ML18011A436
| ML18011A436 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/28/1994 |
| From: | Rankin W, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18011A435 | List: |
| References | |
| 50-400-94-07, 50-400-94-7, NUDOCS 9405200279 | |
| Download: ML18011A436 (31) | |
See also: IR 05000400/1994007
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
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Report No.:
50-400/94-07
Licensee:
Carolina
Power and Light Company
P.O.
Box 1551
Raleigh,
NC 27602
Docket No.:
50-400
License No.:
Facility Name:
Shearon Harris
Inspection
Conducted:
March 28 - April 1,
1994
Inspector:
F.
N. Wright
Accompany Personnel:
W. T.
Loo
+
Dat
Sig
ed
E
App
d ty:~~
D(
W. H. Rankin, Chief
ate
igned
Facilities Radiation Protection Section
Emergency
Preparedness
and Radiological
Protection
Branch
Division of Radiation Safety, and Safeguards
SUMMARY
Scope:
This routine,
announced
inspection of the licensee's
radiation control
program
involved
a review of health physics activities primarily associated
with the
. current Unit
1 refueling outage
number five.
The specific areas
evaluated
included audits
and appraisals;
changes
to the radiation protection program;
planning
and preparation; training and qualifications of personnel;
external
and internal
exposure controls; control of radioactive material
and
contamination,
surveys
and monitoring;
As Low As Reasonably
Achievable
(ALARA)
program implementation;
and the licensee's
response
to previously identified
inspection findings.
In addition, the implementation of the
new
10 CFR Part 20 requirements
was
evaluated utilizing Temporary Instruction (TI) 2515/123
"Implementation of the
Revised
The review focused primarily on the areas of high
and very high radiation areas,
declared
pregnant
women,
planned special
exposures,
and total effective dose equivalent
ALARA program implementation.
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Results:
Based
on interviews with licensee
personnel,
records
review,
and observation
of work activities in progress,
the inspector
found that the Radiation Control
program adequately
protected
the health
and safety of plant workers.
With respect to the revised
10 CFR Part 20 focus areas
reviewed,
appropriate
incorporation of the requirements
into procedures
and training programs
was
noted.
Significant improvements
in the licensee's
labeling
and control of
contaminated
and radioactive material
were observed
from previous inspections.
Radiation protection
program audits evaluated quality aspects
of the program
and were
a program strength.
ALARA activities appeared
to be receiving strong
management
support
as
evidenced
by personnel
resources
committed to the program,
purchase
and
contracts of equipment beneficial
in dose reductions
and the use of incentives
for ALARA program participation
and dose reduction performance.
Two non-cited violations
(NCVs) were identified:
1) Failure to post
radiological control
areas
in accordance
with licensee
procedures
(Paragraph
6.d);
and 2) Failure to control
and store contaminated
or
radioactive material
in accordance
with licensee
procedures
(Paragraph
10.b).
~ ~
0
REPORT DETAILS
Persons
Contacted
Licensee
Employees
V. Ballard, Training Senior Specialist
- A. Barbee,
Training Senior Specialist
- N. Bertrand,
General
Employee Trainer
- D. Braund, Security Hanager
- J. Bryan, Simulator Manager
- B. Christiansen,
Maintenance
Manager
- T. Cockerill, Nuclear Engineering
Department
- J. Collins, Training Manager
- J. Dobbs,
Outages
Manager
- J. Floyd, Senior
ALARA Specialist
- J. Gurganious,
Environmental
and Chemistry Manager
- H. Hamby, Corrective Action Program/Operational
Experience
- H. Hill, Harris Plant Assessment
- J. Kiser, Radiation Control
Manager
- C. Neuschaefer,
Nuclear Assessment
Department
- L. Woods,
Technical
Support
Manager
- H. Palmer,
Acting Work Control
Manager
- J. Pierce,
Training Manager,
- B. Pruty, Licensing
and Regulatory Projects
Manager
- A. Powell, Operations
Manager
- B. Robinson,
Site Vice President
- C. Schnell, Audit Services
- S. Simerly, Materials
and Contracts
Manager
- G. Sinders,
Nuclear Regulatory
Issues Director
- D. Tibbitts, Operations
Manager
H. Wallace,
Senior Regulatory
Compliance Specialist
B. White, Environmental
and Radiation Control
Manager
- E. Willis, Radiation Control Supervisor
Other licensee
employees
contacted
during the inspection
included
technicians,
maintenance
personnel
and administrative personnel.
Nuclear Regulatory
Commission
- D. Roberts,
Resident
Inspector
- P. Stohr, Division Radiation Safety
and Safeguards
Director
- J. Tedrow, Senior Resident
Inspector
"Attended March 31,
1994 Exit Meeting
Abbreviations
used throughout this report are defined in the last
paragraph.
2.
Audits and Appraisals
(83750)
Licensee activities, audits,
and appraisals
were reviewed to determine
the adequacy of identification and corrective action programs for
deficiencies
or weaknesses
related to the control of radiation or
radioactive material.
10 CFR 20. 1101(c) requires that the licensee periodically review the
radiation protection
program content
and implementation at least
annually.
The licensee's
independent
audits
and appraisals
in the radiation
control area consisted of formal audits per TS requirements,
documented
observations
and specific surveillance.
A qualified auditor with
significant health physics
and chemistry qualifications
and experience
was assigned
to the station to implementing the licensee's
assessment
activities.
a ~
Assessment
The licensee
had performed
one required audit in the radiation
protection
program area since the previous inspection
conducted
in
Hay 1993.
The radiation protection audit H-ERC-94-01
"HNP
Environmental
and Radiation Control Assessment,"
was performed
February 2-11,
1994.
The report was issued
Harch 1,
1994.
