ML20127N509
| ML20127N509 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/22/1985 |
| From: | Albright R, Cooper W, Jenkins G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127N499 | List: |
| References | |
| 50-302-85-12, NUDOCS 8507010637 | |
| Download: ML20127N509 (9) | |
See also: IR 05000302/1985012
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION il
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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MAY 2 41985
Report No.:
50-302/85-12
Licensee:
Florida Power Corporation
3201 34th Street, South
St. Petersburg, FL 33733
Docket No.:
50-302
License No.:
Facility Name: Crystal River 3
Inspection Conducted: March 25-29, 1985
Inspectors:
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R. H. Albri
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Date Signed
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W. T. Coo'er
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Date Signed
Accompanying P sonnel:
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K. Revsin
Approved by:
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G. R. Jenkinl, Section Chief
Bate Signed
Division of. Radiation Safety.and Safeguards
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SUMMARY
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Scope:
This routine, unannounced inspection entailed,67 inspector-hours on site
in the areas of training and qualifications,' internal exposure control, surveys,
monitoring and control of radioactive material, posting of documents, notices and
forms,- follow-up on licensee personnel concerns,.and inspector follow-up items.
Results:
Three~ violations - (1) Inadequate personal frisking practices (2)
failure to properly Icbel radioactive material (3) failure to have 10 CFR 19.11
documents con <.sicuously posted,
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- V. R. Roppel, Manager, Plant Engineering and Technical Services
- J. Lander, Nuclear Outage and Modifications Manager
- P. J. Skramstad, Nuclear Chem / Rad Superintendent
- J. R. Wright, Site Nuclear Services
- R. Clarke, Radiation Protection Manager
- J. E. Colby, Manager, Site Nuclear Engineering
- K. R. Wilson, Supervisor, Site Nuclear Licensing
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- D. G. Green, Nuclear Licensing Specialist
- J. L. Bufe, Nuclear Compliance Specialist
- L. C. Kelly, Nuclear Operations Training Manager
- J. T. Telford, Director QPD
- W. P. E11sberry, Nuclear Operations Training Supervisor
- R. M. Bright, Manager, Nuclear Licensing
- W. A. Clemons, Nuclear Compliance Specialist
- R.
E. Fuller, Site Nuclear Services
C. Davis, Health Physics Supervisor
C. Brown, Outage Manager
R. Browning, Health Physics Supervisor
Other licensee employees contacted included technicians, and office
personnel.
NRC Resident Inspectors
- T. F. Stetka, Senior Resident Inspector
- J. E. Tedrow, Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on March 29, 1985, with
those persons indicated in paragraph I above.
The violation for (1)
inadequate personal frisking practices (paragraph 6), (2) failure to
properly label radioactive material (paragraph 6), and (3) failure to have
10 CFR 19.11 documents conspicuously posted (paragraph 7) were discussed in
detail with licensee management.
Licensee management disagreed with
violations 1 and 3 but acknowledged violation 2.
Licensee management
stated that their disagreement with Violations 1 and 3 were based on the
use of "should" statements in the frisking procedure and the accessibility
of the required notices, forms and documents posted in accordance with
10 CFR 19.11.
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The Region II NRC staff position regarding the licensee letter dated
February 26, 1985, concerning interpretation and planned method to implen.ent
10 CFR 20.203(f), labeling of radioactive material was discussed. The
inspector also discussed a health physics supervisor's concern that the
outage manager had tried to have radiological work safety requirements
reduced (paragraph 8). The licensee did not identify as proprietary any of
the materials provided to or reviewed by the inspectors during this
inspection.
3.
Licensee Action on Previous Enforcement Matters
Not inspected.
4.
Training and Qualification (83723)
a.
Radiation Protection Technician Training and Qualification
The licensee was required by Technical Specification 6.3 to qualify
radiation protection technicians in accordance with ANSI N18.1. The
inspector discussed the training and qualification program with the
Nuclear Chemistry and Radiation Protection Superintendent,
the
Radiation Protection Manager, the Nuclear Technical Training Supervisor
and a Nuclear Radiological Instructor. Qualification card requirements-
were reviewed.
Paragraph 4.5.2 of ANSI 18.1-1971 required that technicains in
responsible positions have a minimum of two years working experience in
their specialty.
Selected resumes of health physics technicians as
well as resumes of health physics technicians elevated to temporary
acting Chief Technicians for the outage were reviewed to determine
their compliance with this requirement.
Technical Specification 6.4 required a retraining and replacement
training program that shall meet or exceed the requirements and
recommendations of Section 5.5 of ANSI N18.1-1971.
