ML18010B137
| ML18010B137 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/17/1993 |
| From: | Boland A, Pharr E, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18010B135 | List: |
| References | |
| 50-400-93-11, NUDOCS 9307230166 | |
| Download: ML18010B137 (22) | |
See also: IR 05000400/1993011
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
JUN 17
l993
Report No.:
50-400/93-11
Licensee:
Carolina
Power and Light Company
P. 0.
Box 1551
Raleigh,
NC
27602
Docket No.:
50-400
Facility Name:
Shearon Harris
Inspection
Co
cue
ay 17-
,
1993
Inspectors:
E.
B
Pharr
A. T. Bolan
License No.:
D te
'gned
at
Signe
Approved by:
4 /y
W.
H. Rankin,
Chi f
Da e
S gned
Facilities Radiation Prote t on Section
Radiological Protection
and
Emergency
Preparedness
Branch
Division of Radiation 'Safety
and Safeguards
SUMMARY
Scope:
This routine,
announced
inspection of the licensee's
radiation control
(RC)
program involved
a review of health physics
(HP) activities including
organization
and staffing; self-assessment
programs; training and
qualifications; internal
and external
exposure controls; control of
radioactive material;
and
ALARA program implementation.
Results:
Overall, the
RC program appeared
to be functioning adequately.
The
organization
and staffing appeared
stable overall.
However,
a change in.
Environmental
and Radiation Control
(EKRC) Managers
had taken place since the
previous inspection.
An increased
management
focus in areas of the licensee's
auditing program'was
noted, resulting in improvements
in the quality of both
assessments
and followup actions.
No concerns
were identified with the
licensee's
implementation of revised
10 CFR Part 20 terminology and
requirements
into General
Employee Training
(GET)
and craft technical
9307230166
930617
ADQCN 05000400
training, nor into the dosimetry program
and associated
software.
The
licensee's
dose
performance during the first quarter of 1993 was excellent
with a recorded
cumulative exposure of less
than
10 person-rem for the period.
Deficiencies
were identified in the licensee's
program for controlling
radioactive material.
One unlabeled pressurizer relief valve was identified
which required labeling per licensee
procedure
and
10 CFR 20. 1904(a).
Addition'ally, eleven
items with smearable
and/or fixed contamination
were
inappropriately controlled for prevention of the spread of contamination,
per
licensee
procedure.
One apparent
NRC-identified violation resulted
from these
examples of the failure to comply with procedural
requirements for properly
handling radioactive material
(Paragraph
7.b).
REPORT DETAILS
Persons
Contacted
Licensee
Employees
- T. Anderson,
Radiation Control Technician
N. Bertrand, Specialist,
Technical Training
S.
Browne, Corporate
Health Physics,
Dosimetry
D. Cornett,
Radiation Control Supervisor
- J. Floyd, Senior Specialist,
H. Hamby, Project Specialist,
Regulatory Compliance
- J. Kiser, Manager,
Radiation Control
- D. HcCarthy,
Manager,
Regulatory Affairs
- J. Hoyer',
Manager,
Site Assessment
- C. Neuschaefer,
Nuclear Assessment
Department
- M. Parker,
ALARA Technician
R. Pasteur,
Senior Specialist,
Technical Training
- F. Reck, Supervisor,
Radiation Control
- B. Robinson,
Plant General
Hanager
- B. Seyler,
Manager,
Project
Management
G. Simmons, Specialist,
Technical Training
R. Smith, Corporate,
Nuclear
Assessment
Department
- H. Wallace,
Senior Specialist,
Regulatory Compliance
- B. White, Manager,
Environmental
and Radiation Contro
- E. Wills, Radiation Control Supervisor
- B. Wilson, Manager,
Shipping/Nuclear
Fuel
Other licensee, employees
contacted
included engineers
office personnel.
Nuclear Regulatory
Commission
, technicians,
and
W. Rankin, Chief, Facilities Radiation Protection Section,
Region II
- D. Roberts,
Resident
Inspector
- J. Tedrow, Senior Resident
Inspector
"Attended Hay 21,
1993 Exit Meeting
Organization
and Staffing (83750)
The inspector
reviewed
and discussed
with licensee
representatives
changes
made to the radiation control
(RC) organization
since the last
inspection of this area
conducted
September
14-18,
1992,
and documented
in Inspection
Report (IR) 50-400/92-19.
