ML14175B322
| ML14175B322 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/20/1985 |
| From: | Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B320 | List: |
| References | |
| 50-261-85-24, NUDOCS 8509160216 | |
| Download: ML14175B322 (11) | |
See also: IR 05000261/1985024
Text
C1-Cp.FtREG(,t
UNITED STATES
0 oNUCLEAR
REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
)
ATLANTA, GEORGIA 30323
AUG 2 7 1985
Report No.:
50-261/85-24
Licensee:
Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC
27602
Docket No.:
50-261
License No.:
Facility Name:
H. B. Robinson
Inspection Conducted: July 29 -
August 2, 1985
Inspector: ___________/___
T. R. Collins
D te S/gned
Accompanying Per
nnel-
. G
Approve by:
,C,--C.
.
se, -&E~ion Chief
Date Signed
Division of Radiation Safety and Safeguards
SUMMARY
Scope: This routine, unannounced inspection entailed 36 inspector-hours onsite
during regular hours inspecting the radiation protection program including
instruments and equipment used for radiation protection of personnel; posting,
labeling, and control of radiological control areas; radiation work permit
controls; shipment of radioactive materials, internal and external
exposure
controls; training and qualifications of personnel;
10 CFR 61 requirements;
licensee's program for maintaining radiation exposures as low as reasonable
achievable (ALARA), and previously identified inspector followup items.
Results:
Two violations -
Failure to take suitable airborne radioactivity
measurements
in the
containment
seal
table
room
as
required
by
and failure to follow written procedures as required by
Technical Specification 6.5.1.1.1.
8509160216 850827
ADOCK 05000261
050002610
2
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- C. W. Crawford, Acting Plant General Manager
- R. M. Smith, Manager, Environmental and Radiological Control
- D. Baur, Quality Assurance Supervisor
- R. Barnett, Supervisor, Instrumentation and Control
- A. R. Wallace, Director, Onsite Nuclear Safety
- R. Denney, Radiation Control Supervisor
- C. Wright, Senior Specialist Regulatory Compliance
- P. Harding, Radiation Control Project Specialist
B. Ritchie, Radiation Control Forman
M. Crabtree, Radiation Control Foreman
M. Burch, Radiation Control Foreman
J. Petitgout, ALARA Specialist
Other licensee employees contacted included four technicians, three
mechanics, two security force members, and six office personnel.
Other Organizations
Institute of Resource Management, Inc.
NRC Resident Inspectors
- H. Krug, Senior Resident Inspector
- H. Whitcomb, Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on August 2, 1985, with
those persons indicated in paragraph 1 above. Two violations were discussed
with licensee management. One violation was for failure to follow written
procedures as required by Technical Specification 6.5.1.1.1 and the other
involved a failure to take an appropriate air sample as required by
10 CFR 20.103(a)(3). Both violations were a result of work performed on the
incore detectors in the seal table room of reactor containment.
Licensee
management took no exceptions. The licensee did not identify as proprietary
any of the materials provided to or reviewed by the inspectors during this
inspection.
3
3.
Licensee Action on Previous Enforcement Matters
(Closed) Violation (50-261/84-10-04) Labeling of containers with radioactive
material labels. The inspector reviewed and verified the corrective actions
stated in Carolina Power and Light Company's (CP&L) letter of June 1, 1984.
(Closed) Unresolved Item (50-261/85-09-01) Radiation exposure received by a
visitor without completing General Employee Training (GET).
The inspector
reviewed and verified the corrective actions taken by the licensee which
included a procedure revision to DP-001,
Dosimetry Issuance, controlling
radiation exposure received by each visitor to less than 100 mrem in a year.
No violations or deviations were identified.
(Closed) Violation (50-261/85-09-02)
Unauthorized entry into high radiation
areas > 1000 mrem/hr.
The inspector reviewed and verified the corrective
actions as stated in CP&L's letter of March 29, 1985.
4.
Significant Event During Entry to the Seal Table Room (93711)
Through reviews of
licensee records and discussions with licensee
representatives the inspector determined the following:
a.
