ML17221A519
| ML17221A519 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/18/1987 |
| From: | Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17221A517 | List: |
| References | |
| 50-335-87-27, 50-389-87-26, IEIN-86-107, IEIN-87-003, IEIN-87-007, IEIN-87-019, IEIN-87-028, IEIN-87-031, IEIN-87-19, IEIN-87-28, IEIN-87-3, IEIN-87-31, IEIN-87-7, NUDOCS 8711230304 | |
| Download: ML17221A519 (11) | |
See also: IR 05000335/1987027
Text
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STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report Nos.:
50-335/87-27
and 50-389/87-26
Licensee:
Florida Power
and Light Company
9250 West Flagler Street
Miami,
FL
33102
. Docket Nos.:
50-335
and 50-389
Fac'ility Name:
St. Lucie
1 and
2
License Nos.:
and
Inspection
Conducted:
October 26-30,
1987
Inspector:
M ~dd
C.
H. Bassett
ApprOVed by:
.
I~XiI'J~s,I
,C.
M. 'sey,
Secti
n Chief
Division of Radiation Safety
and Safeguards
@i~ f
ate Signed
I<id y7
Date Signed
SUMMARY
Scope:
This
was
a routine,
unannounced
inspection
in the area of radiation
protection including:
external
exposure
control; internal
exposure
control;
control
of radioactive
material
and
contamination,
surveys
and monitoring;
health
physics
aspects
of the outage;
and followup on previous
open items
and
IE Notices.
Results:
One violation with two examples
was identified:
failure to adhere to
radiological control
procedures
for personnel
contamination monitoring and for
properly wearing protective
hoods
as required.
871i2303D4 87iii8
ADO'5000335
Q
P~
REPORT DETAILS
Persons
Contacted
.Licensee
Employees
- K. N. Hams, Site Vice President
- G. J. Boissy, Plant Manager
- N. G.
Roos, guality Control Supervisor
- C. L. Burton, Reliability Maintenance
Supervisor
- H. F. Buchanan,
Health Physics Supervisor
- J. H. Barrow, Operations
Superintendent
- R. E. Cox, Chemistry Supervisor
- J. Krumins, Site Engineering Supervisor
- D. H. West, Technical Staff Supervisor
- R. Dawson, Electrical Maintenance
- R. N. NcCullers, Health Physics
Operations
Supervisor
- H. N. Mercer, Health Physics
Technical
Supervisor
- P.
G. Bailey, Health Physics
Corporate Staff
- B. N. Parks, guality Assurance
Supervisor
- G. R. Madden, Licensing Engineer
L. L. Lange,
Health Physics Assistant Operations
Supervisor
L. R. Baker, Health Physics Administrative Supervisor
K.
W. Payne,
ALARA Supervisor
V. E. Nunne,
Health Physics Shift Supervisor
L. E. Jacobus,
ALARA Coordinator
Other
licensee
employees
contacted
included
technicians,
operators,
mechanics,
security office members
and office personnel.
Nuclear Regulatory
Commission
- R. V. Crlenjak, Senior Resident
Inspector
"Attended exit interview
2..
Exit Interview
'he
inspection
scope
and findings were
summarized
on October
30,
1987,
with those
persons
indicated
in
Paragraph I
above.
The
inspector
described
the
areas
inspected
and
discussed
in detail
an
apparent
violation for failure to adhere
to radiation control
procedures
with two
examples
(Paragraph
7).
The licensee
acknowledged
the inspection findings
and took
no exceptions.
The licensee
did not identify as proprietary any
of the material
provided to or reviewed
by the inspector
during this
inspection.
Licensee Action on Previous
Enforcement Matters
This subject
was not addressed
in the inspection.
4.
Organization
and Nanagement
Controls
(83722)
a ~
b.
Organization
and Staffing
The licensee
is required
by Technical Specification (TS) 6.2.2 to
.implement
the facility organization. specified'n .TS Figure .6.2-2.
Technical Specification 6.2.2 also specifies
the minimum staffing for
the plant.