The inspector reviewed the scope,
objectives
and checklist for the
annual radiation control audit
and determined that the audit plan
was adequate for program assessment.
The assessment
team for the
annual
E&RC assessment
included:
the site's
RC auditor;
a
RC
specialist
from another nuclear facility and four auditors with RC
qualifications from other licensee sites
and the corporate office.
The assessment
identified strengths
in the radioactive waste
disposal
program
and weaknesses
in E8RC management
controls in
addressing
problems identified at other
CP&L sites
and ineffective
use of corrective action program by the
E&RC unit for program
deficiencies.
An ACFR was assigned
to each
element of the
findings.
The inspector
discussed
the issues with the
E&RC staff
and reviewed the proposed corrective actions for the findings with
the site's
NAD auditor for E&RC activities.
The proposed
corrective actions
appeared
appropriate for the findings.
In addition to, verifying applicable radiological protection
program requirements
were being appropriately
implemented
and
maintained,
the
NAD assessment
of the
E&RC programs identified
findings related to the quality aspects
of the
E&RC program.
The
findings reflected
awareness
of the "big picture"
and the
importance of quality improvement activities,
such
as self-
identification of problems
and effective corrective actions,
which
could improve the overall effectiveness
of the site's radiation
protection
program.
The findings were indicative of very good
program assessments.
No concerns
were noted.
b.
Corrective Actions
The licensee
maintained
a corrective action system,
"Adverse
Conditions
Feedback
Report," that was accessible
to employees
utility-wide.
The system provided
a means for identifying,
tracking,
and trending adverse
conditions.
The significance of
each
item entered into the system
was determined
and characterized
as
a level one,
two, three or four ACFR.
The findings of the most
recent radiation protection audit indicated that problems
identified by the Harris staff or at another
CP&L facility were
not being reviewed in such
a manner to cause timely and effective
corrective actions to prevent recurrence.
NAD personnel,
interviewed during the inspection,
reported that the
E&RC staff
had recently increased
use of the corrective action system.
A
list of the ACFR's initiated by the
E&RC staff in 1994 included
more than fifty items of various problems.
Increased
use of the
corrective action system
by the
E&RC staff indicated the self
identification and documentation of adverse
conditions
by the
E&RC
staff was improving.
No concerns
were noted.
C.
Self-Appraisals
The licensee
was preparing
a formal program for unit self-
assessments.
The program
had not been
implemented
and the
individual units were in the process of preparing
implementing
procedures
for the activity.
The licensee
planned to start the
self-assessment
program during the fourth quarter of 1994.
No concerns
were noted.
Changes
(83750)
Changes
in organization,
personnel, facilities, equipment,
programs
and
procedures,
from the previous inspection,
were reviewed to assess
their
impact on the effective implementation of the occupational
radiation
protection program.
'a ~
Organization
and
Management
Controls
By observation
and discussion with cognizant supervisory
and
management
personnel,
the inspector
reviewed
changes
made to the
licensee's
organization,
staffing levels,
and lines of authority
as they relate to radiation protection.
The licensee
had not made
any significant organizational
changes
to the
RC unit since the previous inspection.
The radiation
protection staff consisted
of approximately
46 persons
with all
job coverage
personnel
being ANSI-qualified.
The
E&RC Group did
have
one staff vacancy,
Environmental
Supervisor,
of which the
licensee
was in the process
of filling.
Eighty two personnel,
including
HP technicians
(sixty senior
and fifteen junior HP technicians)
and administrative
support
personnel,
had been contracted to support radiation control
activities for the refueling outage.
No concerns
were noted.
Equipment
and Facilities
The licensee
had recently purchased
small
HEPA filtration units
that can
be carried
by an individual.
The licensee
reported that
the units
had
been
used
and
had provided satisfactory results.
The licensee
began
using
DADs in place of SRPDs
on February
14,
1994, for daily personnel
exposure monitoring.
The implementation
of the
DADs is discussed
Paragraph
5.a of this report.
No concerns
were noted.
Policy and Procedures
The licensee
continued to work on defining the policies for the
control
and labeling of containers
containing contaminated
and
radioactive materials.
The
E&RC staff was also developing
a self-assessment
procedure to
implement
a new plant requirement for each unit to develop
an
annual
self-assessment
plan
and conduct quarterly self-
assessments.
No concerns
were noted.
Goals
The licensee
was able to contract sufficient personnel
and
equipment to work some outage task in parallel
and
was able to
reduce the length of the outage plan by ten days.
The outage
dose
goals were reduced
from 230 person-rem to 198 person-rem.
A
discussion of the
ALARA exposure
goals is included in Paragraph
11
of this report.
No concerns
were noted.
e.
Management
Controls
In the previous refueling outages,
the outage planning group
was
responsible for planning
and directing the implementation of the
outage
plan through the various plant staffs.
In RFO-5, the
regular plant management staff assumed
more involvement
and the
primary responsibility in directing
and implementing outage
activities.
The objective was to increase
ownership
and
responsibility of outage activities by directly involving plant
management
and staff,
as teams,
in implementing those
outage
activities.
To implement the plan the licensee
assembled
four
outage shifts or teams to direct and control outage activities.
Since the outage
was ongoing
and observed
by the inspector during
the initial weeks of the outage the effectiveness
of the plan was
not determined.
No concerns
were noted.
Planning
and Preparation
(83750)
Licensee activities
and documents
were reviewed to determined
the
adequacy of management
and staff efforts in planning
and preparation of
radiation work.
At the time of the inspection,
the licensee
was in the second
week
(days
10-14) of a 45 day refueling outage that began
March 19,
1994.
The licensee
was able to cut
10 days off of the length of the outage
plan by contracting additional
personnel
and equipment
resources
that
would permit work on the
RTD removal project
and the inspection
and
maintenance
of the three
simultaneously.
