ML18004B803
| ML18004B803 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/27/1987 |
| From: | Hosey C, Kuzo G, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18004B799 | List: |
| References | |
| 50-400-87-14, NUDOCS 8705040218 | |
| Download: ML18004B803 (12) | |
See also: IR 05000400/1987014
Text
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UNITED STATES
NUCLEAR REGVL'ATORY COMMISSION
REGION II
101 MARIETTASTREET, N.IN.
ATLANTA,GEORGIA 30323
Report No.:
50-400/87-14
Licensee:
Carolina
Power and Light Company
P. 0.
Box 1551
Raleigh,
NC
27602
Docket No.:
50-400
Facility Name:
Shearon Harris
License No.:
Inspection
Conducted:
March 30-April 3,
1987
(l
Inspector:
%ci.
P
R.
.
e
langton
.J t PA.~
4~~ ( ~xi
6.
B.
Kuzo
'/
Approved by: ~/~~
C..
Hosey,
Se
ion
C ie
Division of Radiation Safety
and Safeguards
ate
>gne
Date Signed
Date
sgne
SUMMARY
Scope:
This was
a special,
unannounced
inspection
in the areas
of allegation
followup and start-up shield test radiation surveys.
Results:
One
violation
was
identified:
inadequate
start-up
shield
verification radiation surveys.
870SD40218
870427
PDR 'DOCK 05000400
Q
,2
REPORT DETAILS
Persons
Contacted
Licensee
Employees
- R. A. Watson,
Vice President,
Harris Nuclear Project
- J. L. Willis, Plant General
Manager
- J. L. Harness,
Assistant
Plant General
Manager
- J.
R. Sipp, Manager,
Environmental
and Radiation Control
- J.
W. McDuffee, Radiation Control Supervisor
- A. Poland,
Project Specialist,
Radiation Control
- D. L. Tibbitts, Director, Regulatory
Compliance
- 0. N. Hudson,
Senior Engineer,
Regulatory
Compliance
- B. A. Meyer, Principal Health Physics Specialist
- J. L. Gerald,
Health Physics Specialist
- C. L. McKenzie, Principal equality Assurance
Engineer
- B. W. Stephenson,
Senior Specialist,
Radiation Control
- D. Bailey,
DIVERSCO Corporate
Vice President
- L. E. Boyette,
DIVERSCO Project Manager
R. Wright,
DIVERSCO Shift Supervisor
L. Williams, DIVERSCO Section
Leader
J.
For'tune,
DIYERSCO Section
Leader
J. Floyd, Radiation Control Supervisor
A. James,
DIVERSCO, Deconner
S. Hawkins,
DIVERSCO, Deconner
L. Collins,
DIVERSCO, Deconner
C. Allen, DIVERSCO, Deconner
B. Mathews,
DIVERSCO, Deconner
D. Cassidy,
DIVERSCO, Deconner
R. L. Batchelor,
Health Physics
Technician
W. Powell, Director, Training
Other
licensee
employees
contacted
included radiation control
foremen,
health physics technicians,
security
ad office personnel.
NRC Resident
Inspectors
- G. F. Maxwell, Senior Resident
Inspector
S. Burris, Rsident 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 following issues
were
discussed
in detail:
(I) an apparent violation for failure to document
health
physics qualification trai ning (Paragraph
4)
and (2)
an apparent
violation for failure to perform adequate
start-up shield verification
radiation
surveys
(Paragraph
5).
Licensee
representatives
acknowledged
the
inspection
findings
and
stated
that
they
took exception
to both
apparent
violations.
In regard
to the first apparent violation, they
.
stated that training documentation
would have
been in place before any of
the contractor
employees
would have
been allowed to act independently
and
that they were not required 'to train contractor
personnel
or to document
training
programs.
In
regard
to
the
shield
surveys,
licensee
representatives
stated that the surveys
had
been adequately
performed
and
in accordance
with their procedures
and
FSAR commitments.
The licensee
did not identify as proprietary
any of the materials
provided to or
reviewed
by the inspector during this inspection.
