ML18004B876
| ML18004B876 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/06/1987 |
| From: | Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18004B875 | List: |
| References | |
| 50-400-87-22, IEIN-86-103, IEIN-86-107, IEIN-87-003, IEIN-87-007, IEIN-87-3, IEIN-87-7, NUDOCS 8707150210 | |
| Download: ML18004B876 (16) | |
See also: IR 05000400/1987022
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
ATLANTA,GEORGIA 30323
Di7; 08 1gP
Report No.:
50-400/87-22
Licensee:
Carolina
Power and Light Company
P.
0.
Box 1551
Raleigh,
NC
27602
Docket No.:
50-400
License No.:
Facility Name:
Shearon Harris
Inspection
Conducted:
Jun
15-19~198
Inspects,r:
e
>ng on
Acc
panying Personnel
R
B. Shortridge
Approved by:
osey,
ec ion
ie
Division of Radiation Safety
and Safeguards
7
a
e
tgne
a
>ne
SUMMARY
Scope:
This was
a routine,
unannounced
inspection in the areas
of organization
and
management
controls,
training
and
qualifications,
external
exposure
control, internal
exposure control, control of radioactive material, facilities
and equ>pment,
licensee's
program for maintaining occupational
exposures
as
low
as -reasonably
achievable
(ALARA), solid wastes,
transportation,
followup on
bulletins,
followup on inspection
followup items
and followup on Information
Notices.
Results:
One violation was identified:
inadequate
evaluation of individual
exposures
to noble gas.
87071502l0
870708
ADOCK 05000400
8
REPORT DETAILS
Persons
Contacted
Licensee
Employees
~J.
L. Harness,
Assistant Plant General
Manager
- J.
R. Sipp,
Manager,
Environmental
and Radiation Control
~D.
L. Tibbitts, Director, Regulatory Compliance
"0.
N. Hudson,
Senior Engineer,
Regulatory Compliance
"H.
W.. Bowles, Director, Onsite
Nuclear Safety
"J. Bradley,
Radwaste
Supervisor
- T. Morton, Acting Manager,
Maintenance
~W.
R. Wilson, Technical
Support Supervisor
"E. Willett, Plant Modifications M'anager
"C.
L. McKenzie, Principal equality Assurance
Engineer
"G.
L. Forehand,
Director equality Assurance
Engineer
- A. D. Poland,
Proj'ect Specialist Radiation Control
~T.
E. Woenker,
Radiation Control
Foreman
~J.
L. Floyd, Radiation Control
Foreman
J.
W. McDuffee, Radiation Control Supervisor
J. O'Halloran, Radiation Control
Foreman
B. Webster,
Corporate
Health Physicist
S. Croslin, Corporate
Health Physics Staff
D.
L. Beidelman,
Senior Specialist,
Other licensee
employees
contacted
included radiation control staff
and
technicians,
security
and office personnel.
NRC Resident
Inspectors
~G.
F. Maxwell, Senior
Resident
Inspector
S. Burris, Resident Inspector
~Attended exit interview
Exit Interview
The inspection
scope
and findings were summarized
on June
19, 1987, with
those
persons
indicated
in Paragraph
1 above.
The. apparent violation
concerning
inadequate
evaluation of individual exposures
to noble gas
was
discussed
in detail
(Paragraph
5).
Licensee
representatives
acknowledged
the
inspection
findings
and took
no exceptions.
The licensee
did not
identify as proprietary
any of the materials
provided to or reviewed by
the inspector during this inspection.
0
Organization
and Management
Controls
(83722)
Through
discussions
with
licensee
representatives,
the
inspector
determined
that the licensee
had not made organization
changes
which had
any
adverse
effect
on the licensee's
ability to control radiation
and
radioactive material.
The
inspector
discussed
with licensee
representatives
their system for
documenting
identified
problems
and
corrective
actions.
Licensee
Admini strative
Procedure
(AP)-513, Radiation Safety Violation, Revision 2,
October
1,
1986,
described
the
licensee's
program.
Radiation Safety
Violations
(RSVs)
were written by Radiation Control based
on either their
own observations
or reports
from other
work groups.
