ML17347A448
| ML17347A448 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/21/1987 |
| From: | Cioffi M, Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17347A446 | List: |
| References | |
| 50-250-87-15, 50-251-87-15, NUDOCS 8705040326 | |
| Download: ML17347A448 (11) | |
See also: IR 05000250/1987015
Text
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UNITE D STATES
NUCLEAR R EGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
~pp g 9 )987
Report No.:
50-250/87-15
and 50-251/87-15
Licensee:
Florida Power and Light Company
9250 West Flagler Street
Miami, FL
33102
Docket No.:
50-250 and 50-251
Facility Name:
Turkey Point
Inspection
Conducted:
March 29-April 3,
1987
License No.:
DPR-31 and
Inspectors:
~ W.
.
oo
e
10
1
Accompanying Personnel:
D.
M. Collins
Approved by:
o ey,
ect
n
se
Division of Radiat
on Safety
and Safeguards
ate
S gne
Date
Soigne
ate
Soigne
SUMMARY
Scope:
This routine,
unannounced
inspection
involved
a
review of the
licensee's
.health
physics
program,
including internal
exposure
control
and
assessment,
external
exposure
control
and
personal
dosimetry,
respiratory
protection,
control of radioactive
materials,
a
review of the licensee's
program to maintain exposures
as
low as
reasonably
achievable
and
a review of
open items.
Results:
One violation for failure to
post
documents
as
required
by
t
8705040326
870429
ADOCK 05000250
8
4
REPORT DETAILS
Persons
Contacted
Licensee
Employees
- C. N. Wethy, Site Vice President
- C. J. Baker, Plant Manager
- D. D. Grandage,
Operations
Superintendent
- F. H. Southworth,
Maintenance
Superintendent
- J.
W. Anderson,
equality Assurance
Supervisor
- J. Arias, Jr., Regulation
and Compliance Supervisor
- P.
W. Hughes,
Health Physics
Supervisor
- G. Salamon,
Compliance
Engineer
- J. A. Labaraque,
Technical
Department Supervisor
- R. E. Lee, Acting guality Control Supervisor
- A. D. Rice, Radiochemist
N.
A Jimenez, Staff Health Physicist
- E. R. LaPierre,
Chemistry Project Supervisor
M. L. Cooper,
General
Employee Training Supervisor
T. A. Coleman,
Health Physics Administrative Support
J.
R. Bates,
ALARA/Support Supervisor
R. Brown, Health Physics
Operations
Supervisor
R.
M. Givens,
ALARA Engineer
G. L. LaGarde,
Health Physics
Radwaste
Supervisor
D. Hicks, Health Physics
Foreman
D.
E. Cooper,
Health Physics
Foreman
G.
E. Jennings,
Health Physics
Foreman
M. E. Lauzon, Health Physics
Foreman
F. Marder, Health Physics
Coordinator
Supervisor
Other licensee
employees
contacted
included three construction
craftsmen,
ten technicians,
two operators,
three
mechanics,
and
seven
office
personnel.
Nuclear Regulatory
Commission
- D. R. Brewer, Senior Resident
Inspector
- Attended exit interview
Exit Interview
The inspection
scope
and findings were
summarized
on April 3, 1987, with
those
persons
indicated in Paragraph
1 above.
The inspector
discussed
the
inspection
findings in detail with licensee
management.
The inspector
also
discussed
one
apparent
violation involving the failure to post
documents
as
required
by
10 CFR 19. 11(a)(4)
(Paragraph
4).
Licensee
management
acknowledged
the inspection findings
and took
no exceptions.
0'
The licensee
did not identify as proprietary any of the materials
provided
to or reviewed
by the inspectors
during this inspection.
Licensee Action on Previous
Enforcement Matters
(92702)
(Closed)
Violation (85-17-01):
This violation involved
a failure to
package
Low Specific Activity (LSA) material to
DOT specifications.
The inspector
reviewed
and verified the licensee's
corrective actions
as
stated
in FPSL's letter of August 8, 1985.
(Closed)
Violation (86-04-01):
This violation involved
a failure to
properly train individuals in the use of survey instruments.
The inspector
reviewed
and verified the licensee's
corrective actions
as
stated in FPSL's letter of May 28,
1986.
(Closed)
Violation (86-36-02):
This violation involved the failure to
calibrate airline pressure
on the
Nomonox air distribution system.
