ML17222A514
| ML17222A514 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 09/08/1988 |
| From: | Bassett C, Hosey C, Lauer M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17222A512 | List: |
| References | |
| 50-335-88-19, 50-389-88-19, IEIN-88-008, IEIN-88-032, IEIN-88-32, IEIN-88-8, NUDOCS 8809260181 | |
| Download: ML17222A514 (25) | |
See also: IR 05000335/1988019
Text
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Licensee:
Florida Power and Light Company
9250 West Flagler Street
Miami,
FL
33102
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W.
ATLANTA,GEORGIA 30323
gpi4$ %
Report Nos.:
50-335/88-19
and 50-389/88-19
Docket Nos.:
50-335
and 50-389
Facility Name:
St. Lucie
1 and
2
Inspection
Conducted:
August 1-5,
1988
Inspectors:
06CE446kf
C.
H. Bassett
License
NoseI
D te
igned
M.
.
uer
Approved by:~
'
C.
M. Hosey,
Section Chief
Division of Radiatio
Safety
and Safeguards
ate
Signed
Date Signed
SUMMARY
Scope:
This routine,
unannounced
inspection
was conducted
in the areas
of the
facility radiation protection
program including: organization
and
management
controls; training
and qualifications;
the solid radioactive
waste
program;
transportation
and the health
physics
aspects
of the Unit 1 outage.
Followup
on open items
and Information Notices
was also performed.
Results:
The licensee's
radiation protection
program continues
to be effective
in protecting
the health
and safety of occupational
workers.
However,
two
violations
were identified:
1) failure to perform adequate
surveys
and
2)
failure to.label
containers of radioactive material.
88092I~01 -.1 880914
ADOCK 05000835
0
REPORT
DETAILS
Persons
Contacted
Licensee
Employees
"'J. Barrow, Fire Protection Supervisor
- J. Barrow, Operations
Superintendent
- G. Boissy, Plant Nanager
- H. Buchanan,
Health Physics
Supervisor
- C. Bu'rton, Reliability Naintenance
Supervisor
.*C. Crider, Outage
Nanagement
Supervisor
R. Czarnecki,
Security Coordinator
- J. Danek,
Corporate
Health Physicist
R. Finch,
General
Employee Training Coordinator
T. Geissinger,
Administrative Supervisor
D. Haithcox, Health Physics
Radioactive
Waste Assistant
Coordinator
- J. Harper,
Superintendent
of equality Assurance
L. Jacobus,
ALARA Coordinator
- C. Leppla, Instrumentation
and Control Supervisor
- R. NcCullers, Health Physics
Operations
Supervisor
- L. NcLaughli n, Technical Staff
- H. Nercer,
Health Physics Technical
Supervisor
- R. Parks,
Project Nanager
K. Payne,
Health Physics
ALARA Supervisor
- C. Pell, Technical Staff
L. Pugh,
Nuclear Plant Coordinator
- B. Sculthorpe, Reliability and Support Supervisor
- C. Wilson, Nechanical
Nai ntenance
Supervisor
- E. Wunderlich, Reactor
Engineering Supervisor
Other
licensee
employees
contacted
included
technicians,
operators,
mechanics,
and office personnel.
Nuclear Regulatory
Commission
- G. Paulk, Senior Resident
Inspector
- H. Bibb, Resident
inspector
- Attended exit interview
and Initialisms used
throughout this report
are listed in the
last paragraph.
Organization
and Nanagement
Controls
(83722)
a.
The licensee
is required
by Technical Specification (TS) 6.2.2 to
implement
the facility organization
specified
in
TS Figure 6.2-2.
The
responsibilities,
authority
and
other
management
controls
necessary
for establishing
and maintaining
a health
physics
(HP)
program for the facility are outlined in Chapters
12 and
13 of the
Final
Safety Analysis Report
(FSAR).
TS 6.5. 1 also specifies
the
composition
of the Facility Review
Group
(FRG)
and outlines its
functions
and authorities.
The inspector
reviewed the licensee's
plant organization,
as well as
the responsibilities,
authority
and control
given to management
as
they relate
to the site radiation protection
program.
No recent
changes
in plant management
had been
made that would adversely affect
the ability of the licensee
to continue
implementing
the critical
elements
of the
program.
The inspector also discussed
the support
received for the radiation protection
program with the site Health
Physics
Supervisor
and determined that it was adequate
and improving.