The
RSVs
were
classified
as
being
one of three possible severity levels
and then routed
to the
responsible
organization
for
a written response.
The written
response
was
sent
to either
the
Environmental
and
Radiation
Control
Manager,
the Plant
General
Manager or the Site Vice President'or
review
and approval
of corrective
actions
depending
on the severity level.
The
inspector
determined that six RSVs had been written in 1987 and that five
had
been written in 1986.
The inspector
reviewed the
RSVs that had been
written in the past
two years.
The inspector
noted that only one
RSV had
been written concerninq
inadequate
personnel
contamination
surveys
and
that none concerned radiation work permit or procedure violation,
Licensee
representatives
also stated that they
had recently prohibited
personnel
from carrying all
products
that could
be
smoked,
eaten,
or
chewed into the control area
since they had found evidence of smoking and
other prohibited activities inside the controlled
area.
Some
personnel
had
reportedly
been
caught
in the
act.
None of the
RSVs
on file
documented this problem.
The inspector stated to licensee
representatives
that it appeared
that identified problems
were not being documented
and
as
a result appropriate
management
review of trends
and corrective actions
could not be performed.
The licensee
acknowledged
the comment
and stated
that
the
emphasis
in the radiation
control
group
had
been
educating
workers
and that writing RSVs .initially might have
been counterproductive.
The inspector
stated
documentation of problems
and corrective actions
can
be
performed
in
a constructive,
nonpunitive
manner.
The
licensee
acknowledged
the
comment
and stated that actions
would be taken to ensure
that problems
are documented
via the
RSV.
No violations or deviations
were identified.
Training and Qualifications
(83723)
The inspector
discussed
the
licensee's
organization
and staffing with
licensee
representatives
and
selectively
reviewed
the training
and
qualifications
of various
members
of the radiation control staff.
The
inspector interviewed selected unit staff members
and observed
performance
of selected
radiation control functions.
The inspector
determined that
acceptable
training had been performed.
No violations or deviations
were identified.
External
Exposure Control
(83724)
The inspector discussed
with licensee
representatives
the organization
and
staffi ng of the dosimetry section.
The section
was
headed
by a radiation
control
foreman
and
had
assigned
four licensee
and
three
contract
technicians
and five contract technician aides.
The dosimetry office was
continuously
manned,
with at least
one technician
and one technician
aide
on each shift.
The inspector
reviewed records of occupational
radiation exposure
received
by licensee
employees
and determined that individual quarterly exposures
were
being
maintained
well
below the limits of 10 CFR 20. 101.a.
The
inspector
reviewed selected
records of dose
assignments
and investigations
performed during
1987
as
a result of lost or damaged
dosimetry or other
nonrouti ne
ci rcumstances
and
determined
that
the
licensee's
followup
actions
had
been
appropriate.
The inspector
noted that there
had
been
35 thermoluminescent
dosimeters
(TLDs) reported lost during 1987.
The
licensee
acknowledged that this was
an excessive
number
and that they were
evaluating
means of reducing the
number of lost TLDs.
The inspector
reviewed the following external
exposure control procedures:
DP-001,
Dosimetry Issue,
Rev. 4, January 7,
1987
DP-003,
Personnel
Exposure Investigation,
Rev. 4, January
6,
1987
. DP-004,
Updating Dose Records,
Rev.
5, January
6,
1987
DP-012,
Dose Limit Extension Authorization,
Rev. 4, April 6,
1987
DP-105, Operation of Automatic UD-710A/Manual
UD-702E TLD Reader,
Rev.
5,
May 1,
1987
DP-100,
Skin Dose Determination
from Contamination,
Rev.
1,
March 27,
1987
The
inspector
discussed
with licensee
representatives
their system of
administrative
exposure
limits.
The licensee
had
a system of incremental
exposure
limits which. required
an increasing
higher level of management
approval.
The, licensee
had not yet processed
any requests
for exposure
extensions.
The licensee
processes
TLDs onsite.
The inspector discussed
the operation
and calibration of the
TLD reader
with licensee
representatives
and
reviewed
records
of daily quality control
checks
and calibrations
performed during 1987.
