ML17348B099

sur veillance

procedures

for documenting

completed

surveys

of materials

released

from

the

NCV of

TS 6. 11. 1 with

licensee

corrective actions

completed

prior to the end of the onsite inspection.

NRC-identified repeat

violation for failure to follow HP surveillance

procedures

for labelling

an onsite

storage

cask containing radioactive

material

in excess

of 10

CFR, Part

20, Appendix

C limits.

Violation of

TS 6.11.1.

NRC-identified violation for failure to maintain

a continuously operable

emergency

response

telephone

line for use with hazardous

transportation

activities in accordance

with 49

CFR 172.604(a).

Violation of 10 CFR 71.5

requirements.

REPORT DETAILS

Persons

Contacted

Licensee

Employees

J

J

W.

J

H.

Q ~

J

J

J

M.

L

J

g*L

D.

K.

R.

Arias, Technical Advisor

Balaguero,

Acting, Technical

Department Supervisor

Bladow, guality Assurance

Manager

Danek, Health Physics,

Corporate Office

Harween, Supervisor,

Health

and Safety

Kaminskas,

Superintendent,

Operations

Kirkpatrick, Supervisor,

Emergency

Planning

Knorr, Regulatory

Compliance Supervisor

Lindsey, Supervisor,

Health Physics

Mayland, Superintendent,

Maintenance

Nee, Supervisor,

Safety

O'Brian, Superintendent,

guality Control

Pearce,

Plant Manager

Powell, Superintendent,

Licensing

Rowe,

Radwaste

Engineer

Schubert,

Supervisor,

Radwaste

2.

Other

licensee

employees

contacted

included

engineers,

technicians,

operators,

and office personnel.

Nuclear Regulatory

Commission

bR. Butcher, Senior Resident

Inspector

G. Schnebli,

Resident

Inspector

L. Trocine, Resident

Inspector

Attended March 1,

1991, Exit Meeting

O'Participated

in July 16,

1991, teleconference

Organization

and Staffing (83729)

The inspector

reviewed

the

RP organizational

structure,

selected

staff

qualifications,

and licensee

and contractor staff levels utilized for the

current dual unit outage activities.

'a ~

Organization

Cognizant licensee

representatives

outlined changes

implemented since

the

inspection

of

RP activities

conducted

from

February

25

through

March

1,

1991,

and

documented

in Inspection

Report

( IR)

50-250,

-251/91-08.

No significant organizational

changes

were

identified.

Three

supervisors

responsible

for

operations,

technical

support,

and administrative tasks,

continued to

report directly to the

HP supervisor.

Responsibility for routine

and outage

RP activities

and radioactive waste

(Radwaste)

processing

continued

to

be detailed

to five Health

Physics shift supervisors

(HPSSs)

reporting to the operations

supervisor.

Currently three

specialists

and

a supervisor,

reporting directly to the Technical

Support Supervisor,

were providing ALARA program guidance.

Licensee

representatives

informed

the

inspector

that

an additional

ALARA

specialist

position

recently

was

approved

within the

technical

support area.

In addition,

an instrumentation

supervisor,

and three

engineers

involved with Radwaste,

technical

support,

and operations,

respectively,

continued

to

report

to

the

technical

support

supervisor.

Dosimetry/records

and

administrative

support

supervisors,

and

a procedure/training

coordinator

reported

to the

administration supervisor.

From review of licensee

operations

during

tours of facility, no concerns

regarding

the current organization

structure

were noted

by the inspector.

No violations or deviations

were identified.

b.

HP Staffing and qualifications

TS 6.3 requires that

HP Supervisor qualifications

meet or exceed

the

specifications

of Regul,atory

Guide

1.8 or compensatory

action is

taken in which the Plant Nuclear Safety Committee determines

that the

action

meets

the intent. of TSs.

In addition,

each facility staff

member

must

meet

or

exceed

the

minimum qualifications

of

ANSI

N18.1-1971Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.1-1971" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..

The qualifications of the individual selected

in June

1991 to fill

the

recently

vacated

Supervisor

position

were

reviewed

and

discussed

with licensee

personnel.

The

selected

individual's

=- educational

qualifications included

a bachelor of science

degree with

additional

training

involving nuclear

theory

and

HP training.

Experience

included

approximately

13 years

of applied

radiation

protection activities of which

11 years

involved work at commercial

nuclear facilities.

The inspector

noted

the

new

HP Supervisor

selected

met the

TS requirements

and the licensee's

timely action in

filling the vacated

position

was expected

to maintain continuity for

ongoing

RP initiatives and activities.

Current

Turkey Point Nuclear

(TPN) Florida

Power

and Light (FP&L)

Company

HP staffing

included

59 Radiation

Protection

Man

(RPM)

technician positions allocated to the'nsite

RP program.

At the time

of the onsite inspection,

two

RPM technician

vacancies

were noted.

Licensee

representatives

stated that all

RPM staff were qualified in

accordance

with ANSI

18. 1 criteria.

No significant changes

were

expected

in

the

technician

staffing.

The

Technical

Support

Supervisor position,

vacant

since July 1, 1991,

was- to be filled in

September

1991.

All other supervisory positions allocated to the

RP

group were staffed.

The current

RP staff and supervisory

personnel

appeared

adequate

to provide

coverage

for outage activities.

No

concerns

regarding

the

FP&L, TPN permanent

HP staff qualifications or

staffing, levels were identified.

No violations or deviations

were identified.

c.

Contractor

HP Technicians

Licensee

representatives

stated that in November

1990, approximately

220 contractor

HP technicians

were hired for the dual unit outage.

At the time of the onsite

inspection

approximately

108 contractors

remained

on site, including

29 dosimetry/control

point and six decon

personnel.

From observations

of work activities

in progress

and

discussions

with selected

workers,

no

concerns

were

identified

.

regarding the current contractor

HP technician staffing levels.

Licensee

representatives

stated that increased

supervisory review of

field activities continued relative to previous

outages.

Further,

two lead technicians

continued to be assigned

to both the Refueling

Floor

and

Biowall

access

control

points.

The

lead

technicians

monitored

and

supervised

entry,

and

coordinated

activities within

each

area.

During tours of the

Unit

3

(U-3) containment,

the

inspector

reviewed

and verified implementation of RPM and supervisory

staff assignments.

From discussion

with selected

work groups

and

observation

of outage

activities,

the

inspector

noted

that

technician

coverage

appeared

sufficient for the jobs in progress.

No violations or deviations

were identified.

3.

Training and gualifications

(83729)

10 CFR 19. 12 requires

the licensee

to instruct all individuals working or

frequenting

any portion of the restricted

area

in the health protection

aspects

associated

with exposure

to radioactive material or radiation, in

precautions

or procedures

to minimize exposure,

and in the

purpose

and

functions

of protection

devices

employed,

applicable

provision

of

Commission regulations,

individual's responsibilities

and the availability

of radiation exposure

data.

0

a

~

General

Employee Training

(GET)

Licensee

Administrative Procedure

O-ADM-306, General

Employee Plant

Access

Training,

dated

December

19,

1989,

describes

the training

program for employees

who require

unescorted

access

to the

TPN plant

site.

GET is divided into two categories.

Category

I is provided to

employees

requiring

unescorted

access

to the protected

area while

Category II, Radiation Controlled Area Training

(RCAT), is provided

to employees

requiring unescorted

access

to the

Both categories

require

trainees

to pass

an

exam with

a

minimum of an

80 percent

score.

RCAT also requires

trainees

to pass

performance

tests.

No

procedural

changes

were

noted for the

GET Program

since

the last

inspection in this area

conducted

February

25 - March 1, 1991,

and

documented

in IR 50-250, -251/91-08.

The inspector

reviewed

GET records for both Category

I and Category

II'RCAT) training.

