ML18005B148
| ML18005B148 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/03/1989 |
| From: | Potter J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005B146 | List: |
| References | |
| 50-400-89-23, NUDOCS 8911220282 | |
| Download: ML18005B148 (18) | |
See also: IR 05000400/1989023
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
ISO'
8 1989
Report No.: 50-400
Licensee:
Carolina
Power and Light Company
P. 0.
Box 1551
Raliegh,
NC 27602
Docket No.: 50-400
Facility Name:
Shearon
Harris
Inspection
Condu t d
S pt mber 18-22,
1989
License No.:
NFP-63
Inspect r:
F
.
Wra
lrZI
t
Signed
Approved by:
J.
. Potter,
hief
Facilities Radiation Protection Section
Emergency
Preparedness
and Radiological
Protection
Branch
Division of Radiation Safety
and Safeguards
a
Signed
SUMMARY
Scope:
This
unannounced
inspection
of the licensee's
radiation protection
prooram
included
a
review of: organization
and
management
controls;
training
and
qualifications;
external
exposure
controls;
control of radioactive material,
contamination,
and surveys;
and the transportation
of radioactive material.
Results:
One violation with four examples
for failure to follow radiological
control
procedures
required
by licensee
The violation
included
two examples of failure to make radioactive contamination
surveys at
a
frequency
necessary.
to
detect
changinG
radiological
conditions
in which
personnel
contaminations
occurred;
fai lure
to
perform
adequate
personnel
.
contamination
monitoring to detect
measurable
personnel
contamination;
and
fai lure of a radiation worker to follow verbal
instructions
as required
by
a
Radiation
Work Permit. Although these
items
had
been identified by the licensee,
the licensee
was
not evaluating
the events
or developing corrective actions
utilizing their system for assuring
appropriate
root cause
determination
and
correction action.
The licensee's
preparations
for the upcoming outage
appeared
adequate.
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REPORT DETAILS
1.
Persons
Contacted
Licensee
Employees
- A. Boone, Radiation Control
Foreman,
Operations
- D. Elkins, Radiation Control
Foreman,
Radioactive Materials/Dosimetry
- J. Floyd, Radiation Control
Foreman,
Operations
- C. Gibson, Director, Programs
and Procedures
- J. Hammond,
Manager,
Onsite Nuclear Safety
- C. Hinnant, Plant General
Manager
- J. Kiser, Supervisor,
Radiation Control
- C. McKenzie, Principal guality Assurance
Engineer
- A. Poland, Project Specialist,
Radiation Control
- F. Reck, Radiation Control
Foreman,
Operations
Support
~R. Richey, Manager, Harris Nuclear Project
- J. Sipp, Manager,
Environmental
and Radiation Control
- W. Slover, Project Engineer,
Technical
Support
- J. Smith,
Radwaste
Supervisor
- D. Tibbitts, Director, Regulatory Compliance
Other
licensee
employees
contacted
during this
inspection
included
technicians
and maintenance
personnel.
Nuclear Regulatory
Commission
M. Shannon,
Resident
Inspector
- Attended exit interview
2.
Organization
and Management
Controls
A.
Organization
The inspector
reviewed
changes
made to the licensee's
organization,
staffing levels,
and lines of authority as they related to radiation
protection,
and verified that the
changes
had not adversely
affected
the
licensee's
ability
to
control
radiation
exposures
or
radioactivity.
The licensee
recently
completed
an Organizational
Analysis in which
several
site positions
were eliminated with reductions
in force
and
other positions
were modified
and or transferred.
Only one position
was
lost
in
the
Environmental
and
Radiological
Control
(E&RC}
organization
which affected
the radiation protection
program.
The
Dosimetry Radiation
Control
Foreman position in the Operations
Group
was
eliminated.
The
loss
of the position
reduced
the
number of
Radiation Control
Foremer, positions in the
EKRC organization
from five
to four.
The
licensee
transferred
a
foreman
position
from the
Technical
Support
Group to the Operations
Group following the position
loss.
As
a result
of the
move,
the
Operations
Group
obtained
responsibility for part of the plant Radiation Monitoring System.
The
licensee
modified individual
foreman responsibilities
to accommodate
the additional task assignment.
No violations or deviations
were identified.
Management
Controls
The inspector
reviewed the licensee's
program for self-identification
of weaknesses
related
to the radiation protection
program
and the
appropriateness
of correction action taken.
