ML17223A606
| ML17223A606 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/05/1990 |
| From: | Hughey C, Potter J, Shortridge R, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17223A604 | List: |
| References | |
| 50-335-90-07, 50-335-90-7, 50-389-90-07, 50-389-90-7, NUDOCS 9004200188 | |
| Download: ML17223A606 (16) | |
See also: IR 05000335/1990007
Text
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0
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
APR oh
Report Nos.:
50-335/90-07
and 50-389/90-07
Licensee:
Florida Power and Light Company
9250 West Flagler Street
Yiiami, FL
33102
Docket Nos.:
50-335
and 50-389
Facility Name:
St. Lucie
1 and
2
License Nos.;
and
Inspection
Conducted:
February
26 - March 2,
1990
Inspectors:
F. h. Wria t
R. B. Shortridoe
J
C. A. Hug
e
.r
Approved by:
J.
- Potter,
ref
Facilities Radiation Protection Section
Emergency
Preparedness
and Radiological
Protection
Branch
Division of Radiation Safety
and Safeguards
+s
~
Da
e Sioned
Ky'u
at
igned
SUYiYiARY
Scope:
This
unannounced
inspection
of radiation
protection activities
included
a
review of the licensee's
organization
and
management
controls, training
and
qualifications,
external
and internal
exposure
controls,
as
low as
reasonably
achievable
(ALARA) program,
surveys
and control of radioactive material,
and
follow-up of previously identified items.
Results:
Two violations were identified.
One violation was identified for failure to
have
adequate
written procedures
for controlling access
and activities in high
radiation
areas.
Another violation was identified for failure to maintain
positive
access
control
to. a high radiation area.
Overall, the licensee's
radiation protection
program
appears
to
be generally effective in protecting
the health
and safety
of the workers.
Licensee
policy,and
procedures
for
qualifying vendor
HP personnel
was
a program strength.
The licensee
exposure
goals were agressive.
9004200188
90040:-
PW~
ADCiCV. 0.000=
REPORT
DETAILS
Persons
Contacted
Licensee
Employees
- W.
- J
- G
- H.
- E
- G
- R.
- T
- J
- B
- J
- L
J.
- C
- M
- R.
- H
B.
- K.
- J
- R.
- J
- D
- D
- J
- J
- H.
- D
- C
- E
Alfera, Safety Supervisor
Barrow, Operations
Superintendent
Boissy, Plant- Manager
Buchanan,
Health Physics Supervisor
Burgess, guality Improvement
Team
Casto,
Emergency
Planning
Church,
Chairman,
Independent
Safety Evaluation
Group
Coste, guality Assurance Staff
Danek, Corporate Health Physics
Frechette,
Chemistry Supervisor
Harper, Superintendent,
guality Assurance
Jacobus,
ALARA Coordinator
Leifhelm, Health Physics Instructor
Leppla, Instrumentation
and Controls Supervisor
MacLead,
Nuclear Engineerina
McCullers, Health Physics
Operations
Supervisor
Mercer, Health Physics Technical
Supervisor
Parks, guality Assurance
Payne,
Health Physicist
Powell, Technical Staff
Riha, Nuclear Engineering Staff
Riley, Procedures
and Graphics Supervisor
Rogers, Electrical Maintenance
Saoer,
Site Vice President
Sipos,
Services
Manager
Spodick, Training Department
Walker, Health Physics
Emergency
Preparedness
Ware, Trainina
West, Technical Staff Supervisor
Wood, Outage
Management
Wunderlich, Reactor Engineering
Other
licensee
employees
contacted
during this
inspection
included
craftsmen,
technicians,
and office personnel.
Nuclear Regulatory
Commission
- J. Potter,
Section Chief, Facilities Radiation Protection,
Region II
- M. Scott,
Resident
Inspector
- Attended exit interview held March 2,
1990
Organization
and Management
Controls
The inspectors
reviewed the licensee's
organization, staffing levels,
and
lines of authority
as
they related to radiation protection
program,
and
verified that the licensee
had
necessary
staffing levels to monitor and
control outage
work activities in radiological
areas.