The inspector
discussed the training / replacement training program with the Radiation
Protection Manager and the Nuclear Technical Training Supervisor.
Program elements were foun.d adequate to meet the requirements of
Section 5.5, ANSI N18.1.
The inspector reviewed the program for qualification of contract
radiation protection technicians.' Selected resumes of senior contract
technicians were examined to determine if their previous experience and
training were comprehensive or if it had been limited to selected
tasks. The inspector also discussed what limits had been placed on
their activities.
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b.
Radiation Protection Supervisor Qualifications
Technical Specification 6.3 committed the licensee to ANSI N18.1-1971
which required radiation protection supervisory staff to have four
years experience in their specialty.
Resumes of permanent Health
Physics Supervisors and Health Physics personnel who had been promoted
to temporary / acting supervisory positions were reviewed to determine
their conformity to ANSI N18.1-1971.
No violations or deviations were identified.
5.
Internal Exposure Control (83725)
The licensee was required by 10 CFR 20.103 to establish a qualification
program for workers who wear respiratory protective equipment. Elements of
the qualification program outlined in 10 CFR 20.103 are delineated in
NUREG-0041. 10 CFR 20.103(a) established the limits for exposure of
individuals to concentrations of radioactive materials in air in restricted
areas.
The inspector observed workers using respirators while they were
performing various tasks in the reactor building and discussed this use with
the Health Physics Technician covering the job.
The inspector reviewed
recent and proposed changes to the respiratory protection program and
discussed these changes with the Health Physics Respiratory Protection
Supervisor. A contract Emergency Medical Technician (EMT) was responsible
for performing the medical qualification examination for personnel who were
required to wear a respirator.
The inspector discussed the medical
qualification program with the EMT and found that the licensee physician had
not supplied written acceptance criteria for medical qualification of
respirator users. The EMT was not authorized by the physician to evaluate
the results of the medical tests, however, the EMT was allowed to authorize
the respirator fit testing of licensee personnel. Licensee personnel stated
that the physician will generally review the medical qualifications and sign
the evaluation within twenty-four hours. Through discussions with licensee
representatives, the inspector determined that it would be possible for an
employee to receive a physical from the EMT, attend respirator training, be
fit tested with a respirator, and then be issued a respirator for use in an
airborne contamination area prior to the licensee physician reviewing the
employee's medical qualifications.
The inspector did not find examples
where an individual had used a respirator before the doctor had reviewed and
approved the physical.
A licensee representative stated that the
respiratory protection verification sheet, Enclosure 1 of procedure number
RP-102, " Respiratory Equipment Manual," was being revised to remove the EMT
signature space.
In this manner, it would be assured that the licensee
physician would sign the verification prior to the employee being issued a
respirator.
This item will
be reviewed during future inspections
(50-302/85-12-01).
10 CFR 20.103(b) required the licensee to use process or other engineering
controls, to the extent practicable, to limit concentrations of radioactive
material in air to levels below those specified in Part 20, Appendix B,
Table I, Column 1 or limit concentrations, when averaged over the number of
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hours in any week during which individuals are in the area, to less than 25
percent of the specified concentrations. The use of process and engineering
controls to limit airborne radioactivity concentrations in the plant was
discussed with licensee representatives and the use of such controls was
observed during tours of the plant.
10 CFR 20.103(b) required that when it is impracticable to apply process or
engineering controls to limit concentrations of radioactive material in air
belew 25% of the concentrations specified in Appendix B, Table 1, Column 1,
other precautionary measures should be used to maintain the intake of
radioactive material by any individual within seven consecutive days as far
below 40 MPC-hours as is reasonably achievable.
By review of records,
observations and discussions with licensee representatives, the inspector
evaluated the licensee's respiratory protection program, including training,
medical qualifications, fit-testing, MPC-hour controls, quality of breathing
air, and the issue, use, decontamination, repair and storage of respirators.
The inspector reviewed the following plant procedures which established the
licensee's internal exposure control and assessment program and verified
that the procedures were consistent with regulations, Technical Specifi-
cations and good health physics practices:
RP-101
Radiation Protection Manual
RP-102
Respiratory Equipment Manual
RP-106
Radiation Work Permit Procedures
RP-202
Radiological Surveys
RP-208
Bioassay Sampling Procedure
RP-230
MPC Hour Calculation Procedure
HPP-322
Whole Body Counting System Calibration
The inspector discussed planning and preparation for the current twenty week
outage with licensee representatives. Specific areas discussed included the
use of auxiliary ventilation systems, decontamination of equipment prior to
maintenance and availability of respiratory protection equipment.