The licensee's
radiological control planning for RFO-5 included the
following:
involvement of ALARA personnel
in the early stages
of the
outage planning; evaluations of RTD removal activities at other
facilities to determined
an acceptable
removal
process;
providing ALARA
training to site staffs prior to the outage
which incorporated
lessons
learned in previous refueling outages;
increasing
the
RC staff by
82 contract persons; utilization of mock-ups for steam generator
and
replacement
projects;
developing
ALARA work plans for all jobs having
a
collective dose greater
than I rem;
and utilization of remote monitoring
equipment to reduce
personal
exposures.
Other ALARA activities are
discussed
in Paragraph ll of this report.
The
E&RC supervisory
and
management
personnel
maintained
24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> supervision of radiation
protection activities to monitor implementation of the outage plan.
The
inspector determined that there
was adequate
management
support for
planning
and implementing effective radiological control measures
for
the refueling outage.
No concerns
were noted.
Training and gualifications
(83750)
Training and qualifications were reviewed to determine
whether
contractor
HP technicians
were qualified in accordance
with the
licensee's
standards
and procedures,
that radiation workers were
receiving appropriate
instructions for their work assignments
and that
the licensee
had incorporated
the changes
of 10 CFR Part 20, Standards
for Protection Against Radiation,
in the various training programs.
.
10 CFR 19. 12 required that licensees
instruct all individuals working or
frequenting
any portion of the restricted
areas
in the health protection
aspects
associated
with exposure to radioactive material or radiation,
in precautions
or procedures
to minimize exposure,
and in the purpose
and function of protection devices
employed,
applicable provisions of
the Commission Regulations,
individuals responsibilities
and the
availability of radiation exposure
data.
a ~
General
Employee Training
The inspector
reviewed selected
lesson
plans for GET initial and
retraining
and noted that the training material appropriately
included
an introduction to revised
10 CFR Part 20 terminology,
definitions,
and regulatory limits.
The training program was
divided into two areas,
GET Level I and
GET Level II.
GET Level I
training generally
was taught in a two and
a half day course with
a 50 question
exam given with a passing
grade of 80 percent.
Topics included the licensee's
Fitness-for-Duty program, plant
security, industrial safety,
chemical control program,
emergency
preparedness,
and fundamentals
of radiation safety.
GET Level II
training generally
was taught in a half day course with a 50 exam
question
given with a passing
grade of 80 percent.
Topics
included more specific areas of radiation protection
such
as
biological effects of radiation, radiation area posting
and
control methods,
ALARA concept,
contamination
areas
and control
measures,
and radiation work permits.
In the event
an individual
did not pass the retraining program
exam the first time, that
person
would review the self study guide
and retake the test
on
another
day.
If that individual did not pass the
exam
a second
time, that person
would have to go through the initial program
again.
The licensee
implemented
the use of a new
DAD dosimeter
system
on
February
14,
1994.
A few months prior to implementing the
new
system the licensee
incorporated
a videotape,
developed
by the
DAD
manufacturer,
into the
GET program to provide information on
proper
DAD use for the radiation'orkers.
Licensee
and contractor
personnel
receiving
GET training following that date received
instruction
on the
new
DAD system.
The training department
also
presented
the videotape
at the safety meetings
held during January
and February of 1994.
The training was provided for those
employee's
that
had not recently attended
a
GET training class.
NAD auditors believed that the method of training utilized at the
Harris site
had not been
as well planned
and implemented
as the
utility's other sites
and identified the
DAD training process
at
Harris as
an adverse
condition in a recent audit.
The inspectors
observed
personnel utilizing the equipment
on several
occasions
and
had not identified any specific problems with worker knowledge
or use of the
DADs.
The
RC staff maintained
personnel
in the area
to assist
any persons that might have
had
a question
or problem
with the equipment.
No concerns
were noted.
Radiation Control Technician Training
The inspector
reviewed continuing training presented
to the
RCTs.
The inspector
noted that since
Nay 21,
1993,
the licensee
had
conducted
two continuing training sessions
for RC personnel
for
the third and fourth quarter
1993.
Because of the ongoing outage
no continuing training was conducted for the first quarter
1994.
The inspector noted that the training material
included
a review
of industry events,
hazardous
materials,
ALARA activities at the
facility, various plant systems,
and emergency
response.
The inspector also discussed
with licensee
representatives
their
methods for receiving
and incorporating feedback
and plant needs
into the training program.
The inspector noted that the licensee
accomplished this through the use of a
PPH which met once
a year
to review radiation protection training.
The
PPH received
feedback
from the
RC staff on what topics should
be discussed
and
developed
a schedule for the next four quarter.=, to include the
topics to be discussed.
However,
due to changes
in previous
schedules
of topics to be discussed,
starting in 1994, the
PPH
would meet every quarter to develop
a training schedule for
topics.
This would ensure that current topics,
issues
and other
industry events
could be reviewed during that quarter of training.
In addition, through discussions
with licensee training
representatives,
the inspector determined that training
representatives
attended
the
RC weekly meetings to ensure that
areas of concern
addressed
at these
RC weekly meetings
could be
incorporated into the continuing training program.
No concerns
were noted.
Contractor Radiation Control Technician gualifications
The inspector
reviewed training records
and qualifications
(resumes)
for selected
RC contractor technicians
involved in RFO-5
activities.
For the records
reviewed,
the inspector determined
that the contractor technicians
met or exceeded
qualifications
and
had completed
GET, indoctrination training,
examinations,
and procedural
reviews in accordance
with procedural
requirements.
No concerns
were noted.
d.
Implementation of New 10 CFR Part 20 Requirements
in Training
Programs
The inspector
reviewed various aspects
of the licensee's
training program with respect to incorporation of information
related to implementation of the revised
In
addition,
the programs
were evaluated for any changes
implemented
since the last inspection of this area
conducted
Hay 17-21,
1993,
and documented
in IR 50-400/93-11.