The daily quality control check included reading
three
TLDs (background
and two spiked to 500 mi llirem and 4000 millirem).
Calibrations
were performed semi-annually
by personnel
from the licensee's
Harris Energy
and Environmental
Center
(HEEC).
On the morning of June
17,
1987, there
was
a reactor
and
an operator
accompanied
by
a
health
physics
technician
was
assigned
to enter
containment
to inspect
the
'C" circulating water
pump.
Prior to the
entry,
the
licensee
not'ed that
the
Radiation Monitoring System
(RMS)
instrumentation
showed that
no particulate
airborne
radioactivity was
detectable,
but that
noble
gas activity was approximately at
maximum
permissible
concentration
(MPC)
levels
as
defined
in
Appendix B,
Table 1,
Column 1.
The
licensee
also
obtained
a grab air
sample
from
an
RMS connection
which
samples
the air just inside the
airlock.
That
sample
indicated that particulate
and
iodine airborne
radioactivity were not detectable
and that noble gas
was present,
but the
concentration
was
a factor of 25 lower than that indicated
by the
instrumentation.
The entry
lasted
approximately
30 minutes,
eighteen
minutes
of which
was
inside
the bioshield
in the vicinity of the
circulating water pump.
The inspector
questioned
the licensee
on
how the exposure
from noble gas,
especially
skin
exposure,
was
assessed
and
was
informed that the
measured
noble
gas
exposure.
After reviewing the documentation that was
available
on the
licensee's
TLD dose
algorithms onsite,
the inspector
visited the dosimetry section at the
HEEC for a more detailed explanation
on the TLDs ability to measure
noble
gas
exposure.
The
TLD dose algorithm
used
a
beta
correction
factor
based
on either
Thallium-204
or
Strontium-90, Yttrium-90 depending
on the characteristics
of the radiation
to which the
TLD was exposed.
Therefore the lowest energy beta radiation
for
which
corrections
were
made
was
for that
of Thallium-204
(approximately 0.7 MeV).
Exposures
due to radiations
with energy levels
beIow those of Thallium would therefore
be underestimated.
The licensee
had performed
a test with Technetium-99
(which has
a maximum beta energy
comparable
to Xenon-133).
The study indicated that the
dose
algorithm
underestimated
the skin
dose
from Technetium-99
by a factor of 2.6.
The
inspector
stated
that it appeared
that the licensee
had not adequately
.
assessed
the potential
exposure
during containment entries to the lens of
the
eye
and
the
skin of the
whole
body
from noble
gas.
Licensee
representatives
acknowledged
that the personnel
at the Harris site
had
a
misconception
concerning
the capabilities
of the TLD, but stated that if
noble
gas
concentrations
had
been
higher they would have recognized that
additional
assessments
were necessary.
10 CFR 20.201(b) requires'hat
each licensee
make or cause to be
made
such
surveys
as
may
be
necessary
for the
licensee
to
comply with the
regulations
and are reasonable
under the circumstances
to evaluate
the extent of radiation hazards that
may be present.
10 CFR 20. 101(a)
specifies
the
quarterly
occupational
radiation
dose
limits to the lens of the eyes
and the skin of the whole body.
Failure of the licensee
to have
a program in place to evaluate potential
hazards
from noble
gas
exposure
during containment entries
was identified
as
an apparent violation of 10 CFR 20.201(b)
(50-400/87-22-01).
Internal
Exposure Control (83725)
The inspector
reviewed the following internal
exposure control procedures:
HPP-300,
quantitative
and qualitative
Fit Testing,
Revision
3,
May ll, 1987
HPP-302,
Selection
and
Issue of Respiratory
Equipment,
Revision 1,
May 1,
1987
The
licensee
performed
quantitative
respirator fit test inside
a test
booth using corn oil.
The inspector
discussed
the operation of the fit
booth
with licensee
personnel.
Records
of selected fit tests
were
reviewed.
The licensee's
records
indicated that respirator fit testing
was,
being
adequately
performed
and that individuals
were
achieving
measured
mask filtration efficiencies
in
excess
of the
published
protection factors.
The
inspector
reviewed
results
of physical
examinations
performed to
determine
.that individuals were medically qualified to wear respiratory
protective
devices.