On the morning of July 16, 1985, two individuals entered the seal table
room to do preliminary work on incore detector system using a routine
radiation work permit (RWP) 4012. The work was unsuccessful and they
exited the area. Subsequently, the licensee determined that a second
entry would be made to 1) correct the problem in "C" 5th path incore
detector drive system and 2) replace the "D" incore detector.
A
radiation control (RC)
technician was assigned the responsibility for
job coverage by the RC foreman and was told that the foreman would be
in the area to direct activities. The RC technician looked at previous
surveys for the area and noted that general radiation levels around the
"C" detector box was 50 mR/hr with smear surveys of 130,000 dpm/100
cm2 . At 1:35 pm six individuals entered the seal table room to change
out the "D" incore detector.
An Instrumentation and Control (I&C) foreman and RC foreman were on the
scene directing the activities of their personnel.
A qualified health
physics (HP) technician was there to perform necessary surveillance of
the work.
When the maintenance personnel opened the cabinet that
contained the cable and associated couplings, dose rate measurements
revealed 200-300 mR/hr towards the back of reel and about 400 mR/hr
general area.
Because of concern with the radiation levels,
no
contamination surveys were taken.
Upon exiting the area the individuals discovered facial and nasal
contamination on their person. The individuals were immediately taken
to dosimetry for whole body counting. Preliminary results indicated
that they all had inhaled radioactive contamination
and that the
maximum exposed individual contained 80% of a maximum permissible organ
4
burden in the upper gastrointestinal (GI)
tract.
A more complete
analysis of this individual on 7/17 revealed the following activities:
% MPOB
% MPOB
microcuries
Isotopic
lung
lower torso
lower torso
-0-
28
333
Co-58
1.0
37.21
335
3.0
165.82
498
1-133
-0-
10
31
b.
Technical Specification 6.5.1.1.1 requires that written procedures be
established, implemented and maintained covering applicable procedures
recommended in Appendix A of Regulatory Guide 1.33, Rev. 2,
February 1978.
Appendix A Regulatory Guide
1.33 states that the
licensee should
have radiation protection procedures governing a
radiation work permit system, and respiratory protection.
Plant Programs Procedure PLP-16,
Radiation Work Permit (RWP)
Program,
required an
RWP to be written for a specific task.
Health Physics
Procedure HP-006, Section 5.6, Control of Internal Dose, required that
respiratory protection or stay times be utilized to maintain internal
exposures "As
Low As Reasonably Achievable"
(ALARA).
The inspector
reviewed Radiation Work Permit (RWP)
4012,
surveys, qualifications of
the personnel performing the work and training of the individuals
involved. A review of the RWP revealed that a general (non
specific
RWP) RWP was used to control the activities of the work.
Failure to use a specific RWP for the seal table work as required by
Plant Procedure PLP-16 was identified as an apparent violation of
TS 6.5.1.1.1 (50-261/85-24-02).
Discussions with licensee representatives indicated that there were no
contamination surveys taken inside the detector cabinet prior to the
work. Post event followup surveys revealed contamination levels in
excess of 2 million dpm per 100 cm2 . An analysis of these levels prior
to the work would have indicated that respiratory protection should be
considered to maintain exposures ALARA.
Failure to use respiratory
protection or stay times to maintain internal exposures ALARA was
identified as another example of an apparent violation of Technical
Specification 6.5.1.1.1 (50-261/85-24-02).
c.
10 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 in this part,
and (2)
are reasonable under the
circumstances to evaluate the extent of radiation hazards that may be
present.
10 CFR 20.201(a) defines "survey"
as an evaluation of the
radiation hazards incident to the production, use, release, disposal,
or presence of radioactive materials or other sources of radiation
under a specific set of conditions.
When appropriate, such evaluation
5
includes a physical survey of the location of materials and equipment,
and measurements of levels of radiation
or concentrations of
radioactive material present.
10 CFR 20.103(a)(3) requires the licensee to use suitable measurements
of concentrations of radioactive material in air for detecting and
evaluating airborne radioactivity in restricted areas.
The inspector reviewed the airborne radioactivity survey records and
noted there were no airborne radioactivity measurements taken in the
breathing zone of the workers either before, during or after the
detector replacements.