Staffina
TS 6.2.2 also specifies
the minimum staffing for the facility.
Chapters
12 and
13 provide further details
on staffing levels at the
site.
The inspector
reviewed
the subjects
of the attrition rate,
use of
contractor
HP personnel,
promotions
and
actual
versus
authorized
staffing levels with licensee
representatives.
At -the time of the
inspection,
23 of the
24 senior technician
(ANSI) qualified positions
were filled and all
7 of the junior technician positions were filled.
One
new junior technician
position
was to
be
approved
in the near
future.
Due to the
outage
that
was in progress,
the licensee
had
acquired
the assistance
of 96 contractor
HP technicians
(techs),
specifically,
52 senior techs
and
44 junior techs.
Upon completion
of the
outage,
the
licensee
did not plan to continue to use
the
services
of any contractor
HP personnel.
The inspector
discussed
job coverage with the site
HP Supervisor
who
stated
that
a
new philosophy
had
been
adopted.
In the-past,
an
tech
was
assigned
to
oversee
all the
jobs
in
an
area
in the
facility/building (designated
"zone coverage")
and provide whatever
coverage
was
needed.
The
current
philosophy
is
to
provide
job-specific coverage.
The licensee
indicated that this could cause
some delays
in the work schedule
but that the extra coverage
provided
additional
and
needed
help in the
areas
of contamination
control,
exposure
control
and
proper
radiological
work practices.
The
inspector
noted that this type of coverage,
while being
an advantage
in terms of radiological control, might require
an increase
in staff
to support all the work.
Controls
The inspector
reviewed
the licensee's
Radiological
Incident Reports
for 1988, which were used to document safety incidents.
It was noted
i
3
that the reports all dealt with personnel
contamination.
Licensee
representatives
stated
that other incidents requiring
a Radiological
Incident Report
had not been identified for this time period.
The
inspector
discussed
this type of problem identification and reporting
system with the site
HP Supervisor
and the means
used to ascertain
the
root cause
and provide adequate
corrective actions, if required.
The
licensee
indicated
that
when
personnel
errors
are
detected,
the
required corrective
actions
are
completed
through
the corporate
or
company disciplinary
system.
When
a
problem
cannot
be
remedied
informally,
a person
is given
a letter of reprimand,
time off, or
terminated
as the case warrants.
No violations or deviations
were identified.
3.
Training and gualifications
(83723)
General
Employee Training
(GET)
10 CFR 19.12 requires that all individuals working in or, frequenting
any portion of
a restricted
area shall
be provided basic radiation
protection training.
The inspector
reviewed
lesson
plans for the licensee's
GET..
All
topics specified in 10 CFR 19.12 were covered in the course.
The
curriculum required approximately three
days to complete
and included
practical
factors with hands
on protective clothing
and
equipment
instruction,
information
on current
industry events,
and written
exam'icensee
representatives
stated that two contract instructors
had been obtained to assist
in GET training for the outage.
Licensee
training personnel
believed that with the additional staff, adequate
GET training was being provided for the large contingency of outage
personnel.
Selected training records of contractor personnel
working
in the radiation control area
(RCA) were reviewed.
b;
Requalification
GET requalification is required
annually
and presently
consists
of
the individuals taking the
same three
day class
taught during initial
qualification.
However, licensee
representatives
stated that in the
near future
a
new
one
day requalification class will be initiated
which will also include practical factors
and
a written exam.
The licensee
plans
to begin using
an
INPO generic radiation worker
course
and test covering plant specifics
and practical
factors
to
satisfy
10 CFR Part 19 requirements.
This course will be given to
individuals who have proof of GET training at another
INPO accredited
facility in the past year.
This
GET option should
be in place in
late
1988.
No violations or deviations
were identified
4.
Occupa iional Exposure
During Extended
Outages
(83729)
a.
External
Exposure Control
and Dosimetpy (83724)
Dosimetry Program
(2)
The licensee
is required
by
10 CFR 20. 101
and
102 to maintain
workers'oses
below specified levels.
10 CFR 20.202 requires
each
licensee
to supply appropriate
personnel
monitoring devices
to specific individuals and require the use of such equipment.
~,i~I see
external
exposure
control
and
personnel
dosimetry
programs
were
reviewed
by the
inspectors.
This
included
facilities, equipment,
personnel,
records,
and procedures
used
to control exposures
and determine
doses.
Exposure
records
of plant
and contractor
personnel
for 1988,
year-to-date
(YTD), were selectively
reviewed.