The inspector
reviewed the plant organization
and the staffing of the
health
physics organization with the Health Physics
Supervisor.
It
was noted that the support
received
from other members of management
was
a'dequate
to maintain
an effective radiation protection, program.
It was
also
noted
that
the health
physics
organization
was fully
staffed
and that there apparently
were sufficient contractor health
physics
technicians
to support
the outage
in progress
and maintain
adequate
control over the work involved.
Controls
The inspector
reviewed
the licensee's
Radiological
Incident Reports
written since the last inspection in July 1987.
The system
appeared
to
be functioning
as
intended
and
problems
were being investigated
and corrected
as required.
No violations or deviations
were identified.
5.
External
Exposure Control
and Dosimetry (83724)
a
~
b.
'Personnel
Nonitoring Devices
10 CFR 20.202 requires
each
licensee
to supply appropriate
personnel
monitoring devices
to specific individuals
and require
the
use of
such
equipment.
During tour s of the Unit 2 Reactor
Containment
Building (RCB) and other areas
of the Radiation Control Area
(RCA),
the
inspector
observed
workers
wearing
appropriate
personnel
monitoring devices.
The inspector
also
reviewed
and
observed
the
determination
of need,
use
and
placement
of multiple badging
and
extremity monitoring.
Radiologically Controlled Areas
specifies
posting
and
control
requirements
for
radiation areas,
airborne radioactivity areas,
and radioactive material
areas.
During plant tours,
the inspector
observed
the licensee's
posting
and
control
of radiation,
high radiation,
airborne radioactivity
and
radioactive material
areas.
The inspector also verified that various
locked
in the Reactor Auxiliary Building (RAB)
were being maintained
locked as required.
High radiation
areas
accessible
to personnel
in the Unit 2
RCB with
radiation levels
such that
a major portion of the whole body could
receive
in
one
hour
a
dose
in excess
of one
thousand
millirem
(1,000 mr)
and which could not be enclosed
or locked were roped off,
conspicuously
posted
and marked with a flashing light as required
by
4
Personnel
Exposure
Control
The
licensee
is
required
by
and
102 to maintain
workers'oses
below specified
levels.
The
inspector
reviewed
selected
occupational
exposure
histories of contractor
and licensee
personnel
and verified that the licensee
was requiring
a completed
Form
NRC-4 or its equivalent
to
be maintained
on file prior to
permitting
an
individual
to
exceed
the
limits specified
in
The
inspector
also
reviewed
the
Form
NRC-5
equivalent printout for the plant
and determined
that the radi.ation
exposures
recorded
were within the quarterly limits specified
above.
Dosimetry Reports
The inspector
reviewed selected
Self-Reading
Pocket Dosimeter
(SRPD)
and Thermoluminescent
'Dosimeter
(TLD) Discrepancy
Reports
and Lost,
Offscale or Abnormal
TLD/SRPD Reports.
The reports
and
subsequent
dose
assignments
made
following appropriate
investigations
of the
occurrences,
when applicable,
appeared
adequate.
No overexposure
investigations
had
been
performed
since
the
preceding
inspections
because
no
exposures
exceeding
local administrative
or regulatory
limits had occurred.
Personnel
Contamination
The inspector
reviewed
selected
Personnel
Contamination
Reports
and
reviewed the calculations
made to determine
dose to the skin due to
the
contamination.
The
calculated
skin
doses
ranged
from
45 millirem (mr) to 558 mr.
All reports
appeared
to be adequate
and
the
calculations
and
methodology
used
were
consistent
with
Dose Calculation for Contamination of the Skin Using
the
Computer
Code
VARSKIN, August
1987.
The licensee's
revised
procedure for skin dose
assessment
was also reviewed.
The procedure,
HP-72,
Revision 3,
Determination
of
Dose
to the
Skin
from Skin
Contamination,
dated
September
25,
1987,
appeared
to be adequate
as
well.
Radiation
Work Permit
(RWP) Program
Health
Physics
Procedure,
HP-l, Revision 22, Radiation
Work Permits
dated
September
3, 1987, specifies
the requirements
for issuing
RWPs.
