector independently verified radiation and contamination levels in various Auxiliary Building locations and other areas of the RCA.
The inspector noted that in all cases, areas were posted in accordance with the radiation hazards present.
Furthermore, at the time of the inspection no concerns with the adequacy or frequency of the selected radiological survey activities were identified by the inspector.
No violations or deviations were identified in this area.
High Radiation Areas Procedure No. AP-504, Rev.
5, Change No. 2, dated March 21, 1994, entitled "Administrative Controls for Locked, Restricted and Very High Radiation Areas" provides instructions for implementing the RCKPP requirement to maintain control over entries into locked, restricted, and VHRAs.
During tours of the Auxiliary, Waste Processing, and Fuel Handling Buildings, the inspector observed and independently verified that all HRAs were locked and/or posted as required.
During discussions with licensee representatives and a review of records, the inspector determined that the RCSS in the RWP office maintained a shift turnover logbook.
During each shift turnover,
the RCSS would conduct an inventory for each of the LHRA keys for accountability and control.
The keys to each of the LHRAs were maintained in a locked box on a wall in the RWP office.
In addition, the licensee maintained records for each time a
LHRA key was checked out and in to ensure adequate key control for the LHRAs.
Through further discussions and reviews of records, the inspector noted that on June 10, 1994, a
LHRA was opened without the proper key on two occasions during one shift.
As a result of these i'ncidents, the licensee initiated ACFR No. 94-21116 and conducted
.a special Root Cause Investigation into this matter.
Based on the investigation the licensee determined that two RCTs on two occasions entered a
LHRA on the 261'levation lo'cated in the Fuel Handling Building without the proper key.
On each occasion the individuals attempted to unlock the door with the key issued to them but were unsuccessful.
The individuals then reached through the wire mesh cage door and released the door locking mechanism to unlock the door.
On the first occasion an RCT entered the room to decontaminate the area.
On the other occasion an RCT entered the room to down post the area because the radiation levels in that room no longer required it to be a
LHRA.
Upon completion of the investigation the licensee identified two other LHRAs that had the same physical barriers and replaced the striker guard plates and support plates with wider ones.
In addition, the licensee counseled the RCTs on the significance of the LHRA boundary and the necessity to stop, and notify their management when unexpected situations occurred.
Other corrective actions taken by the licensee included two RCT meetings where the RC manager stressed the importance of the LHRA boundary and his expectations for actions regarding such circumstances.
Furthermore, the licensee was still in the process of implementing corrective actions and the inspector informed licensee representatives that the implementation of these actions would be reviewed during future inspections.
No violations or deviations were identified in this area.
Personnel and Area Contamination Section 5.22 entitled
"RCA Exit - Personnel" of Procedure No. AP-535, Rev.
0, dated April 23, 1994, entitled "Performing Work in Radiation Control Areas" states, in part, that upon exiting the primary RCA personnel shall monitor for contamination with a whole body contamination monitor. If the whole body monitor alarms again, personnel shall note the areas of contamination indicated by the monitor, notify HP, and await further instructions.
Upon leaving the Security Building, the inspector observed a swing gate attached to a stanchion that one would have to go through upon exiting the whole body contamination monitors.
Attached to the swing gate was a sign that informed individuals to wait one
second before exiting the monitor.
During tours of the plant, the inspector observed several individuals entering the whole body monitors located in the Security Building and not waiting a second.
The individuals observed by the inspector walked through the monitors without stopping.
Furthermore, upon conducting more
.
tours of the plant, the inspector observed several individuals exiting the primary RCA exit whole body contamination monitors.
Upon completing the whole body monitor, one individual caused the monitor to alarm.
The individual then walked out of the monitor, and after waiting a few minutes the individual walked back into the whole body monitor and caused the monitor to alarm a second time.
The individual again walked out of the monitor in apparent frustration in not being able to proceed and waited a few more minutes.