In a telephone
conversation
on April 16,
1987,
between
the inspector
and
the
Environmental
and
Radiological
Control
Manager,
the
licensee
was
informed that
the
issue
concerning
undocumented
training
would
be
considered
an
Unresolved
Item~,
pending
subsequent
NRC review of the
timeliness
and adequacy of the licensee's
corrective actions.
3.
Licensee Action on Previous
Enforcement Matters
This subject
was not addressed
in the inspection.
Allegation
(RII-87-A-0024).
following concerns:
(2870024001)
On approximately
February
6,
1987,
the alleger
and
two
co-workers
were
working
on
the
236
Elevation of the Auxiliary,
Building when
an air monitor alarmed.
The alleger
and
one of the
co-workers left the
area,
but were
ordered
to return
by their
supervisor.
The monitor continued
to alarm during the entire time
that the alleger
remained in the area
(from 8:00-9:30 p. m.).
(2870024002)
The alleger
and
a co-worker notified the Health Physics
Field Office by telephone
between
8: 15-8:30 p.
m. of the* alarming air
monitor
on the
236
Elevation of the Auxiliary Building, yet they
never responded.
(2870024003)
The alleger
and co-workers
had received
Levels I and II
of General
Employer Training (GET).
They were told that they would
receive
specialized
training before
being
assigned
decontamination
work, which was never given.
Some of the other workers
had already
worked in contaminated
areas
in radwaste.
~
~
4.
Allegations Followup (99014).
a ~
This allegation
consisted
of the
Unreso
ve
stems
are
matters
about
which more
information is required
to
determine whether they are acceptable
or may involve violations or deviations.
(2870024004)
On February
13,
1987,
the alleger
and three
co-workers
were working on the
216 Elevation of the Auxiliary Building when an
air monitor alarmed.
The alleger's
supervisor
required
the workers
to remain in the
area
from 2:30-5:00
p.
m.
.
The air monitor was
alarming during the entire time.
(2870024005)
The alleger's
supervisor failed to notify health physics
on the alarming air monitors
on the
216
and
236 Elevation of the
Auxiliary Building.
(2870024006)
On February
19,
1987,
the alleger
was directed
by the
alleger's
supervisor
to enter
an
area
on the
216 Elevation of the
Auxiliary Building to
remove
contaminated
protective clothing, wipe
off pipes,
massolin
mop the floor, and clean
and dust.
The alleger
objected
to the assignment
because
the alleger
had not been trained
in decontamination.
The alleger
was then terminated for refusing the
assignment.
b.
Discussion
The inspector discussed
the substance
of the allegation with, licensee
representatives
and
interviewed licensee
employees
who may have .had
first hand
knowledge of the alleged
events.
The inspector
also
reviewed
licensee
records
and procedures
related to the allegation..
As a result of the review, the following was determined:
(1)
There
were
three
types
of monitors
(air radioactivity,
radiation,
and
process)
in the Auxiliary Building which gave
local audible
and visual
alarms.
The Particulate,
and
Noble
Gas
(PING)
monitors
were
used
to
measure
airborne
radioactivity in work areas
and inside ventilation ducts.
The
- PING consoles
had only
a local alarm and strip chart recording
of the monitoring results.
The AMS-3 was
a work area airborne
radioactivity monitor which measured
only particulates
and gave
only local alarms.
The area radiation monitors
(ARMs) measured
general
area
radiation
levels
and
gave
audible
and visible
alarms locally at the console
and remotely to the control
room
and health
physics. field office.
The local
alarms
had to be
physically silenced
at
the
console (i.e.
they could not
be
silenced
from a remote location).
In many cases,
the area
being
monitored
was different from the location of the console, that
is the air sampler
or detector
would be, for example,.in
a
cubicle,
and
the console
would be outside
so that it would be
more readily accessible.
(2)
For several
days
around
the date of February 6,
1987,
process
radiation monitor REM-IMD-3530 on the 236 Elevation of the Waste
Processing
Building
had
been
periodically alarming
and
was
tagged
with
a deficiency
tag indicating that it was giving
spurious
alarms.