In general
an
RWP is required for:
(1) entry into the
Reactor
Containment Building, (2) entry into a high radiation area,
(3) entry
into an airborne radioactivity area with airborne activity equal
to
or greater
than
25K of the
Maximum Permissible
Concentration
(MPC)
and (4) work involving equipment or surfaces
contaminated
to levels
greater
than 10,000 disintegrations
per minute per one hundred
square
centimeters
(dpm/100 cm').
The,inspector
reviewed selected
RWPs with respect
to the adequacy of
the
requirements
specified
for radiation monitoring, radiation
and
contamination
surveys,
airborne monitoring, protective clothing and
dosimetry.
The requirements
listed
on the
appeared
adequate.
The inspector reviewed the following Unit 2
RWPs:
-87-3031
Inspect/Repair/Take
Measurements
(Including Divers) of the
UGS Lift Rig ICI Assembly Floor Plate
and
Support Plate
(62'levation
RCB).
-87-3313
Install/Remove
GENSIS and Related
Equipment in the Steam
Generators (18'levation
RCB)
-87-3332
Remove/Replace/Inspect
and
PT Steam
Space
Nozzles in the
Pressurizer
(62'levation
RCB)
-87-3336
Divers Assist
BSW in Disassembly of UT Equipment
(62'levation
RCB)
-87-3408
Install/Remove
Nozzle
Dams (18'levation
RCB)
-87-3410
RTD Replacement/Removal
and Inspections.
No violations or deviations
were identified..
6.
Internal
Exposure Control
and Assessment
(83725)
a ~
Air Sampling
and Bioassays
10 CFR 20. 103 establishes
the limits for exposure
of individuals to
concentrations
of radioactive materials
in air in restricted
areas.
Section 20. 103
also
requires
that
suitable
measurements
of
concentrations
of radioactive material in air be performed to detect
and evaluate
the airborne radioactivity in restricted
areas
and that
appropriate
bioassays
be performed to detect
and
assess
individual
intakes of radioactivity.
The inspector
reviewed
the results
of air samples
taken during the
current
outage.
The air
sample
log indicated that the airborne
radioactivity
had
seldom
been
above
25K of the
Maximum Permissible
Concentration
(MPC) of radionuclides
specified
in
Appendix B, Table 1,
Column 1,
and
the majority of those
instances
indicating levels
above
25K MPC occurred during the first two days of
the outage.
It was noted that the air samples
had
been evaluated for
alpha,
beta
and
gamma activity and analyzed
to determine
the specific
isotopes
present.
The results
of selected
whole
body counts
(WBC) and the licensee's
assessment
of intakes
of radioactive material
performed
since
the
last inspection
were also reviewed.
No instances
were noted in which
personnel
received
greater
than
the
limits
specified
in
b.
c ~
Engineering Controls
10 CFR 20.103(b)(l) requires
that the licensee
use
process
or other
engineering
controls
to
the
extent
practicable
to
limit
concentrations
of radioactive materials
in the air to levels
below
those
which
specify
an
airborne
radioactivity
as
defined
in
20.203(d)(l)(ll).
During tours of the Unit 2
RCB and the
RCA, the inspector
observed
various
engineering
controls
employed
to limit concentrations
of
radioactive materials
in air.
These
included construction of tents
with associated
high efficiency particulate air
(HEPA) filters and
the
use
of auxiliary ventilation ducting.
The ducting
used
to
support
work in the
steam
generators
was set
up such that air could
be drawn through either the hot or the cold leg depending
on the work
and air flow requirements.
The air was then directed
through
filters or into the regular containment ventilation system.
Respiratory Protection
Program
10 CFR 20. 103(b)
requires
that,
when it is impracticable
to apply
process
or
engineering
controls
to limit concentrations
of
radioactive
materia'ls
in air
below
25K of the
concentrations
specified
in Appendix B,
Table 1,
Column 1,
other
precautionary
measures
should
be
used
to maintain
the
intake of radioactive
material
by any individual within seven
consecutive
days
as far below
40 MPC-hrs as is reasonably
achievable.