The training documentation for selected

worker s

involved in the Unit 3

Key Way Gate repair,

Spent

Fuel

Pool Transfer

Canal

surveys,

and other recent

outage activities indicated that all

worker

GET

was

current

and that individuals

had

passed

written

examinations

with a greater

than

80 percent score.

No violations'or'deviations

were identified.

Health Physics Technician Training

Licensee

Administrative

Procedure

O-ADM-360,

Health

Physics

Department

Personnel

Training

and gualifications,

dated

June

15,

1991,

provides for initial and continuous training programs for both

Health Physics Administrative Technicians

(HPATs)

and

RPMs.

Initial

training is provided to ensure

a

base

knowledge of health

physics

fundamentals

and

to verify

performance

of job related skills.

Continuing training is designed

to provide training

on plant

and

industry

changes,

lessons

learned,

performance

weaknesses,

and

emergency

duties.

As applicable,

completion of satisfactory

job

performance

measures

and

an

80 percent

exam

grade

are

required to

demonstrate

an understanding

of the material

presented.

Upon

review of the

RPM Training

Program,

dated

May

1991,

and

discussions

with cognizant

licensee

personnel;

the inspector

noted

RPMs are provided with two cycles of continuing training

a year with

each

cycle consisting

of approximately

40

hours of instruction.

HPATs were

provided continuing training

as delineated

in the

HPAT

Training Program,

dated April 1991.

Since

the

of the

HP training

program

conducted

from February

25 through

March 1,

1991,

and

documented

in

IR 50-250,

-251/91-08,

Cycle I of the

RPM continuing training was

provided in April -

May 1991.

The training primarily focused

on

implementation

of the health

physics

aspects

of the

TPN Emergency

Plan

but also

included

modules

on heat stress,

and

hot particle

control.

The course materials

reviewed appeared

to address

properly

the

scope

of the training.

No specific plant systems

training was

provided in the initial 1991

RPM continuing training; however,

the

Cycle II training to begin

in

S'eptember

1991

was

scheduled

to

dedicate

one

day to specialized

training

on valves

and

charging

pumps.

Licensee

representatives

stated that the scheduled

training

will include full use of mock-ups

and will integrate

maintenance

personnel.

The inspector

also

reviewed

the licensee's

program for weekly and

shift/special

briefings

provided for both contractor

and

company

technicians.

The licensee

appeared

to have

a timely and

thorough

e

program for informing personnel

of recent

procedural

changes,

items

of non-compliance,

industry events,

and special

items of interest.

The

inspector

particularly

noted

that

the

recent

NRC violation

regarding

posting of radioactive

waste

and the subsequent

procedural

changes

were addressed

in weekly briefings

as well

as

a June

1991

Shift Briefing.

Licensee

procedure

O-ADM-360,, also

requires

that contract

Health

Physics

Technicians,

RPMs,

and Junior

RPMs,

successfully

complete

performance

tests

prior to

performing

a

duty without direct

supervision. 'he

inspector

reviewed

records for randomly selected

licensee

and contractor

HP technicians

and verified satisfactory

completion

of job

performance

measures.

In addition,

from

discussions

with selected

contractor

technicians,

the

inspector

determined

that the personnel

had received ti.aining as appropriate.

The overall

program for RPM technician training, including continuing

and shift training, appeared

comprehensive

and effective.

No violations or deviations

were identified.

4.

Respiratory Protection

Program

(83729)

10 CFR 20. 103(c)

permits

the licensee

to maintain

and to implement

a

respiratory protective

program that includes,

at

a minimum: air sampling

to identify the

hazards;

surveys

and

bioassays

to evaluate

the actual

exposures;

written procedures

to select, fit and maintain respirators;

written procedures

regarding

supervision

and training of personnel

and

issuance

of records;

and determination

by

a physician prior to use of

respirators

that the individual user is physically able to use respiratory

protective equipment.

a ~

Program

Implementation

TS 6. 11. 1 requires

procedures

for personnel

radiation protection to

be prepared consistent with the requirements

of 10 CFR Part 20 and

be

approved,

maintained,

and

adhered

to for all operations

involving

personnel

radiation exposure.

Health

Physics

Administrative

Procedure

O-HPA-060,

Respiratory

Protection

Plan,

dated

August

5,

1990,

provides

guidelines

and

general

information for maintaining,

issuing,

and using respiratory

protective

equipment

to limit inhalation of airborne

radioactive

material.

A successful

medical

exam

and completion of respiratory

protection training are required prior to respirator initial use

and

annually thereafter.

A quantitative fit test is required prior to

use

and biennially thereafter.

Health

Physics

Surveillance

Procedure

O-HPS-063.4,

Selection

and

Issue of Respiratory Protection

Equipment,

provides the implementi'ng

guides for selecting

appropriate

respiratory protection equipment to

limit the inhalation of airborne radioactive material

and for the

issuing

and tracking the use

of, respiratory .protection equipment.

The inspector

selectively

reviewed

current respiratory

protection

program

records

to verify training,

completion

of individual

physicals,

and fit testing for individuals in activities requiring

the

use of respiratory protection

equipment

as specified

by selected

Radiation

Work Permits

(RWPs).

From

a

review of records

and

discussion

with licensee

representatives,

the inspector

determined

that

an individual assigned

to

a

RWP requiring the use of a full face

respirator

was not qualified to use the respirator

due to

a lapsed

fit test.

The non-qualified individual worked on

RWP 91-2717,

Rinse

and

Perform Initial Surveys, of the Unit Spent

Fuel

Pool Transfer.

Canal,

on July 9,

1991,

wearing

a full face respirator.

The

individual's fit test qualifications

had expired June

30,

1991.

The

individual was

an

HP technician,

who had transferred

from St. Lucie,

checked

the

RWP

requirements'nd

self-issued

the

respiratory

equipment.

The inspector

informed the licensee

representatives

that

the failure to follow KP respiratory protection

procedures

to issue

respiratory protection

equipment

to qualified workers in accordance

with O-HPS-63.4,

was

an example of an apparent violation of TS 6.11.1

(50-250, -251/91-26-01).

After the apparent violation was identified the licensee

determined

that Enclosure

1 of O-HPS-063.4 did not list correctly the Respirator

Codes;

however,

a correct revised list of codes

had

been distributed

and

was available at the respiratory

issue location.

In a subsequent

July

16,

1991 teleconference,

the licensee

informed the inspector

that

a thorough review of respiratory

issue

records

found one other

individual

who

was

not qualified to wear

the

issued

respiratory

equipment.

During the facility tours,

the inspector

noted that all full-face

respirators

available for issuance

at the dress

out building location

were

stored,

individually bagged,

and

labelled

as

required

by

licensee

procedures.

The inspector verified that

a current weekly

printout of respiratory qualifications

was available for use,by the issuer.

One example of an apparent violation for failure to follow HP

~ respiratory protection procedures for issuance

and use of a full-face

respirator

was identified.

Breathing Air guality

10

CFR Appendix A, Footnote

(d) requires

adequate

respirable air of

the quality and- quantity required

in accordance

with

NIOSH/NSHA

certification

described

in

30

CFR

Part ll to

be

provided for

atmospheric-supplying

respirators.

30

CFR 11. 121 requires that compressed,

gaseous

breathing air meets

the applicable

minimum grade

requirements

for Type

1 gaseous air as

set'orth

in

the

Compressed

Gas

Association

(CGA)

Commodity

Specifications for Air, G.7.1

(Grade

D or higher quality).