The inspector observed operation of the whole body counter and discussed its
operation and results with licensee representatives. The inspector reviewed
selected results of the licensee bioassay program for the period January
1984, through the first quarter of 1985. Licensee personnel stated that no
personnel had been exposed to greater than 40 MPC-hours in one week.
No violations or deviations were identified.
6.
Surveys, Monitoring, and Control of Radioactive Material (83726)
10 CFR 20.201(b) required each licensee to make or cause to be made such
surveys as (1) may be necessary for the licensee or comply with the
regulations and (2) are reasonable under the circumstances to evaluate the
extent of radiation hazards that may be present.
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The inspector reviewed the following plant procedures which established the
licensee's radiological survey and monitoring program and verified that the
procedures were consistent with regulations, Technical Specifications and
good health physics practices:
RP-103
Decontamination of Personnel, Areas, and Equipment
RP-106
Radiation Work Permit Procedure
RP-202
Radiological Surveys
RP-206
Radiation Protection Instrumentation Calibration Procedures
The inspector reviewed selected records of radiation and contamination
surveys performed during March 1985, and discussed the survey results with
licensee representatives.
During tours of the plant the inspector observed health physics technicians
performing radiation and contamination surveys.
The inspector performed independent radiation surveys in the reactor
building and in the restricted area outside the auxiliary building and
verified that the areas were properly posted.
Technical Specification 6.8.1 stated that written procedures shall be
established, implemented and maintained for certain activities including
applicable procedures in Appendix A of Regulatory Guide 1.33,
1972.
Appendix A of Regulatory Guide 1.33, November 1972, required procedures for
surveys and monitoring.
Chemistry and Radiation Protection Procedure
RSP-101, Basic Radiological Safety Information and Instructions for
" Radiation Workers," step 3.1.4 required that, when exiting the Auxiliary
Building "RCA," a whole body frisk must be performed in accordance with
Section 3.3.
RSP-101, Section 3.3 delineated the " Guidelines for Conducting
a whole body frisk using an RM-14 with HP-210 Probe." This guidance used
"should" statements to describe the recommended frisking technique.
The
procedure stated no requirements for personnel to follow in order to perform
an adequate personal frisk. T_his guidance indicated that hands be frisked
first for 5 seconds each prior to picking up the probe.
Personnel are
instructed in notes to Section 3.3.2 that, "if any increase in count rate is
noted, THEN return the probe to the suspected area of contamination for a
minimum of five (5) seconds. If the ALARM sounds or a significant increase
(i.e., greater than 50 cpm above background) is visual or audible response
is noted, THEN notify Health ohysics personnel immediately." The guidance
recommended frisking the hands, head or hat, face, neck, front of body
trunk, bottma of each foot, each dosimetry device or other small personal
item fo. approximately 5 seconds each.
The guidance recommended the
remainder of the body including the arms, legs, knees, buttocks, and back to
be frisked slowly for approximately 30 seconds.
If this guidance were
followed, e whole body frisk would take approximately 70 seconds.
Chemistry ::nd Radiation Protection procedure RP-101, Radiation Protection
Manual, step 4.8.4.e required that, " prior to donning personal clothing, all
individuals should conduct a whole body frisk at the nearest frisking
station" and 4.8.5.a required that "All personnel shall conduct a Whole Body
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Frisk prior to each exit from the 95 foot elevation control complex RCA."
The description of the whole body frisk contained in this procedure is
similar to that contained in RSP-101 and described above.
The inspector observed approximately thirty workers at the reactor building
(RB) exit and at the RCA exit using the personnel frisker (RM-14/RM-16 with
HP-210 pancake probe) to perform contamination surveys of themselves prior
to exiting the controlled area.
All 30 individuals observed by the
inspectors did not perform whole body frisks as described in procedures
RSP-101 or RP-101.
Personnel generally picked up the probe without first
frisking their hands and quickly passed the probe over the feet, hands, face
and occasionally the front part of the body. Two of the above individuals
were observed frisking at the RB exit and then at the RCA exit and the
frisks at both frisking stations were inadequate as described above. The
arms, legs, back of the body, head or hard hats generally were not surveyed.
The whole body frisks generally were completed in less that thirty seconds
at both frisking locations. The frisker probe movement during the frisk was
so fast that a significant amount of contamination would have to be present
on the individual in order for the instrument audible response to indicate
that an area needed additional frisking.
The increase in the frisker
audible click rate would not be noticeable such that an individual would be
alerted to resurvey a body area to find the small amount of contamination
that would, during the refrisk of an area and while holding the prpbe
stationary, cause the frisker to indicate 50 counts per minute above
background.
Frisking procedures in RSP-101 and RP-101 were written as
recommendations and did not state the requirements for an adequate frisk by
personnel exiting contaminated areas on the RCA.