The inspectors
discussed
with the Radiation
Protection
Supervisor
the
type,
methods,
and
degrees
of interaction with other plant work groups
during the Unit
1 refueling outage.
The inspectors
determined that the
licensee's
radiation protection organization
was adequately
structured
to
support the refueling work.
The inspectors
reviewed
the licensee's
program for self-identification
of weaknesses
related
to
the
radiation
protection
program
and
the
appropriateness
of corrective action taken.
In a previous inspection,
the
inspectors
determined
that the licensee
was not identifying radiological
protection
program problems or deficiencies
in a corrective action program
to determine
root causes
and corrective actions.
However,
no violations
of
NRC
requirements
were identified
and
a
continued
review of the
licensee's
practices
for initiating
and
documenting
radiological
protection
program
discrepancies
will be
reviewed
during
subsequent
inspections.
The licensee's
procedure
HP-101, Identification and Reporting
of Radiological
Events,
Revision 4, required that the licensee
document
events
reportable
to the
NRC.
However,
other deficiencies,
such
as
failure to follow radiation protection
procedures
were not required to be
documented
on
a radiological
event report
(RER).
The licensee
revised
HP-101 in August 1989.
The inspectors
reviewed the revised
procedure
and
determined
that the licensee
had specified
requirements
for documenting
radiological
program inadequacies
and poor work practices.
The inspectors
reviewed
selected
radiological
event reports
made in 1990
and verified
that the licensee
was taking corrective action measures
for the identified
program inadequacies.
No violations or deviations
were identified.
Program for Maintaining Exposures
As Low As Reasonably
Achievable
(ALARA)
10 CFR 20. 1.c states
that
persons
engaged
in activities under licenses
issued
by the
NRC
should
make
every
reasonable
effort to maintain
radiation
exposures
as
low as
reasonably
achievable.
The
recommended
elements
of
an
ALARA program
are
contained
in Regulatory
Guide 8.8,
Information Relevant
to Ensuring that Occupational
Radiation
Exposure at
Nuclear
Power Stations will be ALARA, and Regulatory Guide 8.10, Operating
Philosophy for Maintaining Occupational
Radiation
Exposures
The last time the licensee
had two refueling outages
in one year was
1987
and
the licensee's
collective
dose
was
448
person-rem
per unit.
The
licensee
had
a collective dose of'84.5 person-rem
per unit in 1988
and
231.5
person-rem
per unit in 1989.
The licensee
established
their 1990
collective dose
goal to meet
a three year average
aoal of 288 person-rem
per unit.
In order to meet that goal the licensee
would have to keep the
collective
dose total for 1990
below
692 person
rem.
The licensee's
estimate of collective dose for 1990,
based
on work planned
and historical
data,
was
748 person-rem.
Significant dose tasks for 1990 included Unit
1
tube pull and plug tasks,
and reactor coolant
pump impeller
inspection
on Unit 2.
In efforts to increase staff involvement
in the
ALARA program,
the Plant
Yianager requested
each
department
head to develop
an action plan to reduce
their department
dose.
The
plans
were to
be
completed
prior to the
start of the Unit
1 outage.
However, the Unit
1 outage
began three
weeks
early
and most'lans
were
not
completed
or submitted.
The
Coordinator
reported
that
the
licensee
had
established
a new'nnual
personnel
exposure
limit of 2,500 millirem.
The
ALARA coordinator
reported
that
the
lowered
administrative limit had
heightened
worker
attention to keep personnel
exposures
ALARA.'n
an effort to minimize primary system
general
corrosion rates,
reduce
deposition
and activation of corrosion
products
on fuel cladding,
and
therefore,
reduce
general
plant
dose
rate
source
term,
the licensee
had
previously
implemented
an elevated
lithium control
proaram in the reactor
coolant
system.