Health

Physics

Administrative

Procedure

O-HPA-060,

Respiratory

Protection

Plan,

dated

August

5,

1990,

requires

that

station

breathing air compressors,

portable breathing'ir

compressors,

and

compressors

used to fill SCBA air bottles to be sampled quarterly in

accordance

with

Surveillance

Maintenance

Mechanical

Procedure

0-SMM-101. 1,

Grade

D Breathing Air Periodic Testing.'rocedure

0-SMM-101. 1, dated

June

15,

1990, details the methodology to be used

for testing

and certifying breathing air as

Grade

D.

The inspector reviewed'nd

discussed

with licensee

representatives

the program for testing

and qualifying breathing air as

Grade

D.

The

inspector

was

informed that

the

permanent

station

breathing air

compressors

were not being

used during the current outage

due to the

unavailability of adequate

component cooling water; instead,

portable

air compressors

were being utilized to supply station breathing air

as well as air for specific work projects.

The inspector

reviewed recent

breathing air testing records for the

station breathing air compressors,

portable air compressors,

and Self

Contained

Breathing

Apparatus

(SCBA) bottle filling compressors.

Available records

indicated that the

SCBA compressor

and the station

breathing air compressors

were last tested

in August

1990,

and the

SCBA compressor

was mislabelled

as

being tested

"December

1991."

No

records

were available

documenting

the

December

1990 test.

No

immediate

concerns

were identified regarding

the lack of quarterly

testing

on the

SCBA compressor

because

cognizant

HP and, safety

and

fire protection

personnel

indicated

an

awareness

of the compressor

inoperability

and stated

that the

compressor

had not

been

used

to

fill SCBA bottles.

Discussions

with cognizant

licensee

representatives

and

a review of

the program for testing the portable air compressors

revealed that no

testing for air quality occurred during the period of November

1990

through

May

1991

of the

current

outage.

However,

portable

compressors

were in use during this time period to supply air for

work requiring

the

use

of forced air respirators

(i.e.,

Unit

4

pressurizer

and

steam generator

work).

The

1991 testing of portable

compressors

consisted

of tests

conducted

on

June

3,

1991,

and

thereafter for a limited number of compressors.

Further review and

discussions

regarding verification of Grade

D quality air for the

portable

compressors

in use at the time of the onsite

inspection,

indicated that

compressor

No.

30688,

one of two compressors

being

used to supply the station breathing air supply header,

had not been

tested for air quality.

According to licensee

representatives,

this

compressor

was placed into service to replace

compressor

No.

531702

which

was relocated

to the Unit 3 Spent

Fuel

Pool

on approximately

July 8,

1991.

Licensee

personnel

indicated

no knowledge of testing

the

compressor

or the overall station

breathing air system

when

No.

30688

was installed.

The inspector

informed the licensee

that

failure to follow

HP respiratory

protection

procedures

for air

quality testing

was

an additional

example of a violation. of TS 6. 11. 1

(50-250,

-251/91-26-01).

On July ll, 1991,

the licensee

tested

and

subsequently

verified Grade

D air quality for the compressor.

Subsequent

to

the

onsite

inspection,

the

licensee

informed

the

inspector that

a Radiological

Investigation

Report

(RIR) was issued

on June

3,

1991, identifying the lack of air quality testing.

The

immediate

RIR corrective

actions

included testing

breathing

air

compressors

in

use

(completed

June

3

and

4,

1991),

as well

as

procedural

changes

requiring sign-off of certification prior to use.

The latter action

was scheduled for completion

by November 30,

1991.

Although the licensee

did take immediate corrective actions to ensure

breathing air in use at the time was tested,

no interim measures

were

implemented

to track the

replacement

and

movement of compressors

until such

time

as the

new procedural

requirements

were implemented.

The inspector

noted that this failure may have contributed to the use

of the untested

compressor

discussed

previously.

Other observations

regarding breathing air. indicated that compressors

used to supply breathing air were not clearly marked or labelled with

the certification.

In addition,

one

compressor

was

placarded

indicating that it was being

used for breathing air but actually was

being used for instrument air.

On July

16,

1991,

licensee

management

contacted

the inspector to

advise of additional corrective actions resulting from the identified

apparent

violation.

- These activities

included notification of all

departments

regarding

use

of Grade

D air

and

ensuring

that all

compressors

used for breathing

are posted with Grade

D certification.

An additional

example of an apparent violation for failure to follow

HP respiratory protection

procedures

for verifying Grade

D breathing

air was identified.

5.

Administrative and'Operational

Radiological

Controls

(83729)

a

~

Form NRC-4

10 CFR 20. 102(b) requires,

under certain circumstances,

the licensee

to obtain

a certificate

on

Form

NRC-4,

signed

by the individual

showing

each

period of time after the individual attained

the age of

18 in which

an occupational

dose to radiation

was received.

This

signed

and

completed

form shall

be obtained

before permitting the

individual in

a restricted

area to receive

an occupational

radiation

do'se in excess

of the standards

specified in 10 CFR 20. 101(a).

To verify completion.and

maintenance

of individual's

Form NRC-4,

as

appropriate,

the

inspector

reviewed

selected

licensee

dosimetry

records

of workers

signed

on

RWPs initiated/utilized for high dose

rate tasks.

The inspector verified

a completed

Form NRC-4 on file

for all workers

as applicable.

No violations or deviations

were identified.

Radiation

Exposure

Extensions

Licensee

procedure

0-HPS-031. 6,

Processing

Radiation

Exposure

Extensions,

dated

December

12,

1990,

details

requirements

and

responsibilities

for processing

extensions

of selected

exposure

facility guidelines.

The inspector

reviewed selected

January

1, through June 30,

1991 dose

records

for personnel

who

exceeded

the licensee's

administrative

whole

body exposure limit of 1800 millirem per quarter

(mrem/qtr)

requiring

HP,

Supervisor

approval.

For the

personnel

reviewed

the

inspector verified that,

as applicable,

extensions

were approved,

and

both

Forms

NRC

4 and

NRC

5 were current.

The inspector

noted that

the

dosimetry

controls

and

records

were

considered

a

program

strength.

No violations or deviations

were identified.

Control of Material

Released

from the

HP surveillance

procedure

O-HPS-021.3,

Release

of Material from the

Radiation Controlled Area,

dated

October

10,

1990, provides

guidance

for controlling release

of bulk material

from the

The procedure

requires,

in part,

that all materials

released

from the

RCA be

surveyed

and subsequent

documentation

be maintained

on

Form HP-124.

From

discussion

with

licensee

representatives

and

review of

applicable

records,

the inspector verified that all bulk materials

released

from the

RCA from July 8 through ll, 1991, were surveyed

and

documentation

was

maintained

in

accordance

with the

applicable

procedure.

During review of this program area,

licensee

representatives

informed

the inspector of concerns

regarding the adequacy of surveys

conducted

for scrap

copper

cable

released

from the

RCA on January

30,

1991.

Further inspection

indicated that the subject event

was identified,

reviewed,

and

documented

by cognizant

licensee

personnel

in

RIR

91-93-1,

dated

February

6,

1991,

and an'associated

Nuclear Problem

Report.

The inspector

reviewed

and discussed

with cognizant licensee

representatives

details of the evaluation,

findings,

and subsequent

actions

taken to prevent recurrence

of the issue.

The report noted

that bulk scrap

copper material

was

released

on January

30,

1991,

from the

RCA and that the. adequacy

of surveys utilized for final

release

of the materials

from the

RCA was questionable.

Further,

the report

noted that

the appropriate

documentation

regarding

the

release

surveys

was not completed

as required.

The inspector

noted

10

that the failure to complete

proper documentation,

Form HP-124, in

accordance

with procedural

guidance

utilized for release

of bulk

materials

from the

was

a violation of

TS 6.11. 1

(50-250,

-251/91-26-02).

Further

discussions

with

cognizant

licensee

personnel

indicated that the

scrap

copper

cable

was

removed

from

non-contaminated

systems

and that, at that time the material

was

surveyed,

the

cable

was

determined

to

be free of measurable

contamination.