Failure to make appropriate airborne radioactivity surveys to evaluate
the hazard present
was
identified as
an apparent violation of
(50-261/85-24-01)
The inspector reviewed the results of the analysis performed for the
positive counts that were related to the seal table incident.
The
inspector discussed the assessments and corrective actions with the
supervisor of the Instrumentation and Control technicians that had
positive counts.
The inspector also reviewed the MPC-hours for the
seal table incident and discussed action taken for all staff receiving
greater than 40 MPC-hrs in one week.
The inspector had no further
questions.
5. Training and Qualifications (83723)
a. Basic Radiation Protection Training
The licensee was required by 10 CFR 19.12 to provide basic radiation
protection training to workers.
Regulatory Guides 8.27, 8.29,
and
8.13,
outline topics that should be
included in
such training.
Chapters 12 and 13 of the FSAR contain further commitments regarding
training. The inspector discussed the initial and refresher general
employee radiation
protection training (GET) with the Training
Supervisor. The inspector attended GET training sessions for selected
topics. The inspector reviewed the GET training records for selected
workers to determine if
records reflected adequate completion of GET
initial and refresher training.
b. Radiation Protection and Chemistry Technician Qualification
The licensee was required by Technical Specification 6.3 to qualify
radiation protection
and chemistry technicians in accordance with
ANSI N18.1. The inspector reviewed the training records for selected
technicians to assure all topics were completed.
The inspector
discussed, with one radiation protection technician, the qualification
program and assignments to assure that they had not been assigned to
work independently and had been qualified for assigned tasks.
6
c. Radiation Protection and Chemistry Foreman Qualifications
Technical Specification 6.4 required radiation protection and chemistry
supervisory staff have four years experience in their specialty.
The
inspector discussed, with one foreman from the radiation protection
department, his training and experience
and selected duties and
responsibilities of the position.
The inspector reviewed the records
of this individual's experience.
No violations or deviations were identified.
6. Organization and Management Controls (83722)
a. Organization
The licensee was required by Technical Specification 6.2 to implement
the plant organization specified in Figure 6.2-2.
The responsi
bilities, authorities,
and other management controls were further
outlined in Chapters 12 and 13 of the FSAR.
Technical Specification 6.5.1.6 specified the members of the Plant Nuclear Safety Committee
(PNSC) and outlined its functions and authorities. Regulatory Guide
8.8 specifies certain functions and responsibilities to be assigned to
the Radiation Protection Manager and radiation protection responsi
bilities to be assigned to line management.
The inspector reviewed recent changes to the plant organization, to
determine their effect on plant radiological controls, by examining the
resulting
changes
to
administrative
procedures
and
position
descriptions and discussing the changes with the Manager of Environ
mental and Radiological Control.
The inspector discussed with a radiation protection foreman, the type,
methods of,
and degree of interaction between plant groups.
The
inspector discussed with the Manager of Environmental and Radiological
Control (E&RC) and a Radiological Control Foreman, how frequently they
toured the plant and radiation control areas.
b. Staffing
Technical Specification 6.2.3 specified mimimum plant staffing.
Chapters
12 and 13 also outlined further details on staffing.
The
inspector discussed authorized staffing levels vs.
actual on-board
staffing separately with the Manager of E&RC.
The inspector examined
shift staffing for the dayshift on July 31,
1985, to determine if
it
met minimum criteria for radiation protection.
.
No violations or deviations were identified.
7
0*
7.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring
(83726)
The licensee was required by 10 CFR 20.201(b) 20.403, and 20.401 to perform
surveys to show compliance with regulatory limits and to maintain records of
such surveys. Chapter 12 of the FSAR further outlines survey methods and
instrumentation. Technical Specification 6.5.1.1 required the licensee to
follow written procedures. Radiological control procedures further outlined
survey methods and frequencies.
a. Surveys
The inspector observed, during plant tours, surveys being performed by
the radiation protection staff.
The inspector reviewed selected
Radiation Work Permits
(RWP)
to determine if
adequate controls were
specified. The inspector discussed the controls and monitoring with
the radiation protection technician assigned and one worker for each
task.
During plant tours, the inspector observed radiation level
and
contamination survey results outside selected cubicles.