The inspector
reviewed
Lesson
Plan
TM6COIG, "10 CFR 20 Overview," dated
June
26,
1992,
and noted
that topics included changes
to the revised
new
ALARA initiatives, Declared
Pregnant
Women,
new
terminology,
changes
with regards to the use
and selection of
respirators,
and Very High Radiation Area posting.
The inspector
noted that
no significant changes
had
been
made to the
RC related
training program since this area
was last reviewed.
The inspector
informed licensee
representatives
that their
training program for both general
employees
and licensee
RC
technicians
appeared
to adequately
address
the facility's
procedural
changes
associated
with the revised
requirements
and
no concerns
were noted with the training
material.
No concerns
were noted.
External
Exposure Control
(83750)
and (TI 2515/123)
This area
was reviewed to determined
whether personnel
dosimetry,
administrative controls,
and records
and reports of external radiation
exposure
met regulatory requirements.
'a ~
Personnel
Dosimetry
requires
each licensee to monitor occupational
exposure to radiation
and supply and require the use of individual
monitoring devices for:
(1)
Adults likely to receive,
in one year from sources
external
to the body,
a dose in excess of 10 percent of the limits in
(2)
Hinors and declared
pregnant
women likely to receive,
in one
year for sources
external
to the body,
a dose in excess of
10 percent of any of the applicable limits of 10 CFR 20. 1207
or 10 CFR 20.1208;
and
(3)
Individuals entering
a high or very HRA.
The licensee's
personnel
dosimetry program was
NVLAP accredited
in
all eight categories.
Based
on direct observation,
discussion
and
review of records
personnel
dosimeters
were being effectively
utilized.
The dose tracking system
RIHS tracked personnel
exposures
in order to ensure
adherence
to procedural
administrative
allowances
as well as
10 CFR Part 20 limits.
RIHs
was also utilized to monitor worker qualifications for planned
activities.
The licensee
reported that there
had not been
any
personnel
administrative limits over exposures
since the last
inspection.
the inspector
reviewed personnel
exposure
reports
and
noted that there were
no personnel
doses
near administrative
limits.
No concerns
were noted.
b.
Administrative Controls for External
Exposures
10 CFR 20. 1201(a) requires
each licensee to control the
occupational
dose to individual adults,
except for planned special
exposures
under
10 CFR 20.1206, to the following dose limits:
(1)
An annual limit, which is the more limiting of:
(i)
The total effective dose equivalent
being equal to
5 rems;
or
(ii)
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:
(i)
An eye dose equivalent of 15 rems;
and
(ii)
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 contract personnel
for the period
June,
1993 through Harch,
1994.
Through review of dose
information, the inspector confirmed that all whole body exposures
assigned
during the period were within 10 CFR Part 20 limits.
10
The inspector
reviewed selected
RWPs for their work activity and
determined that they appeared
to prescribe
adequate
radiation
protection requirements
for the assigned
task.
The inspector
observed
plant workers being interviewed
by the
RCTs at the main
control points.
RCTs were asking workers appropriate
questions
to
determined
the nature
and
scope of the worker's specific task.
RCTs would review recent radiological
survey information and
discuss
the radiological
hazards that might be encountered
by the
workers
and provided appropriate radiological protection coverage
and guidance for the work.
The inspector
observed
personnel
reviewing
and logging into DADs dose tracking system.
The inspector
observed
RCTs in the plant monitor worker activities
in their assigned
locations,
make radiation
and contamination
surveys
and advise workers
on appropriate radiological protection
procedures.
The licensee
was using telemetric dosimetry,
communication
equipment
and video cameras
to monitor several
jobs planned inside
containment.
The equipment permitted radiological protection staff
personnel
the ability to monitor live time dose
and dose rates
in
low dose areas.
Other licensee efforts to reduce the sources of
external radiation levels are discussed
with licensee
ALARA and
radiation protection personnel
throughout the inspection
and are
discussed
in Paragraph
11 of this report.
No concerns
were noted.
Licensee
TS required,
in part, that each
HRA with radiation levels
greater
than or equal to 100 mrem/hr but less
than
1000 mrem/hr
be
barricaded
and conspicuously
posted
as
a HRA.
In addition,
any
individual or group of individuals permitted to enter
such
areas
were to be provided with or accompanied
by a radiation monitoring
device which continuously indicated the radiation dose rate in the
area or a radiation monitoring device which continuously
integrated
the dose rate in the area,
or an individual qualified
in radiation protection procedures
with a radiation dose rate
monitoring device.
During tours of the Auxiliary, Waste Processing,
Containment,
and
the Fuel Handling Buildings the inspector
noted that all
HRAs were
locked and/or posted
as required.
During discussions
with
licensee representatives,
the inspector determined that the
RC
Shift Supervisor for the
BOP maintained
a shift turnover logbook.
During each shift turnover, the
RC Shift Supervisor would conduct
an inventory for each of the Locked
HRA keys for accountability
and control.
The keys to each of the Locked
HRAs were maintained
0'%
k
11
in a locked box on
a wall in the
RC work area.
In addition, the
licensee
maintained
records for each time
a Locked
HRA key was
checked
out and in to ensure
adequate
key control for the Locked
HRAs.
No concerns
were noted.
Posting
and Labeling
During tours of the plant
and selected
outside radioactive
material
storage
areas,
the inspector noted that the licensee's
posting
and control of radiation areas,
airborne radioactivity areas,
contamination
areas,
radioactive
material
areas,
was generally
adequate.
TS 6. 11. stated 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.