10 CFR Part 50, Appendix B, Criterion XVI states
that measures
shall
dev
be established
to assure
that conditions
adverse
to quality
such
iations,
and nonconformances
are promptly identified and corrected,
In the case of significant conditions adverse
to quality, the measures
shall
assure
that
the
cause
o
the
condition is
determined
and
corrective action taken to preclude repetition.
Licensee
procedure,
Plant
Program
Procedure
(PLP)-511,
Radiation
Control
and Protection
Program,
Revision 3, Section
5. 12 states
in
part, that the
issuance
of Radiation
Safety Violations
(RSVs) is
a
constructive
method of identifying and
documentina
instances
wher
s iort comings
on
the
part of persons,
organizations,
procedures,
I
ere
practices,
or equipment
have
led to deviations
from requirements
of
the Radiation Control
and Protection
Program.
Licensee
procedure
AP-513,
RSVs, Revision 3, describes
the method for
documenting,
reviewing, resolving,
and tracking
RSVs.
The procedure
generally defines
a
RSV as
an infraction of procedures,
instructions,
or training.
The licensee
has three levels of significance for RSVs,
with level
I being
the
most significant..
The procedure
also gives
examples of RSYs for each severity level.
Paragraph
4 of this report identifies several
radiological protection
program deficiencies
for failure to follow procedures
required
by
licensee
Technical Specifications '(TSs).
During
a review of the
two
events
associated
with
these
radiological
control
program
deficiencies,
the inspector
noted that the licensee
had not initiated
a
RSV or documented
the
inadequacies
in the licensee's
corrective
action program.
Instead,
the
licensee
was
documenting
the
events
and corrective
actions
taken in letters
to plant files.
The licensee
had
begun
an
investigation
into the
two events
during
a previous
inspection
in
August,
1989,
and
was still preparing letters to plant files during
the most recent inspection,
The use of the letters to plant files did
not
implement
the
aspects
of the
RSV
system
that
would
assure
effective root cause corrective action.
The inspector stated that the
licensee's
evaluation
of
a
review of the
method for documenting
procedural
and regulatory violations would be tracked
as
an inspector
follow-up item (IFI) 50-400/89-23-01.
The first personnel
contaminations
were identified by the licensee
on
Wednesday,
August 9,
1989.
Inspection
team
members
determined
on
Thursday,
August 17,
1989, that the licensee
had not documented
the
problem or similar procedure violations occurring
on August
11 and
16
in any of the licensee's
corrective action
programs that would cause
the root cause
to be identified or caused corrective actions to occur.
The licensee's
failure to document
the violations of August 9, in
their corrective action
program
has
prevented
credit for
a licensee
identified violation since it was
not clear that the licensee
would
have
determined
the root
cause
of the
personnel
contaminations
or
take necessary
steps to prevent recurrence,
within a reasonable
time.
C. Outage
Nanagement
Preparation
The inspector
discussed
the planning
and preparation for the upcoming
outage
with licensee
representatives.
Specific
areas
discussed
included
increases
in staffing,
special
training,
licensee
control
over health physics
(HP) technicians,
and dose reduction methods to be
employed,
and
performance
is these
areas
was
found to
be currently
satisfactory.
No violations or deviation were identified.
3.
Training and gualifications
The inspector
reviewed
the licensee's
qualification
and training program
for vendor
HP technicians.
Licensee
TS 6.4 requires that
a retraining
and replacement
training program
for the unit staff meet or exceeds
the requirements
of the September
1979
draft of ANS 3.1, with exceptions
arid alternatives
as noted
nn Final Safety
Analysis Report
(FSAR)
pages
1.8-8 (AN.20), 1.8-9 (AN.26), 1.8-10 (AN.27),
1.8-11
(AN.27), 1.8-12
(AN,27),
and
1.8-13
(ANi.27). Table 1.8-1 of the
licensee's
cross
references
positions
with
the
qualification
requirements
of the standard.
Licensee
procedure
ERC-104,
Contract
ESRC Technician gualification
and
Training,
Revision 2, June,
1989,
includes instructions for verifying and
documenting
the
qualifications
and
training
of contract
technician
personnel
with radiation control or chemistry responsibilities.
However,
the
procedure
does
not state
the
minimum qualification
and training
requirements,
nor describe
how assessments
would
be
made.
The previous
procedure
revision
had
a form to evaluate
vendor personnel
qualifications;
however,
the form had
become
outdated
and
was
removed
from the procedure.