There
were
no records
of any other monitor
alarms during this time period in this location.
(3)
(4)
(5)
(6)
(7)
(8)
(9)
There
was
a record of a
PING alarm at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />
on February
13,
1987
on the
216 Elevation of the Auxiliary Building.
Licensee
health
physics
personnel
determined
that
the
alarm
had
been
caused
by
noble
gas
and
the
conditio'n
had
persisted
for
approximately
one
and
a half hours.
There were
no records of
any other alarms
on this date in this location.
The contractor personnel
had always signed into the work area
on
one of three radiation work permits
(RWPs),
as follows:
RWP 86-0110,
Revision
1, October 31,
1986,
Reactor
Containment
Building and
Fuel
Handling Building, All Work Activities Prior
to Initial Criticality Except
Fuel
Load
RWP H87-0012,
Revision
1,
December
29,
1986,
General
Entries
Into the
RCA, Clean Areas Only
H87-0005,
Revision
1,
January
1,
1987,
General
Decon of
Areas/Items
25,000
DPM/100
cm'he
alleger
had
made
175
RWP entries
during
the
period
November 10,
1986, to February
19,
1987.
The entries
in 1986
had
been
under
RWP 86-0110
and under
RWP H87-0012 in 1987.
The
alleger
had never worked under
RWP H87-0005, which was the only
one of the three
which involved work if> Lontaminated
areas
and
required that protective clothing be worn.
The alleger did not
make
any
RWP entries
on February 6,
1987,
but did make entries
on February 4,
1987 during the time period
that the monitor was allegedly alarming (i.e., 8-9:30 pm).
The
alleger's
next
RWP entries
were
on February 7,
1987,
but were
not made during the time period in question.,
The alleger
made three
RWP entries
on February
13, 1987, during
the period 4:26-10:44
pm.
The monitor was allegedly alarming
during the period 2:30-5:00
pm.
The alleger
was assigned
a total of 27 millirem for all of the
RWP entries
made in 1986
and
1987.
The alleger
had whole body
count measurements
performed
on November 7, 1986, January
13 and
February
19,
1987.
None of the counts
showed
any detectable
radioactivity, except for naturally occurring potassium-40.
The alleger
had successfully
completed
General
Employee Training
(GET)
Levels
I
and II.
GET Level I training
was
general
familiarization training
which
enabled
a
person
to receive
dosimetry
and enter
the plant protected
area.
GET Level II
covered
use of protective clothing,
RWP procedures
and response
to warning devices.
GET Level II training qualified the person
to work under
a
RWP, including work in a contaminated
area.
(10) The contractor
employees
had worked inside the plant controlled
area
performing general
housekeeping
duties
such
as mopping
and
emptying trash
cans.
The licensee
had
determined
that they
wanted the'ontractors
to begin
working
as
decontamination
personnel
("deconners")
cleaning
up
areas
as
they
became
contaminated.
The contractors
were also to be used to "frisk
trash," that is to perform surveys of materials
from the plant
controlled
area
so that it could
be released
for unrestricted
use.
A health physics technician
was assigned
to each shift and
was
required
to
provide
continuous
coverage
while
the
contractors
were
performing decontamination
or were frisking
trash.
Contractor
personnel
were
being
rotated
into the
contaminated
area
duties.
This work under the supervision of a
health
physics
technician
had
been
described
to the contractor
management
and
employees
as
on the job training
by licensee
representatives.
There
was
no
formal training
program or
documentation for this qualification training.
The licensee
had
prepared
a three
hour class
on decontamination
techniques
and
had
scheduled it to be presented
in mid February
1987, but it
was
reportedly
cancelled
because
of
a
snow storm.
Licensee
representatives
stated
that
they
intended
to
provide
qualification cards for the contractors
in the future.
Technical Specification 6.4. 1 requires
that
a retraining
and
replacement
training
program for the unit staff shhll
be
maintained.
