ML20127N509

Insp Rept 50-302/85-12 on 850325-29.Violation Noted: Inadequate Personal Frisking Practices,Failure to Properly Label Radioactive Matl & Failure to Conspicuously Post 10CFR19.11 Documents

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: ML20127N496 ML20127N501 ML20127N509
References
50-302-85-12, NUDOCS 8507010637
Download: ML20127N509 (9)

See also: IR 05000302/1985012

Text

^^

.

-

,

UNITED STATES

[p rMo "'o, ' NUCLEAR REGULATORY COMMISSION

8%- REGION il

f* I

r

101 MARIETTA STREET, N.W.

ATLANTA, GEORGI A 30323

% *****

/ 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.: DPR-72

Facility Name: Crystal River 3

Inspection Conducted: March 25-29, 1985

Inspectors:

R. H. Albri

I

g

k f.2/-P5

Date Signed

O 6 /d

W. T. Coo'er

p j Date Signed

Accompanying P sonnel: B K. Revsin

Approved by:  %/ TN

G. R. Jenkinl, Section Chief

=

h2.2./8

Bate Signed

Division of. Radiation Safety.and Safeguards ,

'

,

SUMMARY .  ;

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,

y

,u ,

.

,

-

.s

_

,

x '

~' 8507010637 850024

PDR ADOCK 05000302

G PDR .

.y v ,

P d,

4 Y

T

- _ , . , , - ,

., ,

v .

, -.

T = - -

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 _ ._

• 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.

,- .

-

2

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.

i.

-

.

3

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

.- .

-

, .

4

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.

-

.

5

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

.

6

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) ,

^

7

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  !

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

r-

-

. .

8

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.