ML14191A898
| ML14191A898 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 01/25/1988 |
| From: | Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14191A896 | List: |
| References | |
| 50-261-88-02, 50-261-88-2, NUDOCS 8802030427 | |
| Download: ML14191A898 (11) | |
See also: IR 05000261/1988002
Text
RE(,
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
<
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report No.:
50-261/88-02
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: Jnuary 4-8, 1988
Inspector: :
<
C. H. Bassett
ate igned
Accompnying Personnel: C. M. Hosey
Bermudez
Approved by c ,
C. M. Hosey, Section Chief
ate'Signed
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This was a routine, unannounced inspection in the area of radiation
protection including:
licensee action on previous enforcement matters;
organization and management controls; training and qualifications; external
exposure control; internal exposure control; control of radioactive materials
and contamination,
surveys and monitoring; the program for maintaining
exposures as low as reasonably achievable (ALARA); the solid waste program;
transportation and inspector followup on Information Notices.
Results:
Two violations were identified - (1) failure to perform an adequate
release survey on an item leaving the site, and (2) failure to document a
survey performed to release an item leaving the site,(no Notice of Violation
issued -
licensee identified).
8802030427 880128
PDR ADOCK 05000261
ci
REPORT DETAILS
1. Persons Contacted
Licensee Employees
- G. Beatty, Vice President, Robinson Nuclear Project Department
- D. Crocker, Radiation Control Supervisor
- R. Crook, Specialist, Regulatory Compliance
R. Hammond, Senior Specialist, ALARA
P. Harding, Project Specialist, Radiation Control Support
- E. Harris, Jr., Director, Onsite Nuclear Safety
- D. Quick, Acting Plant Manager
R. Smith, Manager, Environmental and Radiation Control
Other licensee employees contacted included radiation control foremen,
technicians, supervisors, security force members, and office personnel.
NRC Resident Inspector
R. Latta
- Attended exit interview
2. Exit Interview
The inspection scope and findings were summarized on January 8, 1988, with
those persons indicated in Paragraph 1 above. The inspector described the
areas inspected and discussed in detail an apparent violation for failure
to perform an adequate release survey on an item leaving the site
(Paragraph 8) and a licensee-identified violation concerning the failure
to document the survey performed to release the item leaving the site
(Paragraph 8).
Proprietary information is not contained in this report.
No dissenting comments were received from the licensee.
3. Licensee Action on Previous Enforcement Matters (92702)
(Closed) Violation 50-261/87-24-01, Failure to comply with radiological
control procedures for protective clothing and personnel frisking.
The
inspector reviewed and verified the implementation of the corrective
actions stated in Carolina Power and Light Company's (CP&L)
letter of
September 9, 1987.
The inspector verified that a training session was
held with the individuals- involved in the incidents along with other
workers who worked under Radiation Work Permit 87-0188.
The inspector
also verified that the subject of frisking requirements was incorporated
into the General Employee Training (GET)
Level 2 Annual Retraining
Program, and the incidents were discussed at routine monthly information
meetings. Corrective steps discussed in the referenced licensee's letter
were implemented as scheduled.
2
4. Organization and Management Controls (83722)
a. Organization and Staffing
The licensee is required by Technical Specification (TS)
6.2.3 to
implement the facility organization specified in TS Figure 6.2.2.
The inspector reviewed the plant organization with the Radiation
Protection Manager (RPM)
and discussed recent changes in personnel
and the organizational structure within the radiation protection
staff.
The licensee discontinued the use of health physics
contractors except for decontamination personnel.
Ihe health physics
organization consisted of a total of 47 persons, with one current
vacancy and a turnover of three employees through November 1987.
The
ALARA group recently began reporting directly to the RPM through the
Senior ALARA Specialist.
It appeared that the low turnover of in-house personnel, along with a
more direct line of communication between the RPM and the ALARA
group, positively affect the administration of the licensee's
radiation protection program.
b. Controls and Quality Assurance Surveillances
The inspector reviewed the licensee's reports dealing with
radiological problems including Plant Operating Experience Reports,
Radiation Safety Violation Reports and Nonconformance Reports issued
during the second half of 1987. It appeared that these systems were
functioning as intended in that problems were being identified,
investigated and corrected.