Although
some
source
term reductions
had
been
noted
during previous
outages,
the
licensee
planned
to
suspend
the elevated
lithium control
program
immediately in Unit
1
and during the next fuel
cycle in Unit 2.
This
change
back to
a coordinated
lithium/boron
pH
control
scheme
was
prompted
by recent
general
industry concerns
linking
elevated lithium levels'ith primary water stress
corrosion cracking.
Ouring the inspection,
the licensee
remained
below the estimated
weekly
dose projection.
However, at the
end of the inspection
the licensee
was
11 days behind schedule.
No violations or deviations
were identified.
Training and gualifications
The
inspectors
reviewed
changes
in the
licensee's
training
program,
policies,
and
goals
relating to the radiation protection
program
and
discussed
the
changes
with licensee
representatives.
The inspectors
verified that
the
changes
should
not adversely
affect the licensee's
program.
Prior to
being
allowed
to perform
unsupervised
health
physics
(HP)
technician
job coverage,
senior level
vendor technicians
were carefully
screened
by the licensee.
The guidelines for the screening
process
were
described
in a
recommended
practice entitled "Guidelines for Training and
gualification of ANSI Contract Health Physics Technicians."
This guidance
was developed
for
and
implemented
at both the St. Lucie and Turkey Point
sites.
The licensee
procedures
defined standard
duties for senior level
vendor technicians,
set
minimum experience
requirements,
and established
training
and testing requirements.
The inspectors
reviewed
and discussed
the program with cognizant plant personnel
and noted the following program
highlights:
The standard
duties of a senior level
HP technician
were
based
on
a
focused job/task analysis.
b.
Each
vendor senior technician
must pass
a written examination
based
on the
above
described
tasks.
The test
covered
basic
HP theory,
equipment
and
procedure
knowledge.
Minimum passing
score
was
80
percent.
Retesting
was at the discretion of the
HP Supervisor.
No
retesting
was allowed for a score of less that
60 percent.
Once
a
technician
passed
the test, retesting
was not required
as long as the
technician
had not been inactive for more than
one year.
c.
Technicians
were also trained
and tested
annually
on site specific
policies
and
procedures
with the
same pass/fail criteria
as
above.
Junior level
technicians
were not required to
be tested,
however,
they were not allowed to perform senior level tasks
unless
they were
directly supervised.
d.
A review of the lesson
plan developed for vendor technician training
showed it to be very comprehensive
and complete.
e.
Minimum experience
requirements,
using
ANSI/ANS 3. 1-1978
as
a basis,
were defined
in detail.
Resumes
of contract
HP technicians
were
verified by contacting at least
two of the individual's. prior work
sites.
f.
A selected
review of several
vendor qualifications
packages
found
them to
be complete.
These
packages
included test results,
resume
verification information,
and experience
evaluations.
The vendor
HP technician qualification and training program was considered
by the inspectors
to be
a licensee
strength.
No violations or deviations
were identified.
5.
External
Exposure Control
and Personnel
Dosimetry
The
inspectors
reviewed
the
licensee's
external
exposure
controls
including use of radiation
work permits
(RWPs), posting of radiological
areas,
access
controls for high radiation
and locked high radiation areas
(HRAs),
and
licensee
procedures.
The inspector
determined
that
the
licensee's
procedures
for controlling access
to
HRAs were inadequate,
in
that,
they
did
not
adequately
describe
the
licensee's
methods
for
controlling
and monitoring activities in high radiation
areas.
As
a
result the licensee
received
a violation for inadequate
procedures,
and
a violation for not adequately
securing
a locked
HRA, after inspectors
were
able to open
a "locked high radiation" gate.
Hi gh Radi ati on Areas
10 CFR 20.202 defines
a
HRA as
an area,
accessible
to personnel,
in
whi ch there exists radiation at levels
such that
a major portion of
the
body
could
receive
in
any
one
hour
a dose'n
excess
of
100 mi llirem.
requires
a licensee
who establishes
a
HRA to
control
each entrance
by one of three methods.