The inspector noted that the
organization
and staffing had remained relatively stable,
in that the
RC
organization
continued to be staffed
by approximately
40 technicians
and
supervisors.
The inspector
noted that since the previous inspection,
the position of Chemistry Manager
was vacant with the individual which
had previously filled that position being assigned
as the Environmental
and Radiation Control
(EKRC) Manager.
The inspector
was informed that
the previous
EhRC Manager
had
been transferred
to another plant
department.
The inspector
noted that this organizational
change did not
adversely affect the program in that the
RC Hanager,
who fulfilled Final
Safety Analysis Report
(FSAR) qualifications
as the Radiation Protection
Hanager,
had remained constant.
The inspector
was also informed that during the period in which the
E&RC
Hanager position
was vacant
and to date,
during the transitional
period
for the newly appointed
manager,
the
ALARA function was reporting to the
RC Hanager
instead of directly to the
E&RC Hanager,- as
done previously.
The inspector
was informed that this was
a temporary
arrangement
to lend
stability to the ALARA function during the transitional
period.
The inspector
informed licensee
representatives
that the
RC organization
and staffing levels continued to be appropriate
and appeared
to be
functioning adequately
to support ongoing activities.
Additionally, the
recent organizational
changes within the
E&RC function did not appear to
adversely affect the organization's ability to protect the health
and
safety of plant workers.
No violations or deviations
were identified.
Radiation Protection Training (83750)
10 CFR 19. 12 requires,
in part, that the licensee instruct all
individuals working in or frequenting
any portion of a restricted
area
in the health protection aspects
associated
with exposure to radioactive
material
or radiation; in precautions
or procedures
to minimize
exposure;
in the purpose
and function of protection devices
employed; in
the applicable provisions of the Commission regulations;
in the
individual's responsibilities;
and in the availability of radiation
.
exposure
data.
a ~
General
Employee Training
(GET)
The inspector reviewed the licensee's
program for providing
radiation protection training to licensee
employees.
The
inspector noted that
GET appropriately includ"d revised
10 CFR Part 20 terminology, definitions,
and regulatory limits.
As well,
plant security,
emergency
preparedness,
industrial safety,
recent
industry events,
and exposure
concerns
were included in the
training.
The inspector also noted that the
GET material, or
craft technical training,
was updated
as
needed to include recent
concerns
with radiation worker practices,
and subsequent
revisions
to E&RC-related plant policies.
The inspector
informed licensee representatives
that
GET appeared
to be thorough
and well prepared
and appropriate for informing
plant workers
as required
by 10 CFR 19. 12.
No violations or deviations
were identified.
3
RC Technician Training
During the onsite inspection,
the inspector
reviewed the initial
training program for newly hired
RC technicians
and the continuing
training program offered
on
a quarterly basis to the
RC staff.
The inspector reviewed training records for a recently hired
RC
technician
and noted that the individual had received
GET and
respiratory protection training as required for all radiation area
workers.
The inspector
noted that the .RC technician training also
included
Emergency
Plan training as well as Radiological
and
Environmental Honitoring training.
The inspector also noted that
the initial technical training included courses
related to
mitigating core
damage,
basic
PWR systems,
providing
RC coverage
and support activities,
and radiation control.
Additionally, the
inspector
noted that after successfully
completing prerequisite
training the technician
had completed task qualification cards for
various field activities.
The inspector also verified that
individuals evaluating the
new technician's
proficiency in these
tasks
were qualified and certified as task evaluators.
The inspector reviewed quarterly continuing training presented
to
RC technicians
since the previous inspection
conducted
September
14-18,
1992,
and documented
in IR 50-400/92-19.
The
inspector
noted that
12 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of continuing training were
offered each quarter.
During review of course outlines the
inspector
noted that the training material
included review of
recently implemented
procedures
and major revisions to existing
procedures,
industry events
and exposure
concerns,
various plant
systems,
emergency
response,
and revised
The
inspector
reviewed the revised
10 CFR Part 20 training material
and noted that the training included
an overview of the regulatory
revisions
and
how these revisions would apply to plant radiation
protection activities.
The inspector also noted that the training
addressed
procedural
changes
resulting from Part
20 revisions.
The inspector
informed licensee
representatives
that their
training program for licensee
RC technicians
appeared
to be
comprehensive
and
no concerns
were noted with the training
material.
No violations or deviations
were identified.
Contractor Technician Training
At the time of the onsite inspection the licensee
was in the
process of finalizing a CPEL-wide generic training program for
contractor
RC technicians.