Medical evaluations
were performed at least
every
12 months.
The inspector
discussed
with licensee
representatives
their procedures
for
ensuring air quality to airline respirators
and self-contained
breathing
apparatuses.
A dedicated
compressor
which was- tested
for Grade
D air
quality every
3 months
was
used to fill air bottles.
Plant instrument air.
was
used for airline supplied respirators.
Air quality was checked
every
3 months
and the first time a connection
was
made to a given outlet.
The
inspector
observed
the operation of the licensee's
equipment
issue
room
from which respiratory
protection
equipment
was
issued.
Each
qualified
person
carried
a card indicating his fit test,
training
and
medi,cal qualification expiration dates.
A log sheet
was
used to document
the issuance
of respirators.
The inspector
discussed
the
operation
of the whole body counter with
licensee
personnel.
The
inspector
also
discussed
whole body counting
frequency
and
the
performance
of daily and other periodic performance
checks.
The inspector
reviewed
records
of whole body counts
performed
during. 1987.
There
had been
no confirmed internal
exposures.
No violations or deviations
were identified.
Control of Radioactive Material
(83726)
The inspector
reviewed selected
records of special
and routine radiation
and contamination
surveys.
During tours of the facility
the inspector
noted the posting
and control for radiation
and high radiation areas.
The
inspector
performed
independent
radiation
surveys
and
noted
no
inconsistencies
with licensee
postings
and survey results.
No violations or deviations
were identified.
Facilities
and Equipment
(83727)
By observation
and discussion with licensee
representatives
the inspector
determined that there
had been
no chanqes
to the licensee's facilities and
equipment for radiation protection activities which adversely affected the
radiation protection program.
No violations or deviations
were identified.
Licensee's
Program
for
Maintaining
Exposures
as
Low
as
Reasonable
Achievable
(ALARA) (83728)
The inspector
reviewed the following ALARA procedures:
PLP-501,
ALARA Program,
Rev.
2, September
16,
1986
AP-502,
ALARA Subcommittee,
Rev. 1, October 7,
1986
AP-509,
ALARA Improvement
Program,
Rev.
2, September
26,
1986
AP-510, Radiation
Dose Budgeting,
Rev.
0, August 21,
1985
AP-514,
ALARA Job Evaluations,
Rev.
1,
December
12,
1986
AP-520,
RC/ALARA Review of Plant Procedures,
Rev.
1, March 31,
1987
The inspector
discussed
with licensee
representatives
their criteria for
performing
preplan
and
post
job
ALARA reviews.
ALARA preplans
were
required for jobs with exposure
estimates
of greater
than
one man-Rem,
or
if the exposure field'was greater
than
10
Rem per hour or as designated
by
radiation
control
management
for special
work such
as
steam
generator
entries.
Post job reviews were-required for all work which expended
more
than
10
man-Rem
or which exceeded
the
exposure
estimate
by more
th'an
2 man-Rem
for
those
jobs with exposure
estimates
between
one
and ten
man-Rem.
The
ALARA subcommittee
also
reviewed jobs whose total exposure
exceeded
25
man-Rem.
The inspector
noted that
a criteria for performing
ALARA post job reviews
as
a percentage
in excess
of the estimate
might be
more meaningful
than the
2
man-Rem criteria
used
by the licensee.
The
licensee
had not yet performed
any post job reviews
and only three jobs
had met the preplan criteria.
The licensee
had
an
ALARA suggestion
program.
The licensee
had received
15 suggestions
in 1986
and
3
sn
1987.
The inspector
reviewed selected
suggestions
and
noted that
the
licensee
had
been
responsive
and
had
documented their action in response
to the suggestion.
A person wishing
to
make
a suggestion
had to reproduce
a copy of the suggestion
form from
the
administrative
procedure
and
his
suggestion
to the
specialist.
The
inspector
stated
that
. having
blank copies
of the
suggestion
form and
a drop
box in a conspicuous
location might promote
participation in the
ALARA program.
The licensee
acknowledged
the
comment
and stated
they would pursue putting up a suggestion
box.