The materials

were

moved to

a staging

area prior to

transfer

from the

The following shift the cable

was released

from the

All the scrap

copper cable released

was maintained

on

site.

After notification of concerns

regarding

RCA release

surveys,

HP.

personnel

required

the material

to

be returned

to the

All

vehicles,

equipment,

and

personnel

utilized to transport

the

materials

from the

RCA,

and the onsite location outside of the

where the material

was stored

were surveyed

and verified to be free

of contamination.

Subsequently,

the material

was stored within the

RCA for approximately

three

days prior to being

resurveyed.

Upon

resurveying,

contamination

was detected

on

some of the copper cable.

Licensee

followup evaluations

indicated

that

the

contamination

occurred

most likely after the cable

was returned

to the

RCA and

resulted

from cross-contamination

from additional materials

placed in

the

storage

area.

The inspector

reviewed

and

discussed

proposed

corrective

actions

including

removing

material

from

the

immediately after completion of surveys

or securing

material after

completion

of surveys

to prevent

additional

materials

from being

added

to the material

awaiting

release.

In addition,

licensee

representatives

provided

the

inspector

with

a, memorandum

dated

February

8,

1991,

instructing all

HPSSs

to verify surveys

were

conducted

and that the responsible

supervisor is contacted prior to

release

of the material

from the

The

inspector

informed

licensee

representatives

that issue

and subsequent

corrective actions

met the conditions of 10 CFR Part 2, Appendix

C, V.G. 1, and that the

failure to follow procedures

for releasing

bulk materials

from the

RCA would not be cited.

One licensee-identified

NCV for failure to follow HP surveillance

procedures for documenting

the release of bulk materials

from the

was identified.

e

6.

Audits (83729)

TS 6.5.2.8

requires

audits

of facility activities to be performed

under

"

the

cognizance

of the

Company

Nuclear

Review Board

(CNRB) encompassing

conformance

of facility operation to all provisions contained

in the

TSs

and applicable

License

Conditions at least

once

per

12 months,

and the

Process

Control

Program

(PCP)

and

implementing

procedures

at least

once

per

24, months.

11

During the onsite inspection,

Licensee

Quality Assurance

(QA) personnel

informed the inspector that

a May 1991'QA audit reviewed selected

areas

of

the licensee's

radiological respiratory protection

program.

The inspector

selectively

reviewed

QA Audit QAO-PTN-91-038,

dated

June

13,

1991, to

determine if findings similar to those

identified during the current

inspection

(Paragraph

4) were identified previously.

No issues

similar to

the current findings were identified.

In general,

the audi.t identified

concerns

regarding

respiratory

protection

program

procedural

adequacy;

calibration of equipment;

maintenance,

testing

and storage

of measuring

and .test

equipment

used in the program;

and storage of selected

records.

The inspector

noted that

responses

to the identified issues

were

due

on

July 14,

1991,

and thus,

were not available for review during the onsite

inspection.

Also, the audit noted that requirements

of the

QA program

were effectively addressed

by the respiratory protection

procedures,

and

that

procedural

implementation

was effective.

The inspector

informed

licensee

representatives

that these

issues

would be reviewed subsequent

to

completion

of the

appropriate

licensee

responses.

In general,

the

inspector

noted

the audits

continued

to

be well-planned

and documented,

and contained

items of substance

related to the overall

RP program.

The inspector

noted that based

on the depth of review and significance of

identified issues,

the

present

audit

program

was

considered

a program

strength

and continued to contribute to the

RP program improvements.

No violations or deviations

were identified.

7.

Internal

Exposure

(83729)

10 CFR 20. 103(a)(1)

states

that

no licensee

shall

possess,

use,

or

transfer licensed material in such

a manner

as to permit any individual in

a restricted

area

to inhale

a quantity of radioactive" material

in any

period of one

calendar

quarter

greater

than

the quantity which would

result

from inhalation for 40

hours

per

week for 13 weeks

at uniform

concentrations

of radioactive material in air specified in 10 CFR Part 20,

Appendix B, Table 1,

Column 1.

10 CFR 20. 103(a)(3)

requires for purposes

of determining

compliance with

the

requirements

of this

section,

the

licensee

to

use

suitable

measurements

of concentrations

of radioactive

materials

in air for

detecting

and evaluating airborne radioactivity in restricted

areas

and in

addition,

as

appropriate,

to

use

measurements

of radioactivity in the

body,

measurements

of radioactivity excreted

from the

body,

or

any

combination of such

measurements

as

may

be

necessary

for the timely

detection

and assessment

of individual intakes of radioactivity by exposed

individuals.

a.

Whole Body Analyses

Health

Physics

Administrative

Procedure

O-HPA-031,

Personnel

Monitoring of Internal

Dose,

dated

October

15,

1989,

requires

initial, annual,

and termination

bioassay

measurements

for workers

12

accessing

the

The inspector

reviewed

selected

reco'rds

of

recently terminated or hired individuals and verified that whole body

analyses

were performed

as required.

In addition,

the

records of

individuals involved in recent

outage incidents, including

a Reactor

Coolant

Pump

(RCP)

Seal. Tent event,

Unit 3 Loss of Air event,

and

facial contaminations,

as well as routine activities were reviewed.

Records

for all individuals indicated that current,

routine whole

body measurements

were conducted.

Additionally, the

licensee's

program for special

bioassays

was

evaluated.

'rocedure

0-HPA-031 requires

that

a special

bioassay

measurement

be

performed

when

the

following criteria

are

met:

(1) nasal

swabs

or facial

contamination

in

excess

of

5000

disintegrations

.per

minute

(dpm);

(2)

exposure

to

airborne

radioactivity

in

excess

of

30

maximum

permissible

airborne

concentration-hours

(HPCa-hrs) in one week;

(3) any real or suspected

accidental

internal exposure;

and (4) accumulation of greater

than or

equal

to

10 NPCa-hrs of tritium in one day.

The inspector reviewed

the

RIRs for April through

June

1991, detailing individuals reported

to

have

positive facial

contamination

or potential

unanticipated

exposure

to airborne activity for the events

discussed

above.

For

all the reviewed cases,

special

whole body analyses

were conducted

in

accordance

with procedural

guidance,

and

no positive

measurements

were obtained.

In addition, the inspector

reviewed in detail

a facial contamination

incident which occurred

during the onsite inspection.

The incident

occur red while the worker

was

removing

from the reactor cavity

a

contaminated

vacuum

hose

used

for cleaning.

The

licensee

appropriately

conducted

special

whole

body

measurements

with

an

initial, maximum permissible

organ

burden

(NPOB) -of 4.85

percent

Cobalt-60

being

measured.

After three

successive

decontaminations

and releasing

the individual to go home,

a negative whole body count

was obtained

the next morning.

The licensee's

preliminary results

indicated

that the

measured

contamination

was primarily external;

however,

the final

RIR and assessment

of the incident

had not been

completed at the conclusion of the inspection.

The inspector

noted

the licensee's

preliminary and proposed

actions to be appropriate

and

had

no additional

questions

regarding this issue.

No violations or deviations

were identified.

Instrumentation

and guality Control

The inspector

reviewed

and discussed

with the licensee future changes

to the whole body counting equipment.

At the time of the inspection,

the licensee

continued to use

a "moving bed"

and

a "chair" geometry

systems

located

adjacent

to the Health

Physics

administrative

and

dosimetry offices.

However, licensee

representatives

indicated that

within the next six weeks

the

new Fast

Scan

"standing"

geometry

13

counter

should

be

operational.

The

new

system

currently

was

undergoing

software, verification and validation.