The program was designed to require
the contracted
vendor to certify that the technicians
meet certain
licensee
determined qualifications.
Following the contractor
RC
technician's
successful
completion of GET, the licensee
would
administer
a basic
knowledge test,
appropriate to the contractor's
job classification,
to verify the vendor's qualification program.
Site specific training with an orientation
program would also
follow.
The inspector reviewed study guides which the licensee
had
developed for the basic
knowledge test,
and test questions
which
comprised the examination
bank for the basic
knowledge test
and
the supplemental
tests for different job classifications.
The
inspector
noted that the study guides
and test questions
incorporated
revised
10 CFR Part 20 terminology and requirements.
The inspector further noted that the guides
and examinations
seemed
appropriate to assure
the qualifications of contract
RC
technicians.
The inspector
was informed that the licensee
was still in the
process of finalizing implementing procedures
for the contractor
RC technician training program.
Thus, the program
was subject to
management
review and revisions.
The inspector
informed licensee
representatives
that the finalized training program would be
reviewed in detail during future inspections.
No violations or deviations
were identified.
4.
Self-Assessment
Program
(83750)
Technical
S ecification
TS
6.
The inspector
reviewed reports of NAD assessments
conducted
since the
previous
NRC inspection
conducted
September
14-18,
1992,
and documented
in IR 50-400/92-19.
The inspector also noted that since the previous
inspection,
the
ESRC position within the site
NAD organization
had
been
assumed
by an individual with an appropriate level cf ELRC knowledge
and
experience.
Those particular assessments
reviewed
by the inspector
included
a Harris Nuclear Plant
(HNP) Sitewide assessment
conducted
October 5-16,
1992,
an
HNP outage
assessment
conducted
September 12,-
December
4,
1992
(H-OUT-92-01),
and
an
E8RC assessment
conducted
March 8-12,
1993
(H-ERC-93-01).
The inspector
noted that the
assessments
appeared
to be well planned
and documented.
The assessment
reports
were thorough with numerous
strengths
and improvement
items
being identified.
The inspector also noted
improvements
in management
oversight in that appropriate
focus
was given to identified findings,
proposed corrective items,
and resolution of concerns.
Additionally,
the inspector reviewed frequent observations
of program effectiveness
P
(
)
5.4.1 required audits of the facility to
be performed
by the Nuclear Assessment
Department
(NAD) encompassing
conformance of facility operation to the provisions contained within 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.
made
by the site
E&RC auditor.
Although these plant walkdowns,
work
performance
observations,
procedural
reviews,
and housekeeping
inspections,
were not formal
NAD assessments,
the inspector
noted that
identified weaknesses
were brought to
E&RC management's
attention
and
were promptly corrected.
The inspector
informed licensee
representatives
that the addition of a
permanent
E&RC auditor within the site
NAD organization
and increased
management
attention to
NAD identified issues
appeared
to be beneficial
in improving the overall effectiveness
of the
NAD function.
In addition,
the inspector
reviewed
and discussed
with licensee
representatives
the program for identifying and correcting deficiencies
and weaknesses
related to the implementation of the radiation protection
program.
Since the last inspection of this area in September
1992, the
licensee
had finalized and issued
Procedure
ERC-201,
E&RC Feedback
Report,
Revision
(Rev.) 3, dated
October
13,
1992.
This revision,
formalized the improvements
in trending, tracking,
and followup actions
discussed
in
NRC IR 50-400/92-19.
In addition, the licensee
had
modified the radiation safety violation program
as described
in
Procedure
PLP-511,
Radiation Safety Program,
Rev.
7, dated
January
1,
1994, to reflect two categories
of findings, significant and non-
significant.
The former type was followed-up utilizing the Adverse
Condition Report
(ACR) program
and the latter was assessed
and corrected
utilizing the Feedback
Report System.
Review of selected
Feedback
Reports
and Radiation Safety violations for
the period October
1,
1992 through
Hay 19,
1993,
noted that the licensee
was appropriately identifying and correcting health physics
problems
areas,
and
no trends of adverse
performance
were identified.
In
particular, the inspector
noted that the licensee's
continuing efforts
to reduce the backlog of old Feedback
Reports
were effective.
No violations or deviations
were identified.