The inspector reviewed the following Quality Assurance Surveillance
Reports (QASRs):
QASR No.
Area
Date 87-054
Radwaste Shipping
6/29/87 87-064
Radwaste Shipping
7/29/87 87-072
Radiation Monitoring System
8/20/87 87-076
Radwaste Shipping
8/25/87 87-094
Radwaste Shipping
10/30/87 87-100
Personnel Dosimetry
11/18/87 87-106
Source Comparison
12/15/87 87-107
Radwaste Shipping
12/31/87 87-109
Radwaste Shipping
12/21/87
It was noted during the review of the Radwaste Shipping QASRs that
the surveillances were limited to ensuring that the necessary
documentation was filled. Quality Assurance personnel acknowledged
that additional training in the area of transportation of radioactive
3
materials related to the licensee's systems, procedures and controls
would enhance the Quality Assurance functions in this area.
No violations or deviations were identified.
5. Training and Qualifications (83723)
a. General Employee Training (GET)
The licensee is required by 10 CFR 19.12 to provide basic radiation
safety training for workers.. Regulatory Guides 8.13, 8.27, and 8.29
provide an outline of the topics that should be included in such
training/retraining programs.
The inspector and licensee representatives discussed an item
identified in Inspection Report
No. 50-261/8/-12
and further
discussed in Report No.
50-261/87-24 regarding the development of a
special retraining program for employees with marginal performance
during their GET.
Licensee representatives indicated that during
non-outage periods there are few instances in which employees perform
marginally during their GET due to the low volume of personnel being
processed. They indicated that the few cases of marginal performance
were being followed closely and that a full special retraining
program will be in place by the next outage.
b. Qualifications
Technical Specification 6.3.1 requires the radiation protection staff
to meet or exceed the requirements
and recommendations of
ANSI N18.1-1971 with regard to the minimum qualifications for
comparable positions.
The inspector reviewed the qualifications of selected members of the
licensee's health physics organization and discussed with licensee
representatives the licensee's Qualification Card Program.
The
inspector determined that
the qualification criteria of
had been met for the plant personnel
who's
qualifications were reviewed.
No violations or deviations were identified.
6. External Occupational Exposure Control and Dosimetry (83724)
a. Personnel Monitoring
10 CFR 20.202 requires each licensee to supply appropriate monitoring
equipment to specific individuals and requires the use of such
equipment.
During tours of the plant, the inspector observed workers wearing
appropriate personnel monitoring devices.
4
0
b. Personnel Exposure Control
The licensee is required by 10 CFR 20.101, 20.102, 20.201(b), 20.202,
20.401 and 20.407 to maintain workers' doses below specified levels
and to keep records of the exposures. The inspector reviewed the NRC
Form 5 equivalent computer printouts for calendar year 1987,
and
verified that the radiation doses recorded for plant personnel were
within regulatory limits.
c. Control of Radiation Areas
10 CFR
20.203
specifies the posting,
labeling and control
requirements for radiation areas, high radiation areas, airborne
radioactivity areas and radioactive material.
During tours of the plant, the inspector reviewed the licensee's
posting and control of radiation areas,
airborne radioactivity areas, contamination areas,
and radioactive
materials areas and the labeling of radioactive material.
The
inspector performed independent radiation surveys using NRC equipment
and verified that radiation fields measured were consistent with area
postings.
d. Skin Dose Assessment
The inspector reviewed the following plant procedures:
HPP-005, Control of Personnel Contamination and Decontamination
Techniques, Rev. 7, November 5, 1987
DP-019, Noble Gas Exposure Tracking and Skin Dose Calculations,
Rev. 0, December 31, 1987
HPP-105, Grab Air Sampling and Control of MPC-hours,
Rev.