No exposure
qreater
than limits in
10 CFR 20. 101 or the stations
quarterly
administrative limit were noted.
The inspector verified that
the licensee
possessed
an
NRC
Form
4 for selected
individuals
exceeding
1250 mRem/quarter
as specified in 10 CFR 20.101(b).
A
review of the station's
Radiation
Exposure
Summary
Report for.
August 3, 1988; indicated
a maximum individual dose of 1865
mrem
for the current quarter.
The inspector
determined
that the licensee's
thermoluminescent
dosimetry
(TLD) program
had
been
accredited
by the National
Voluntary Laboratory Accreditation
Program
on July 1, 1988.
Extremity Yionitoring
Througii discussions
with licensee
representatives,
the inspector
determined
that
extremity
monitoring
for
the
hands
is
accomplished
using
a wrist TLD.
For selected
tasks in radiation
fields with steep
gradients,
the use of wrist dosimetry
can
be
nonconservative
in
measuring
extremity
doses
relative
to
finger-ring dosimetry.
NRC sponsored
studies
conducted
in this
area
suggest
that wrist TLDs underestimate
finger doses,
as
monitored with finger-ring TLDs, by
a factor of four.
Licensee
representatives
stated
that finger-ring TLDs will soon replace
wrist TLDs for extremity monitoring pending
vendor delivery of
equipment
and
system
testing,
tentatively
planned
for
implementation
by early 1989.
The inspector
reviewed individual
extremity
dose totals for the current quarter.
Even if the
above stated correction factor is applied,
doses
were well below
the
18.75
Rem limit specified in 10 CFR 20. 101.
The inspector
informed licensee
personnel
that the initiation of extremity
monitoring using finger-ring TLDs, including procedure revision
and test data,
would be reviewed during subsequent
inspections
and will be tracked
by the
NRC as
an inspector follow-up item
(IFI) (50-335/88-19-01).
Radiation
Work Permits
The
inspector
observed
selected
outage-related
work
being
performed
using
radiation
control
requirements
dictated
by
radiation
work permits
(RWP).
The inspector
noted that
many
included
general
requirements
such
as "air sample
as
required."
The licensee
was
informed that
such non-specific
guidance
could result in the nonconservative
interpretation of
job coverage
requirements
by an
HP tech controlling the work.
On
August 2,
1988,
the
inspector
observed
a job in which
dosimetry requirements
specified
on the
RWP, were not followed.
Specifically,
No. 88-1336, 62'CB:
Rethread
and
Repair
Incore Thimbles,
required wrist and
ankle
dosimetry,
however
workers
were
not wearing
ankle
dosimetry
while rethreading
thimbles,
Licensee
representatives
stated
that
dose
rate
gradients
to the ankles did not warrant use of ankle dosimetry
for the particular
portion of the job which the inspector
observed.
A review of the
dose rate gradients
present
during
the job evolution supports
the licensee's
statement.
Further
review
by the inspector
determined
that work began
under
No. 88-1336 approximately
three
days prior to the finding with
10 to
15 sign-ins
and that ankle dosimetry
was never issued in
support of the
RWP.
Licensee
representatives
stated that the
dosimetry
requirements
where
changed
by senior
HP techs with
verbal
approval
of the
HP Operations
Supervisor.
However, this
change
was not documented
in the
RWP.
Health Physics
procedure
HP-1, Radiation
Work Permits,
Revision
22,
dated
September
30,
1987,
and HP-2, Health Physics
Manual,
Revision 6, dated
August 6,
1987,
specify,RMP documentation
and
compliance
requirements.
A review of these
procedures
disclosed
inadequacies
in the requirements
covering changes
which are
made
to issued
RWPs.
Changes
in
RWP requirements
may
be
made
by
health
physics
personnel
followed
by
changes
in
the
documentation
"at
the
earliest
convenient
time."
A
clarification of "health physics
personnel"
was
not included,
therefore
possibly allowing
a junior technician
to make
such
changes.
Also, differentiation
between
documentation
and
management
review requirements
for
RWP changes
which increase
the radiation protection
requirements
and
those
changes
which
decrease
the
level
of protection
was
not included
in the
procedures'ome
ambiguity in the procedures
also existed.
The inspector
discussed
these
concerns
with the "Health Physics
Supervisor
who verbally
committed
to review
and revise
the
procedures
which control the issue,
use, termination,
and change
to an
RMP, to be completed
by September
30, 1988.