The inspector
stated
that
the qualification
and training of vendor
personnel
working during the fall 1989 refueling outage
would be tracked
as
IFI 50-400/89-23-02.
No violations or deviations
were identified.
External
Exposure
Control, Surveys,
Personnel
Monitoring, and Control of
Radioactive Material
TS 6.8 through
reference
to Regulatory
Guide 1.33,
Revision
2,
February
1978, requires written radiation protection
procedures for; access
control
to radiation
areas,
a radiation
work permit
(RWP)
system,
radiation
surveys,
airborne radioactivity monitoring,
contamination
control,
and
personnel
monitoring.
requires
each
licensee
to make or cause
to be
made
such
surveys
as
(1)
may
be
necessary
for the licensee
to comply with the
regulations
and
(2) are
reasonable
under the circumstances
to evaluate
the
extent of radioactive
hazards
that may be present.
The
inspector
reviewed
the
plant
procedures
which
established
the
licensee's
radiological
survey
and monitoring program
and verified that the
procedures
were consistent with regulations,
TSs,
and
oood
HP practices.
The
inspector
reviewed
selected
records
of radiation
and
contamination
surveys
performed
during August
and
September,
1989,
and discussed
the
survey results
with licensee
representatives.
During tours of the plant,
the
inspector
observed
technicians
performing
radiation
and
contamination
surveys.
The
inspector
performed
independent
radiation
and
loose
surface
contamination
surveys
in the Auxiliary and
Radwaste
Buildings and verified
that the areas
where properly posted.
A.
Spent
Fuel Receipt Activities
In July
1989,
the
licensee
began
receiving
spent
fuel
from the
Brunswick Steam Electric Plant
(BSEP) for storage
in their spent fuel
'
pool.
While participating
on
a maintenance
team inspection
on August
17,
1989,
the inspector
determined
that the licensee
had experienced
some radiological control
problems associated
with spent fuel casks
in
August
1989.
The inspector
determined that several
employees
working
in the licensee's
Fuel
Handling 'Building (FHB) had
been
contaminated
with
low level
radioactive
material.
The
contaminated
radiation
workers
had clothing or skin contaminations
which were less
than
400
counts
per minute
(cpm)
above
background
when
measured
with
a thin
window Geiger-Mueller
(GM) detector.
The licensee
was still examining
and investigating
the events
up to the time of the maintenance
team
inspection exit on August 18,
1989. Consequently,
the team was unable
to to sufficiently review the adequacy of the licensee's
radiological
controls
and
any
subsequent
corrective actions
associated
with the
event.
A review of the
licensee's
actions
associated
with the
contaminations
.was
made
IFI 50-400/89-16-02
in the maintenance
team
inspection report.
On August 4, 1989,
the licensee
received its second
shipment of spent
fuel
from BSEP.
On August 5,
1989,
the spent fuel cask
was
lowered
into the
cask
unloading
pool
(CUP)
located
in the
FHB. While the
licensee
was attempting
to remove
the shipping
cask lid one of the
four lifting straps
broke.
The licensee
attempted
to level the cask
lid and
a
second lifting strap
broke.
The cask
was
removed
from the
CUP and placed into the decontamination pit that day
and
new lifting
cables
were ordered
from BSEP.
On August 6,
1989,
the lifting straps
>>ere replaced
and the cask lid was'eventually
removed about 5:00 a.m.
that day.
The licensee
reported
that
the
cask lid had shifted following the
first lifting strap failure and that
a bind between
the lid and
one of
the
studs
led to the
second
cable break.
The licensee
reported that
personnel
did not detect
the binding during the lift due to the poor
visibility underwater.
The lifting yoke, attaching cables,
and lower
crane block were about
15 feet underwater
and the workers were wearing
t espirators
for respiratory protection.
The
NRC reviewed
the lifting
problem and documented
the results of the review in another inspection
report.
The licensee
suspected
that the event
may have
damaged
the
shipping cask
and prepared
to inspect
the cask following unloading.
The licensee
completed
cask
unloading
about
5:00 a.m.
on August 9,
1989,
and planned to remove the fuel support basket
from the shipping
cask for a cask sealing
surface
inspection.
A radiation survey of the
basket
indicated
a direct
exposure
rate of
3 R/hr.
To remove
the
basket
from the
cask, it would have to
be lifted out of the
cask
unloading pool,
and
moved across
several
feet of floor space
on the
286 foot elevation
of the
FHB before it could
be
lowered into the
flooded unit 2-3 transfer canal.