Additionally, the

whole

body

counting

Quality Assurance/Quality

Control

(QA/QC)

program

procedures

and

records

were

reviewed.

Specifically, procedure

O-HPT-014.5, Calibration

and Operation of the

Health Physics

Whole

Body Counter,

dated

December

7,

1989, describes

the daily background

and

energy calibrations,

annual

calibrations,

and quarterly interlaboratory

cross-checks.

The inspector verified

that

daily

background

and

energy

calibration

checks

using

Europium-152 were conducted

as required,

and all of the reviewed data

were within the established

control limits.

The annual calibrations

as well as

a special calibration

due to an amplifier replacement

also

"

were reviewed.

No concerns

were noted.

The

licensee's

participation

in

an

interlaboratory

cross-check

program

was

r'eviewed.

The checks

were performed quarterly with an

approved

vendor.

Although the results of 1991 cross-checks

were not

available for review during the inspection,

the December

1990 cross-

check

was

evaluated.

The inspector

noted that the

"moving bed"

geometry

system failed the

cross-check

acceptance

criteria.

This

problem

has

occurred

for previous

cross-checks

conducted.

The

inspector

was

informed

and verified in procedures

that the

"moving

bed"

scanner

was

used

only for routine, qualitative analyses.

Any

special

measurements

of suspected

intakes

were

performed

using the

chair

geometry.

No problems

were

noted with the "chair" counter

cross-checks.

No violations or deviations

were identified.

8.

External

Exposure

(83729)

10 CFR 20. 101 requires

that

no licensee

shall

possess,

use or transfer

licensed

material

in

such

a

manner

as

to

cause

any individual in

a

restricted

area to receive

in any period 'of one calendar

quarter

a total

occupational

dose

in excess

of 1.25

rems to the whole body;

head

and

trunk; active

blood

forming organs;

lens

of the

eyes;

or

gonads;

18.75

rems to the hands

and forearms; feet and ankles; and'.5

rems to the

skin of the whole body.

The inspector

reviewed

the

January

1 through

June

30,

1991 cumulative

whole

body

cumulative

exposures

for both

-licensee

and

contractor

personnel.

The inspector verified that the assigned

quarterly doses

were

within

10 CFR Part 20 limits.

The

maximum

cumulative year-to-date

exposure

listed

was

3458 millirem (mrem) assigned

to

a contract worker.

The inspector verified that

exposure history'iles

were

completed

and

extensions

were

reviewed

and granted

in accordance

with the applicable

procedure;

14

Licensee

HP administrative

procedure

O-HPA-034.2, Determination of Dose to

the Skin

From Skin Contamination,

dated

June

20,

1989, details

guidance

for determining

skin

dose

due to surface

contamination.

Skin

dose

calculations

are

required

when

total

exposure

exceeds

25,000

disintegrations

per minute-hours

(dpm-hrs) for a hot particle.

The inspector

reviewed selected

RIR data,

Personnel

Contamination

Reports,

and Hot Particle

Logs issued

from January

1, 1991, through July 10,

1991.

Skin dose calculations

conducted for selected

personnel

were reviewed

and

discussed

with cognizant

licensee

representatives.

In particular,

licensee

actions

and

subsequent

preliminary evaluation

regarding

a July

10,

1991

skin

contamination

event

were

reviewed

in detail.

The

contamination

was identification

as

a discrete

particle

located

on

a

.

worker's

s'calp.

The

inspector

reviewed

and verified decontamination

activities,

preliminary activity measurements,

stay

time estimates

and

parameters

utilized during the evaluation.

A preliminary skin

dose

as

measured

through

a density

thickness

of

7 milligrams per centimeter

squared

(mg/cm') of 2865

mrem

was reported.

Licensee

actions

regarding

this issue

were considered

adequate.

For all

RIRs reviewed the licensee

contamination

and skin dose evaluations

were considered

appropriate.

No violations or deviations

were identified.

9.

As Low As Reasonably

Achievable

(83729)

a ~

ALARA Initiatives

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

ALARA.

The

inspector

reviewed

and

discu'ssed

with cognizant

licensee

representatives

ALARA program

implementation

and initiatives for

selected

Unit (U)-3'nd U-4 outage activities.

In particular,

ALARA

initiatives concerning

Resistance

Temperature

Detector

(RTD) removal,

steam

generator

(S/G)

Eddy

Current

testing

(ECT),

and

use

of

temporary

shielding

in containment

were

reviewed

and

discussed

in

detail.

Licensee

representatives

discussed

with the inspector

general

area

dose

rate

reduction

resulting

from increased

use

of temporary

shielding

within the

containments

during

the

current

outage.

Approximately 120,000

pounds

(lbs) of lead shielding

were installed

in each

containment.

This

compares

to previous

outages

when only

one-tenth

of this

amount of shielding

was utilized.

Based

on

an

expenditure

of

approximately

56

person-rem

for

shielding

installation,

a

subsequent

estimated

dose

rate

reduction

of

approximately

25

mrem/hr,

and

an

estimate

of approximately

18500 hours

worked in both containments

as of June

20,

1991,

a total

savings

of 407 person-rem

was estimated

for the

outage activities

completed

to date.

Licensee

representatives

stated

that additional

15

dose

rate

measurements

made

following completion

of the current

outage,

and/or prior to initiation of subsequent

outages

would

supplement

the evaluation of dose expenditure

reduction. provided

by

the use of increased

temporary shielding.

The inspector

reviewed

and discussed

with licensee

representatives

the man-rem expenditure for both U-3 and

U-4

RTD bypass

elimination

tasks.

An initial estimate of 105 man-rem per unit was projected for

completion of the task.

Review of preliminary ALARA report data for

the

RTD by-pass

removal

task indicated

a total of approximately

76

and

54 person-rem

expended for U-4 and

U-3

RTD removal activities,

respectively.

Licensee

representatives

stated

that the projected

. dose expenditures for'he U-3 and

U-4

RTD bypass

elimination tasks.,

approximately

60 percent

less

than original estimates,

would be

among

the lowest reported for the industry.

The inspector

noted that the

licensee's

preplanning,

increased

use of temporary

shielding,

and

detailed

mockup

training

were

considered

program

initiatives/improvements contributing'o the reduced

dose expenditure

for the subject task.

In addition,

licensee

representatives

informed

the

inspector

of

significant

dose

reductions,

approximately

50

percent,

for the

100 percent

ECT of the

U-4 S/G.

A total of 6.89

person-rem

was

expended

relative

to

an

average

of

13.3

person-rem

previously

expended

for similar

tasks.

Identified

improvements

included

pre-wrapped

probes

on disposable

reels,

reduced

frequency of probe

changes,

elimination of ECT power sources

in containment,

increased

pull

speed

for data

collection,

overhaul

and/or testing

of

ECT

equipment prior to installation

on

S/G platforms,

and

use of a lead

technician to direct

HP effort and coordinate

ECT work.

Licensee

representatives

informed the inspector that as of week 30 of

the

dual unit outage,

a total of approximately

642 person-rem

as

measured

by direct reading dosimeter

(DRD) had been

expended with the

majority of dose

intensive

work completed.

Further, this value

was

less,

by

a significant margin,

than

the approximate

900 person-rem

projected for the

same

amount of work.

The inspector

informed

licensee

representatives

that their

ALARA

activities

and initiatives

associated

with the

current

outage

operations

were considered

a program strength.

No violations or deviations

were identified.

b.,

Performance

Parameters

During the onsite audit,

the inspector

reviewed

and discussed

with

cognizant licensee

representatives,

selected

quantitative

parameters

regarded

as

indicators

of or which contributed

to the

RP program

effectiveness.

The reviewed parameters

included person-rem

expended,

16

personnel

contamination

events

(PCEs),

and the percentage

of the

regarded

as contaminated.