The inspector
reviewed
and verified the licensee's
corrective actions
as
stated
in FPSL's letter of December 26, 1986.
(Closed)
Violation (86-36-05):
This violation was for the failure to
conduct
an adequate
alpha
survey
program
and the failure to evaluate
the
alpha hazard present.
The inspector
reviewed
and verified the licensee's
corrective actions
as
stated in FPSL's letter of December
26, 1986.-
(Closed) Violation (86-04-02):
This violation involved multiple Technical Specification 6.8. 1 violations of procedures.
The inspector
reviewed
and verified the
licensee's
corrective
action
commitments
made during
an
Enforcement
Conference
held in the
Region II
office on January
31,
1986.
The corrective actions included meeting held
by the plant
manager
with all workers
emphasizing
the
requirement
to
follow procedures
and
regulations;
review of plant
procedures
for
appropriateness
of health
physics
controls
with revisions
made
where
controls
were
found
inadequate;
and administratively controlling the
transversing
incore probes
during outages.
Organization
and Management
Controls
(83722)
The inspector
reviewed the licensee's
health physics
(HP) staffing level
related
to having
two units in outage.
Approximately 200 senior
ANSI
qualified contract health physics technicians
(HPT) were onsite to provide
outage
support.
Licensee
representatives
stated that the work load was
increasing
and the licensee
and contract
HPT groups
were being scheduled
to
work
seven
ten-hour
days.
The
inspector
stated
that
routine
observations
should
be made for fatigue of the
HP staff, such that fatigue
would not impact performance.'
required
the licensee
to post current
copies of any
Notice of Violation involving radiological
working conditions
and
any
response
from the licensee.
This section
also requ'ired the
documents
to
be posted within two working days after receipt
from the Commission,
and
to remain
posted for
a
minimum of five working days or until actions
correcting
the violation we'e
completed,
whichever
was later.
The
inspector
reviewed the postings
on plant bulletin boards
in the facility
and
noted that
the Notice of Violation contained
in Inspection
Report
No. 50-250,
251/86-36
was not posted.
The inspector also noted that the
licensee's
response
to the Notice of Violation was not posted
and actions
correcting
. the
violations
were
not
scheduled
for completion until
April 30,
1987.
The inspector
discussed
the posting
requirements
with
licensee
representatives
who
stated
that
the
postings
were
the
responsibility
of
the
guality
Control
Department.
Licensee
representatives
further stated
that it did not appear
that the postings
had
been
updated
since
the licensee
put the
new Administration Building
into use in May 1986.
The inspector stated that the failure to post the
Notices of Violation and
any licensee
response
was
an apparent
violation
(50-250, 251/87-15-01).
Internal
Exposure Control
and Assessment
(83725,
83525)
The inspector
reviewed
selected
portions of the licensee's
whole
body
counting
and respiratory protection programs.
The inspector
reviewed the assignment of maximum permissible concentration
hours
(MPC-hrs) for iodines for those individuals entering the Unit 3 and
Unit 4 containments
after
shutdown.
While initial entries
into the
containments
were
made
using
self
contained
breathing
apparatus,
subsequent
entries
by
some
licensee
personnel
were
made
using airline
respirators
or full-facepiece respirators
equipped with particulate
and
charcoal
(GMRI) cartridges.
The licensee
did not have
an exemption from
the
NRC which would allow the licensee
to take protection factor credit
for respiratory
protection
from iodines
when
GMRI cartridges
were used.
The inspector
reviewed the
RWP sign-in sheets
for personnel
entering the
Unit 3
and
Unit 4
containments
and verified that
MPC-hrs
were
being
assigned
and tracked
as required.
The inspector also reviewed
a computer
printout listing the MPC-hrs for all plant personnel
and verified that no
personnel
had
exceeded
the
40 MPC-hr control
level
as
specified
in
(3) required
a written policy statement
on respirator
usage
to
be
issued
covering
such
things
as:
use
of practicable
engineering
controls
instead
of respirators;
routine,
nonroutine,
and
emergency
use of respirators
and relief from respirator
use.
This section
also required
the licensee
to advise
each respirator
user that the user
may
leave
the
area
at any time in the event of equipment malfunction,
physical
or psychological
distress,
procedural
or communication failure,
significant deterioration of operating conditions, or any other condition
that
might
require
such relief.