The licensee
prepared
a special
RWP for the cask inspection
and took
the following precautions
prior to removing the basket:
The Control
Room
was
requested
to shift the
FHB ventilation
emergency
exhaust
and
was alerted
to expect
alarms
on the area
radiation monitor system.
Personnel
access
to the
286 foot elevation of the
FHB was
restricted.
HP personnel
were positioned
to monitor dose
rates
and airborne
radioactivity during the basket lift and movement.
The fuel basket
was first raised to the surface at about 6:00 a.m.
on
August 9,
1989.
The first
and
second lifts of the
basket
were
unsuccessful
in reaching
the proper height to clear the floor.
On the
first two lifts the licensee
sprayed
the basket with water from the
cask unloading pool spray ring. The basket
was able to clear the floor
on the third lift and
was
lowered into the transfer
pool at about
10:00 a.m. that day.
At approximately
11: 15 a.m., the licensee's
HP staff became
aware that
several
radiation
workers
had
become
contaminated
on the
286 foot
elevation of the
FHB. The inspector
reviewed the licensee's
personnel
contamination reports.
Two of the workers
had
been working on the fuel
basket
move and
had radioactive material
contamination
on their wrists
up to
400 cpm
above
background
when measured
directly with a thin
window (pancake)
Gll detector
and count rate monitor.
The personnel
contamination
reports listed
improper undress
from the contaminated
area
as the cause.
Another worker removing contaminated
trash
had
up
to
150
cpm radioactive material
on his chest
which was believed to
have
occurred
in the
clean
area
following the
removal
of his
protective clothing.
A fourth worker had radioactive contamination
on
his
shoes
up to 400
cpm.
The operator's
shoes
became
contaminated
while
he
crossed
the
clean
areas
of the floor on his regular
inspection
rounds.
A gross
(masslin cloth) contamination
survey of the clean area floors
showed that they were contaminated.
The licensee
secured
access
to the
floor, posted
the area
as contaminated
and conducted
surveys revealing
clean
areas
contaminated
with up to 35,000 disintegrations
per minute
per
100 square
centimeters
(dpm/100 cm~).
The licensee
was not sure
how the clean
areas
of the
286 foot floor
had
been
contaminated.
Licensee
personnel,
that were present
when the
fuel basket
was
sprayed with the
CUP cask spray ring, reported that
a
column of water mist rose about
15 feet above the floor level when the
fuel basket
was
sprayed.
The inspector
determined
that the licensee
had failed to monitor the clean
areas
on the floor for contamination
following the fuel
basket
move
and prior to returning
the floor to
normal
access.
Licensee
procedure,
PLP-511, Radiation Control
and Protection
Program,
Revision
3,
states
in part,
that
routine
radiation
surveys
of
accessible
plant areas
shall
be performed
on an appropriate
frequency,
depending
on the probability of radiation
and contamination
levels
changing
and
the
frequency
of the
areas
visited.
Furthermore,
the
procedure
states,
in part,
that
surveys
relating
to specific
operations
and
maintenance
activities in support of
PWPs shall
be
performed to
keep
exposures
as
low as
reasonably
achievable
(ALARA)
and insure that
persons
are
informed of changing plant radiological
conditions.
Contrary to the above,
on August 9, 1989, the licensee failed to make
radioactive
contamination
surveys at
a frequency
necessary
to detect
changing
radiological
conditions,- in that,
the clean
areas
on the
286 foot fuel handling floor became
contaminated
causing
personnel
to
unknowingly
become
contaminated
with radioactive
material.
The
inspector
stated that failure to evaluate
the extent of radiological
hazards
present
in clean
areas
on the fuel handling floor in order to
comply with licensee
procedures
was
an apparent violation of TS 6.8.
(50-400/89-23-03).
The licensee
began decontamination. of 286 foot elevation in the
FHB on
August 9,
1989,
and
was able to clean
and release
the walkways the
following day.
On August
11,
1989, .the licensee
was .ready to return
the basket to the shipping cask.
The licensee
had to lift the basket
out of the unit 2/3 transfer pool
and move it across
a portion of the
fuel
handling floor to the
decontamination pit where the
cask
was
located.
In addition to moving the basket,
the licensee
also
had to
retrieve
a screw that fell into the basket
when the cask
was
damaged.