External
Exposure Controls
(83750)
10 CFR 20. 1201
(a) requires
each licensee to control the occupational
dose to individual adults,
except for planned special
expo'sures,
to the
following dose limits: (1)
an annual limit,'hich is the more limiting
of the total effective dose equivalent,
being equal
to 5 rems,
or the
sum of the deep-dose
equivalent
and the committed dose equivalent to any
individual organ or tissue other than the lens of the eye,
being equal
to 50 rems,
and (2) the annual limits to the lens of the eye, to the
skin,
and to the extremities,
which are
an eye dose equivalent of
15 rems,
and
a shallow-dose
equivalent of 50 rems to the skin or to any
extremity..
The inspector
reviewed
and discussed
with licensee
representatives
external
exposures
for plant and contractor
employees for the period
October
1,
1992 through
May 18,
1993.
For the period, the inspector
verified that the assigned
1992 fourth quarter
doses
and year-to-date
1993 doses
were within the applicable
10 CFR Part 20 limits.
For the
fourth quarter
1992, the maximum whole body, skin,
and extremity
exposures
assigned
at the Harris plant were
1080 millirem (mrem),
1080 mrem,
and
1493
mrem, respectively.
For 1993, the maximum year-to-
date total effective dose equivalent
(TEDE) assigned
by TLD was
213 mrem
with similar doses
assigned for the skin of the whole body, lens of the
eyes,
and the extremities.
For those individuals who had exceeded
or who were expected
to exceed
1.25 rem in the fourth 'quarter of 1992, the inspector verified that
exposure
extensions
were authorized.
Review of corresponding
records
determined that exposure history files were completed
(NRC Form-4)
and
extensions
were granted
based
on quarterly
and lifetime exposures,
as
required.
For the period,
most extensions
were associated
with steam
generator
and cavity painting/stripping activities, with the maximum
extension
g} anted to 2000 mrem.
Effective January
1993, the licensee
established
new annual
administrative
dose limits coincident with
implementation of the
new Part 20.
These limits were
as follows:
500 mrem
TEDE without determination of additional current year dose
and
2000
mrem and 4000
mrem TEDE if current year dose
was determined.
In
addition,
a lifetime administrative
dose limit of 1N rem, where
N equals
the individual's
age in years,
had
been established.
The inspector
was
informed that
no dose extensions
had
been granted
thus far in 1993.
No
concerns
were noted with the licensee's
administrative limits or dose
extension
process.
10 CFR 20. 1208(a) requires that the dose to the embryo/fetus
not exceed
500 mrem during the entire pregnancy
due to occupational
exposure of a
declared
pregnant
woman.
Licensee
procedure
RC-PD-07,
Embryo/Fetus
Exposure Monitoring, dated
December
28,
1992, establishes
the licensee's
program with respect to the aforementioned
requirements.
The inspector
noted that the provisions of the procedure
were consistent with
regulatory requirements
and
no concerns
were noted.
Since January
1993,
the licensee
stated that only one such declaration
had
been
made,
and
the inspector
noted that appropriate
documentation
was maintained.
The
individual had not received
any
1993 exposure
as of the time of the
onsite inspection.
Licensee representatives
stated that
no significant changes
had
been
made to the dosimetry program since the last inspection of this area in
September
1992.
The licensee
continued to utilize the Panasonic
UD-802
thermoluminescent
dosimeters
(TLDs) for measurement
of dose of record
and pocket ion chambers
(PICs)
as secondary
dosimeters
for daily dose
tracking.
Licensee representatives
stated that efforts to implement
digital alarming dosimeters
(DADs) were on-going.
Testing of various
products
had
been
completed with a recommendation
for
a specific vendor
expected
by July 1993.
Full implementation
was targeted for the next
refueling outage in 1994.
During observation of activities in the Auxiliary Building, Waste
Processing
Building, and the Fuel Handling Building, the inspector
observed
workers wearing personal
dosimetry devices
in accordance
with
licensee
procedural
requirements.
No concerns
were observed.
No violations or deviations
were identified.
Internal
Exposure Controls
(83750)
10 CFR 20.1204 states that for purposes of assessing
dose
used to
determine
compliance with occupational
dose equivalent limits, the
licensee,
when required to 'monitor internal
exposure,
shall take
suitable
and timely measurements
of concentrations
of radioactive
materials
in air, quantities of radionuclides
in the body, quantities of
radionuclides
excreted
from the body, or combinations of these
measurements.