These include:
(1)
A control device that would cause
the level of radiation to be
reduced
below
100 millirem per hour
upon personnel
entry into
the area.
(2)-
A control
device
to notify persons
entering
the
area
and
licensee
supervision of the entry.
(3)
Maintain the
area
locked except
during periods
when access
to
the area is required, with positive control over each entry.
In lieu of the "control device" or "alarm signal"
requirements
of
licensee
Technical Specification (TS) 6.12
requires
that areas
having
dose
rates
greater
than
100 millirem per
hour but less
than 1,000 millirem per hour be conspicuously
posted
as
a
HRA and
access
controlled
by use of a
RWP.
Additionally, persons
permitted to enter
such
areas
shall
be provided with or accompanied
by one of the following:
(1)
A radiation monitoring device which continuously indicates
the
dose rate in the area.
(2)
A radiation monitoring device which continuously integrates .the
radiation
dose
rate in 'the area
and alarms
when
a preset
dose
is received,
or
(3)
A
HP qualified individual with
a
dose rate monitoring device,
who is responsible
for providing positive control
over the
activities within the
area,
and
who shall
perform periodic
radiation surveillance at the frequency specified
by the facility
Health Physicist
on the
RWP.
TS 6. 12.2 requires
that
each
HRA accessible
to personnel,
in which
there exists
radiation at levels
such that
a major portion of the
whole
body could receive,
in any
one
hour,
a
dose
in excess
of
1,000 millirem,
be
secured
to prevent
unauthorized
entry.
The
requirement
states
the following:
(1)
That
areas
having
dose
rates
greater
than
1,000 millirem per
hour
(mrem/hr)
shall
be
locked to prevent
unauthorized
entry
with keys controlled by licensee
supervision.
(2)
Doors
shall
remain locked
except
during
access
by personnel
under
an approved
RWP which shall specify the dose rates in the
area with maximum allowable stay times for individuals in the
area.
(3)
In lieu of the stay time specification of the
RWP, direct or
remote
(such
as
use of closed circuit TV cameras)
continuous
surveillance
may
be
made
by personnel
qualified in radiation
protection
procedures
to provide positive
access
control
over
activities within the area.
(4)
Individual areas
accessible
to personnel
with radiation levels
such that
a major portion of the body could receive in one hour
a
dose
in excess
of 1,000 millirem, that are located in large
areas
such
as containment
where
no enclosure exists for purposes
of locking and
no enclosure
can
be reasonably
constructed
around
the individual areas,
shall
be
roped off, conspicuously
posted
and provided with a flashing light as
a warning device.
TS 6. 11 requires that procedures
for personnel
radiation protection
be consistent with the requirements
of 10 CFR Part 20 and
be approved,
maintained,
and
adhered
to for all operations
involving personnel
radiation exposure.
Over
a
three
day
period,
inspectors
observed
work in Unit
1
Containment Building and in the Unit
1 and
2 Auxiliary Buildings.
On
February 26,
1990,
while performing radiation
and
high radiation
surveys
in the Unit
1 Containment Buildino, the inspectors
were able
to open
a gate
leading to
a locked
HRA.
The inspectors
entered
a
HRA boundary
and
observed
a radiation level of 400 mrem/hr at the
surface
of
a locked
gate
leading to the Unit
1 Regenerative
Heat
Exchanger
(RHEx) room.
With very little effort the inspectors
were
able to obtain
an
18 inch wide opening in the
42 inch doorway,
by
repeatedly
pushing
on the gate
and raising the chain.
The inspectors
immediately notified the
HP Operations
Supervisor.
The
HP supervisor
made
a cursory survey inside the
RHEx room and then properly locked
the gate.
After
a brief investigation the
HP Supervisor
found that
the lock could only enter the outside links on each
end of the chain
and that the chain, if only wrapped
once
around the gate
and post,
would provide the
18 inch opening.