Licensee
representatives
stated
that they
had
an
ALARA awareness
program
which included posters
and
ALARA talks during monthly safety meetings.
However,
the
licensee
did not
have
a
suggestion
incentive or awards
program.
As of April 1987,
the total
exposure
at the facility was 11. 178 man-Rem
compared
to the
annual
goal of 100
man-Rem.
The radioactive waste
goal
was
6500 cubic feet and,
as of the inspection,
none
had been
shipped.
The
goal
on area of the plant controlled
as contaminated
was less than 25,000
of the 461,783
square
feet
(5.4%) in the facility excluding containment.
As of June
8,
1987, -only 1517
square
feet of the facility was
being
controlled
as
contaminated,
which
had
decreased
from 3021 square feet
on
Hay 4, 1987.
No violations or deviations
were identified.
10.
Solid Mastes
(84722)
At the time of the inspection,
the licensee
had not yet identified or
sampled
any plant waste
steams
for 10 CFR Part 61 classification purposes.
The licensee
used contractor provided generic scaling factors to determine
concentrations
of nuclides
in wastes
that could not
be measured
onsite.
Licensee
representatives
stated that they expected
to complete their first
group of waste
stream
samples
within the next three
months
and would
sample quarterly thereafter
to build up a waste
stream data
base.
The
licensee
used
an onsite
vendor
service
to solidify waste
and to
dewater
resins.
The inspector
reviewed the licensee's
preparations
for
their first radioactive
waste
shipments.
Haste
liners
of evaporator
bottoms
were being solidified and resin dewatering
was also in progress.
The inspector
reviewed
the licensee's
process
control
program which had
been
submitted
to the
NRC
on
September
4,
1985.
The inspector
also
reviewed the following contractor
procedures:
Chem-Nuclear
Systems,
Inc. =Process
Control
Program for CNSI
Cement
Solidification Units,
Rev.
T, June
17,
1986
CNSI Bead Resin/Activated
Carbon Dewatering Procedure for CNSI 14-195
or Smaller Liners,
Rev.
F, January
13,
1987
Licensee
representatives
stated that they had performed
a technical
review
of the vendor procedures,
but the procedures
had not been submitted to the
Plant Nuclear Safety
Committee for review.
However they did incorporate
into their
approved
procedures
a checklist
which followed the vendor
process
and
provided
various quality control
checks
by the licensee's
radwate
personnel
during
and after the completion of the process.
The
inspector
determined
this arrangement
provided
an acceptable
degree
of
control over the vendor process.
No violations or deviations
were identified.
11.
Transportation
(86821)
The
inspector
reviewed
the
following transportation
of radioactive
material
procedures:
HPP-103,
Curie
Determination
in
Radioactive
Material
Packages,
Rev.
3,
May 1,
1987
HPP-ill, Segregation
and
Packaging
of Dry Active Waste,
Rev.
0,
May 23,
1985
HPP-113,
Receipt of Radioactive Material,
Rev.
2, January
27,
1987
HPP-115,
Classification
of Radioactive
Material
for
Shipments,
Rev.
3,
May 1,
1987
HPP-116,
Classification
of Radioactive
Waste
for Burial,
Rev.
1,
October 3,
1985
HPP-120,
Shipment of Empty Radioactive
Material
Packaging,
Rev.
2,
October 21,
1986
HPP-123,
Shipment of LSA-Type
A Radioactive
Waste to the Barnwell
Disposal Site,
Rev.
2, October 21,
1986
HPP-124,
Shipment of LSA-Type
B Radioactive Material to the Barnwell
Disposal Site,
Rev.
1, October 21,
1986
HPP-125,
Shipment
of Type
A Radioactive
Material to the Barnwell
Disposal Site,
Rev.
1, October 21,
1986
HPP-126,
Shipment
of Type
B Radioactive
Material to the Barnwell
Disposal Site,
Rev.
1, October
21,
1986
HPP-127,
Shipment of Highway Route Controlled quantity Radioactive
Material to the Barnwell Disposal Site,
Rev.
1, October 21,
1986
HPP-133,
Shipment
of
LSA-Type
A Dry Active Waste
to Scientific
Ecology Group, Inc.,
Rev.