The
inspector
reviewed
licensee
procedures
to determine
compliance with the requirement.
The inspector
determined
that there
was
no written statement
on policy.
Licensee
representatives
stated
that the policy statement
was apparently
omitted
when
the
procedure
went
through
the
procedure
upgrade
program.
It
appeared
that the last procedure
that contained
the policy statement
was
revised April 30,
1985.
The licensee
provided the inspector with a copy
of a recent
equality Assurance
(gA) audit that contained
a finding related
to the
absence
of the policy statement.
At the time of the inspection,
the
licensee
had not responded
to the
gA finding.
The inspector stated
that in accordance
with the criteria outlined in 10 CFR 2, Appendix C, for
licensee
identified violations,
no Notice of Violation would be issued.
However,
since
the actions
correcting
the licensee
identified violation
had not been
completed at the time of the inspection,
the inspector stated
that the corrective
actions
implemented
as
a result of the
gA finding
would be
an inspector followup item and would be reviewed during
a future
inspection
(50-250, 251/87-15-02).
The inspector
requested
a copy of all positive whole body counts for 1986
and
1987.
Licensee
representatives
stated that there
had been
no positive
counts for either of the years
requested
by the inspector.
The inspector
reviewed
the implementation of the licensee's
program for
sampling,
analysis
and posting of airborne
alpha radiation
areas.
The
licensee
had established
an action point for alpha control
when the ratio
of beta/gamma activity to alpha activity fell below 50 to 1.
The program
currently in place required that the highest
beta/gamma
smear
found in a
particular
area
also
be counted for alpha emitting radionuclides.
Smears
and air samples
which had
been sent to an offsite vendor for analysis
had
indicated
the
presence
of various
alpha
emitting radioisotopes.
The
licensee
has established
an alpha
MPC value of 2.0 E-12 microcuries
per
milliliter (uCi/ml) based
on Curium-241.
Due to the
presence.
of large
amounts
of radon
and
decay
products
found in the area,
licensee
representatives
stated that
some trouble
was being experienced
in posting
areas
as potential
alpha airborne areas,
due to the long half-life of the
products.
The
inspector
stated
that
based
upon
the
studies
performed
by the
licensee
staff,
areas
where
alpha activity was
most
likely to be found could be determined.
The inspector also stated that
the control efforts put in place
by the licensee
should concentrate
on
those
areas
to insure
proper controls
were
implemented
whenever
alpha
airborne contamination
was suspected.
The evaluation
performed
by the licensee in addressing'lpha
contamination
was
thorough,
well
documented
and
provided
good
guidance
to
those
personnel
responsible for implementing the program.
No violations or deviations
were identified.
External
Occupation
Exposure Control
and Personal
Dosimetry (83724)
The inspector
toured
the Unit
4 containment
and
observed
the
outage
activities in progress.
The inspector
noted that the licensee
was using
flashing lights to warn personnel
of areas
where the
dose rates
exceeded
/
one
rem per
hour (R/hr), even
though this practice
was not addressed
by
the facility Technical
Specifications
(TS).
A licensee
representative
stated that the use of the flashing lights was
a commitment
made
by
HP to
the plant
management
and
was
not intended
to
be
used
as
a control for
and that locked doors or HP escorts
were still
being
used
to ensure
access
controls
were maintained.
The inspector
stated that the
TS required that areas
where dose rates
exceeded
one R/hr
would
be required to
be locked to restrict
access
or would require the
presence
of a
HPT to control access
to the area.
The inspector
noted that
lead shielding
had
been
hung around the Unit 3
reactor cavity drain line to restrict access
to the area
and that flashing
lights were also in use.
The inspector also noted that
a step ladder was
in position outside
the shielding
and would provide access
to the area.
The inspector
reviewed
survey
data for the Unit 3 reactor cavity drain
area
and
found the highest
general
area
dose
rates
in the area
to
be
800 millirem per hour.
The inspector
reviewed
the licensee's
program for the identification of
hot particles
and
the skin
dose
calculations
to
be
used if the skin
contamination
was found to be
due to
a hot particle.
The licensee
had
recently
updated
the
personnel
contamination
procedure
to incorporate
recent
guidance
and
had
changed
the methodology for performing skin dose
calculations.