The licensee
was
informed that the revised
RNP procedure
would be reviewed
during subsequent
inspections
and tracked
by the
NRC as
an IFI
(50-335/88-19-02).
tio violations or deviations
were identified.
b.
Internal
Exposure Control
and Assessment
(83725)
Engineering
Controls
10 CFR 20. 103 (b)(l) requires
other engineering
controls to
concentrations
of radioactive
below
those
which delimit an
def i ned 20. 103(d) (1) (ii ) .
that the licensee
use
process
or
the extent practicable
to limit
materials
in the air to levels
airborne radioactivity area
as
(2)
During tours of the Auxiliary (Aux) Building and
the Unit 1
Reactor
Containment
Building (RCB), the inspector
observed
the
use
of various
engineering
controls
employed
to limit the
concentration
of radioactive material in air.
The licensee
used
enclosed
chemistry-type
hoods
and
vendor
supplied
sealed
chambers
to decontaminate
various tools
and items of equipment.
The
hoods
and
chambers
were
kept
under
negative
pressure
by
means
of high efficiency particulate air
(HEPA) filtration
systems
which
to
the filtered auxiliary ventilation
ducting.
In other areas
where personnel
were required to be in
close proximity to highly contaminated
items,
ducting was
used
to
draw air
away
from the
workers
and
into the filtered
ventilation
system.
Tents
had
also
been
constructed
and
equipped with
HEPA filtered ventilation
systems
to control
and
limit the spread of airborne radioactivity.
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
material
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 Maximum Permissible
Concentration-hours
(MPC-hrs)
as is
reasonably
achievable.
Through
records
review,
observations
and
discussion
with
licensee
representatives,
the
inspector
evaluated
the
respiratory
protection
program
including training,
medical
qualifica'tions, fit testing,
MPC-hr assignment,
and the issue,
use
and
storage
of respirators.
Review of respirator
issue
logs
indicated that only personnel
who
had
been
trained
and
qualified to wear
respiratory
protective
devices
were
issued
('3)
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
and that the MPC-hr calculations
were adequate.
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 concentration
of radioactive material
in air be performed to
detect
and evaluate
that 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 the air samples
taken
during the current
outage.
The air 'sample
log indicated that
the airborne
concentration
had
seldom
been
above
25% of the
Maximum
Permissible
Concentration
(MPC)
of
radionuclides
specified
in
Appendix
B, Table
1,
Column
1.
The
licensee
indicated that the outage
schedule
had been altered to
accommodate
a chemistry test that was to be performed just after
the reactor
shutdown.
This allowed extra time for the plant to
cool
down
and for additional
Reactor
Coolant
System
(RCS)
cleanup.
This
apparently
allowed sufficient time for the
elimination of almost all of the radioactive
iodine that is
normally present
upon initial entry into
containment.
The
licensee
indicated
that
a
complete
and
thorough
fuel
reconstituion
during the previous
outage
had also
helped with
the radioiodine
problems that
had
been
noted in the past.
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
(WBCs)
were also
reviewed.
No instances
were
noted in which'ersonnel
received
greater
than
the limits specified
in
Also,
as
noted previously,
no significant uptakes of radioactive material
had occurred
since the last inspection.
No violations or deviations
were identified.
Control
of Radioactive
Materials
and
Contamination,
Surveys
and
Monitoring (83726)
Surveys
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.
TS 6. 11
requires
that
procedures
for
personnel
radiation
protection
shall
be prepared
consistent
with the requirements
of
and shall
be approved,
maintained
and adhered
to
for all operations
involving personnel
radiation exposure.
Health Physics
procedure
HP-20, Area Radiation
and Contamination
Surveys,
Revision
7,
dated
June
18,
1987,
requires
in
Section 8.6.2. 1 that
any
area
containing
removable
surface
contamination
in excess
of 1000 disintegration
per minute per
one
hundred
square
centimeters
(dpm/100
cm~)
beta/gamma
or 20
dpm/100
cm~ alpha shall
be posted
as
a Contaminated
Area.
While touring
the facility, the
inspector
observed
workers
exiting the
Radiation
Control
Area
(RCA)
and
the
movement of
material
from the
RCA to clean
areas
to determine if'dequate
surveys
were being
performed
by workers
and if adequate
direct
and smearable
contamination
surveys
were preformed
on materials.
All personnel
and material
surveys
appeared
to
be
adequate.