HP supervision
stated that
a memorandum identifying the problem
and
the correct method for locking the gate to the Unit 1
RHEx room would
be
issued
to all
HRA key holders
and further training would
be
provided.
The survey
performed
by the
HP supervisor
revealed
dose
rates of 200-1,700
mrem/hr at
18 inches
and 3,000 mrem/hr on contact
on the
RHEx.
The inspectors
informed licensee
management
that the
failure to sufficiently lock the gate to the
RHEx'oom to prevent
unauthorized
entry
was
an
apparent
violation
of
(50-335/90-07-01).
During the inspection,
the inspectors
observed
a worker installing
a
snubber in a
HRA on the -5 foot elevation of the Unit
1 containment
building.
The worker was in a high radiation
area
working off the
floor in the overhead,
without
a radia'tion monitor.
When questioned
about the location of a monitoring device the worker stated that
he
had
a dose rate monitoring device
near the area.
The worker had to
leave his position in the overhead to obtain it.
The worker stated
that
HP had initially performed the area
survey
and then left.
The
worker was
aware of the dose rates
in the immediate
area
where
he
wa
workino.
The inspectors
observed
a similar situation in the Unit
1 Auxiliary
Building.
A worker
was
working
on
a ladder
in
a
HRA without
a
radiation monitor or
a
HP technician with
a monitor near
by.
The
inspector
determined
that the worker did have
a radiation monitor
a few feet
away at the
HRA boundary.
When questioned
about the dose
rates
in the area
where
he was working, the worker reported
the dose
rates
were nearly twice those
measured
by the inspectors.
The inspector notified
HP supervision of the events
and inquired
as
to what constitutes
periodic radiation surveillance or continuous
job coverage.
HP supervision
at first stated
continuous
coverage
required direct
eye contact within voice control of the workers.
However,
a later definition
was
given
by
HP supervision.
That
definition basically stated that periodically
a
HP technician
should
visit the job site at his discretion
based
on the radiological
conditions at the job site.
The inspectors
questioned
HP technicians
in the containment building
and the auxiliary building as to what conditions
would exist before,
periodic job coverage
should
be changed
to continuous
coverage.
None
of the
answers,
when
provided
by the
HP technicians
showed
any
consistency.
The inspector
determined that the licensee staff was uncertain
as to
what continuous
coverage 'was
and
when it was to be applied
and that
the licensee's
procedures
provided
no guidance
on what activities
required
continuous
coverage.
supervision
stated
that
procedures
did not define periodic coverage
or continuous
coverage
required
by the
TS 6. 12.
Licensee
procedures
did not define periodic
radiation surveillance
requirements,
duties,
and responsibilities for
health physics
personnel
monitoring activities within HRAs.
The inspectors
reviewed
licensee
procedures
to determine
the type of
instruction that was provided
by the licensee for personnel
entering
HRAs.
Licensee
procedures
did
not
define
worker monitoring
responsibilities
within
high
radiation
areas,
when
radiation
" monitoring devices
were
issued
for purposes
of meeting
TS
6. 12
requirements.
'
Failure to
approve
and
maintain written
procedures
addressing
radiological
protection
requirements
for activities
in
as
required
by licensee
was identified as
an apparent violation
of licensee
TS 6. 11 (50-335/90-07-02)
The
inspectors
identified additional
procedural
weaknesses
which
included:
o
Lack of guidance
or defini tion of what constitutes
an acceptable
barrier for meeting the requirements
of TS 6. 12.2.
Lack of guidance
concerning
acceptable
uses of flashino warning
lights used in meeting
access
control requirements
of TS 6. 12.2
for areas
impracticable to lock.
Licensee
representatives
acknowledged
procedural
inadequacies
for
high radiation
areas
and
committed to develop,
approve,
and maintain
written procedures for HRA activities.
b.
Personnel
Honitoring
10 CFR 20..202 requires
each
licensee
to supply appropriate
personnel
monitoring equipment to specific individuals
and re'quire the
use of
such
equipment.