The
licensee
held
a
pre-job briefing
and
began
fabricating
an
extension
tool for the
screw extraction
. The licensee
also attempted
to
remove
some
of the
basket
contamination
by moving the
basket
back-and-forth
several
times in the transfer
canal prior to its lift.
The licensee
also secured
FHB ventilation and restricted
access
to the
286 foot elevation of the
FHB during the basket transfer.
The licensee
installed
a portable
high efficiency particulate air (HEPA) filter in
the
area
adjacent
to the
basket
path
and positioned
additional air
. sampling
equipment
on the floor.
On August ll, 1989,
the licensee
transferred
the fuel
basket
back to the spent
fuel
cask
which was
located
in decontamination pit.
The licensee
completed
the
move at
about 8:00 a.m.
According to licensee
representatives
the operators
did not spray
the basket with water at any time during the basket
movement.
Followino the basket
move,
two of the workers exiting the
FHB 286 foot
elevation
had radioactive
contamination
on their shoes
up to 200 cpm.
The personnel
contamination
reports
indicated that the workers
shoes
had
become
contaminated
in the clean areas of the floor. The licensee
did not detect significant airborne radioactivity during the move and
was
not sure
how the clean
areas
had
become
contaminated
aoain.
The
inspector
stated
that
failure
to
to
evaluate
the
extent
of
radiological
hazards
present
in clean
areas
of the fuel handling
building, during
and following the fuel
basket
move
on August 11,
1989,
at
a
frequency
necessary
to detect
changing
radiological
conditions
to
prevent
persornel
contaminations
in clean
areas,
appeared
to
be
another
example
of failure to follow procedures
required
by TS 6.8 (50-400/89-23-03)..
Personnel
Contamination
Event
FHB August 16,
1989
In order to protect safeguard
information associated
with the receipt
of spent fuel, the licensee
ensured that
HP personnel
working with the
fuel
had
the
appropriate
security
clearances.
The
licensee
also
decided
to protect all radiological
survey information associated
with
the
spent
fuel
cask
as
safeguards
information.
This included all
survey
information for work associated
with the spent fuel
and
cask
within the licensee's
FHB. The licensee's
decision
caused
the main
Office to
be without current
survey information for FHB, since
the
surveys
were being secured for 10 days prior to their release.
On August 16,
1989,
a radiation worker reported to the licensee's
Office
and told the
personnel
that
he
needed
to
remove
some
concrete
forms
on
286 foot elevation of the
FHB. The
HP personnel
in
the
RWP Office told the worker to review
and
sign in on General
Radiation
Work Permit
(GRWP) H89-0010
and instructed the the worker to
report to the
HP technician
covering work in the
FHB.
GRWP
10 was for
routine maintenance
activities in all areas.
Authorized work included
set
up,
testing,
calibration,
and
performance
of preventative
maintenance
on equipment in the Radiation Control Area
(RCA).
The radiation worker located
the
FHB
HP technician
on the floor who
was
conducting
a
radiological
survey.
The
worker
got
the
technician's
attention
and
stated
that
he
needed
to
remove
two
concrete
forms >>hich were located
near the cask unloading pool.
The forms were
used in setting recently
added
concrete
support
bases
for underwater light hangers
on the east
and south
sides of the
CUP.
The forms were inverted
"L" shaped
with sides parallel to the floor
and walls of the
CUP (the forms extended
several
inches into the pool
cavity).
The south
form was completely within a high contamination
area
and the east form was partially in a contaminated
area
and
a high
contamination
area
since
the
walls
of the
CUP
were
highly
contaminated.
The licensee
defines
a contaminated
area
(CA) as
any area
where the
removable
surface
contamination exist in excess
of 1,000 dpm/100
cm'nr
beta
and
gamma radiation
and
20 dpm/100
cm~ of alpha radiation.
The licensee
defines
a high contaminated
area
(HCA) as
an area
where
surface
contamination exist of 5,000 dpm/100 cm'or beta
and
gamma
radiatio'n
and or 100 dpm/100
cm~ of alpha radiation.
the
HP technician
allowed the
worker
to enter
the
CA to perform
preparatory
work, but told the worker that entry into the
HCA would
not
be
allowed until
a detailed
survey of the
area
was
made.
The
worker entered
the
CA with single full dress protective clothing while
the
HP technician
surveyed
the
HCA and accessible
surfaces
of the
CUP.
The
technician
exited
the
area
to
count
the
smears.