Also during plant tours,
the inspector
examined radiatjon'evel
and contamination
survey results
posted
outside selected
areas.
The inspector
performed
independent
radiation level
surveys
of
selected
areas
using
NRC equipment
and
the results
compared
favorably with licensee
survey findings.
During tours of the yard,
the
RCB and the
Aux Building, the
inspector
also
observed
several
radioactive
material
storage
areas
and verified that
the
items
stored
therein
had
been
surveyed
and were properly labeled
and the areas
were properly
posted.
However,
during
a tour of the Unit 2 Cask
Washdown
Second
Floor
Roof area,
which
was
an
area
exposed
to the
environment, it was
noted
that
the
area
was
posted
as
a
radioactive material
area
but
no other postings
were present.
The roof was constructed
with
a raised
portion in the center
surrounded
by
a trough or slightly depressed
area
where water
could collect.
Portions of the trough
area
were
damp but no
drain was noted.
Various items, which were stored in the raised
area,
had
been partially wrapped in a hercul.ite-type material to
protect
them
from the
weather.
The
inspector
performed
radiation level
surveys
in the area
and,
along with a licensee
representative,
took several
smears
to verify that
no removable.
surface
contamination
was present.
Upon leaving the area
and
checking the smears,
contamination
levels to 50,000
dpm/100
cm~
were noted.
The licensee
was immediately notified and the area
was posted
as
a Contaminated
Area and the area
and items stored
there were decontaminated.
The
inspector
reviewed
survey
maps
of the
area
from the
preceding
weeks
and
determined
that the
area
had last .been
(2)
(3)
surveyed with no contamination
detected
on July 7,
1988.
The
licensee
indicated that .this
was
an
area
requiring
a weekly
survey
but
surveys
since
July
7
had listed
the
area
as
inaccessible.
It was
noted that the inadequate
surveys of the
roof area
lead to the area
not being propely posted.
Failure of
the
licensee
to perform
an
adequate
survey of the
area
to
determine
the
extent
of the radiation
hazards
present
was
identified as
an apparent violation of 10 CFR 20.201(b)
(50-335,
389/88-19-03).
Labeling of Containers
requires
that
each
container
of licensed
material shall
bear
a durable, clearly visible label identifying
the radioactive
contents.
states
that
a
label
shall
bear
the radiation
caution
symbol
and the words
"CAUTION, RADIOACTIVE MATERIAL" and that the label shall provide
sufficient information
(such
as
radiation
levels, find of
material,
estimate
of activity present,- etc.)
to
permit
individuals handling or using the container,
or working in the
vicinity thereof,
to take
precautions
to avoid or minimize
. exposures.
During the tour of the Unit 2 Cask
Waskdown
Second
Floor Roof,
it was
noted that several
items were being stored in the area.
The area
was posted
as
a radioactive material
area
but none of
the
items
stored
there
were
labeled
as
being
radioactive
material.
Two thermal
shield transfer
casks
and
some wire rope
slings,
which were
wrapped
in
a herculite-type material,
were
surveyed
and
found
to
have
radiation
levels
of about
one
millirem per hour (mr/hr) at contact.
The licensee
indicated
that these
items
had
been
used during
a recent fuel reracking
effort and
had
been
stored
on the roof for approximately five
months.
Failure of the licensee
to label containers
and items
of radioactive material
was identified as
an apparent violation
(50-335, 389/88-19-04).
Radiation Detection
and Survey Instruments
The inspector
reviewed the licensee's'use
of portable radiation
detection
instruments
for
routine
radiation
protection
activities.
During plant tours, the inspector verified that all
instruments
observed
in
use
had
been
calibrated within the
prescribed
time period
and observed
proper use.and
selection of
instruments
appropriate
for the radiation protection activity
required.
The inspector
reviewed issue log entries for selected
portable survey instruments identified in the field and verified
that the required battery
check, out-of-date calibration check,
and
source
check
had
been
performed
prior to its
issue.
Licensee
personnel
stated that the quantity and type of portable
10
radiation detection
instruments
were adequate
for the increased
radiation protection activities resulting from the outage.
Health Physics
Operating
Procedure
HP-111A, Set-up, Calibration
and
Weekly Functional
Test of the National
Nuclear Corporation
Gamma-10
Portal
l1onitor,
Revision
4
dated
March
22,
1988,
reouires
the monitor alarm to actuate
with the detection
of
approximately
450-500
nanocuries
of Cesium-137.