During tours of the plant, the inspectors
observed
workers wearing appropriate
personnel
monitoring devices.
The majority of personnel
entering containment
were observed
to place
their thermoluminescent
dosimeter
(TLD) and self-reading
dosimeter
(SRD) in
a clear plastic
bag
and tie it to the chest
area
on the
outside of the protective clothing.
However, workers performing floor
scabbling in the Unit 2 auxiliary building were working in a radiation
area
with paper
suits
over their
and
SRDs.
The inspectors
informed
the
Health
Physics
Operations
Supervisor
that this
was
considered
to be
a poor radiological
work practice since it inhibited
the worker from frequently monitoring their
SRD without an increased
risk of contamination.
HP supervision
reported
that they would
evaluate this practice to determine if changes
were needed.
Two violations were identified.
6.
Internal
Exposure Control
requires
the
licensee
to
use
process
or engineering
controls,
to
the
extent
practicable,
to limit concentrations
of
radioactive material
in air to levels
below that specified
in Part 20,
Appendix B, Table
1,
Column 1, or limit concentrations
when averaged
over
number of hours in any week during which individuals are in the area,
to
less
than
25 percent of the specified concentrations.
The use of process
controls
and engineering controls to limit radioactive
concentrations
in air was discussed
with licensee
employees
and controls
were
observed
in the Unit
1 Containment
and Auxiliary Buildinas.
The-
licensee
was also observed to use
containment
devices for work in highly
contaminated
areas
and drip containers
on valves with radioactive leaks.
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
25
percent
of the concentrations
specified
in Appendix 8,
Table 1, Column 1, other precautionary
measures
should
be used to maintain
the
intake
of radioactive
material
by
an
individual within seven
consecutive
days
as far below 40 NPC-hours
as is reasonably
achievable.
10 CFR 20. 103(c)
(2) provides that the licensee
may make allowances for
the
use
of respiratory
protection
equipment
in estimating
exposures
of
individual to radioactive material
in air provided the licensee
maintains
and
implements
a respiratory
protection
program that
includes,
as
a
minimum,
written
procedures
reaardino
supervision
and
training
of
personnel
and issuance
records.
The inspectors
reviewed the licensee's
procedures
for use of supplied air
respirators.
The
inspectors
observed
that
breathing
air mainfolds,
pressure
and
monoxide
monitors
inside
containment
were
calibrated
and workina properly.
Breathing air was currently in use in
the steam generator
cubicles
and
on the refueling floor for reactor vessel
cavity cleanup.
No violations or deviations
were identified.
Surveys, Nonitorina,
and Control of Radioactive Naterial
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
and
(2) are reasonable
under the circumstances
to evaluate
the
extent of radioactive
hazards
that may be present.
The
inspectors
reviewed
the
plant
procedures
which established
the
licensee's
radiological
survey
and monitoring program
and verified that
the procedures
were consistent
with reaulations,
Technical Specifications
and good Health Physics
(HP) practices.
The inspectors
reviewed
selected
records
of radiation
and contamination
surveys
performed
during the period of January
and
February
1990,
and
discussed
the survey results with licensee
representatives.
During tours
of the plant, the inspectors
observed
HP technicians
performina radiation
and contamination
surveys.
The
inspectors
performed
independent
radiation
and
loose
surface
contamination
surveys
in the Auxiliary and Unit
1 Containment Buildings
and verified that the areas
where properly posted.
10
The inspectors
discussed
with the licensee
the methods
used to release
material
from the restricted
area
and
observed
technicians
performing
release
surveys for material.
No violations or deviations
were identified.
Hot Particle Control
Program
The inspector:
discussed
the hot particle control
program with a cognizant
licensee
representative
and
reviewed
the
licensee
procedures
that
described
the control program
and dose
assignment
methodology.
Known and potential
hot particle
zones
were identified by procedure
and
required
additional
survey
and worker requirements
including additional
protective
clothing,
continuous
HP coverage,
and
trash
and
equipment
removal
techniques
when work was being done in these
areas.