The individual then proceeded to enter the monitor a third time and caused the monitor to alarm again.
After waiting a
few more minutes the individual entered the whole body contamination monitor for the fourth time and was cleared by the monitor to leave the RCA.
The inspector informed licensee representatives of his concerns regarding individuals following RC procedures upon exiting the primary RCA and the Security Building.
After discussions between the inspector and licensee representatives, licensee representatives began to monitor both exits by placing RCTs at the Security Building exit and using remote cameras to observe individuals exiting the primary RCA to ensure that individuals exiting either areas followed RC procedures upon leaving whole body contamination monitors.
In addition, RC representatives discussed the importance of following and adhering to RC procedures by licensee employees with craft supervisors.
After the inspection and upon further review by NRC, it was determined that this was a failure of licensee personnel to follow RC procedures upon exiting the primary RCA.
On August 1,
1994, the inspector informed the RC manager that the findings involving the individual who did not follow RC procedures upon exiting the primary RCA would be identified as an NRC identified violation.
Because the individual did not leave the primary RCA until he had cleared the whole body contamination monitors and based on the actions taken by RC representatives at the time of the incident this NRC identified violation would not be cited because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied.
NCV 50-400/94-16-01:
Failure of an individual to follow RC procedures prior to exiting the primary RCA.
Through discussions with licensee representatives and a review of selected records, the inspector noted that the licensee maintained approximately 445,000 ft', excluding containment, as radiologically controlled.
Of the 445,000 ft'esignated as radiologically controlled, approximately 7,200 ft'as designated
by the licensee as non-recoverable.
As of July 28, 1994, the contaminated area tracked by the licensee was approximately 1,265 ft'.
During facility tours, the inspector observed adequate material control and housekeeping practices.
The inspector reviewed selected monthly PCE reports documented by the licensee for the year 1994 to present.
For the year 1994 to present, the licensee had a total of 187 occurrences.
Of the 187 PCEs documented by the licensee, 79 involved skin contaminations and 108 involved clothing contaminations.
Of the 187 PCEs, 18 involved hot particles for skin and clothing contaminations while 46 of the skin contaminations were facial.
For RF05 the licensee established a goal of 100 yet later changed that goal to 150.
During RF05 the licensee documented 168 PCEs, 73 involved skin contaminations and 95 involved clothing contaminations.
All 46 of the facial contaminations documented for the year 1994 to present were incurred during the outage.
Although the overall goal for PCE occurrence was not met, the licensee attributed this to decreased respirator usage, increased outage work scope and new craft personnel who had very little nuclear power plant experience.
Review of selected contamination events noted that licensee documentation and followup on the individual events were appropriate, and skin dose assessments were performed, when required.
For those selected reports reviewed, resultant exposures were minor and not significant.
One NRC Identified NCV and no deviations were identified in this area.
e.
Radiation Detection and Survey Instrumentation During tours of the plant, the inspector noted that the portable radiation detectors, air samplers, and friskers and contamination monitors observed had up-to-date calibration stickers and appeared to have been source-checked as required.
In addition, at the time of the inspection the licensee appeared to possess an adequate number of operable survey instruments and related equipment.
Furthermore, background radiation levels at selected survey locations were observed by the inspector to be within an acceptable range.
No violations or deviations were identified in this area.
The inspector noted that at the time of the inspection the licensee maintained adequate housekeeping and contamination practices regarding the control of radioactive material throughout the licensee's facility to include the Auxiliary and Radwaste 8uilding Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA) (83750)
CFR 20. 1101(b) requires that the licensee use, to the extent practicable, procedures and engineering controls based upon sound RP principles to achieve occupational doses and doses to members of the public that are ALARA.
The inspector reviewed the license's program to maintain occupational exposures ALARA.
During discussions with licensee representatives, the inspector was informed at the time of inspection that the cumulative radiation exposure for the year 1994 to date was approximately 209.991 person-rem.