Through
records
review, observations
and discussions
with licensee
representatives,
the inspector
evaluated
the respiratory protection
program including training, fit testing,
MPC-hr assignments,
quality
of breathing air
and
issue,
use,
decontamination
and
storage
of
respirators.
Review of the
MPC-hr
assignments
for
selected
individuals revealed that all exposures
were well under the 40 MPC-hr
per week control level.
No violations or deviations
were identified.
7.
Control of Radioactive Material
and Contamination,
Surveys
and Monitoring
(83726)
a ~
Surveys
The licensee
is required
by
and 20.401 to perform
surveys
and to maintain
records
of such
surveys
necessary
to show
compliance
with
regulatory
limits.
Survey
methods
and
instrumentation
are
outlined in
Chapter
12, while
TS 6. 11
provides
requirements for adherence
to written procedures.
During plant tours,
the
inspector
examined
radiation
levels
and
contamination
survey
results
posted
outside
selected
rooms
and
cubicles.
The inspector also
performed
independent
radiation level
surveys
of selected
areas
and
compared
them with licensee
survey
results.
No violations or deviations
were identified.
b.
Frisking
Technical Specification 6.11 requires
that procedures
for personnel
radiation protection
be prepared
consistent
with the requirements
of
and
be
approved,
maintained
and
adhered
to for all
operations
involving personnel
radiation exposures.
Health Physics
Procedure,
HP-70, Revision 6, Personnel
Contamination
Monitoring and Decontamination,
dated
September
25,
1987, requires
in
Section 8. 1.3 that
personnel
exiting the
RCA who have
been
in
a
contaminated
area
perform
a whole body frisk.
During tours of the plant, the inspector
observed
the exit of workers
and
movement of materials
from the
RCA to the clean
areas
of the
plant to determine if proper frisking was being performed
by workers
and proper fixed and transferable
contamination
surveys
were being
performed
on materials.
No
problems
were
noted with material
surveys;
however,
personnel
frisking deficiencies
were noted.
During the afternoon of October 28,
1987,
the inspector
observed
licensee
and contractor personnel
exiting the Unit 2
RCB and frisking
at the access
point in the Reactor Auxiliary Building (RAB) and the
craft
RCB access
point near the equipment hatch.
In bothareas,
four
friskers
with
hand
held
probes
were
provided
for personal
contamination monitoring.
No frisking deficiencies
were noted at the
access
point
but
5
out
of
16 people
noted
exiting
the
contaminated
area at the craft
RCB access
point failed to perform an
adequate
whole body frisk.
The
5 individuals all frisked their hands
and feet plus varying isolated portions of their bodies
but did not
perform
a complete whole body frisk.
Failure of personnel
to perform
a complete
whole
body frisk upon
exiting
a contaminated
area
as required
was identified as
an example
of
an 'pparent
violation
of
TS
6. 11
(50-335/87-27-01
and
50-289/87-26-01).
c ~
Protective Clothing
Technical
Specification 6.1l.requires
that procedures
for personnel
radiation protection
be prepared
consistent
with the requirements
of
and
be
approved,
maintained
and
adhered
to for all
operations
involving personnel
radiation exposures.
Health
Physics
Procedure,
HP-50,
Revision 7,
Protective
Clothing
Requirements,
dated
June
18,
1987,
requires
in Section 4.2 that
protective clothing
be worn in such
a
way
as to cover the
maximum
part of the body for which it was designed.
On October 28,
1987, the inspector toured the Unit 2
RCB and observed
various
jobs in progress
including removing
items
used
during the
outage
from the
RCB,
in-service
inspection
work
and
a diving
operation
in the Refueling Cavity near the reactor
vessel
to untangle
cables
and rigging gear associated
with a vendor's ultrasonic testing
(UT) device.
The inspector
also
reviewed
the
procedure
used
to
control
the health
physics
aspects
of the dive,
HP-25, Revision 0,
Radiological
Controls for Underwater
Diving Operations
in the
RCA,
dated
August
13,
1987.
