ML14176A795
| ML14176A795 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/17/1989 |
| From: | Collins T, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A791 | List: |
| References | |
| 50-261-89-22, NUDOCS 8911060406 | |
| Download: ML14176A795 (5) | |
See also: IR 05000261/1989022
Text
SREG(
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
0 1 ;
ATLANTA, GEORGIA 30323
OCT 16 198q
Report No.:
50-261/89-22
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 Conducte
September 11-15, 1989
Inspector:
// /0
ST. Collin
Da e igned
Approved by:
0.
)
Potter, Chief
D. e igned
Facilities Radiation Protection Section
Emergency Preparedness and Radiological
Protection Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This was a routine, unannounced inspection in the area of radiation protection
includino:
Licensee action on previous enforcement matters; organization and
management controls; control of radioactive materials and contamination surveys
and monitoring; and followup on an event where the licensee failed to perform
adequate surveys of materials,
and radioactive/contaminated material was
released outside the protected area to an unauthorized recipient.
Results:
One violation was identified - failure to perform an adequate release survey on
an item leaving the site.
On July 31, 1989, welding equipment actually with
contaminated levels up to 8,500 dpm/100 cm2 was shipped, as uncontaminated, to
an offsite vendor.
Nine other uncontrolled or undocumented contaminated
releases from a Radiation Control area to other onsite areas were noted since
October,
1987.
Corrective actions taken by the licensee appeared to be
adequate to preclude recurrence of similar events.
8911060406 891017
PDR ADOCK 05000261
Q
PNU
REPORT DETAILS
1. Persons Contacted
Licensee Employees
- M. Burch, Radiation Control Support
- R. Crook, Senior Specialist Regulatory Compliance
- J. Curley, Director, Regulatory Compliance
- M. Crabtree, Radiation Control Foreman
C. Dietz, Manager of Robinson Nuclear Project Department
- A. Eaddy, Environmental and Radiation Control (E&RC) Supervisor
- S. Griggs, Technical Aide, Regulatory Compliance
- A. McCanley, Principal Engineer
- D. Morgan, General Manager
- D. Nelson, Maintenance Supervisor
- M. Page, Technical Support Manager
- B. Ritchey, Radiation Control Foreman
CJ.
Shepperd, Manager of Operations
- R. Smith, Manager of euRC
- B. Toney, Radiation Control Foreman
Other licensee employees contacted included radiation control foremen,
technicians, supervisors, security force members, and office personnel.
GNuclear
Regulatory Commission
L. Garner, Senior Resident Inspector
K. Jury, Resident Inspector
- Attended exit interview
2. Occupational Exposure, Shipping and Transportation
a. Organization, Staffing, and Management Controls
The licensee is required by Technical Specification (TS) 6.2.3 to
implement the facility organization specified in TS 6.2.2.
The inspector reviewed the proposed plant reorganization with the
Project Manager, Plant Manager and Manager of Environmental and
Radiological Controls (E&RC) and discussed proposed changes in
personnel
and the organizational structure within the radiation
protection staff.
Licensee management representatives informed the
inspector that a new Manager of E&RC would be appointed on
September 23, 1989 and the current- Manager of E&RC would be assigned
to Manager of Maintenance.
The inspector discussed with licensee
management that whomever they appointed as the Manager of E&RC must
meet the requirements
of TS 6.3.2 and Regulatory Guide 1.8,
2
September 1975.
Licensee management acknowledged the inspector
comments and stated that they would take appropriate actions as
necessary to satisfy the requirements of TS 6.3.2.
The inspector
informed licensee management representatives that the actions taken
by the licensee would be reviewed after the reorganization is
approved to determine the qualifications of the newly appointed
Manager of E&RC as required by T.S. 6.3.2.
No violations or deviations were identified.
b.
Control of Radioactive Materials and Contamination,
Surveys and
Monitoring
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 10 CFR Part 20,-and (2)
are reasonable under the
circumstances to evaluate the extent of radiation hazards that may be
present.
Plant Technical Specification 6.5.1.1.1.a requires written procedures
to be established, implemented,
and maintained to cover the
activities recommended in Appendix A of Regulatory Guide 1.33,
Revision 2, February 1978.
Appendix A of Regulatory Guide 1.33,
recommends written procedures for contamination control..
Plant Procedure
HPP-004,
Radiological Controls of Tools and
Equipment, Revision 4, dated May 9, 1989, Section 10.1.4.2, states a
release criterion that items must not display any detectable
activity, i.e., no smearable beta contamination and less than 100
background corrected counts per minute (ccpm) total
beta
contamination for unconditional release.