When specific information on the behavior of the material
in an individual is known, that information may be used to calculate
the
Committed Effective Dose Equivalent
(CEDE).
a 0
Whole Body Counting
and Exposure Tracking
The inspector
reviewed
and discussed
the licensee's
program for
monitoring internal
dose.
Radiation Control
and Protection
Hanual,
Revision 21, dated April 1,
1993, states
that based
on
historical bioassay
data plant workers are not likely to exceed
10 percent of the annual
intake limits during routine operations;
therefore,
routine internal
exposure
monitoring is not required to
comply with 10 CFR 20. 1502(b).
However, the licensee's
program
continues to require periodic monitoring for internal
radioactivity.'he
program includes the follcwing:
(1)
Performance of an initial and termination bioassay;
(2)
Performance of a bioassay
on workers within 2 weeks of
completing work involving planned internal
exposures
when
exposures
exceeding
40 Derived Air Concentration-hours
(DAC-
hrs) could have
been received
based
on
a prospective
evaluation';
(3)
Performance of a bioassay
at least
once
each calendar year
for individuals permanently
assigned
dosimetry;
and
(4)
Performance of a bioassay
when conditions indicate the
intake of an appreciable
quantity of radioactive material
may have occurred.
Further,
the inspector noted that DAC-hrs would not be
individually tracked;
however,
discussions .with licensee
personnel
and review of the Radiation Control
and Protection
Manual revealed
that internal
and external
doses
are required to be
summed,
regardless
of the amount,
whenever
an individual is determined to
have
a measurable
body burden
due to licensed activities.
The
~
~
inspector
reviewed the licensee's
software to support the tracking
and
summation of doses.
Review of a test
case
by the inspector
noted that internal
and external
doses
were properly added to
determine
TEDE,
and
no concerns
were identified.
Licensee representatives
stated that no positive internal
contaminations
had
been identified to date in 1993; therefore,
no
determinations
of internal
dose or summing of doses
had occurred.
The inspector reviewed two internal contamination
events
which
occurred during the
1992 refueling outage.
The first event,
documented
in ACR 92-471,
occurred
on October 7,
1992, during
cavity drain down.
According to the licensee's
investigation,
the
event
was caused
by elevated
airborne radioactive material
(up to
54 percent of maximum permissible concentration)
due to the rapid
cavity drain down.
The licensee
performed whole body counts for
the affected workers
and determined
the maximum exposure to be
3. 10 Haximum Permissible
Concentration-hours
(HPC-hrs)
due to
Cobalt-58.
The other workers'xposures
were determined to be
less
than
1 HPC-hr.
Discussions
with licensee
representatives
determi'ned that implemented corrective actions
were effective in
preventing similar airborne problems during the subsequent
drain
down.
The second
event,
documented
in ACR 92-567,
occurred
on
November 3,
1992, during refueling operations.
The event
was
associated
with elevated
airborne concentrations
due to the
securing of the containment pre-entry purge
when
a high humidity
alarm was received.
During refueling operations,
RC was
identifying and monitoring increasing
airborne levels;
however,
they were unaware that the purge
had
been secured.
Refueling
workers were allowed to continue work during this period based
on
initial sampling data,
and HPC-hr tracking was initiated.
Upon
exit from containment,
the crew alarmed the personnel
contamination monitors
and subsequent
whole body analyses
were
performed.
For the four affected workers, the maximum exposure
was approximately
5 HPC-hours
due to Cobalt-58
and 60.
Based
on
the inspector's
review of the two events,
the licensee's
followup
and investigation activities appeared
appropriate,
and
no concerns
were noted.
Review of exposure files for selected
contractor
employees
associated
with Refueling Outage-4
(RFO-4) determined that the
licensee
was conducting initial and termination whole body
analyses
in accordance
with procedural
requirements.
No concerns
were noted.
Based
on the above evaluation,
the inspector concluded that the
licensee's
program for monitoring, assessing,
and controlling
internal
exposures
was conducted
in accordance
with regulatory
and
procedural
requirements
with no exposures
in excess of
10 CFR Part 20 limits identified.
No violations or deviations
were identified.
b.
Respiratory Protection
permits the licensee to maintain
and to
implement
a respiratory protection program that includes: air
sampling to identify the hazard;
surveys
and bioassay
to evaluate
the actual
intakes; testing of respirators for operability
immediately prior to each
use; written procedures
regarding
selection, fitting, issuance,
maintenance,
and testing of
respirators;
supervision
and training of personnel;
monitoring,
including air sampling
and bioassays;
and recordkeeping;
and
determination
by a physician prior to initial fitting of
respirators,
and at least every
12 months thereafter,
that the
individual user is physically able to use respiratory protective
equipment.