Carolina
Power
and
Light Nuclear Training Section
Training
Manual, July 16,
1986,
which specified
the licensee's
training
policy,
required
that
training
programs
be
conducted
in
accordance
with written
procedures,
that
there
be
course
outlines, job task analyses
and examinations.
c.
Findings
(Concern
2870024001)
This concern
was substantiated.
There
was
an alarm
on the
date
and time and in the
area
alleged.
The
supervisor
did tell the workers to return to the area
based
on
information
he
had
received
from the assigned
health
physics
technician
regarding
the deficiency tag that was
on the monitor.
It could not
be
independently
established if the supervisor
explained to the workers the reason that they could go back to
the
work area.
The
coworkers
in the area
were told of the
deficiency tag
on the monitor when health
physics
was called.
The alleger
was
reportedly
shown
the deficiency
tag
by
a
coworker.
The inspector
determined
therefore that the alleger
had sufficient information provided to understand
there
was
no
radiological
hazard
in the area.
No violations or deviations
were identified.
(2)
(3)
(4)
(Concern
2870024002)
This concern
was not substantiated.
The
licensee
did not maintain
any documentation
of when personnel
responded
to
and
silenced
alarms.
The status
of
ARMs was
monitored
by
a health
physics technician in their field office..
In
many
cases,
the
technician
could
determine
from the
computerized
monitoring terminal if the
alarm
was
due to
a
malfunction.
The
known spurious
alarm was not given
as
high a
priority to sending
a health physics technician to investigate
and silence.
However, it could not be established
when, or if,
the alarm was investigated
by health physics or for how long the
alarm
continued.
The
inspector
discussed
with licensee
representatives
the importance of promptly responding
to alarms,
even if they
are
thought
to
be
spurious.
Licensee
representatives
stated that their health physics
personnel
would
be
so instructed.
No violations or deviations
were identified.
(Concern
2870024003)
This concern
was partially substantiated.
The contractors
had
received
GET Levels
I and II training and
there
was
an
intention that
they
would receive
additional
training specific to decontamination.
However, it could not be
e-tablished if they were told they would receive this training
prior to being
assigned
decontamination
work,
The inspector
determined
that the informal
on the job training that was given
was apparently
not consistent with Technical Specification 6.4. 1
and the licensee's
policy as stated
in their corporate training
procedure.
Performance
of free release
surveys
was normally
a
task
required
to
be performed
by
a health
physics
technician
acting
in
a responsible
position.
However,
the licensee
was
committed
to
the
1979 draft of
which permitted
individuals,
not fully qualified, to perform, specific tasks if
they
had
been
trained
and qualified
on those specific tasks.
The
licensee
was
in
the
process
of
conducting
limited
qualification training, yet
had
no procedure,
lesson
plans,
qualification cards,
or other documentation
or specification for
this training.
Failure to adequately
conduct health
physics
qualification training
program
was identified
as
an apparent
violation of Technical Specification 6.4.1.
However, consistent
with
the
Commission
Policy
Statement
on
Training
and
Qualification
and
the
memorandum
of understanding
with INPO,
this matter will be
designated
an
unresolved
item pending
subsequent
NRC review of the acceptability of the licensee's
corrective actions for this matter (50-400/87-14-01).
(Concern
2870024004)
This concern
was partially substantiated.
There
was
a
PING alarm,
but there were discrepancies
that could-
not
be
resolved
regarding
the
time of the
alarm
and
the
'orresponding
times that the alleger
had
been
present
in the
area
as evidenced
by the
RWP time sheets.
As with the previous
concern,
the
time the, alarm
was
silenced
could
not
be
established.
No violations or deviations
were identified.
O
(5)
(Concern
2870024005)
This concern
was not substantiated.
It
was
independently
confirmed that the supervisor
had discussed
the alarm
on the
236 Elevation with health
physics
and
had not
been
present
when the alarm occurred
on the
216 Elevation.
No
violations or deviations
were identified.
(6)
(Concern
2870024006)
This concern
was partially substantiated.