On August 30,
1989, the licensee was notified by a vendor who had
received tools and welding equipment that surveys indicated gross
contamination on several pieces of welding equipment.
Licensee
records revealed that this equipment had been surveyed and released
from the RCA and protected area on July 31, 1989.
On August 30,
1989, the licensee sent a Radiation Controls (RC)
representative to the vendor's facility to confirm the vendor survey
results.
On August 31,
1989, the RC representative notified the
Manager of E&RC that contamination levels on the welding equipment
were up to 850 counts per minutes (cpm) gross which is equivalent to
8,500 disintegrations per minute (dpm) and approximately equivalent
to 850 ccpm. The RC representative performed additional surveys of
the facility and area where the welding equipment was located and
found no detectable radioactivity.
The
inspector discussed this issue with licensee management
representatives and noted that a similar event had occurred in
October 1987 and that a Notice of Violation was issued in NRC
Report No. 50-261/88-02.
The licensee's corrective action was to
3
develop a training program for RC personnel and they also determined
that this event was an isolated problem. However, since that event
and the latest event of July'31,
1989, there have been nine other
events where tools or equipment have been either released outside the
and later found to be greater than the
100 ccpm (or
1000 dpm/100 cm2 ) or equipment was released outside the RCA without a
documented survey record.
None of these events resulted in offsite
contamination. These nine events were identified by the licensee, as
Non Conformance Reports (NCRs); however, the licensee did not believe
a programmatic breakdown had occurred in their radiation protection
program which allowed these events to occurs.
The NCRs were not
reviewed separately by the licensee to determine a historical trend.
Following the latest event of July 31, 1989, and after the inspector
discussed the other nine event NCRs where material was not surveyed
adequately, the licensee took the following corrective actions:
(1) All outgoing material will require a survey with an independent
verification prior to release from the RCA or Protected Area.
(2) All persons who will receive material from another nuclear
facility shall notify Radiation Control at the Shift Outage
Turnover Meeting or the SWAG Meeting to survey the material
prior to entry into the protected area.
(3) RC will increase surveillance in the following areas:
(a) Protected Area -
RC will perform random surveys of
non-permanent items on a weekly basis.
(b) Materials Control Areas - RC will perform daily surveys of
the Unit #1 and Unit #2 materials receiving areas.
(c) Maintenance/I&C Shop - RC will perform daily surveys of the
shop areas.
(d) RCA/Protected Area - Containers/boxes will be opened for a
survey of their contents prior to leaving the area.
(4) The licensee formed a Special Task Force to investigate and
evaluate the root cause analysis of these events.
The inspector concluded that the corrective actions taken by the
licensee appeared to be adequate to preclude further events
where materials could be released either outside the RCA or
Protected Area containing radioactive materials.
However, the
inspector informed licensee management representatives that
failure to perform an adequate release survey of the welding
equipment released offsite on July 31, 1989 would be considered
an apparent violation 10 CFR 20.201(b) (50-261/89-22-01).
4
3. Licensee Actions on Previous Enforcement Matters (92702)
(Closed) Violation 50-261/88-02-01, Inadequate release survey -of an item
leaving the plant site.
This item is discussed in Paragraph 2 where an
earlier similar violation had occurred. A Notice of Violation for the
latest event will be issued for failure to perform adequate surveys of
materials release offsite as required by 10 CFR 20.201(b).
4. Exit Interview
The inspection scope and finding were summarized on September 15, 1989,
with those persons indicated in Paragraph 1 above.
The inspector
described the areas inspected and discussed in detail a violation for
failure to perform an adequate release survey of an item leaving the site
(Paragraph 2) and the successive failures to perform adequate surveys of
tools and equipment released from the RCA,
as identified by the licensee.
The licensee did not determine that these earlier licensee identified
events were evidence of a programmatic breakdown and no root cause
analysis or adequate corrective actions were performed,
to preclude
similar events. Licensee management acknowledged the inspector's findings.
The licensee was informed of the status of the item in Paragraph 3.
Proprietary information is not contained in this report.
No dissenting
comments were received from the licensee.
Item Number
Description and Reference
50-261/89-22-01
VIO -
Failure to perform adequate
release surveys of tools and equipment
leaving the plant site as required by
10 CFR 20.201(b) (Paragraph 2).