10,
December 31, 1987
The inspector determined that the referenced procedures provide for
an adequate assessment of skin doses resulting from routine surface
contaminations and exposures to noble gases.
e. Personnel Contamination Events
During 1987,
there were 231 personnel contamination. events, out of
which
132 were
skin contaminations
and
99 were clothing
contaminations.
Skin doses associated with these events were well
below regulatory limits.
f. Hot Particle Program
The inspector discussed with.licensee representatives the status of
the facility's Hot Particle Program. The inspector was informed that
5
the licensee is not currently experiencing hot particle problems but,
due to a small amount of fuel leakage being observed at the facility
and increased industry awareness of the potential
problems,
procedures
and training exercises were being developed and
implemented to prepare personnel in the event the problem occurred.
The inspector reviewed the capabilities of the licensee's laundry
services vendor for detecting hot particles in the laundry. Licensee
representatives indicated that during the next outage they intend to
test for fuel leakage around several fuel bundles prior to tuel
reloading.
They indicated that results of the tests will provide a
good indication of the potential for the spread of contamination,
including hot particles, around plant systems and areas.
In addition, the licensee is currently performing calibration studies
to accurately determine the activity present in hot particles.
No violations or deviations were identified.
7. Internal Exposure Control and Assessment (83725)
10 CFR 20.103(a) establishes the limits for exposure of individuals to
concentrations of radioactive materials in air in restricted areas. This
section also requires that appropriate bioassays be performed to detect
and assess intakes of radioactivity.
10 CFR 20.103(b)(2) establishes a
40 MPC-hour/week control measure which requires investigation of the
circumstances surrounding such exposures.
The inspector reviewed Plant Procedure DP-018,
Personnel Whole Body
Counting,
Rev. 6, dated June 15,
1987.
The inspector noticed that the
referenced procedure established an investigation action level of 5% of
Maximum Permissible Organ Burden (MPOB).
The inspector pointed out that
for radionuclides commonly found in the facility, such as Co-60, Cs-137
and
Cs-134,
the 40 Maximum Permissible Concentration-hour
(MPC-hr)
equivalent in terms of % MPOB, as per ANSI N343-1978 methodology, is less
than 5%.
The inspector indicated that this could result in the licensee
inadvertently missing the 40 MPC-hr/week control measure required by
Licensee representatives indicated that they
currently investigate all positive whole body counts regardless of whether
or not the 5% MPOB action level is reached.
Licensee representatives
indicated that they will evaluate the adequacy of Procedure DP-018.
The inspector reviewed selected personnel exposure records for 1987 which
showed positive whole body counts and the documentation related to the
licensee's investigation of the circumstances surrounding the various
uptakes.
No violations or deviations were identified.
6
8.
Control
of Radioactive Materials and Contamination,
Surveys,
and
Monitoring (83726)
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 20 and (2)
are reasonable under the circumstances to
evaluate the extent of radiation hazards that may be present.
10 CFR 20.401(b) states that each licensee shall maintain records showing
the results of surveys required by Section 20.201(b).
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,
1978,
recommends written
procedures for contamination control.
Plant Procedure HPP-004, Radiological Controls of Tools and Equipment,
Revision 12,
November 5, 1987,
Section 10.1.4.2, states as release
criterion that items must not display any detectable activity, i.e., no
smearable beta contamination and
less than 100 ccpm total beta
contamination for unconditional release.
On October 6, 1987, while trying to exit the Protected Area, an individual
alarmed the exit portal monitor. Upon using the frisker in the area, the
individual noted that his left hand was reading greater than 100 counts
per minute (cpm).
He immediately notified Health Physics. The individual
indicated that he had entered the Protected Area late in the day and had
not gone inside the Radiation Control Area (RCA).
The Health Physics
group then performed surveys inside the construction fabrication shop
where the individual said he had been working.
The construction worker
had been working on the Dry Storage Canister Mock-up (DSCM).
This item
was found to have contamination levels as high as 190,000 disintegrations
per minute per 100 square centimeters (dpm/100 cm2), which is
approximately equivalent to 19,000 cpm/100 cm2 . Areas on the floor of the
fabrication shop were found to be contaminated up to 2,500 cpm.