The licensee'.s original exposure goal was 250 person-rem but was changed to 222.500 person-rem because of activities not conducted during RF05 that the licensee had anticipated on collecting exposure.
With five months left in the calendar year the licensee appeared to be on target in meeting their collective exposure goal for the year with no more planned outages scheduled.
For RF05, the licensee's exposure was 195.435 person-rem which was below the exposure of 198 person-rem.
Through discussions with licensee representatives and a review of selected records, the inspector noted, at the time of the inspection, that the licensee was trending hot spots for historical reasons.
In addition, the licensee was in the process of finalizing a surrogate tour to assist in pre-briefs and job plannings for future outage and non-outage activities.
The inspector noted that these initiatives appeared to be beneficial in maintaining calendar year and outage exposures essentially as projected.
The inspector also reviewed ALARA committee meeting minutes and noted that the committee had met,once a month on three occasions since the last inspection to discuss and review ALARA initiatives involving selected RCA activities.
In addition, the inspector reviewed selected ALARA Improvement Requests with licensee representatives and found that the licensee had received 4 requests since the last inspection of which the licensee was still in the process of reviewing.
Through further review of selected records and discussions with licensee representatives, the inspector noted that through the licensee's ALARA incentive program each work group had been assigned monthly dose goals.
In the event a work group maintained their dose below their dose goal that group would be recognized through the incentives program for that achievement.
The inspector noted that the activities of the ALARA staff with the apparent support of site management appeared to be advancing the effectiveness of the sites ALARA program.
No violations or deviations were identified in this are.
Effectiveness of Licensee Controls (83750)
Through discussions between the inspector and licensee representatives and a review of selected records, the inspector noted that the licensee had completed a pre-INPO assessment.
During that assessment the licensee identified several areas of improvement in the area of RC to include radioactive material control and radiological posting.
Based on those observations and recommendations the licensee was in the process of conducting proposed actions to achieve and improve the licensee's activities in those areas identified.
No violations or deviations were identified in this area.
13.
Exit Heeting (83750)
At the conclusion of the inspection on July 29, 1994, 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 and indicated that no apparent violations or deviations were identified.
The licensee did not indicate any of the information provided to the inspector during the inspection as proprietary in nature and no dissenting comments were received from the licensee.
Upon further review by NRC, on August 1, 1994, the inspector informed the RC Hanager that the findings involving the individual who did not follow RC procedures prior to exiting the primary RCA would be identified as an NRC Identified NCV as discussed in Paragraph 10.d.
No dissenting comments were received by the licensee.
Item Number Status Descri tion and Reference 14.
50-400/94-16-01 Closed NCV - Failure of licensee employee to follow RC procedures prior to exiting the primary RCA (Paragraph 10.d).
Index of Abbreviations Used in this Report ACFR ALARA CBT CFR cm'P&L E&RC EAD HEPA HP HPP HRA INPO IR Adverse Condition Feedback Report As Low As Reasonably Achievable Computer Based Training Code of Federal Regulations Centimeters Squared Carolina Power
& Light Environmental and Radiation Control Electronic Alarming'Dosimeter Square Feet High Efficiency Particulate Air-filter Health Physics Health Physics Procedures High Radiation Area Institute for Nuclear Power Operations Inspection Report
mrem NAD NCV NRC NVLAP PCE RC RCA RC&PH RCRPP RCT Rev.
Hilli-Roentgen Equivalent Han Nuclear Assessment Department Non-Cited Violation Nuclear Regulatory Commission National Voluntary laboratory Accreditation Program Personal Contamination Event Radiation Control Radiation Control Area Radiation Control and Protection Hanual Radiation Control and Protection Program Radiation Control Technician Revision Re-Fueling Outage Resistance Temperature Detector Radiation Work Permit Total Effective Dose Equivalent Temporary Instruction Thermoluminescent Dosimeter Violation
0