0,
December
9,
1986
The inspector
determined that the licensee
did not
use
any radioactive
material
packages
for which
an
NRC Certificate of Compliance
had
been
issued.
The
licensee
also
did not perform
any
waste
compaction
or
laundering of contaminated protective clothing onsite.
Shipments
had been
made
to
an offsite
contaminated
laundry
and
provisions
had
been
established
to send compactable
waste to a licensed waste broker who would
reduce the volume,
repackage
the waste
and then deliver it to the disposal
site.
0
No violations or deviations
were identified.
12.
Followup on Bulletins (92703)
(Closed)
78-BU-07,
Protection
Afforded
by Air-Line Respirators
and
Supplied-Air
Hoods.
The licensee
had not made
a written response
to this
bulletin
and
had not been
required to
do
so
as part of the licensinq
process.
The inspector
determined that the licensee's
use of protection
factors
for respirator
protective
devices
was
consistent
with the
information contained within the bulletin.
13.
Followup on Inspector, Identified Items
(92701)
(Closed) IFI (50-400/86-43-09)
Finish Installing=High Radiation Area Doors
in the
Radwaste Building.'icensee
representatives
stated that lockable
doors
had
been installed in areas
anticipated
to become
high radiation
areas.
During tours
of the
radwaste
building, the inspector
observed
lockable doors
and gates at the entrances
to cubicles
and other areas.
14.
Followup on IE Information Notices
(92717)
The inspector
determined that the following NRC IE Information Notices
(IEN)
had
been
received
by the
licensee,
reviewed for applicability,
distributed to appropriate
personnel
and that actions,
as appropriate
were
taken or scheduled.
IEN 86-103:
Respirator
Coupling Nut Assembly Failures
IEN 86-107:
Entry Into
PWR Cavity With Retractable
Incore Detector
Thimbles Withdrawn
, IEN 87-03:
Segregation
of Hazardous
and Low-Level Radioactive
Wastes
IEN 87-07:
equality Control of Onsite Dewatering/Solidification
Operations
by Outside Contractors
Docket No.
50-400
,License
No.
0
Carolina
Power
and Light Company
ATTN:
Mr.
E.
E. Utley
Senior Executive Vice President
Power Supply and Engineering
and Construction
P.
0.
Box 1551
Raleigh,
NC
27602
Gentlemen:
SUBJECT:
(NRC INSPECTION
REPORT
NO. 50-400/87-22)
This refers
to the Nuclear Regulatory
Commission
(NRC) inspection
conducted
by
R.
E.
Weddington
on June
15-19,
1987.
The inspection -included
a review of
activities authorized
for your Shearon
Harris facility.
At the conclusion of
the inspection,
the findings were discussed
with those
members of your staff
identified in the enclosed
inspection report.
Areas
examined
during the inspection
are identified in the report.
Within
these
areas,
the inspection
consisted
of selective
examinations
of procedures
and
representative
records,
interviews with personnel,
and
observation
of
activities in progress.
The inspection
findings indicate that certain activities
appeared
to violate
NRC requirements.
The violation, references
to pertinent
requirements,
and
elements
to
be included in your response
are described
in the enclosed
Notice
of Violation.
It is our understanding
that the problem described
in the enclosed
Notice of
Violation concerning your thermoluminescent
dosimeter
(TLD) dose algorithms
and
assessments
of exposure
to
noble
gas
may also exist at your Robinson
and
'runswick facilities.
Therefore,
your
response
should
also
include
a
statement of the applicability of this finding to your other facilities and the
corrective
actions
taken at
these facilities.
Your response
should
also
include
an
assessment
of the magnitude
of previous
individual exposures
to
noble
gas which may have
gone unassigned.
In accordance
with Section 2.790 of the
NRC's
"Rules of Practice,"
Part 2,
Title 10,
Code of Federal
Regulations,
a copy of this letter and its enclosures
will be placed in the
NRC Public Document
Room.
The responses
directed
by this letter
and its enclosures
are not subject to the
clearance
procedures
of the Office of Management
and Budget
as required
by the
Paperwork Reduction Act of 1980,
PL 96-511.
0