Section 8.5. 1,
of the Radiation Control
5 Protection
manual,
Revision 22, dated
December
20,
1993, required that contaminated
area controls
be
applied to an area
where removable contamination
was in excess of
1,000 dpm/100 cm'eta-gamma.
Additionally, Section 7.6.5 of the
RCKPH required
"Each area meeting the definition of a contaminated
area shall
be conspicuously
posted with signs bearing the
radiation
symbol
and the words: "Caution Contaminated
Area."
The
inspector
conducted tours in the licensee's
Auxiliary Huilding on
Narch 29,
1994,
and discovered that
a set of doors from a
containment penetration
room on the
236 foot elevation to
a
containment
access
area
was barricaded with radiation rope
and
posted with a sign containing the "radiation symbol" and "Caution
No Entry."
The inspector determined that the double doors were
not locked
and when opened the inspector could see into the
containment
personnel
access
airlock portal.
The inspector
determined that radiation posting for the
same
area but adjacent
to the
SOP identified the area
as
a contaminated
area
and
radiation area.
The inspector reported the posting discrepancy to
the
RC technicians controlling access
to containment
and reported
that all boundaries
into the containment
access
area
needed to be
posted to identify the radiological conditions within the
controlled area.
The penetration
area
was
a radiation area
and it
did not appear that posting
an additional radiation area sign at
the double doors
was need.
However, the inspector stated that
posting the area
as
a contaminated
area
was required
and the
licensee
posted the area
as
a contaminated
area.
A similar
problem was identified by the inspector for a ladder
on the
261 foot elevation of the fuel handling building leading to a
mezzanine
area.
The ladder
had
a sign containing the "radiation
symbol"
and "Caution
No Entry."
Licensee
personnel
reviewed the
radiological conditions of the area
and
added
a "Radiation Area"
insert to the sign.
The inspector stated that failure to post the
12
areas
as
a contaminated
area or radiation
area
appeared
to be
a
violation of the licensee's
posting procedures.
Licensee
corrective action for the violation included correcting the
posting
and documenting the issues
in the
ACFR corrective action
system.
This
NRC identified violation is not being cited because
criteria specified in Section VII.B of the Enforcement Policy were
satisfied.
NCV 50-400/94-07-01:
Failure to post radiological control
areas
in accordance
with licensee
procedures.
A violation for failure to control radioactive material
was
identified as
a violation (50-400/93-11-01)
of licensee
procedures
during
a previous inspection in May 1993.
The violation concerned
failure to label or tag contaminated
or radioactive material
in
radiological controlled areas.
The licensee's
controls of
radioactive materials
was closely examined throughout this
inspection during tours of the facilities.
In general,
the
inspector determined that the licensee
had
maae substantial
improvements
in the control
and labeling of contaminated
and
radioactive material
from the previous inspection.
No additional
examples of failure to tag or label contaminated
or radioactive
material
were identified by the inspector.
However, the inspector did find an item tagged
as radioactive
material that was not stored in a radioactive material
storage
area
as required
by licensee
procedures.
A discussion
of the
issue is included in Paragraph
10.b. of this report.
One
NCV was identified.
Internal
Exposure Control
(83750)
This area
was reviewed to determined
the adequacy of licensee's
use of
process
and engineering controls to limit exposures
to airborne
radioactivity,
adequacy of respiratory protection program, licensee's
administrative controls for assessing
the total effective dose
equivalent in radiation
and airborne radioactive materials
areas,
assessments
of individual intakes of radioactive material
and records of
internal
exposure
measurements
and assessments.
'a ~
Use of Process
or Engineering Controls
The use of process
and engineering controls to limit airborne
radioactivity concentrations
in the plant were discussed
with
licensee
representatives
and numerous
use of such controls were
observed
during tours of the plant.
No concerns
were noted.
13
Respiratory Protection
Program
Requirements for TEDE/ALARA reviews were addressed
in
Section 7.8.2 of the
RCLPH and licensee
procedure
PLP-510,
"Respiratory Protection
Program," Revision 5, effective January
1,
1993.
The procedure
required
ALARA evaluations
to be performed
and documented
by
RC prior to performing work in airborne
radioactivity areas
to demonstrate
that respiratory protection
provisions
are consistent
with the goal of maintaining individual
and collective total effective dose equivalent
The
inspector
reviewed licensee
records of ALARA reviews for
respirator
usage
and verified that the procedures
were being
implemented.
/
Through discussions
with licensee
representatives,
the inspector
determined that for the year
1993,
approximately
946 respirators
had
been
used.
For the year
1994 to present,
the licensee
had
used approximately
254 respirators.
For the refueling outage in
progress,
the licensee
had
used
193 respirators.
Hased
on those
reviews
and discussions
with licensee
representatives,
the
inspector determined that the licensee
had
made efforts to
maintain
TEDE exposures
No concerns
were noted.
Internal
Exposure
Assessments
10 CFR 20. 1204 stated 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
CEDE.
The inspector
reviewed
and discussed
the licensee's
program for
monitoring internal
dose.
RCB,PM, Revision 22, dated
December
20,
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.
The program includes the
following:
(1)
(2)
Performance of an initial and termination bioassay;
Performance of a bioassay
on workers within 2 weeks of
completing work involving planned internal
exposures
when
exposures
exceeding
40 DAC-hrs could have
been received
based
on a prospective
evaluation;
0
P
e ')
(3)
(4)
Performance
of a bioassay
at least
once
each calendar year
for individuals permanently
assigned
dosimetry;
and
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
RCPH revealed that internal
and external
doses
were required to be
summed,
regardless
of the amount,
whenever
an
individual was determined to have
a measurable
intake
and
exposure.
The inspector reviewed the results of assessments
for personnel
having indications of positive intakes of radioactive material.
No problems
were found during
a review of the procedure
or of
selected
bioassay
records.
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.
s.