Personnel

Dose

Expenditure:

For the period January

1,

1988,

through

December

31,

1990,

the site annual

cumulative personnel

exposure

per

unit

was

approximately

385,

216,

and

365 person-rem,

respectively.

From January

1 through

Nay 31,

1991,

a

dose

expenditure

of approximately

238 person-rem

per

unit

was

reported

with

a

1991

annual

dose

of less

than

500 person-rem

per unit projected.

For week 30 of the dual unit

.outage

which started

in November

1990, the licensee

reported

an

expenditure

of

approximately

321

person-rem

per

. unit,

significantly less

than the

450 person-rem

per unit originally

projected for the

same period of time and for similar job scope.

Licensee representatives

stated that increased

ALARA initiatives

have contributed to the reduced

person-rem expenditure.

Personnel

Contamination

Events

(PCEs):

For the January

1, 1988,

through

December

31,

1990 period,

the licensee

reported

362,

168,

214,

PCEs annually.

In particular,

the inspector

noted

a

significant decrease

for the period January

1 through

Nay 31,

1991, during which the licensee

reported approximately

61 PCEs.

The licensee

projected

approximately

121

PCEs for the current

year.

Discussions

with licensee

representatives

indicated that

improvements

in laundry facilities,

including

upgrading

of

monitoring

equipment,

utilization of

an

additional

vendor

laundry onsite

and

improved licensee facilities resulted in the

noted reduction.

No

Contaminated

Surface

Area Control:

The inspector

noted

the

licensee's

continued efforts at maintaining reduced

contaminated

floor space within the

RCA during the dual unit outage.

As of

June

30,

1991,

13,232

square feet, approximately

11 percent, of

the

119,015

square

feet of total

recoverable

space within the

was

maintained

as

contaminated.

This

figure

was

significantly reduced

from the

20 percent previously associated

with extended

outages

at

the facility.

The

continued

low

percentage

was attributed to extensive

decontamination effort,

the use of catch containments,

tracking and repair of leaks,

and

increased

awareness

of plant personnel

regarding

contamination

control.

The licensee

was projecting to reduce

the

area of

contaminated

space

reduced

to approximately

6345

square

feet,

5 percent

by December

31,

1991.

violations or deviations

were identified.

0

10.

Facility Tours

(83729,

86750)

During the onsite inspection,

the inspector

toured selected

areas

of the

U-3 and

U-4 Auxiliary Building, U-3 Containment,

U-3 and

U-4 Spent

Fuel

Storage

Pools,

and radioactive

waste

processing

and/or storage

locations.

17

The inspector

observed facility operations,

and selected

work activities

to evaluate

the

implementation

and effectiveness

of the licensee's

RP.

program.

The following specific radiation protection issues

and concerns

were noted

and discussed'ith- licensee

representatives.

a ~

Instrumentation

b.

c ~

All survey meters

and continuous air monitors in use within the

Locked High Radiation Areas

were observed to be operable,

calibrated,

and source

checked daily in

accordance

with licensee

procedures.

In addition,

background

radiation levels at survey locations

were observed

to

be within an

acceptable

range,

less

than

300 counts

per minute.

No violations or deviations

were identified.

Notices to Workers

10 CFR 19.11(a)

and (b) require, in part, that the licensee

post

current copies of Part

19, Part 20, the license,

license conditions,

documents

incorporated

into the license,

license

amendments

and

'operation

procedures,

or that

a licensee

post

a notice describing

these

documents

and where they may be examined.

10 CFR 19. 11(d) requires that

a licensee

post

Form NRC-3, Notice to

Employees.

Sufficient copies of the required forms are to be posted

to permit licensee

workers to observe

them

on the

way to or from

licensed activity locations.

During the inspection,

the inspector verified that

NRC Form-3

was

posted

properly at various plant locations permitting worker access

to licensed activities.

Although the license,

associated

amendments,

and regulations

were not posted individually, a reference

was posted

noting

the

location

and availability of this information.

In

particular,

the inspector verified both of the aforementioned

items

were posted at the

new entrance

of the Protected

Area at the time of

the inspection.

No violations or deviations

were identified.

TS 6. 12.2 requires that areas

accessible

to personnel

with radiation

levels

greater

than

1000

mR/hr at

18

inches

to

be provided with

locked

doors

to

prevent

unauthorized

entry in addition

to the

requirements

of

TS- 6.12. 1.

The

keys for the locked high radiation

areas

are to be maintained

under administrative control.

Discussions

with licensee

personnel

and

a

review of procedure

0-HPS-025. 1,

General

Posting

Requirements

for Radiological

Hazards,

dated

December

30,

1990, indicated that

an administrative requirement

for posting

locked

high radiation

areas

has

been

established

at

800 mR/hr.

18

During tours of the

U-3 containment

and

the

U-3 and

U-4 Auxiliary

Building, all locked high radiation

areas

were verified to be locked

and conspicuously

posted.

Observation of work activities in progress

U-3 Spent

Fuel

Pool Transfer

Canal

survey noted the

area

to

be

posted

and controlled properly.

Initial posting

as

a

locked high radiation

area

was required

due to the presence

of dose

rates of

1 R/hr and

3 R/hr at

18 inches

from two discrete horizontal

canal

surface

areas.

However,

in lieu of locking the

area,

continuous

coverage

was

provided to maintain positive

access

control.

The locked radiation

area

controls were'aintained

until

initial

decontamination

efforts

were

completed.

After

decontamination,

maximum

radiation

levels

were

reduced

to

'pproximately

600 mrem/hr,

and the licensee

subsequently

posted

and

maintained

the area

as

a high radiation area.

No violations or deviations

were identified.

Labelling and Posting

10 CFR 20.203(e)

requires

each

area. in which licensed

material

is

used

or stored

and

which contains

any radioactive

material

in an

amount exceeding

ten times the quantity of such material specified in

Appendix

C of this part to be posted with a sign or signs bearing the

radiation

caution

symbol

and

the

words:

"Caution,

Radioactive

Material(s)."

10 CFR 20.203 (f) requires,

in part,

each container of

licensed

material

to

bear

a

durable,

clearly visible

label

identifying the radioactive

contents.

The label

is to bear

the

radiation

caution

symbol

and

the

words

"Caution,

Radioactive

Material,"

and

also

provide sufficient

information to

permit

individuals

handling

or using

the containers,

or working in the

vicinity thereof, to take precautions

to avoid or minimize exposures.

Health

Physics

Surveillance

Procedure

O-HPS-041,

Control

of

Radioactive

Material

Inside

the

Radiation

Controlled Area,

dated

May 2,

1991,

requires,

radioactive

material to'e

posted

and

otherwise

identified

as

required

by

0-HPS-025. 1.

Procedure

0-HPS-025. 1,

General

Posting

Requirements

for Radiological

Hazards,

dated

December

31,

1990,

requires

individual

containers

of

radioactive

material

containing

greater

than

10 CFR Part 20,

Appendix

C quantities to be labelled.

During tours of the licensee's

radioactive

waste storage

areas

and

the

Radwaste

Building

on July 9,

1991,

the inspector

noted

the

presence

of an onsite storage

resin cask within the Radwaste

Building

which was not labelled or tagged

adequately.

Although the cask

was

posted

as

a

"High Radiation Area,"

no label

was present

indicating

the radioactive contents of the cask or radiation levels,

nor was the

access

to the area controlled.

Subsequent

surveys

by the licensee

on

July 9,

1991, indicated

dose rates of 15 mR/hr contact

and

6 mR/hr at

18 inches

and licensee

representatives

confirmed radioactive material

contents

greater

than

Appendix

C limits.

The licensee

promptly

e

19

,labelled the cask with the proper information.