The alleger
was given
an assignment
to work in a contaminated
area,
which was refused.
It could not be confirmed that lack of
training
had
been
raised
as
an issue
by the alleger.
Persons
who
observed
portions
of the
events
of February
19,
1987,
recalled
the alleger
complaining that the protective clothing
was not the proper size
and that the alleger
preferred to have
a
job outside
a
contaminated
area.
By all
accounts
by the
alleger's 'coworkers,
no request for additional
information or
instruction in health physics matters
had ever
been
refused
by
contractor or licensee
management.
No violations or deviations
were identified.
d.
Conclusions
10 CFR 19. 12 require's that individuals working in or frequenting
any
portion of a restricted
area
shall
be instn.'cted
in certain topics,
which include precautions
or procedures
to minimize exposure,
the
purposes
and
functions
of protective
devices
employed
and
the
appropriate
respon
'e to warnings
made in the event of any unusual
occurrence
or malfunction that
may involve exposure
to radiation or
radioactive material.
The inspector
determined that the alleger
had been adequately
trained
pursuant
to
10 CFR 19. 12 by virtue of having successfully
completed
GET Levels
I and II.
The decontamination qualification training did
not meet the Technical
Specification
requirements
for such training,
however, participation in the training would not have compromised
the
immediate
safety of the workers involved since
continuous
coverage
was always provided by health physics
personnel.
5.
Radiation Protection - Startup
(83521)
10 CFR 20.201(b). requires
surveys
to be
made
as
necessary
to comply with
10 CFR Part 20 and are reasonable
under the circumstances
to evaluate
the
extent
of radiation
hazards
that
may
be
present.
Section 12.3.2,
Shielding of the
Shearon
Harris Nuclear
Power Plant
(SHNPP)
Final Safety
Analysis Report
(FSAR) details
the primary design objectives of the plant
radiation shielding for containment
and auxiliary radiation
sources
at
SHNPP.
FSAR Section
12.3.2.1.state
that shielding
design
conforms with
Regulatory
Guide 8.8
(Rev. 3),
100,
and
50, Appendix
A
Criterion 19.
FSAR Section 12.3.2.2 details radiation access
zones
based
on
maximum dose
rate levels.
Section 1;8, of the
SHNPP
FSAR commits to
Regulatory
Guide
1.68, Initial Test
Programs
for Water-cooled
Nuclear
Power
Plants,
Rev.
2,
August
1978.
FSAR Section 14.2. 12.2.28 details
shield
survey
methodology
to
be
performed
at
50
and
100'%ower
(Section 5.b.b Regulatory
Guide 1.68).
The inspector
reviewed
and
discussed
with licensee
representatives
the
following shield survey procedures
utilized in the
SHNPP
power ascension
program:
AP-504,
Administrative
Controls for Locked
and
Restricted
High
Radiation Areas,
Rev.
1, 8/19/86
HPP-060,
Performance
of Radiation
and Contamination
Control Surveys,
Rev.
1, 6/9/86
SUM-1-1900-S-01,
Power
Ascension
Test
Program -
Power Escalation,
Rev. 2, 8/26/86
SUM-1-9103-S-33,
Shield Test Survey at Zero
(
5%) Power Test Plateau,
Rev. 0, 8/12/86
SUM-1-9105-S-12,
Shield
Test
Survey at
50%
Power
Test
Plateau,
Rev.
1, 2/11/87
SU-1-22,
Power Ascension Test Program,
Rev.
29
The
inspector
reviewed
and
discussed
Procedure
SUM-1-9105-S-12
with
licensee
representatives.
Licensee
representatives
stated
that
Program for Testing Radiation Shields
in Light Water
Reactors
(LWR), was utilized as
guidance for preparation
of the shield
survey
procedure.
In contrast
to
ANSI/ANS 6.3. 1, Sections
5.4.3. 1
and
5.4.4.2,
respectively,
the licensee
procedure
did not require
surveys of
auxiliary shielding required during power operations
nor extrapolation of
survey results
to rated full power.