No concerns
were noted.
Planned
Special
Exposures
(83750)
and (TI 2515/123)
This area
was reviewed to determined
whether the licensee's
program for
planned special
exposures
met the regulatory requirements.
10 CFR 20. 1206 permits the licensee to authorize
an adult worker to
receive
doses
in addition to and accounted for separately
from the doses
received
under the limits specified in 10 CFR 20. 1201 provided that
certain conditions are satisfied.
Such exposures
cannot
exceed
the dose
limits in 10 CFR 20. 1201(a) in any year or five times the annual
dose
limits during
an individual's lifetime.
Section
6. 10 of the licensee's
RC&PH, Revision 22, states
the
CPKL
policy on planned special
exposures.
Specifically,
the utility states
that it will not utilize the planned special
exposure
provisions of
10 CFR Part 20 to allow individuals to receive
dose in excess
of annual
dose limits.
Discussions with licensee
personnel
noted that in light of
the policy no procedures
had
been developed
at the Harris plant for
implementation of this aspect of the
new
10 CFR Part 20 regulations.
No concerns
were noted.
9.
Dose to the Embryo/Fetus
and Exposures of Declared
Pregnant
Women
(83750)
and (TI 2515/123)
This program area
was reviewed to determine that the licensee's
program
for Declared
Pregnant
Woman met the regulatory requirements
and that the
dose to the embryo/fetus
were within the regulatory limits.
'I
0
15
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.
Section 6.3 of the
RCLPH and Procedure
RC-PD-07,
"Embryo/Fetus
Exposure
Honitoring," detailed the licensee's
program
and policies regarding
declaration of pregnancy
as well as exposure
monitoring and dose limits
for the declared
pregnant
woman
and embryo/fetus.
The inspector
noted
that the procedures
were consistent
10 CFR Part 20 requirements
and
Regulatory
Guide provisions.
The inspector
reviewed the documentation
for the three declarations
made in 1993.
No concerns
were noted with
the licensee's
declared
pregnant
woman policy or procedures.
No concerns
were noted.
10.
Control of Radioactive Haterials
and Contamination,
Surveys,
and
Honitoring (83750)
This program area
was reviewed to determine
whether survey
and
monitoring activities were performed
as required
and control of
radioactive materials
and contamination
met requirements.
'a ~
Surveys,
Personnel
Honitoring,
and Instrumentation
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.
During tours of the plant, the inspector noted that portable
radiation detectors,
air samplers,
friskers,
and contamination
monitors
had up-to-date calibration stickers
and
had
been source-
checked
as required.
In addition, the licensee
appeared
to
possess
an adequate
number of survey instruments
and related
equipment.
No concerns
were identified.
The inspector reviewed selected
records of routine
and special
radiation
and contamination
surveys
performed during the current
refueling outage
and discussed
the survey results with licensee
representatives.
During tours of the plant, the inspector
observed
HP technicians
performing radiation
and contamination
surveys.
The inspector
independently verified radiation and/or
contamination levels in selected
areas of the containment,
auxiliary, waste processing,
and fuel handling buildings.
No
concerns with the adequacy
or frequency of the radiological
survey
activities were identified.
No concerns
were noted.
16
Control of Contamination
and Radioactive Material
10 CFR 20. 1904(a) requires
the licensee to ensure that each
container of licensed material
bears
a durable, clearly visible
label bearing the radiation
symbol
and the words "Caution,
Radioactive Material," or "Danger,
Radioactive Material."
The
label
must also provide sufficient information (such
as
radionuclides
present,
and the estimate of the quantity of
radioactivity, the kinds of materials
and mass
enrichment) to
permit individuals handling or using the containers,
to take
precautions
to avoid or minimize exposures.
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.
Section 5.6. 1 of PLP-511,
"Radiation Control
and Protection
Program," requires that radioactive material
and contamination
control measures
be established
to minimize the spread of
contamination to clean
areas within the
RCA and prevent the spread
of contamination to clean
areas
outside the
RCA.
Section 5.6.2 of
PLP-511,
established
contamination limits for equipment,
materials
and tools.
Items were considered
contaminated
whenever:
Beta
and
gamma contamination levels exceeded
100 ncpm with a
pancake
GM detector
(Total of Fixed and
Removable
Contamination)
Beta
and
gamma contamination levels
exceeded
1,000 dpm/100
cm 'Removable
Contamination)
Section 5.6. 10 of PLP-511, required contaminated
equipment tools,
material
and trash shall
be controlled
as radioactive materials
and stored only within contaminated
areas,
high contaminated
areas
or other areas
approved
by
RC supervision.
On March 29,
1994;
an item (Fitting for Gate Seal)
contaminated
with 3,000 dpm/100 cm'as
found improperly stored in a
maintenance
gang
box on the 286 foot elevation of the
Fuel
Handling Building outside
a contaminated,
highly contaminated
or
radioactive materials
storage
area designated
by
RC supervision.
Licensee
immediate corrective actions for the problem included
placement of the item in a radioactive materials
storage
area
and
the initiating of an
ACFR.
This
NRC identified violation is not
being cited because criteria specified in Section VII.B of the
Enforcement Policy were satisfied.
17
NCV 50-400/94-07-02:
Failure to control
and store contaminated
or
radioactive material in accordance
with licensee
procedures.
A NCV was identified.
c.
Control of Contaminated
Areas
During facility tours,
the inspector
noted that contamination
control
and general
housekeeping
practices
were adequate.
Surface
contamination
was aggressively
being controlled at its source.
The licensee
monitors plant area
contaminated
with the total area
included in monitoring program at about 460,000 ft .
That area
excludes
the Containment Building.
The licensee
had approximately
1900 ft'fthe monitored area
contaminated
in non-outage
periods.
