ML20138C417
| ML20138C417 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/18/1986 |
| From: | Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20138C400 | List: |
| References | |
| 50-302-86-06, 50-302-86-6, IEIN-85-006, IEIN-85-007, IEIN-85-042, IEIN-85-043, IEIN-85-046, IEIN-85-42, IEIN-85-43, IEIN-85-46, IEIN-85-6, IEIN-85-7, NUDOCS 8604020487 | |
| Download: ML20138C417 (9) | |
See also: IR 05000302/1986006
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'1 , UNITED STATES / p Eitug'o NUCLEAR REGULATORY COMMISSION . [ ' ' , REGION ll _ g j. 101 MARIETTA STREET.N.W. t ATLANTA, GEORGI A 30323
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m a. a_ Report-No.: 50-302/86-06 ' 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: January 27-31, 1986 b /Y [[ Inspector: B. K. Revsin' \\ Date Signed Approved by: Mf tm h/ 8/(Tb ' C. M. H6sey, Sect'on Chief Date' Signed Division of Radiation Safety and Safeguards . SUMMARY Scope: This routine, unannounced inspection entailed 35 sector-hours onsite during regular hours, inspecting the ' radiation protectir orogram including radioactive materials control, posting and labeling; faci ies and equipment; internal -exposure control and assessment; external e> .re control and assessment; followup on an allegation; and solid radioactiv, .<aste classification and characterization. Results: Two violations - (1) Failure to possess a dose rate meter in a posted High Radiation Area and (2) Failure to properly classify radioactive wastes. . 8604020487 840325 yDR ADOCM 05000302 PDR
__ _ . . REPORT DETAILS 1. Persons Contacted Licensee Em'ployees
- B. J. Hickle, Operations Manager
- P. 'J. Skramstad, Nuclear Chemistry and Radiation Protection Superintendent
.
- R. Clarke, Radiation Protection Manager
- V. R. Roppel, Plant Engineering and Technical Services Manager
- G. R. Clymer, Nuclear Waste Manager
- S. E. Chapin, Nuclear Waste Supervisor
- J. A. Frijouf, Nuclear Compliance Specialist
- W. L. Rossfelb, Site Nuclear Compliance Manager
M. Siapno, Health Physics Supervisor . S. L. Lashbrook, Health Physics Supervisor D. A. Van Oosterwyk, Health Physics Supervisor Other licensee employees contacted included two technicians, two security force members, and two office personnel. NRC Resident Inspectors
- T. Stetka, Senior Resident Inspector
- J. Tedrow, Resident Inspector
- Attended exit interview
2. Exit Interview The inspection scope and findings were summarized on January 31, 1986, with those persons indicated in paragraph I above. Two apparent violations were discussed in detail: '(1) failure to possess a radiation monitoring device in a High Radiation Area (paragraph 7), and (2) failure to adequately determine scaling factors for use in classifying shipments of dry active waste (paragraph 10). The licensee acknowledged the inspection findings and took no exceptions. The licensee did not identify as proprietary any of the materials prOvided to or reviewed by the inspector. 3. Licensee Action on Previous Enforcement Matters (Closed) Violation (50-302/85-34-01) Procedure for calculating MPC hours for- cases of radioactive material ingestion. The inspector reviewed the licensee's response dated November 14, 1985 and verified that the corrective action specified in the response had been achieved.