According to licensee

representatives,

the

cask

was

labelled

previously;

however,

in

preparation for transport

in late

Nay 1991, the label

was

removed.

Subsequently,

as

a result of radiological concerns,

the cask

was not

shipped

as

planned,

and

the

required

label

was

not

replaced.

Therefore,

the

cask

remained

unlabelled

from approximately late

May

1991 through July 9,

1991.

The inspector

informed the licensee that

the failure to follow HP surveillance

procedures

for labelling the

storage

cask

was

an

apparent

violation of

TS

6. 11. 1

(50-250,

-251/91-26-03).

The inspector

noted that the violation was similar

to

a violation identified during an inspection

conducted

February

25

- March

1,

1991,

and

documented

in IR 50-250,

-251/91-08.

Licensee

representatives

took prompt action to survey.

and properly label

the

cask

during

the

onsite

inspection.

During

a July

16,

1991

teleconference,

licensee

management

informed

the

inspector

of

immediate

and

planned

corrective

actions

improper

labelling issue.

These activities included:

formulation of a team

to review all radioactive materials for proper posting

and labelling,

ensuring

that all radiation protection

personnel

are

cognizant of

identified labelling

problems,

development

of specific

tagging

criteria to be incorporated

into procedures

by August 1,

1991,

and

a

review of previous audits to determine

any broad programmatic issues.

The inspector

acknowledged

the licensee's

corrective actions

and

had

no additional

concerns.

One

repeat

apparent

violation regarding

the failure to follow HP

surveillance

procedures

for labelling

an onsite

storage

cask

was

identified.

e.

Independent

Surveys

During the facility tours,

the inspector

independently verified

radiation

and/or

contamination

levels, in radwaste

areas,

various

Auxiliary Building locations,

storage

vans,

Radwaste

Building,

radioactive

waste

shipping

containers

prepared

for transport,

and

general

waste processing/storage

locations.

The inspector

noted that

excluding

the onsite

storage

cask

(Paragraph

10.d) all containers,

materials,

and

areas

were

properly

labelled,

posted,

and/or

safeguarded

in accordance

with the radiation

hazards

present.

General

Observations

During the plant tours,

the following general

observations

regarding

contamination control, general

labelling,

and industrial safety were

noted

and discussed

with the licensee.

Contamination Control:

A sea

van used to store slightly contaminated

lead shielding

was

found

to

have

a

broken, side

door

lock.

The

licensee

expeditiously replaced

the broken

hasp

and locked the van.

20

Tools

having

fixed

contamination,

painted

"purple,"

were

observed

in clean areas

inside the

RCA..

One tool was found in a

tool

box at Gate

50 and another

in a clear plastic

bag outside

the

U-3 cask

decon

area.

Contamination

surveys

indicated that

the tools did not have loose contamination

and were most likely

misplaced

during transit

to work locations.

The

licensee

expeditiously

removed

the

tools

and

placed

them in proper

storage.

Several

examples of equipment

and hoses straddling

contamination

area

boundary

lines

were

found.

The licensee

performed

applicable

surveys

and

moved

the material

to the

correct location in a timely manner.

Labelling and Posting:

Several

trash

bins in the clean trash sorting area

were found

unlabelled.

The licensee

took immediate corrective action to

properly label

them.

The inspector

noted that individual survey

maps were not

maintained

at the entrance

to each

room or area.

Currently,

only selected

survey

maps

are

posted at area/building

entrances

while all survey measurements

are

posted at the entrance

to the

RCA for evaluation

by entering workers.

This area

was discussed

in-depth with the licensee,'nd

representatives

stated

that

these

measures

had

been

implemented to better control the posted

information

and

ensure

only current information

was available

for workers.

The chicken-wire

gate

located

south

and outside

of the

U-4

Transfer

Canal

which controls

access

to

a potential

locked High

Radiation Area during fuel movement

was in disrepair.

A "High Radiation Area" posting

was found laying at the base of

the west door to the

U-3 Spent

Fuel Pool.

Although the posting

was

not affixed to the door, the inspector verified access

to

the

area

was

controlled

by

the

locked

door.

Licensee

representatives

indicated that

a

new adhesive

used to attach the

sign to the

door

had failed.

Immediate action

was

taken to

replace

the sign conspicuously

on, the door.

At the

U-4 equipment

hatch,

an unlabelled cart

was

used for

transferring

contaminated material.

Industrial Safety:

The eye wash station at the

U-4 guard

shed

was not pressurized

and

was inoperable.

The licensee

had noted this earlier during

a site tour

and was in the process

of correcting the problem.

21

Compressed

gas

cylinders

in the

Radwaste

Building

and

U-3

Containment

Seal

Table area

were not secured

properly.

During

the onsite

inspection,

the inspector

noted that the licensee

took

prompt action

to

remove

the cylinder in the

Radwaste

Building.

The inspector also noted that

no emergency

evacuation exit

signs

di recting workers to the outside

were posted

on the U-3

containment

refueling

elevation.

The

licensee

agreed

to

evaluate

the

placement

of

"Evacuation"

signs

in

the

containments.

In addition to the above,

during the tour of the U-3 Containment

a

test of the containment

'evacuation

alarm

was conducted.

The alarm

was clear'ly audible

by the inspector within the bioshield;

however,

an announcement

preceding

the test

was not heard.

Discussions

with

licensee

representatives

and management

at the exit meeting indicated

that

a study of alarm audibility was ongoing to address

previously

identified

concerns

in this

area.

During

a

July

17,

1991

teleconference,

the inspector

discussed

with licensee

representatives

NRC Bulletin 79-18, Audibility Problems

Encountered

on Evacuation of

Personnel

from High-Noise

Areas,

and

noted that

the

licensee's

, evaluation

of audibility problems

with containment

public address

system

would be tracked

as

an inspector followup item (IFI) (50-250,

-251/91-26-04).

One IFI regarding

the

review of the licensee's

evaluation of the

,audibility of the U-3 and

U-4 containment public address

systems

was

identified.

ll.

Low-Level Radioactive

Waste Storage Facilities

(65051)

The

Low-Level Radioactive

Waste

Policy Amendments

Act provides for the

closing of the Barnwell

Waste

Management Facility on

December

31,

1992.

In anticipation of this closing, the licensee's

plans for dealing with the

closure were reviewed.

The original interim Storage of Dry Active Waste in the Storage

Warehouse

developed

consistent

with

NRC Generic Letter 81-38, "Storage of Low-Level

Radioactive

Waste at Power Reactor Sites"

was outlined in PC/M 83-24.

The

storage

warehouse

provided for approximately

40,000 cubic feet of waste

having

a total activity of 14.8 curies.

In anticipation of the

need to'pdate

the Dry Active Waste

(DAW) Storage,

the licensee

has prepared

two Request for Engineering Actions (REAs),

REA

No.91-092,

Requalify

Dry Storage

Warehouse

for

DAW Storage,

dated

April 22,

1991,

and

REA No.91-138, Onsite Storage for Spent Resin,

dated

June

18,

1991.

The

REAs are currently awaiting prioritization and project

scheduling.

23

49

CFR 172.203(d)(i)

requires

the description for

a

shipment

of

radioactive material

to include the

name of. each radionuclide in the

radioactive material

and the activity contained

in each

package

of

the shipment in terms of curies, millicuries, or microcuries.

49

CFR 172.604(a)(1)(3)

requires that

a person

who offers

a hazardous

material for transportation

must provide

a 24-hour emergency

response

telephone

number

(including the

area

code or international

access

code) for use in the event of an emergency

involving the hazardous

material.

The telephone

number must

be monitored at all times

and

entered

on the shipping paper.