During tours of the facilities, the inspector
observed
the use of
catch basins to minimize the spread of contamination.
No concerns
were noted.
d.
Personnel
Contaminations
For 1993, the licensee essentially
met their goal of 60
PCEs with
8 skin contaminations
and
37 clothing contaminations.
Of the
45
PCEs,
.5 involved hot particles for clothing contaminations.
The licensee
had not identified any hot particles
on skin.
The
45
PCEs in 1993
was the site's
lowest annual
number of PCEs.
Approximately 14
had occurred in 1994.
Review of selected
contamination
events
noted that licensee
documentation
and follow-
up on the individual events
were appropriate,
and skin dose
assessments
were performed,
when required.
For reports reviewed,
resultant
exposures
were minor.
No concerns
were noted.
ll.
Program for Maintaining Exposures
As Low As Reasonably
Achievable
(83750)
This program area
was reviewed to determine the adequacy of ALARA
program.
Areas reviewed included organization support, training, goals
and objectives,
radiation source reduction,
worker awareness
and
involvement,
ALARA plans
and reviews,
and
ALARA results in the
implementation of the licensee's
ALARA program.
10 CFR 20. 1101(b) requires that the licensee
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 licensee's
full-time ALARA staff consisted of a senior radiation
specialist
and
one
RCT.
However, the licensee
had assigned
four
contract personnel
to the
ALARA staff several
months prior to the outage
18
to support outage planning activities
and another
RCT to support the
ALARA staff during the outage.
The organizational
structure
and
responsibilities for the
ALARA staff were clearly defined in
organizational
charts
and licensee
procedures.
The inspector determined that the licensee's
ALARA policy and objectives
were clearly described
in GET Level II Training.
ALARA concepts
and
dose reduction techniques
were also presented
in the training program.
In the fourth quarter of 1993, the
ALARA and Training staff provided
an
ALARA overview training as continuing training for plant staff including
EERC,
IKC, Operations,
Maintenance,
and Electrical personnel.
The
training was specific to the work group
and provided information on
lessons
learned,
the unit's performance
in the previous outage,
information on new ALARA tools (telemetric dosimetry,
cameras,
laser
pointers, etc.) available for use,
and
ALARA goals.
The inspector
reviewed selected
ALARA Work Plans for the outage,
including the Refueling Activity, Steam Generator
Haintenance,
and the
RTD Removal projects.
The plans
addressed
the major task within each
project
and included work scope descriptions,
dose estimates,
radiological
hazards
associated
with task,
methods fur radiological
exposure
reductions
and contingency plans.
The licensee
invested
considerable
resources
(time and funds) in researching
and evaluating
processes
for RTD Removal project, developing
a removal plan,
and
preparing
and providing training for implementation of the plan.
The inspector
reviewed selected
ALARA pre-job briefings.
The exchange
of information during the briefings was good.
Participants
discussed
the scope of the work, specific task
and sequence
of work activity, task
preparations,
radiological
hazards
with the processes,
radiological
controls to be implemented,
housekeeping
requirements,
contingency plans
and safety hazards
and precautions.
Licensee
and contractor personnel
appeared
knowledgeable of planned task
and dose reduction techniques
to
be utilized.
The inspector discussed
ALARA initiatives with licensee
ALARA personnel.
Radioactive
source reduction activities included flushing hot spots
and
the replacement of valves containing cobalt.
The licensee
had
identified all valves containing cobalt
and was replacing eight check
valves
on the charging
system during the outage.
Other activities
planned
included continued
study of ultra filtration systems
at other
facilities and specifying electro-polishing of steam generator
primary
side bowls for steam generator
replacement.
Activities to reduce
collective dose during RFO-5 included
use of equipment to enable the
remote monitoring of work activities for high dose task such
as vessel
work,
RTD removal project
and steam generator
inspection
and
maintenance.
The licensee
had purchased
and contracted
remote
camera
systems with multiple cameras,
monitors,
and telemetric electronic
dosimetry.
The inspector learned that the licensee
was also working on
a surrogate tour system for ALARA applications.
An ALARA incentive plan
emphasizing
performance
and team work had
been
used to recognize
and
reward specific work groups having good dose reduction performance.
19
The availability of the Harris reactor
was very high in 1993.
The
reactor availability factor was about 99.5 percent with no forced
outages.
A planned mini-outage occurred
on May 22,
1993, to repair
a
leaking blowdown valve on A steam generator.
The unit returned to
operation the following day with a l. 1 person-rem total for the brief
outage.
The licensee's
collective dose goal for 1993 was
45 person-rem
and actual
dose for the year was 30.8 person-rem,
the site's
lowest
annual collective dose.
The licensee's
three year collective dose
average
dropped in 1993 from about
175 person-rem
(1990-1992) to about
156 person-rem
(1991-1993).
The licensee's
collective dose goal for
1994 was initially set
255 person-rem.
However, the licensee
had
recently reduced
the outage
exposure
estimates
from 230 person-rem to
198 person-rem
when the planned
outage length
had
been
reduced
by
10 days.
The licensee's
annual
dose goal
was reduced to 223 person-rem
goal.
The collective dose through April 1,
1994,
was 1.98 person-rem
compared to the projection of 2.44 person-rem.
The activities of the
ALARA staff with the apparent
support of site
management
appear to be advancing
the effectiveness
of the sites
program.
No concerns
were noted.
Effectiveness
of Licensee Controls
(83750)
This area
was reviewed to evaluate
the effectiveness
of licensee's
program
and performance
in identifying, documenting
and reporting,
determining root causes
and implementation of appropriate corrective
actions for the identified problems.
The licensee
conducted
a self-assessment
of the managements
effectiveness
to prevent repetition of adverse
occurrences
and
conditions.