The inspector
verified that both Unit
1
and Unit 2 Aux Building exit portal
monitors functioned
as required
using
a 450 nanocurie
source of
Licensee
representatives
stated
that
six state-of-the-art
" '."'"-body friskers
(IPl1-8s)
were
on order
and that set-up
testing
documentation,
operating
procedures,
and calibration
procedures
were in draft form.
One of the Nuclear Enterprise
IPYi-8s ordered
was onsite for licensee familiarization and
was
demonstrated
for the inspector.
A detailed investigation of the
instrument's
capabilities
and
setup
configuration
was
not
conducted
during this
inspection
due to the early state
of
development of the project.
However, this initiative exemplifies
an effort
by the
licensee
to maintain
a quality personnel
contamination control program.
The inspector discussed
the use
and detection sensitivity of the
licensee's
laundry
monitor with licensee
representatives.
Licensee
representatives
stated
that
100% of all protective
clothing
(PCs)
are
monitored
inside
out.
The monitor was
calibrated using Tc-99 with detection efficiencies calculated
as
13.74
and 6.25K for the lower and upper detectors,
respectively.
The alarm setpoint
was
10,000
cpm which the licensee
calculated
as
being equivalent
to approximately
72 nanocuries
of Co-60.
Field tests
conducted
by the licensee
using actual
hot particles
found in the plant
showed that
a
141 nanocurie
Co-60 particle
placed
on the inside of the
PCs being monitored caused
an alarm
actuation
100% of the time.
d.
Maintaining Occupational
Exposure
As
Low as
Reasonably
Achievable
(ALARA) (83728)
10 CFR 20. 1(c) specifies
that
the
licensee
implement
programs
to
maintain workers
doses
Other recommended
elements of an
program are outlined in Regulatory
Guides 8.8
and 8.10.
The
FSAR,
Chapter
12, also contains
licensee
commitments
regarding worker ALARA
actions.
(1)
Projects for the Unit
1 Outage
When the Unit 1 outage
was initially planned,
various items were
considered
in order
to
keep
exposures
'ALARA and
reduce
the
actual
duration of the outage.
One item that
was
adopted
was
11
that of the air conditioning the
RCB.
The idea
was initially
advocated
as
a
way to
promote
worker confort
and
thereby
increase
productivity,
improve the quality of work (help to
eliminate
rework
as
much
as possible)
and
promote
the proper
wearing of personnel
PCs.
The licensee
not only found that
these
things were all accomplished,
but also discovered that the
number of personnel
contamination
events
had
decreased.
This
was attributed to the fact that the workers were perspiring less
and, therefore,
there
was less
leaching of contamination
through
the
PCs to the skin of the workers.
The licensee
indicated that
air conditioning
the
RCB will likely continue
in all future
outages.
Another item that was introduced
and adopted prior to the outage
was the construction of movable shielding that could
be placed
around
the
bottom of the
head after it was
removed
from the
reactor
and placed in storage
on the floor in upper containment.
The shielding
was constructed
of one inch of lead
poured into
semi-circular steel
frames.
The shielding
frames
were mounted
nn wheels
in order to facilitate moving the pieces
into place
around
the
head
stand.
The licensee'stimated
that
the
shielding
reduced
the
general
area
radiation
levels
in the
vicinity of the
head
15 mr/hr down to 3-5 mr/hr.
Other
items that were adopted
included the aforementioned
fuel
reconstitution that
was accomplished
during the previous
outage
and the
slow ramp-down of the reactor to allow for chemistry
testing
on the
secondary
side which allowed for better
and more
complete
cleanup of the
RCS and other associated
systems.
(2)
Outage
Exposure
The
inspector
reviewed
the
jobs
involved
and
the
exposures
accumulated
during
the
outage
to
date
.with
licensee
representatives.
The
more significant
jobs that
had
been
performed
and completed
and the person-rem
expended
on each
are
as follows:
Removal
and Install the Reactor
Head
and
Upper Guide Structure Lift Rig
Remove the Control Element Assembly Shafts
and .Install Sleeves
Clean the Reactor
Stud Bolts
Remove
and Install
Head 0-rings
Sludge
Lancing
13.93
12
(3)
Annual
and Outage
Goals
and Projections
The person-rem
projection for the outage
was
220 with a goal of
the 198.
As of June
30,
1988,
169 person-rem
had
been
expended.