Consequently, personnel
exiting contaiminated areas and/or the RCA performed inadequate frisks as
described above.
Failure to establish and implement procedures which
prescribe the requirements for adequate personnel frisking techniques is a
violation of Technical Specification 6.3.1 (50-302/85-12-02).
10 CFR 20.203(f) required that each container of licensed material bear a
durable, clearly visible label identifying the radioactive contents.
The
label shall bear the radiation caution symbol and the words " Caution" or
" Dangerous - Radioactive Material" and shall provide sufficient information
to permit individuals handling or using the containers or working in the
vicinity thereof, to take precautions to avoid or minimize exposures.
During tours of the facility, the inspectors frequently observed radioactive
materials in yellow bags.
The yellow bags were labeled with the words
" Caution Radioactive Material," but the label did not include the radiation
caution symbol. The highest dose rate observed by the inspector on bagged
radioactive material was 8 mR/hr and thus contained greater than the
10 CFR 20, Appendix C, quantity of radioactive material.
This bag was
located in the containment and contained a hoset
The failure to show the
radiation caution symbol on bags of radioactive eaterial is a violation of
10 CFR 20.203(f).
(50-302/85-12-03)
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7.
Posting of Notices, Documents and Forms (92706)
10 CFR 19.11 required conspicuous posting of current copies of: (1) 10 CFR
parts 19 and 20; (2) the license, license conditions, or documents incorp-
orated into a license by reference, and amendments thereto; (3) the opera-
ting procedure applicable to licensed activities; (4) any notice of
violation involving radiological working conditions and any response from
the licensee; (5) Form NRC-3, " Notice to Employees," to permit observation
by individuals engaged in licensed activities on the way to or from the
licensed activity location to which the document applies.
If posting of
(1), (2) or (3) above is not practical, the licensee may post a notice which
describes the document and states where it may be examined.
The required documents were found to be present on the bulletin board at the
entrance to the RCA near the Chem / Rad office; however, the documents were
not conspicuous due to various advertisements and announcements thumb-tacked
over them. A second bulletin board pointed out by the licensee was located
at the berm entrance to the Turbine Building. The documents posted at this
location were incomplete, and in addition, were partially obscured by
various plant and employee announcements.
A third bulletin board was
indicated by the licensee and was found at the first floor entrance of the
Rusty Building.
The postings at this location
were
incomplete.
Additionally, this location does not meet the requirement for conspicuous
posting for observation by workers going to or from the licensed activity
location because the Rusty Building is an office area and most workers would
not observe this posting location.
Failure to conspicuously post required notices to workers is a violation of
10 CFR 19.11 (50-302/85-12-04).
8.
Followup on Licensee Personnel Concerns (92706)
On arrival at the facility, the inspector received a written concern from a
licensee health physics supervisor.
The health physics supervisor wrote
that the outage manager had attempted to use his position to intimidate
health physics management inte reducing health physics controls.
The
inspector discussed the concern with the health physics supervisor. The
concern arose during preplanning for retrieving a tool from the upper vessel
internals.
It was suggested by outage workers that the work could be
performed easier if respiratory protective equipment were not used.
The
Health Physics Supervisor stated that the outage manager, during the pre-
planning meeting, requested the health physics supervisor to remove the
respirator requirement.
Due to high contamination levels on the upper
internals, the possiblity of high airborne concentrations during the work
was a concern.
The health physics supervisor declined to remove the
respirator requirement. There were subsequent discussions of the radio-
logical
requirements and the Chem / Rad Superintendent and Radiation
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Protection Manager discussed the matter with the outage manager. The oubge
manager, during a discussion with the inspector, stated that he was not
trying to determine radiological requirements for the work; however, if
respiratory protective equipment was expected to hamper the job and if
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working conditions did not warrant respirators, then he wanted to pursue
having the requirement dropped. He understood the need for the respirators
for this work after the radiological conditions and potential problems were
explained by health physics management.
Health physics evaluated the
working conditions and the potential for airborne radioactivity, and
determined that respirators were required and the work was performed using
respiratory protective equipment.
Health physics management involvement resolved the problem.
The Health
Physics Supervisor was satisfied that disagreement over health physics
concerns for the work was resolved and withdrew his concern.
No violations or deviations were identified.
9.
Inspector Followup Items (IFI)
(Closed) IFI 84-01-01 - The inspector reviewed licensee procedure number
SP-804 which details the surveillance requirements for fire brigade
respiratory protection equipment. The inspector also reviewed the docu-
mentation of the weekly and monthly checks of the equipment.
The inspec-
tions and appropriate documentation are being maintained as required.