The assessment
was identified as H-SW-94-01, "Harris Plant
Sitewide Assessment,"
and was performed
on February
28 - March 4,
1994.
The report was issued
March 7,
1994.
The assessment
reported that the
HNP management
was
aware of problems
that could lead to extended
outages
and
was taking effective action to
address
the problems that had resulted in performance
problems at other
CP&L facilities.
However, several
findings concerning
management
controls were identified in the report.
One of the findings, H-SW-94-01-I2, reported that insufficient emphasis
had
been placed
on self-assessment
by way of written accountabilities
or
management
expectations.
Some
examples for the finding included:
The site
had not implemented
a formal self-assessment
program.
Reluctance to self-identify ACFRs
among several
plant
organizations
due to concerns of reporting
on peers
and self-
incrimination resulting in retribution.
20
Fourteen of thirty-one
NAD Assessments
conducted
since January
1993
had cited deficiencies
in self-assessment.
The licensee
had issued
a plant directive PLP-003, "Self Assessment,"
Revision 0, effective March 1,
1994, that required
each unit to develop
an annual
plan of self-assessments
which included at least
one per
quarter.
The self-assessment
plans were to include
many elements
of a
good
gA audit.
The plant units were required
implement their self-
assessment
plans beginning the fourth quarter of 1994.
Audit finding, H-SW-94-01-I3, reported continued
problems with procedure
use,
adequacy
and adherence.
The report also stated that, despite
numerous previously identified procedure deficiencies,
corrective
actions in response
to those deficiencies
had
been ineffective.
The specific corrective actions for the recently identified issues
were
not reviewed.
However, the review and documentation
of management
problems
appeared
to be
an appropriate
step in the establishment
of
quality processes
within plant programs.
The report findings indicated
management
needed
to improve communications of objectives
and take
measures
to encourage
and ensure that all plant staffs were more
aggressively
identifying and taking appropriate corrective actions to
prevent repeated
adverse
conditions.
The findings, if appropriately
addressed,
have the potential to improve site program performance.
The inspector noted that the
NAD findings of the
EERC audit conducted
a
couple of weeks prior to the management
effectiveness
audit also
identified needs for self-identification
and corrective action
performance
improvements.
No concerns
were noted.
Action on Previous
Inspection
Findings
(92701)
(Open)
VIO 50-400/93-11-01:
Failure to comply with procedure,
HPP-800,
requirements for properly labeling radioactive materials.
The inspector
reviewed the licensee's
response
to the violation dated July 16,
1993,
and reviewed the implementation of the licensee's
corrective actions.
The inspector verified that the licensee
had completed all of the
corrective actions.
The inspector
noted that the licensee
had
made
significant improvements
in the labeling of contaminated
and radioactive
material
since the previous inspection.
The identification of an
additional
example of failure to control contaminated
and radioactive
material
was identified during the inspection.
The item will remain
open pending
a review of the licensee's
corrective actions for the most
recent failure to control radioactive material in accordance
with
licensee
procedures.
21
Exit Meeting
(83729)
On March 31,
1994,
an exit meeting
was held with those licensee
representatives
denoted
in Paragraph
1 of this report.
The exit meeting
was held at that date in conjunction with two other
NRC exits.
The
inspector
summarized
the scope
and findings of the inspection including
two new issues
as potential violations.
The licensee
did not indicate
any of the information provided to the inspector during the inspection
as proprietary in nature
and
no dissenting
comments
were received
form
the licensee.
The inspector reported that the inspection
would continue
through the following day
and if any new issues'developed
during that
inspection period another exit would be required.
Upon review of
licensee corrective actions for the reported violations
a decision
was
made to identified the violations
as
NCVs as
shown below.
There were
no
new issues
identified following the March 31,
1994 exit meeting.
However, the inspector did reviewed the results of the inspection
activities following the exit with the Manager of Radiation Controls
prior to exiting the site
on April 1,
1994.
~T
e
Item Number
50-400/94-07-01
Status
Descri tion and Reference
Closed
Failure to post
RCAs in
accordance
with licensee
procedures
(Paragraph
6.d).
50-400/94-07-02
50-400/93-11-01
Closed
Closed
Failure to control
and store
contaminated
or radioactive
material in accordance
with
licensee
procedures
(Paragraph
10.b).
Failure to comply with
procedure,
HPP-800,
requirements for properly
handling radioactive materials
(Paragraph
13).
Index of Abbreviations
Used in this Report
ACFR
ANSI
CFR
cm
DAD
dpm
E&RC
Adverse Condition Feedback
Report
As Low As Reasonably
Achievable
American National
Standards
Institute
Balance of Plant
Code of Federal
Regulations
Centimeters
Squared
Carolina
Power
& Light
Derived Air Concentration
Digital Alarming Dosimeter
Disintegration
Per Minute
Environmental
and Radiation Control
ft
GN
HPP
IR
mrem
NAD
ncpm
NRC
PPH
RC
RC&PH
SRPD
TI
TS
22
Square
Feet
Geiger-Muller
High Efficiency Particulate Air-filter
Harris Nuclear Plant
Health Physics
Health Physics
Procedures
Inspection
Report
Milli-Roentgen Equivalent
Van
Nuclear Assessment
Department
Net Counts
Per Minute
Non-Cited Violation
Nuclear Regulatory
Commission
National Voluntary laboratory Accreditation
Program
Personnel
Contamination
Events
Peer
Panel
Neeting
Radiation Control
Radiologically Controlled Area
Radiation Control Protection
Hanual
Radiation Control Technician
Re-Fueling
Outage
Resistance
Temperature
Detector
Radiation
Work Permit
.Step Off Pad
Self-Reading
Pocket Dosimeter
Total Effective Dose Equivalent
Temporary Instruction
Thermoluminescent
Dosimeter
Technical Specification
Violation