Surveys
of other areas inside and outside the Protected Area detected no
contamination.
The licensee's review determined that on September 14, 1987, the DSCM was
released from the RCA to the fabrication shop and on October 1, 1987, had
been sent to an offsite.machine shop for modifications.
The DSCM was
returned to Robinson on October 5, 1987.
A team of Health Physics
personnel was dispatched-to the machine shop to perform surveys of the
facility. A survey of a lathe used to cut the DSCM revealed some low
levels of fixed contamination (60 to 150 cpm) in the metal chips.
These
areas were cleaned, and the metal chips collected and returned to the
Robinson plant.
After cleaning, a final survey of the machine shop was performed and no
contamination found. The licensee's fabrication shop employees as well as
7
two employees from the offsite machine shop were whole body counted.
No
radioactive material normally associated with nuclear .power
plant
operations was detected.
The licensee's investigation of the incident revealed that the radiation
control technician who released the DSCM from the RCA had not performed an
adequate survey in that the survey failed to include the inside bottom
surface of the DSCM.
In addition the radiation control technician who
released the DSCM from the RCA failed to document the release survey. The
release survey was documented by the technician from memory after the
event was discovered.
Corrective actions performed by the licensee included the development and
implementation of a training program for radiation control technicians
covering release survey procedures and the importance of procedural .
compliance.
Licensee management also reviewed the site's historical data
associated with identified contamination control weaknesses and did not
observe a downward trend.
Failure to perform an adequate release survey of the DSCM was identified
as an apparent violation of 10 CFR 20.201(b) (50-261/88-02-01).
Failure to document the release survey of the DSCM was identified as an
apparent violation of 10 CFR 20.401(b).
However, since the finding was
identified during the licensee's investigation, and the licensee's actions
met the criteria in 10 CFR 2, Appendix C, Section V.A, for credit as
licensee-identified violation, no Notice of Violation will be issued
(50-261/88-02-02).
9. Maintaining Exposures ALARA (83728)
a. The ALARA Program
10 CFR 20.1(c) states that licensees should make every reasonable
effort to maintain radiation exposures as low as reasonably
achievable (ALARA), taking into account the state of technology, the
economics of improvements in relation to benefits to the public
health and safety and other societal
and socioeconomic
considerations.
The inspector reviewed portions of the licensee's program for
maintaining occupational
exposures
including the ALARA
Suggestion Program, ALARA Training Program for Technical Staff and
the actions of the Radiation Exposure Reduction Task Force.
(1) The ALARA Suggestion Program
During 1987 the licensee received 19 ALARA suggestions. Action
on three suggestions had been completed by the time of the
inspection.
The inspector reviewed the ALARA Problem Report Log
and noted that some suggestions had been in evaluation status
8
for as
much
as nine months.
Licensee representatives
acknowledged the need to specify due dates for tracking the
status of suggestions. Licensee representatives also indicated
that they were concentrating on increasing the participation of
other groups in the facility since most of the suggestions were
being submitted by personnel in the Operations and Health
Physics groups.
(2) The ALARA Training Program for Technical Staff
Licensee representatives indicated that the corporate office had
an ongoing ALARA Design and Operations Training Program for the
technical staff.
On March 23, 1987, the corporate ALARA group
completed its evaluation of the licensee's existing engineering
processes for ALARA design improvements. An ALARA Design Guide
specific to the licensee's needs was nearing completion at the
time of the inspection.
Revisions to the training program were
also in progress and were scheduled for completion in 1988.
(3) Radiation Exposure Reduction Task Force
In July 1985, a Radiation Exposure Reduction Task Force issued a
Radiation Exposure Reduction Program. The program consisted of
the development of action plans with associated milestones in
the following areas:
(a) Supervisory accountability regarding radiation safety,
personnel exposure reduction and radwaste volume reduction.
(b) Worker awareness of radiation safety, ALARA and radwaste
reduction responsibilities.
(c) Radiological work environment.
(d) Improvement of the company's ALARA program visibility and
employee awareness and involvement.