The inspector
performed independent radiation level surveys of selected areas and
compared them to licensee survey results.
The inspector reviewed
selected survey records for the month of July 1985 and discussed with
licensee representatives methods used to disseminate survey results.
The inspector assured that all locked high radiation areas outside
containment were locked as required by Technical Specification.
b.
Frisking
During tours of the plant, the inspector observed the exit of workers
and movement of material from contamination control to clean areas to
determine if
proper frisking was performed by workers and that proper
direct and removable contamination surveys were performed on materials.
c.
Instrumentation
During plant tours, the inspector observed the use of survey
instruments by plant staff and compared plant survey meter results with
results of surveys made by the inspector.
The inspector examined
calibration stickers on radiation protection instruments in use by
licensee staff and stored in the radiation protection laboratory.
The
inspector discussed with radiation protection technicians the methods
for doing instrument source checks prior to each use and calibration
methods.
d.
Release of Materials for Unrestricted Use
The inspector discussed with a radiation protection technician the
program for survey-out of items from contaminated areas and reviewed
the procedures for such release.
The inspector observed release
8
surveys
performed
by
radiation
protection
technicians,
and
documentation of results.
During tours of plant areas, the inspector
observed posting of containers and performed independent surveys to
determine if containers of radioactive material were properly
identified.
No violations or deviations were identified.
8.
Facilities and Equipment (83727)
FSAR Chapters 1 and 12 specified plant layout and radiation protection
facilities and equipment. During plant tours, the inspector observed the
operation of the contaminated clothing laundry, the flow of traffic thru
change rooms, the use of temporary shielding and the use of glove bags, and
ventilated containment enclosures.
No violations or deviations were identified.
9. Audits
The licensee was required by Technical Specification 6.5 to perform audits
of radiological controls and chemistry operations.
The inspector reviewed
audits of the radiation protection operations for the year of 1985,
the
responses to these audits, and the status of selective corrective actions
resulting from the audits.
The inspector discussed the results of these
audits with licensee representatives. These audits identified several items
needing corrective action. Corrective action had been initiated for all
items.
The audits were conducted using staff members with technical
backgrounds in radiological controls.
No violations or deviations were identified.
10.
Tranportation (86721) and Solid Radwaste (84722)
The licensee was required by 10 CFR 71.5 to prepare shipments of radioactive
material in accordance with DOT regulations.
The inspector observed the
preparation of a shipment of solidified oil and dry active waste
and
discussed the shipment with the shipping supervisor, clerk, and radiation
protection technician. The inspector reviewed the procedure under which the
shipment was made and the resulting documentation.
The inspector made
confirmatory radiation level measurements of the shipment.
10 CFR 20.311 requires a licensee who transfers radioactive waste to a land
disposal facility to prepare all waste so that the waste is classified in
accordance with
and
meets
the
waste
characteristics
requirements of 10 CFR 61.56.
It further establishes specific requirements
for conducting a quality control program and for maintaining a manifest
tracking system for all shipments.
The inspector reviewed the following
plant procedure for the packaging, classifying, and tracking of radioactive
waste shipped to low-level waste burial facilities:
0
9
HPP-201, Shipment of Radioactive Materials
The inspector reviewed the methods used by the licensee to assure that waste
was properly classified, met the waste forms and characteristics required by
10 CFR 61 and met the disposal site license conditions and discussed the use
of these methods with licensee representatives.
Technical Specification 6.5.1.1 requires the licensee to prepare waste for
burial in accordance with a Process Control Program (PCP).
The inspector
discussed the provisions of the PCP with licensee representatives and during
tours of the plant, observed the processing, control and storage of solid
waste.
The inspector reviewed selected manifests prepared for waste
shipments made during the period July 1985 to verify that a tracking system
was being used to insure that shipments arrived at the intended destination
without undue delay.
No violations or deviations were identified.
11.
External Occupational Dose Control and Personal Dosimetery (83724)
During plant tours, the inspector checked the security of the locks at
several locked high radiation areas and observed posting of survey results.
a.