The
technician's
smears
indicated
the floor near
the
south
form had
smearable
contamination
up 25,000
dpm/100 cm'nd
the walls of the
CUP,
which were
common to both forms,
had
smearable
contamination
which measured
0.5 millirad per hour
gamma
and 40.0 millirad per hour
beta.
According to licensee
representatives,
the
HP technician
had
'ust determined
the
smear results
when
he noticed that the worker was
en his
knees
removing
a portion of the east
concrete
form with
a
hammer.
The
HP technician
stopped
the work and
informed the worker
that
a
special
RWP would
be
required
with additional
protective
eouipment before the work could continue.
The worker was instructed to
leave
the area.
The worker exited the contaminated
area
and performed
J
a whole
body. frisk in
a whole
body contamination
monitor that
was
located
in the
FHB.
The monitor did not detect
any radioactive
contamination
and
the worker proceeded
to the 'main
RCA exit.
The
whole
body counter
was
located
on the
FHB
286 foot elevation
to
monitor workers for hot particles.
At the main
RCA exit, the worker performed
a required whole body frisk
in another
whole
body frisker and
received
contamination
alarms for
the head,
shoulders,
and right hand.
Licensee
procedure
AP-503, Entry Into Radiological Areas,
Revision 5,
states
in part, that
upon exiting the
main
RCA, personnel
are to
monitor themselves
for contamination with a whole body contamination
monitor and if the whole body contamination
monitor alarms,
they are
to frisk the
area
indicated
by the whole
body contamination
monitor
with a pancake
GM probe
and count rate meter. If the count rate meter
alarms
the worker is to immediately notify the Radiation Control
Group
and await further instructions. If the area
when surveyed with the
GM
detector
was less
than
100
cpm above
background
the worker is required
to reenter the whole body contamination monitor for a second
count. if
the monitor alarmed
a
second
time the
worker is to contact
a
technician for a survey
and
remain in the area until released
by a
representative.
The worker exited the whole body frisker and performed
a frisk of the
head,
shoulder,
and
hand
and
reported
that
he did not detect
any
measurable
contamination
on the
body.
The worker reentered
the the
whole body frisker at the main
RCA exit for the second
count
and again
received
the
the contamination
alarms.
The worker exited the whole
body frisker and performed his
second frisk with the
GM detector with
negative results.
The worker reported that
a
HP representative
in the
area
had told him that
he could leave the
RCA if his frisk with the
GM
detector did not detect
any contamination.
The worker exited the
RCA.
The worker was unable to identify the
HP technician that allowed him
to leave
the
RCA and, at the time of the inspection,
no
HP technician
had
acknowledged
being in the
RCA exit area
when the worker
had
alarmed
the whole body frisker.
A
licensee
worker
failed
to
perform
an
adequate
personnel
contamination
survey to detect contamination activity, at 100
cpm per
probe
area
above
background,
in accordance
with licensee
procedures.
The inspector
stated
that failure to perform
an
adequate
personnel
survey
and notify the radiation control
group
was another
example of
failure
to
follow procedures
as
required
by
licensee
(50-400/89-23-03).
Licensee
procedure
AP-503, Entry Into Radiological Areas,
Revision 5,
states
in part, that
each individual working in an
RCA is responsible
for complying with the instructions
on
and oral instructions
given by Radiation Control personnel.
10
The
inspector
stated
that failure to follow the
HP 'technicians
instructions
to
do only preliminary work in preparation
for the
concrete
form removal
was another
example of a violation of licensee
procedures
required
by TS 6.8 (50-400/89-23-03).
Radiation
Work Permits
through
reference
to
Regulatory
Guide 1.33,
Revision 2,
February
1978,
requires
written procedures
for access
control to
radiation areas
including
a
RWP system.
Licensee
procedure
PLP-511,
Radiation Control
and Protection
Program,
Revision 3, defines
a
RWP, in part,
as
an administrative control which
authorizes
specific individuals to perform
a specific job or task
within the
RCA and defines
radiological
conditions
and the
minimum
radiation protection measures
required to perform a task.
The licensee
has
two types of RMPs,
GRWP, and Special
(SRWP), that are
used at the
fac i 1 ity.
Licensee
procedure
AP-503, Entry Into Radiological Areas,
Revision 5,
states
in part, that the
GRWP
may
be
used for the following task:
general
entry,
planning,
inspections,
routine maintenance,
routine
operations,
and radiological surveillance.