During

the

inspection;

the

inspector

observed

licensee

shipping

..

activity and

reviewed

the

records

of radioactive

waste

shipments91-048 .and

91-050 transported

to

a

radwaste

processing

contractor.-

The shipping manifests

examined

were consistent

with the applicable

49

CFR Parts

170

through

189

requirements.

The radiation

and

contamination

survey results

were within the limits specified for

this

mode of transport

and shipment classification,

and the shipping

documents

were completed

and maintained

as required.

The inspector telephoned

the 24-hour emergency

response

number listed

on the shipping manifest

as required

by 49

CFR 172.602 for use in the

event of an emergency.

The call was placed several

times during the

evening of July 11,

1991,

and the inspector

was unable to complete

the

call

to

the cellular

phone

maintained

by

the

licensee.

Radioactive

waste

shipment

91-050 left the site

on July ll, 1991,

and

was in transit.

A subsequent call'o the

U-3 and

U-4 Control

Room

was

made

and

they

were

informed of the

unsuccessful

attempts

to

contact the cellular telephone.

Approximately 40 minutes later, the

licensee

was

successful

in contacting

the

emergency

telephone

(cellular telephone).

The licensee

placed

several

test calls the

morning of July 12,

1991,

and obtained unsatisfactory

results.

The

inspector

informed the licensee

representatives

that the failure to

provide

a reliable 24-hour

emergency

telephone

number in accordance

with 49

CFR

172.602

was

a violation of

10 CFR 71.5 requirements

(50-250, -251/91-26-05).

One violation for failure to provide

a reliable

24-hour

point of

contact for waste

shipments

was identified.

13.

Followup Items

(92701)

(Closed)

IFI

50-250/89-14-10:

Reduce

discrepancies

in

pocket

and

Thermoluminescent

Dosimeter

(TLD) measurements.

This item identified large differences

in dose

measurements

between

DRDs

and

TLDs.

Differences of approximately

55 and

25 percent for non-outage

and outage periods, respectively,

were identified.

'68'6no~qk

OLI sW~ed

830 60

ui

(J.OQ)

uoI.ZeZ~odsue~J

go

ZuawZ~edag

aug

go

Z~odsueay

go

apow

aug

oZ aZeudovdde.

suoLZe[nGav

aug

go sZuawazt.nba'[qeoc[dde

aug

qg~e ELdwoo og 'q.~odsue~g

~op ~au~e~

e

oZ [eiwaZew pasua~LL

s~aAiiap

ops zo 'asn

go aoe[d

vaq~o

zo

q.ue[d

sgL

go

sauLguoo

aqq.

apssgno

[eL~agew pasuaoi[

sgvodsuevg

ops aasuaoi[

e ~egg

saainbaa

g'yg gag

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uuog

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aug

pue

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pue EZLguap~ api[onuoipez

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guawdiqs

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go ~uawdLqs

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saz~nbaz

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p~[og

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uoig~ag

soisEqd

qg[eaH

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pa~zagsue~g

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si Guip[Lnq sLqg cog E~t[iqLsuodsa~

aug

gyp

GuL~oq.s

suiGaq

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aug

uaqm

'zanamoH

'~aGeueg

aoinaag

aug

og pau6Lsse

si Egi[toeg sing

mod EgL[iqLsuodsaz

guazzng

agsem

ahtqoe

Exp cog

EZLLsoeg

aGeaoZs

wLaagut.

ue

se

pasn

uaaq

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seq

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saniq.eZuasa~da~

aasuaai[

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suoI.ssnvsig

24

Licensee

representatives

discussed

changes

in dose

monitoring

and the-

results

achieved to date.

In October,

1989 the l.icensee

required

DRD dose

results

less

than

10

mrem to

be recorded

as zero.

Previously,

a value

less

than

10

mrem was automatically

assigned

a value of ten.

Licensee

representatives

stated

that

from October

1989 through

March

1991,

the

average

discrepancies

between

DRD results

and

TLD results for non-outage

and

outage

periods

were

23

and

15 percent,

respectively.

In addition,

improvements

to dose tracking computer system

and subsequent

assignment

of

dose for specific tasks

by

DRD measurements

were expected

to reduce

the

identified discrepancies

further.

The inspector

informed licensee

representatives

that this item would

be*

considered

closed

based

on

the identified

improvements

and

continued

.

actions within this program area.

Licensee Actions Regarding

Items

(92702)

(Closed) Violation 50-250, -251/91-08-04:

Failure to follow procedures

for labelling resin liners maintained in a waste storage

area east of the

old compactor

shed.

This issue

,involved the failure of workers to implement

procedures

for

labelling resin liners containing radioactive materials.

Licensee

review

of the issue

determined

the liners erroneously

were considered

structures

within the

RCA and

as thus did not require labelling.

The inspector

reviewed

and verified implementation of corrective actions

stated

in the

FPSL response

dated

May 20,

1991.

Surveys

and labelling of

the containers

were completed prior to the

end of that onsite inspection.

The inspector verified that

the applicable

procedures

were revised to

clarify

10 CFR 20.203(f)

requirements

and,

in addition,

to detail

labelling requirements

for on site

storage

containers.

Completion of

training for selected

RP staff regarding

the

procedural

changes

was

verified (Paragraph

3).

The inspector

noted that

a repeat violation was identified during the

current onsite

inspection

(Paragraph

10.d).

During

an July 16,

1991,

teleconference,

licensee

representatives

outlined additional

corrective

actions

regarding

the repeat labelling violation.

The inspector

informed

licensee

representatives

that based

on the additional corrective actions

proposed

and

the required

response

for the repeat violation, this item

would

be

considered

closed

and

subsequent

licensee

actions

would

be

tracked

under

item

number

50-250,

-251/91-26-03

detailed

in this

inspection report (Paragraph

10.d).

Exit Interview (65051,

83729,

86750,

92701,

92702)

The inspection

scope

and results

were

summarized

on July 12,

1991, with

those

persons

indicated in Paragraph

1 above.

The general

program areas

reviewed

and the apparent cited and

NCVs reviewed and/or identified during

this inspection

and listed below were discussed

in detail.

In particular,

25

the

inspector

noted

continued

concerns

regarding

the

ra'dioactive

= material/waste

storage

areas

as identified by a re'peat labelling violation

identified during the current inspection.

As

a result of the current

noncompliance

and

issues

identified during previous

NRC inspections,

the

inspector stated that increased

management

attention to activities within

this program area

was

needed.

The licensee

was informed that pending

NRC

management

review,

a previous IFI and violation detailed in Paragraphs

13

and

14, respectively,

would

be closed during this inspection.

Licensee

representatives

acknowledged

the inspector's

comments

and

no dissenting

comments

were received.

During July

16

and

17,

1991

teleconferences,

licensee

representatives

discussed

the

immediate

and

long term corrective actions

to

be taken in

response

to the

NRC issues identified during the inspection.

The specific

action related to each

are detailed in Paragraphs

4, 10.d,

and 12.b.

The

licensee

representatives

further stated

that

an effort would be initiated

to have Technicians

review all health physics

procedures

for clarity and

adequate

programmatic

guidance.

The inspector

informed licensee

representatives

that although proprietary

information was reviewed during this inspection,

such material

would not

be included in the report.

Item Number

Descri tion and Reference

50-250,

-251/91-26-01

NRC-identified violation (VIO):

Failure to

follow HP respiratory

protection

procedures

for

(1) issuing

and

using

a full face respiratory

protection

mask

(Paragraph

4.a),

and

(2)

verifying Grade

D breathing air quality for

a

compressor

supplying

the station

breathing

air

system

(Paragraph

4.b).

Nultiple examples

of a

violation of TS 6.11.1.

50-250,

-251/91-26-02

50-250,

-251/91-26-03

Licensee-identified

VIO:

Failure to follow HP

surveillance

procedures for documenting

completed

surveys

for materials

released

from the