Use of Dosimeters and Controls
The licensee was required by 10 CFR 20.202, 20.201(b), 20.101, 20.102,
20.104, 20.402, 20.403, 20.405,
19.13,
20.407, and 20.408 to maintain
worker's doses below specified levels and keep records of and make
reports of doses.
The licensee was required by 10 CFR 20.203 and
Technical Specification 6.13 to post and control access to plant areas.
FSAR Chapter 12 also contained commitments regarding dosimetry and dose
controls.
During observation of work in the plant, the inspector
observed the wearing of TLDs and pocket dosimeters by workers.
Also
the inspector observed the posting of areas and made
independent
measurements of dose to assure proper posting.
b.
Dosimetry Results
The inspector reviewed the TLD results for 1984 and for the first two
quarters of 1985.
No violations or deviations were identified.
12.
Internal Exposure Control and Assessment (83725)
The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403, and
20.405 to control uptakes of radioactive material, assess such uptakes, and
keep records of and make reports of such uptakes.
FSAR Chapter 12 also
includes commitments regarding internal exposure control
and assessment.
The inspector observed operation of whole body counter and discussed its
operation and results with the counter operator.
10
No violations or deviations were identified.
13.
Maintaining Occupational Doses ALARA (83728)
10 CFR 20.1(c) specifies that licensees should implement programs to keep
workers' doses ALARA.
FSAR Chapter 12 also contains licensee commitments
regarding worker ALARA actions.
a. Worker and Supervisor Actions
The inspector discussed dose control measures with five workers on the
job and one maintenance supervisor to determine their degrees of
involvement in dose reduction.
The inspector discussed with selected
supervisors their actions to reduce individual and collective doses,
concentrating particularly on staff members with highest doses.
The
inspector also discussed these actions to set dose goals for tasks,
methods used to reduce doses, and techniques used to monitor
performance against goals.
b. ALARA Procedure Changes
The inspector reviewed recent changes to administrative procedures that
implemented the elements of ALARA.
The inspector discussed these
changes with the Manager of E&RC and the ALARA Coordinator.
c. ALARA Reviews
The inspector reviewed the ALARA committee minutes during
1985 and
discussed resulting actions with the Manager of Environmental
and
Radiation Control
(E&RC)
and the ALARA Coordinator.
The inspector
noted that a number of outstanding engineering items had been carried
on the ALARA action list for several years. A licensee representative
stated that a recent organization and management change should improve
this situation.
d. ALARA Reports
The inspector reviewed the ALARA
man-rem projection for 1985 and
discussed the results with the ALARA Coordinator and Manager of E&RC.
The goal for 1985 is 375 man-rems. The total cumulative dose to date
for 1985 was 205 man-rems. This represents 55% of the 1985 goal.
The
inspector reviewed the following plant goals and noted the current
status of these goals for 1985:
0t
Current status as of
Goal
7/26/85
% of Goal for 1985
15,000 ft3
11,575.5 ft3
77.17%
of Radioactive waste
7,500 square feet
9652 ft2
129%
of contaminated areas
Less than 500
243 events
48.6%
contaminated events
(40 skin and 210 clothing)
No violations or deviations were identified.
14.
Previously Inspector Identified Items (92701)
(Closed)
Inspector Follow-up Item (IFI)
50-261/84-14-02 Formalize contract
health physics (HP) technicians training program. The inspector reviewed
the licensee's procedure ERC-12, Contract Health Physics Personnel Training
and Qualification Program which formalizes the training and qualification of
contract
Technicians to assure personnel
meet ANSI N18.1, 1971
requirements.
O (Closed)
IFI 50-261/84-05-02 ANSI N18.1,
1971 qualifications of contract
health physics technicians. Corrective actions as stated above addresses
this issue.
15.
IE Information Notices (92717)
The following IE Information Notices were reviewed to ensure their receipt
and review by appropriate licensee management:
IN-84-75, Defective Detector Tubes Model No. 71623 for Eberline Analog
Teletector Model 6112B.
IN-85-06, Contamination of Breathing Air Systems
IN-85-46, Clarification of several aspects of removable radioactive
surface contamination limits for transport packages
IN-85-48, Respirator users notice: Defective self-contained breathing
apparatus air cylinders