The inspector reviewed records for selected
individuals who were
issued respiratory protective equipment during the period from
January
1, to April 30,
1993, to verify that the licensee
was
conducting training to use respiratory equipment, fit-testing,
and
medical
examinations
in accordance
with regulatory
and procedural
guidance.
The inspector
noted that according to licensee
procedures
users of respiratory protective equipment required
training and fit-testing annually, with a 25 percent
An
NRC granted
exemption permitted the licensee to administer
physical
examinations
at an interval of every
9 to
15 months,
rather than annually,
provided that the total time over any three
consecutive
physical
examination periods did not exceed
39 months.
The inspector verified that for selected
records
reviewed users of
respiratory protective equipment
were appropriately trained, fit-
tested,
and medically qualified in accordance
with licensee
procedures.
No violations or deviations
were identified.
Control of Radiative Haterial
and Contamination,
Surveys,
and Honitoring
(83750)
a 0
Area and Personnel
Contamination
The licensee
maintained
approximately 460,000
square feet (ft') of
floor space
as radiologically controlled, excluding the
containment.
According to licensee
representatives,
for 1992, the
average daily contaminated
surface
area
was approximately
1,940 ft', as
compared to a ~oal of 3,500 ft'.
As of April 30,
1993,
approximately
1,750 ft of recoverabl.e
space
was being
tracked
by the licensee
as contaminated.
This represented
approximately 0.4 percent of the radiologically controlled area
(RCA).
10
For 1992, the licensee essentially
met their goal of 135
personnel'ontamination
events
(PCEs) with 38 skin contaminations
and
96 clothing contaminations.
Although the .goals for the year were-
met, the licensee
experienced
an increase
in PCEs during RFO-4*
activities.,
Approximately 99 events
occurred
as
compared to a
goal of 91 and
69 during RFO-3.
In general,
the activity
associated
with the events
was low; however,
a majority were
associated
with discrete particles.
The'licensee's
analysis of
the increasing trend during RFO-4 determined
the primary'particle
sources
to be products of the fuel reconstitution project,
steam
generator
work and the handling of associated
materials,
and cross
contamination of protective clothing.
Regarding the latter, the
licensee
performed
increased
surveys of laundered clothing,
segregated
materials,
and requested
that the vendor's laundry
monitoring setpoint
be lowered to 10,000
cpm (20,000 dpm/100 cm').
Following these actions,
improved performance
was observed,
and
licensee
representatives
stated that improved controls would be
evaluated for the
RFO-5 fuel reconstitution project.
In general,
the licensee's
evaluation
and follow-up actions
were considered
appropriate.
Through April 30,
1993,
approximately
13
had
occurred in 1993,
compared to an annual
goal of 60.
Review of selected
contamination
events
in detail
noted that the
licensee
documentation
and followup on the individual events
was
appropriate,
and skin dose
assessments
were performed,'hen
required.
For the reports reviewed, resultant
exposures
were
minor,
and
no concerns
were noted.
During facility tours, the inspector
observed
overall excellent
contamination control
and housekeeping
practices,
and the
licensee's
efforts with respect to this area continued to be
a
program strength.
No violations or deviations
were identified.
Posting
and Labeling of Radioactive Materials
TS 6. 11. 1 states that procedures for personnel
radiation
protection shall
be prepared
consistent
with the requirements
of
10 CFR Part 20 and shall
be approved,
maintained,
and adhered to
for all operations
involving personnel
radiation exposure;
Health Physics
Procedure,
HPP-800,
Handling Radioactive Materials,
Rev.
0, dated January
1,
1993, provides, instructions for
controlling material in RCAs.
Section 9. l.a. requires,
in
accordance
with 10 CFR 20.1904(a),
each container of radioactive
material with quantities greater than-those listed in
10 CFR Part 20, Appendix C, bear
a durable, clearly visible label
bearing
a radiation
symbol
and words "Danger,
Radioactive
Material" or "Caution, Radioactive Material."
The label
must
provide sufficient information,
such
as radiation levels,
radionuclides,
and
amount of radioactivity, to allow individuals
handling,
using, or working in the vicinity of such containers
to
take precautions
against
exposure.