The procedure
also allows
the
use of
GRMPs in entering
the following areas:
radiation,
high
radiation
areas,
and
locked
contaminated
and
high contaminated
areas;
and radioactive materials
areas.
Licensee
Procedure
AP-503 states,
in part, that the
SRWPs
are issued
for a specific location
and task
and that the
SRMP expires at the end
of the job duration
which normally should
be within seven
days.
The
procedure
also allows
a
SRWP to be extended
up to one calendar year.
The
SRWP
may
be
used
to enter
the
same
areas
as
a
GRMP
and the
following areas:
airborne
radioactivity areas,
beta
hazard
areas,
restricted
and neutron radiation areas.
The
inspector
reviewed
selected
RMPs for appropriateness
of the
'adiation
protection
requirements
based
on work scope,
location,
and
conditions.
The inspector
reviewed the licensee's
SMRP utilizec in the
FHB 261 and
286 foot elevations for handling spent fuel shipping cask.
The
SRMP was utilized for numerous
task associated
with the shipments
and its applicability to the receiving
and storage of the spent fuel
was large in scope.
Many of the instructions
were generic
and like
those
used
on
many of the licensee's
GRWPs.
The inspector
discussed
the potential
problem associated
with large
scope
RMPs with licensee
personnel.
However,
the inspector
determined
that
when the licensee
encountered
problems
with the shipping
cask
and
determined
that
an
inspection'f the shipping cask would be required,
the licensee
issued
a separate
SRMP for the planned work.
11
D.
Radiological Posting,
Labeling,
and Control of High Radiation Areas
specifies
the
posting,
labeling,
and
control
requirements
for radiation
areas,
high radiation
areas,
airborne
radioactivity areas,
and radioactive material. Additional requirements
for control of high radiation
areas
are contained
in TS 6.12.
During
tours of the plant, the inspector
reviewed the licensee's
posting
and
control
of radiation
areas,
high
radiation
areas,
airborne
radioactivity areas,
contamination
areas,
radioactive material
areas,
and the labeling of radioactive material.
No violations or deviations
were identified.
5.
Transportation
Of Radioactive Material
10 CFR 71.5 requires that licensees
who transport licensed material
outside
the confines of its plant or other place of use,
or who deliver licensed
material
to
a carrier for transport,
shall
comply with the applicable
requirements
of the regulations
appropriate
to the
mode of transport of the
Department of Transportation
(DOT) in 49
CFR Parts
170 through 189.
10
CFk 71.91
specifies
the
records
that
the licensee
is required
to
maintain for each
nonexempt
shipment of radioactive material,
The inspector
reviewed
selected
records of radioactive material
shipments
made in 1989,
and verified that
the
licensee
had maintained
the
records
required
by
The
inspector
verified that
the
radioactive
manifests
reviewed
had
been properly completed.
The inspector
reviewed plant procedures
for the preparation,
documentation,
shipment,
and
receipt
of radioactive
material
and verified that
the
procedures
were consistent with NRC and related
DOT regulations.
No violations or deviations
were identified.,
6.
Exit Interview
The inspection
scope
and results
were
summarized
on September
22,
1989,
with those
persons
indicated
in Paragraph
1.
The inspector
described
the
areas
inspected
and
discussed
in detail
the inspection findings listed
below. Proprietary information is not contained in this report.
Item Number
Descri tion and Reference
50-400/89-23-01
50-400/89-23-02
IFI - Review the licensee's
method for identifying
and
resolving
radiological
protection
program
deficiencies
(Paragraph
2).
IFI - Review vendor
HP technician qualifications
and training (Paragraph '3).
12
50-400/89-23-03
NOV - Failure to follow radiological control
procedures
resulting in personnel
contaminations
in the licensee's
FHB on August 9,
11,
and
16,
1989 (Paragraph
4.A.).
Upon further review of the radiological
problems
discussed
in Paragraph
4
of the report,
the decision
was
made to change
the violation discussed
above to failure to follow procedures
required
by licensee
TSs.
During a
telephone
conversation
on October 12, 1989,
between
F.
N. Wright of the
NRC
and representatives
of Carolina
Power
and Light Company,
the licensee
was
informed that
the
apparent
violation of 10 CFR 20.201(b) for inadequate
surveys of radiological conditions in the licensee's
FHB had
been
reviewed
and
changed
to be included
as
examples of violations of TS 6.8 for failure
to follow procedures.