The inspector
informed licensee
representatives
that
Section 12.3.2
details
auxiliary shielding
design criteria
and also describes
the radiation
access
zones
based
on
maximum
dose
rate
levels.
Licensee
representatives
stated
that
the
original
procedure
required
extrapolation
of the shield survey, results
conducted at
50% power to rated full power,
however,
the requirement
was
deleted
during subsequent
procedure
review.
The failure to extrapolate
exposure
rates at
50% power to rated full power and the failure to conduct
shield surveys of auxiliary shielding associated
with sources
external
to
containment
was identified as
an apparent
violation of 10 CFR 20.201(b)
(50-400/87-14-02).
Techniques
utilized in performing the shield
survey were discussed
with
selected
personnel
who had conducted
the
50% power plateau shield survey.
Sections
6.6 and 6.11 of SUM-1-9103-33 require that during shield surveys
the radiation
survey
instrument
is held
about
1 meter
from the wall
Radiation
Base Points
(RBP) and that the radiation levels are continuously
monitored
while proceeding
from one
RBP location to the next.
From
independent
discussion
with selected
individuals the inspector determined
that contrary to the
approved
procedure,
several
technicians
conducted
10
contact
radiation
survey
measurements
and
also failed to continuously
monitor radiation
exposure
rates
between
RBPs.
The failure to follow
approved
procedures
was identified as
an additional
example of failure to
adequatl ey
perform
surveys
as
required
by
(50-400/87-14-02).
FSAR Section
12.3.2.2 details
the radiation
access
zones
based
on the
maximum zone
dose rate levels.
At 50% power approximately
12
RBP survey
locations at inside containment,
mainly on the
286
elevation,
exceeded
the
100K
power
zone
access
limits identified in
FSAR Figure 12.3.2-3.
Licensee
and
vendor evaluation
determined
that calculated
exposure
rates
for this
FSAR Figure failed to include the neutron
dose rate contribution.
Licensee
representatives
stated that the radiation
zone areas
described
in
the
FSAR would be modified accordingly.
During the inspection
independent
verification of
gamma
and
and neutron
shield
survey
exposure
measurements
were
conducted.
Measurements
were
made
on selected
plant elevations
at the outside
containment wall
RBPs
and
areas
and at auxiliary shielding associated
with radiation
sources
outside of containment.
All survey results
were within
limits.
IE Inspection
Report
No. 50-400/86-43
identified potential
personnel
radiation
exposure
hazards
associated
with movement
and storage
of the
incore detectors
in the seal
table
room.
Details regarding
the expected
exposure
rates
and associated
shielding
requirements
were reviewed during
the
inspection
(Letter
from A.
C.
Anderson,
Project
Manager,
EBASO
Services,
to L. I. Loflin, Manager,
Engineering
SHNPP, dated
September
4,
1986).
Dose rates
at the door to the seal
table
room from an activated
detector
and cable
was estimated
to be approximately 2.4 R/hr.
A survey
conducted
February 3,
1987, with the reactor at
30K power
and
3 incore
detectors
located
above
the five pathway
mechanism
indicated
exposure
rates
of 250 mR/hr at
the
entrance
to the
seal
table
room.
Vendor
recommendations
for minimizing radiation
exposure
included administrative
controls and/or the addition of a shield door or concrete wall.
Presently
the matter is addressed
by procedural
controls
and
no shield modifications
are
planned
in the
near
future.
Procedure
Incore
Movable
Detectors,
dated
August 13,
1986,
requires
that the Radiation
Controls
Foreman or his designee
must verify that all personnel
are outside of the
secondary
shield wall
and other
areas
designated
by the
RC technician
prior to movement of incore detectors.
Licensee
representatives
stated
that utilization of administrative
controls
and the potential
need for
additional
shielding
associated
with the
seal
table
room to prevent
potential
exposure
problems
was being evaluated.
The inspector
informed
licensee
representatives
that review of radiation controls associated
with
the
seal
table
room would
be
considered
an
inspector
followup item
(50-400/87-14-03).