Additionally, Section
6. 1.3.b.
of Attachment
13 requires
a completed
Radioactive Material
Tag to
be attached to the material
when removable contamination is
detected
at
a level greater
than
100 net counts per minute
(c~m)
for a survey area of approximately
100 square
centimeters
(cm ).
Section 6.5.2 of Attachment
13 requires tools
and scaffolding
having fixed contamination,
greater
than
100 net
cpm per probe
area,
to be marked with magenta paint if they are to be reused.
During tours of the licensee's facility, the inspector observed
equipment
in the East Hot Machine Shop,
a posted
Radioactive
Materials Area and Radiation Area, which was labeled
as
radioactive material,
and/or
bagged
as contaminated
radioactive
material,
and/or painted
magenta,
and/or identified as
uncontaminated
equipment.
The inspector requested
licensee
representatives
to survey two steam generator
manway stud
detensioners.
Both detensioners
were labeled with a small piece
of "Radioactive" tape.
Contamination
surveys revealed
200 to
1200
cpm fixed contamination,
and
a maximum of
6000 disintegrations
per minute per
a
100 square
centimeter
area
(dpm/100 cm') smearable
contamination
on one detensioner,
and
200
cpm fixed contamination with no smearable
contamination
on the
other detensioner.
Followup surveys of the remaining equipment in
the room, indicated that
an additional
nine items were
contaminated.
All nine items
had evidence of fixed contamination,
ranging from 1,000 to 90,000
cpm, while one item revealed
smearable
contamination,
with a maximum result of 3,000 dpm/100
cm'.
The inspector
informed licensee
representatives
that these
contamination levels were in excess of procedural limits and thus
a violation of HPP-800 which required control of radioactive
material
by tagging material with smearable
contamination or by
painting material with fixed contamination with magenta paint
(YIO:
50-400/93-11-01).
The inspector also noted,
during review of the assessment'reports
and observations,
as referenced
in Paragraph
4,
a recurring
concern with the licensee's
radioactive material control program.
Specifically, during assessment
report,
H-ERC-92-01,
conducted
during March 1992, the licensee identified deficiencies with
posting, labeling,
and subsequent
control of radioactive
materials.
Corrective actions did not appear to be effective in
that additional posting
and labeling deficiencies
and
inconsistencies
and deficiencies
in radioactive material
storage
areas
were identified during observations
and
NAD assessments
documented
in reports
H-OUT-92-01 and H-ERC-93-01.
Based
on the
recurrence
of these deficiencies,
the licensee
had initiated
ACR 93-186
on April 27,
1993, to address
the control of
radioactive material control from a broader perspective.
12
Also, during facility tours,
the inspector
observed
a pressurizer
relief valve in the Receiving
Warehouse
which was contained
in a
- yellow radioactive materials
bag,
placed within a posted
Radioactive Material Area, but did not have
a radioactive material
label.
Based
on licensee
followup, the inspector
was informed
that the valve was in temporary storage
in the Receiving
Warehouse.
The inspector
was also informed that no smearable
contamination
was detected
on the valve and the maximum detect'able
'adiation level
was 0. 1 mrem per hour (mrem/hr)
on contact.
However, the most recent isotopic. analysis of the valve indicated
(Co-60) activity was
6 microCuries (uCi).
The inspector
informed licensee
representatives
that this activity exceeded
10 CFR Part 20, Appendix
C limits of
1 uCi for Co-60
and was
a
violation of HPP-800 requirements for labeling with appropriate
exposure
reduction infor'mation.
Due to the licensee's
immediate corrective actions to properly
label the valve
and to initiate procedural
revisions to prevent
recurrence,
and minimal safety significance,
during the exit
interview on May 21,
1993, the inspector identified the violation
as
a non-cited violation (NCV) of 10 CFR 20. 1904(a) requirements.
However,
based
on
a followup review of this matter, it was
determined that due to the similarities of this violation and the
cited violation (page
as
a
NCV was not
appropriate.
Therefore this issue will be considered
as another
example of failure to properly handle radioactive material
in
accordance
with HPP-800 requirements
(VIO:
50-400/93-11-01).
One apparent
NRC-identified violation regarding multiple examples
of the licensee's
failure to properly handle radioactive material
in accordance
with licensee
procedure,
HPP-800,
was identified.
Program for Maintaining Exposures
As Low As Reasonable
Achievable
(83750)
states
each licensee
shall
use, to the extent
practicable,
procedures
and engineering controls
based
upon
sound
radiation protection principles to achieve occupational
doses
and doses
to members of the public that are
The inspector reviewed
and discussed
with cognizant licensee
representatives
ALARA program implementation
and initiatives for RFO-4
and routine operations.