The
annual
projection for 1988 was set at 609 person-rem with a
goal
of 548 for the entire facility.
As of June
30,
1988,
239 person-rem
had
been
expended
including
both
outage
and
normal operations
exposures.
Personnel
contaminations
have
been
reduced this year from a total of 613 for 1987
(which included
two outages),
to
a total of 205 skin and clothing contaminations
to date.
Job-specific
coverage,
proper
use
of
PCs
and air
condition the
RCB were factors cited
as contributing to this
marked decrease.
No violations or deviations
were identified.
5.
Solid Wastes
(84722)
a.
Waste
Sampling
and Characterization
requires
a
generating
licensee
who
transfers
radioactive
waste
to
a land disposal facility or to a licensed
waste
collector to prepare
all
waste
so that the
waste
is classified
according
to 10 CFR 61.55
and meets
waste characteristic
requirements
of 10 CFR 61.56.
The
inspector
reviewed
St.
Lucie Units
1
and
2 Scaling
Factor
Validation Report,
dated
March 10,
1987.
Principle waste
streams
were
analyzed
and
any
scaling
factors
of difficult to
measure
radionuclides
not within a factor of ten of the actual
measurements
were adjusted.
Inspection
Report
Nos. 50-335/86-09
and 50-389/86-08
described
an IFI (50-335/86-09-02
and 50-389/86-08-02) .in which the
licensee's
method
of isotopic
analyses
of process
filters
was
questioned.
Specifically, the licensee
was using
smears
instead of
filter media
as
samples for isotopic analyses.
-Consequently,
in 1986
and 1987, the licensee
performed
a comparison of the data from filter
media analysis
and filter smears.
The inspector
reviewed results of
these
comparisons,
both of which indicated
that
use
of
smears
resulted
in
a
more conservative
classification
than that obtained
with filter"media.
The use of smears
also resulted in a significant
man-Rem
savings.
Therefore,
the
licensee
indicated
that
smear
samples
are
justified
provided
periodic
re-verifications
are
conducted.
b.
Radioactive
Waste Disposal
Licensee
representatives
stated
that,
in 1987,
19,876 ft~ of,waste
containing,
1237 curies of activity was shipped offsite, either to
a
disposal
site
or vender
supercompactor.
In 1988, year-to-date,
6,620 ft~ containing
10,700 curies
of activity had
been
shipped
offsite.
Approximately 6,644 ft~ of waste
was stored onsite awaiting
13
C.
shipment.
Some liquid radioactive
waste
was
also
being
stored
onsite;
however,
the, licensee
had
not solidified any waste
since
1986.
Future solidification plans were not yet complete.
Audits
TS 6.5.2.8 requires
that audits
of the Process
Control
Program
and
implementing
procedures
for dewatering of radioactive
bead resin
be
performed
at least
once
per
24 months.
The inspector
reviewed .
Quality Assurance
Audit QSL-OPS-88-596,
dated
March 23,
1988.
The
audit appeared
to give greater attention to the implementation of the
Program rather
than the
adequacy
of the
Program
and its associated
procedures.
Discussions
with licensee
representatives
indicated that
the
auditor
lacked
significant
background
in radioactive
waste
processing.
Licensee
representatives
stated
that
the
auditor
currently
assigned
Process
Control
Program
reviews
has
a
more
appropriate
radioactive waste processing
background.
d.
Waste Reduction
Program
The inspector
discussed
radioactive
waste reduction initiatives with
licensee
representatives.
Several
projects
were
underway to reduce
the
amount of material
disposed
of in the
RCA, such
as the increased
use of washable
PCs
instead of disposable
PCs,
the
use of washable
trash
bags,
and the use of lighter weight anti-contamination
covering
material
equivalent to Grifflon and Herculite currently used.
Past
projects
focused
on decreasing
the
amount of material
being brought
into the
RCA which eventually
required disposal.
A trash monitor,
purchase'd
to separate
"clean" trash from the potentially contaminated
trash
and
reduce
the
amount of radioactive waste,
has
not yet been
put into service:
Set-up testing
has
been
performed
and procedures
for its use
have
been
approved.
Licensee representatives
stated that
lack of available
personnel
has prevented
use of the monitor.
A date
for initiation of
the
trash
sorting
project
had
not
been
estabilished.
The inspector
informed licensee
representatives
that
other facilities
have
found that
removal
of "clean"
trash
from
potentially contaminated
trash
had significantly reduced
the
amount
of radioactive waste requiring disposal.
e.