Areas
were
surveyed for hot particles
using
gross
masslin
mopping or
wiping and using
a paint roller type device with sticky tape that would be
rolled over
a floor or other surface.
The masslin cloth
and the paint
roller would
then
be
surveyed directly for hot particles
or any other
significant contamination.
The documented
results of these
surveys
would
be identified as
a "Hot Particle Survey."
The radiation
dose
to the
skin from particles/skin
contamination
was
computed using the acceptable
VARSKIN computer code.
Ouring the Unit
1
outage,
strippable
paint
had
been
applied
to the
surfaces
of the reactor cavity prior to cavity flood-up for refuelino
operations.
The licensee
was very enthusiastic
about
the
use of these
in that
previous
experiences
had
resulted
in significant
reductions
in contamination
levels
and
dose
rates
in the cavity after
draining
and
removal of the coating from the walls and floor.
The use of
underwater
vacuums to remove crud from the floor of the cavity also greatly
assisted
in these
reductions.
No violations or deviations
were identified.
Licensee Actions on Previously Identified Inspector Findings
(Closed)
IFI 50-335/89-01-02:
This item concerned
the establishment
and
implementation
of criteria for initiating investigations
of radiological
protection
program deficiencies.
The inspectors
verified that criteria,
for performing investigations
of program deficiencies,
were incorporated
into written procedures
and
they also
reviewed
selected
Radiological
Event Reports.
The IFI is discussed
in Paraaraph
2.
(Closed)
IFI 50-335/89-19-01:
This
item
concerned
the
licensee's
procedure for estimating radioactivity of material
from direct radiation
measurements
made with survey
instrumentation.
The inspector verified
that
the
licensee
had
provided
guidance
in written
procedures
for
'
¹
selecting
appropriate
equations
when estimating radioactivity from direct
radiation surveys.
The licensee
also revised
procedure
forms to improve
documentation
of the calculated results.
10.
Exit Interview
The inspection
scope
and findings were
summarized
on March 2, .1990, with
those
persons
indicated
in Paragraph
1 above.
The inspectors
described
the areas
inspected
and discussed
in detail the inspection findings and
a
violation (50-335/90-07-01) listed below.
At the exit meeting,
the
inspectors
notified licensee
management
that
their procedures
for access
controls
and monitoring requirements for HRAs
was
a program weakness.
The licensee
acknowledged
deficiencies with their
written procedures for controlling assess
to HRAs.
The licensee
committed
to reviewing
and
revising
licensee
procedures
to better
define
high
r'adiation
area
control policies
and requirements.
Upon further review of
the activities identified during the inspection the inspectors
determined
that
a lack of procedural
guidance in written instructions
was
a violation
of TS 6. 11.
During
a telephone
conversation
on March 15,
1990,
between
J. Potter
and
R.
B. Shortridge of the
NRC and
H. Buchanan of Florida Power
and Light, the licensee
was informed that failure to have adequate
written
procedures
for controlling activities
in
was
a
violation
(50-335/90-07-02)
of TS 6. 11.
Dissenting
comments
were not received
from
the licensee.
The inspectors
reported that the licensee's
policies
and
procedures
for qualifying vendor
HP personnel
was
a program strength.
The
inspector
also
reported
that
the licensee's
collective
dose
goals for
meeting three year industry averages
was aggressive
and
appeared
to have
management's
support.
The
inspectors
noted
that staff participating
in addressing
initiatives and goals
appeared
to be increasing.
Proprietary information
is not contained in this report.
Item Number
Descri tion and Reference
50-335/90-07-01
50-335/90-07-02
Violation - Failure to maintain
positive access
control to
a
(Paragraph
5).
Violati on - Fai lure to maintain
adequate written procedures
for
activities in HRAs (Paragraph
5).
Licensee
management
was
informed that
two IFIs discussed
in Paragraph
9
were closed during this inspection.
4