For the year
1992, the site collective dose
was
213.150 person-rem,
just below the annual
dose goal of 215 person-rem.
This was the first time that Harris had met its annual site goal,
and
reflected 21.5 rem for normal operations,
7.6 rem for the spent fuel
program,
146.3
rem for outages
and special projects,
and 37.8 rem for
steam generator life extension.
For RF0-4, the licensee
expended
approximately
173.7 person-rem
which
was
above the outage
goal of 165 person-rem;
however, this exposure
was
less than the approximately
181 person-rem
estimated
through the
T
13
job evaluation
process.
In addition, the outage
was extended
by 26 days
due to the need to replace auxiliary feedwater. piping as determined
during in-service inspections.
The inspector reviewed the
RFO-4 ALARA
Outage
Report
and discussed
in detail several
dose intensive job
evolutions including: steam generator
tube pulls, alternate mini-flow
redesign,
auxiliary feedwater piping replacement,
pressurizer
surge line
hanger modification,
and general
steam generator activities.
For the
former three activities listed, approximately
15 person-rem
was
,attributed to expanded
work scope.
The inspector also noted that the
licensee's
dose performance for repetitive outage tasks
continued to
trend downward;
however,
the dose for general
and cavity decontamination
activities was significantly higher than previous outages with
approximately
14.5 person-rem
expended.
According to the licensee
the
dose
was attributable,
in part, to the use of a new strippable coating
which was inadequate,
a too rapid cavity drain
down resulting in
airborne contamination,
and inadequate
spray equipment.
The licensee
had developed
a comprehensive
outage report which appropriately
.
addressed
the lessons
learned
and strengths, associated'ith
the work
activities.
At the time of the onsite inspection,
the resultant action
items were being entered into the licensee's
corrective actions
program
for resolution prior to the next outage.
Overall, the inspector
concluded that the dose
expended for the outage
was consistent with the
work performed
and improvements
areas
were being adequately
addressed.
For 1993, the licensee
had established
a dose goal of 45 person-rem.
As
of April 30,
1993, approximately nine person-rem
had
been
expended.
The
inspector discussed
in detail on-going material
upgrade
and painting
activities which had the potential to be
a major contributor to routine
doses.
At the time of the inspection,
approximately eight person-rem
was estimated
to complete work on the
190 South elevation of the
Auxiliary Building with projected
exposure for 190 North elevation work
expected to be higher.
ALARA personnel
were closely monitoring this
evolution to the ensure
unnecessary
exposures
are minimized.
Overall,
the inspector
observed that the
ALARA function was involved in day-to-
day activities
and
had provided .an increased
focus
on routine,
operational
doses.
The inspector discussed
with ALARA personnel
specific dose reduction
activities implemented
as well as those
planned for RFO-5.
Particular
items of note included the use of teledosimetry for steam generator
work, extensive
use of cameras for remote observation,
use of innovative
shielding for the pressurizer
surge line modification, maintenance
of
water levels during auxiliary feedwater piping
replacement,
worker mockup activities,
and
a shielded work station for
resin transfer
operations.
The licensee
stated that resistance
temperature
detector
(RTD) bypass
removal
was planned for RFO-5
and
planning
had already
begun.
Other ongoing
ALARA activities included
purchase of'
surrogate tour system,
additional video
and communications
equipment,
and shielding
as well as the identification of cobalt
containing valves.
~
is
14
9
Based
on the above,
the inspector
informed licensee
representatives
that
the
ALARA program appeared
to be effective .in reducing overall
collective dose,
and was considered
a strength to the overall radiation
protection
program.
No violations or deviations
were identified.
Exit Interview (83750)
The inspection
scope
and results
were summarized
on Hay 21,
1993, with
th'ose
persons
indicated in Paragraph
1 above.
The general
program areas
reviewed
and the inspection findings were discussed
in detail.
Licensee
representatives
acknowledged
the inspector's
comments
and
no dissenting
comments
were received.
The licensee
was informed that although
proprietary information was reviewed during this inspection,
such
material
would not be included in the report.
Item Number
Descri tion and Reference
50-400/93-11-01
VIO - Failure to comply with procedure,
HPP-800,
requirements for properly handling radioactive
materials
(Paragraph
7.b).