Current
guidance
to the
HPT's onsite
was to contact
a
Health
Physics Shift Supervisor if such
a contamination
was
suspected.
Also,
guidance
was
provided to
make
attempts
to
save
the particle if
possible.
The inspector
reviewed
one skin dose calculation
based
upon the
presence
of a Cobalt-60 particle found in one worker's underclothing.
The
calculation,
performed
by the
licensee
and verified
by the inspector,
assigned
400 millirems of dose to the skin of the individual in question.
In discussions
with licensee
representatives, it was
noted that
good
frisking practices
were essential
for the detection
and capture of these
small
particles,
especially
before
they
were
inadvertently
carried
offsite.
Licensee
management
stated
during the exit interview, that it
was the intent of the licensee
to acquire state-of-the-art
frisking booths
to ensure
that
such
an incident would not occur
and to ensure
that all
personnel
exiting the radiation
control
area
received
a
good frisk.
Licensee
management
stated
they planned to have the friskers onsite
and
operational
in four to five months.
No violations or deviations
were identified.
Program for Maintaining Exposures
as
Low as
Reasonably
Achievable
(83728)
The licensee's
program for maintaining occupational
exposures
A's Low As is
Reasonably
Achievable
(ALARA)
was
reviewed
to .determine
program
effectiveness
during the planned Unit 3 outage
and the unscheduled
Unit 4
outage.
The inspector
reviewed selected
procedures,
the
ALARA Shielding
Log, the
RWP dose tracking system,
and conducted
discussions
with licensee
and contractor personnel.
The licensee
appeared
to have
a well-established
ALARA group,
adequate
dose-saving
techniques
and
an effective computer tracking system to track
and trend collective
person-rem for all
RWPs.
The estimated
person-rem
for the
Unit 3
outage
work
packages
appeared
to
be
conservatively
determined.
Many Unit 4 work
package
estimates
had
already
been
exceeded.
The
licensee
stated that the Unit 4 outage
work package
estimates
were based
upon
the
Unit 3
outage
estimates.
The licensee
explained
that this
person-rem
estimating
technique
would permit
a
means for more thorough
documentation
of the problems
encountered
as
a result of the unscheduled
Unit 4 outage
when the post-job
ALARA reviews were performed
on the work
packages.
The licensee's
original
ALARA goal for 1987 was
1000 person-rem.
However,
due to the unscheduled
Unit 4 outage,
the licensee
expects this estimate
will be exceeded.
During discussions
concerning
planning to maintain
exposures
ALARA, the
inspector
learned
that
extensive
work
was
being
planned
to replace
approximately
2,000
Ray-Chem cable splices in each of the licensee's
two
units.
Initial estimates
made
by the
ALARA group concerning
exposures
were that the completion of this work in both units would require
the
expenditure of an additional
100 to 300 person-rem for calendar year 1987.
Licensee
representatives
stated
that
a large part of this work would be
inside the bio-shield,
and therefore
would be
a dose intensive task.
The
inspector stated that the
ALARA planning and exposure controls placed into
effect for the splice replacement
work would be
an inspector followup item
and would be reviewed during
a future inspection
(50-250, 251/87-15-03).
No violations
or. deviations
were identified.
Followup on Inspector
Followup Items
and Unresolved
Items
(92701)
(Closed)
Unresolved
Item (URI) (86-36-03):
This item was for the review
of potential
uptakes
associated
with the failure to calibrate airline
pressure
on the
Nomonox breathing air distribution system.
The inspector
reviewed
the
assignment
of MPC-hrs associated
with this
finding.
The highest
MPC-hrs assigned
to any individual was
22 MPC-hrs,
and did not exceed
the 40 MPC-hr control measure
which would have required
an evaluation to be performed
by the licensee.
(Closed)
URI (86-36-04):
This unresolved
item dealt with the
uptake
assessment
for
workers
using
respirators
with
expired
medical
qualifications.
During inspection
50-250,
251/86-36,
the inspector
had initially stated
that
no grace
period
was allowed for medical qualifications
and that the
medical qualifications
must
be performed at least every
12 months.
Based
upon guidance
received
from the
NRC Headquarters
staff,
a grace period is
allowed
and will be consistent
with the
grace
period allowed for the
compl etion
of
survei1
1 ances
outl ined
in
the faci 1 ity
Technical
Specifications
(+ 25 percent).
.