The dive appeared
to
be well covered
and
adequately controlled.
The procedure
also appeared
to be adequate.
During this tour,
the inspector
noted
numerous
workers wearing the
protective
caps or hoods with the flaps tied or attached
behind their
heads.
When
asked
about this practice,
licensee
health
physics
representatives
stated that this was
an improper practice but that it
often occurred
due to the elevated
temperatures
and uncomfortable
conditions
inside the
RCB.
The licensee
agreed,
however, that the
protective clothing should
be worn as it was designed
to be worn.
Failure of personnel
to adhere
to the procedural
requirements
for
wearing protective clothing was identified as
a second
example of an
apparent violation of. TS 6.11 (50-335/87-27-01
and 50-389/87-26-01).
d.
Caution Signs,
Labels,
and Controls
10 CFR 20.203(f) requires that each container of licensed radioactive
material
bear
a
durable,
clearly visible label
identifying the
contents
when
quantities
of radioactive
material
exceed
those
specified in Appendix C.
During plant tours, the inspector verified
that containers
of radioactive material
were labeled
as required
and
that proper controls were established.
No violations or deviations
were identified.
8.
Maintaining Occupational
Exposure
As
Low As Reasonably
Achievable
(ALARA)
(83728)
10 CFR 20. 1(c) specifies
that
licensees
should
implement
programs
to
maintain workers'oses
Other
recommended
elements
of an
program
are
contained
in Regulatory
Guides 8.8
and 8.10.
The
FSAR,
Chapter
12,
also
contains
licensee
commitments
regarding
worker
actions.
a.
Outage
The
inspector
- reviewed
the
jobs
involved
and
the
exposures
accumulated
during the outage
to date with licensee .representatives.
The more significant jobs being performed
and the person-rem,expended
are
as follows:
Nozzle
dam installation
Pressurizer
nozzle modification
. Sludge lancing
pump insulation
removal/replacement
RTD replacement
Health Physics
coverage/support
b.
Goals
and Objectives
6.9 (completed)
7.7
4.7 (completed)
14.8
4.5
14.0
The
person-rem
goal for the
outage
was
220
and
as of October 30,
1987,
140 person-rem
had
been
expended.
The annual
goal for the
facility was set at
884 while
a total of 637 person-rem
has
been
accumulated
to date.
Personnel
contaminations
have increased
from a
total of 227 for 1986 to .477 for the current year to date.
The
licensee
indicated that the increase
was basically
due to the fact
-that there
was
a Unit 2 outage in 1986 whereas
both Units have
had
an
outage
in
1987.
The Unit
1 outage
during February
through April
accounted for 306 personnel
contaminations.
No violations or deviations
were identified.
9.
Audits (83724,
83725,
83726,
83728)
The licensee
is required
by
TS 6.5 to perform audits of radiological
control operations.
The inspector
reviewed selected
audits
and surveillances
performed
by site
guality Assurance
personnel.
The audits
and surveillances
appeared
to be
of adequate
depth
and
were
performed
by personnel
with appropriate
technical
backgrounds.
No violations or deviations
were identified.
10.
IE Information Notices
(92717)
The inspector'determined
that the following NRC Information Notices
(IENs)
have
been
received
by
the
licensee,
reviewed
for applicability,
distributed
to appropriate
personnel
and that actions,
as appropriate,
were taken or scheduled.
a.
IEN 86-107:
Entry Into,PWR Cavity with Retractable
Incore Detector
Thimbles Withdrawn
b.
IEN 87-03:
Segregation
of Hazardous
and Low-Level Radioactive
Wastes
c.
IEN 87-07:
guality= Control of Onsite
Dewatering/Solidification
Operations
by Outside Contractors
d.
IEN 87-19:
Perforation
and
Cracking
of
Rod
Cluster
Control
Assemblies (Specifically for all Westinghouse
PWRs)
I
e.
IEN 87 28.
Air Systems
Problems at U.S. Light Water Reactors
f.
IEN 87-31:
Blocking, Bracing,
and Securing of Radioactive Materials
Packages
in Transportation.