Clean
Waste
The
inspector
reviewed
the
licensee's
methodology for releasing
"clean" trash to the sanitary landfill.
The current method included
a survey of the
bagged trash
using
a Geiger Mueller detector.
The
inspector indicated to licensee
representatives
that
a more sensitive
instrument would be more appropriate for this type of release
survey.
The licensee
agreed
to assess
their trash
monitoring program for
possible
improvements.
This item will be tracked
by the
NRC as
IFI 50-335/88-19-05.
14
f.
Manifests
requires
that
each
shipment of radioactive waste to
a licensed
land
disposal
facility be
accompanied
by
a shipment
manifest
and specifies
required entries
on the manifest.
The
inspector
reviewed
selected
records
of radioactive
waste
shipments
performed during 1988,
and verified that the manifests
had
been properly completed.
No violations or deviations
were identified.
Transportation
(86721)
requires
that
a licensee
who transports
licensed
material
outside
the confines of its plant or other place of use,
or who delivers
licensed
material
to
a carrier for transport,
shall
comply with the
applicable
requirements
of the regulations
appropriate
to the
mode of
transport
of the
Department of Transportation
(DOT) in 49
CFR Parts
170
through
189.
The
inspector
reviewed
selected
records
of radioactive
waste
and
radioactive
material
shipments
performed
during
1988.
The
shipping
manifests
examined
were prepared
consistent with 49
CFR requirements.
The
radiation
and
contamination
survey
results
were within the limits
specified for the
mode of transport
and shipment classification
and the
shipping
documents
were being completed
and maintained
as required.
No violations or deviations
were identified.
Licensee
Actions
on Previsoulsy
Identified Inspection
Findings
(92701,
92702)
(Closed)
IFI 335/86-09-02
and 389/86-08-02;
Review Sampling Methodology
for Process
Filters to Verify Adequacy for Plant
10 CFR 61 Compliance.
See
Paragraph
5(a) for details.
(Closed) Violation 335, 389/87-04-03:
Failure to Properly Solidify Waste
and
to
Conduct
a
gC
Program
to
Ensure
that
the
Waste
Was
Properly
Classified.
The inspector
reviewed the licensee's
response
dated
April
.27,
1987,
and
verified that
the corrective
actions
specified
therein
had
been
taken.
The
inspector
also
reviewed
the
proposed
specification for contract
radioactive
waste solidification services.
The inspector
reviewed
the
licensee's
analysis
and
evaluations
of sampling
process
filters
and
verified that they were adequate
(Paragraph
S.a).
(Closed) Violation 335, 389/87-27-01:
Failure to Adhere to Radiological
Control
Procedures
for Frisking
and for Properly
Wearing
Protective
Clothing,
15
The inspector
reviewed
the licensee's
response
dated
December
23,
1987,
and verified that the corrective actions had
been
completed.
During the
inspection,
no instances
of personnel
contamination monitoring or frisking
problems
were noted
and all personnel
observed
were properly wearing the
required
PCs,
8.
Followup on IE Information Notices
(92717)
The inspector
determined that the following Information Notices
(IN) had
been received
by the licensee,
reviewed for applicability, distributed to
appropriate
personnel
and that action,
as
appropriate,
was
taken
or
scheduled.
Chemical
Reactions
with Radioactive
Waste
Solidification Agents
Prompt Reporting to
NRC of Significant Incidents
Involving Radioactive Naterial
9.
Exit Interview
The inspection
scope
and findings were summarized
on August 5, 1988, with
those
persons
indicated in Paragraph
1 above.
The inspector described
the
areas
inspected
and discussed
in detail
the inspection
findings listed
below.
No dissenting
comments
were received
from the licensee.
The licensee
did not identify as proprietary any of 'the material
provided
to or reviewed
by the inspector during this inspection.
Item Number
Descri tion and Reference
335/88-19-01
335/88-19-02
335, 389/88-19-03
335, 389/88-19-04
IFI - Followup on the testing
and use of finger
rings and the applicable
procedure
revision.
IFI - Followup on
RWP procedure
change to
further delineate
the methods of changing
RWPs.
Violation - Failure to provide adequate
surveys
on
a contaminated
area.
Violation
- Failure to label container of
radioactive material.
335/88-19-05
IFI - Followup on assessment
of trash monitoring
methods.
Licensee
management
was informed that the items discussed
in Paragraph
7
were considered
closed.