All proposed development action items were completed and their
implementation began in early 1987, except for two items. These
were:
(1) the review of the present planning and scheduling
priority system and necessary revisions to ensure that high
dose/low benefit jobs were worked last or not at all, and (2)
the establishment of employee incentives to promote involvement.
Both
items were still under review at the time of the
inspection; however, the licensee had begun a smaller version of
the employee incentive program by publishing posters and
newsletters illustrating outstanding contributions to the ALARA
Program made by facility personnel.
9
b. Collective Exposures
The licensee's total cumulative exposure for 1987 was approximately
480 person-rems, compared to a goal of 450 person-rems. Unscheduled
work during the previous outage accounted for approximately
50 person-rems.
The estimated collective exposure for 1988 is 540 person-rems.
The
total dose is expected to be distributed as follows:
routine operations
111 person-rems
generic outage (scheduled
for mid-August 1988)
225 person-rems
special modifications
during the outage
204 person-rems
No violations or deviations were identified.
10.
Solid Wastes (84722)
10 CFR 20.311(d)(1) requires the licensee to prepare all waste such that
the waste is classified in accordance with 10 CFR 61.55 and meets the
waste characteristic requirements specified in 10 CFR 61.56.
The licensee identified four separate waste streams used in their program
of waste classification.
These are dry active waste (DAW)
and reactor
coolant system, waste processing system and the spent fuel pit system
wastes.
The waste streams are sampled for analysis every fuel cycle or
every time concentrations of major gamma-emitting radionuclides change by
a factor of 10.
Licensee representatives indicated that no significant
variability in relative concentrations was observed during 1987.
They
indicated that, historically, the main reason for changes in relative
concentrations of radionuclides has been fuel leaks.
The inspector observed the use of a vendor-supplied computer program which
processes input information obtained from a package of waste to determine
the package's waste classification and transportation type.
The program
identified non-gamma emitters based on scaling factors determined by the
corporate staff for the particular waste stream from which the waste was
generated. The program accounted for the generation of daughter products,
calculated radiation levels and activity contents as a function of time
and generated the package's shipping papers for special recipients.
Through direct observation and discussions with technicians who use the
program, the inspector noted that a high degree of care must be exercised
during data input since the program will not identify discrepancies such
as excessive radiation levels or activity contents for the type of package
that could be caused by typographical errors during data input.
Licensee
4I
10
representatives indicated .that computer printouts were thoroughly reviewed
by qualified personnel before disposition of the waste packages.
By the end of 1987, the licensee had disposed for burial approximately
3,571 cubic feet (ft3) of radioactive waste. This consisted of 1,870 ft3
of compacted
DAW,
445 ft 3 of noncompactible
DAW,
321 ft 3 of resins,
696 ft3 of evaporator bottoms and 239 ft3 of filters.
In addition, the
licensee had 1,280 ft3 of uncompacted waste at the licensee's vendor
facility scheduled for compaction and and less than 800 ft3 of uncompacted
waste onsite.
The licensee's vendor can reduce the volume of DAW by a
factor of approximately 6 through the use of a high pressure compactor.
No violations or deviations were identified.
11.
Transportation (86721)
10 CFR 71.5 requires the licensee to prepare shipments of radioactive
materials in accordance with Department of Transportation regulations in
49 CFR Parts 1/0 through 189.
The inspector reviewed the shipping paperwork for selected shipments made
during the second half of 1987. The manifests and related documents were
being completed and maintained as required.
No violations or deviations were identified.
12.
Followup on Information Notices (IN)
(92717)
The inspector determined that the following Information Notices had been
received by the licensee, reviewed for applicability, distributed to
appropriate personnel and that action,
as appropriate,
was taken or
scheduled.
IN 87-03: Segregation of Hazardous and Low-Level Radioactive Wastes
IN-87-07: Quality Control of Onsite Dewatering/Solidification Operations
by Outside Contractors
Blocking, Bracing,
and Securing of Radioactive Materials
Packages in Transportation
Control of HotParticle Contamination at Nuclear Power Plants