i .. . 2 ~ 4 Licensee Audits (83724, 83725, 86721', 84722, 83723) ~ The inspector discussed the audit ard surveillance program with licensee representatives in the- areas of radiation protection, training and qualifications and radioactive waste management and transportation. The inspector reviewed the following Quality Assurance (QA) audits: Audit QP-277, Radioactive Waste, September, 1985. Audit QP-273, Personal Training and Qualifications, June 1985. Audit QP-280, Radiation Protection Training, December, 1985. The inspector discussed with licensee representatives the qualifications of the- audit team in .the areas monitored. The- Quality Audits Supervisor explained that when a functional area was scheduled for audit and the audit team lacked member (s) with expertise in that area, outside consultants were utilized. The inspector reviewed the 1985 audit schedule and the participating auditors and consultants assigned to each. No violations or deviations were identified. 5. Control of Radioactive Materials and Contamination, Surveys and Monitoring (83726) The licensee was required by 10 CFR 20.201(b), 20.403 and 20.401 to perform surveys and to maintain records of such surveys as necessary to show compliance with regulatory limits. Survey methods and instrumentation were outlined in the Final Safety Analysis Report (FSAR), Chapter 12, while Technical Specification (T.S.) 6.11 required adherence to written procedures for all operations involving personnel radiation exposures. Radiological control procedures further delineated survey methods and frequencies, a. Surveys The inspector reviewed surveys performed by the licensee for the month of January 1986. Two Radiation Work Permits (RWPs), No. 86-0055, Removal of 011 Samples from Upper and Lower Motor Sumps and Draining 011 from Reactor Coolant Pump-1A Motor and No. 86-0126, Work On and In Reactor Coolant Pump to include: Inspection, Installation of Shielding and Workup to Install New Pump Internals, were discussed with licensee representatives. During plant tours, the inspector performed independent radiation level surveys of selected areas using NRC equipment and compared these levels with those obtained by the licensee. The inspector noted that 'all locked high radiation areas inside and outside of containment were ~ maintained as required by T.S. 6.12. The inspector also noted that during the last quarter of 1985, the amount of contaminated area in the l i i k
O* 3 , auxiliary building had decreased from 21,000 square feet in October 1985 to 12,500 square feet in January 1986, which corresponds to approximately 18 percent of the total area of the building. The Radiation Protection Manager (RPM) stated that a full-time crew of six persons, supervised by a Health Physics (HP) Supervisor had been dedicated te plant decontamination and that the decontamination effort was to continue. b. Instrumentation During plant tours, the inspector observed the use of survey instruments by plant staff and examined calibration stickers on radiation protection instruments in use by licensee staff and stored in the calibration facility. The inspector discussed calibration methods and methods for performing source checks prior to each use with the calibration facility staff. The licensee utilized an Eberline Model 1000B calibrator which contained eight Cs-137 sources for portable instrument calibration. The source of highest activity was 143 curies and the highest exposure rate achievable by the calibrator was 425 R/ hour. The 1!censee stated that for the high range of the Teletector (1000 R/hcur), one point calibrations at the lower end of the scale were performed. The . inspector discussed overload and geotropism testing with the licensee and reviewed the procedures for calibration of Teletector, R0-2As, beta calibration and frisker calibration. Portal monitor calibration was discussed. c. Release of Materials for Unrestricted Use 4 The inspector discussed with the RPM the program for survey-out of items from contaminated areas and reviewed the procedures for such release. Release criteria for alpha and beta / gamma radiation were discussed. No violations or deviations were identified. 6. Facilities and Equipment (83727) FSAR chapters 1 and 12 specified plant layout and radiation protection facilities and equipment. During plant tours, the inspector observed the operation of the contaminated clothing laundry, the flow of traffic through i the change areas, the u'se of temporary shielding, and the use of ventilated containment enclosures. ' No violations or deviations were identified. - - - - _ _ - - - _ . - . - . --- - -. .. - - - - - - - . -- -. -. - - - -.
_ . ._- ~__ .. . ' 4 i 7. External Occupational Dose. Control and Personal Do'simetry (83724) The licensee was required by 10CFR 20.202, 20.201(b), 20.201, 20.102, 20.104', 20.402, 20.403, 20.405, 19.13, 20.407 and 20.408 to maintoin worker's doses below specified levels and keep records of and make reports of doses. During observation of work in the plant, the inspector observed the wearing of thermoluminescent dosimeters (TLDs) and pocket dosimeters by workers. The inspector discussed the assignment and use of dosimeters with radiation protection technicians. The licensee stated that they were in the process of changing from Eberline to Landauer for dosimetry processing. For outage conditions, Landauer 'ad provided the licensee with a TLD reader and a qualified technician to operate the reader for processing special badges. While the licensee was still using Eberline TLDs to monitor workers' routine exposure, Landauer TLDs were.used for jobs requiring multibadging. A complete change over to Landauer TLDs was expected to occur within several months. 10 CFR 20.203 required the licensee to post and control access to plant areas. T.S. 6.12.1 specified that in lieu of the " control device"'or " alarm signa'l" required by 10 CFR 20.203(c), a High Radiation Area in which the intensity of radiation is greater than 100 mrem / hour but less than 1000 mrem / hour shall be barricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by issuance of a Radiation Work Permit and any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device -which continuously indicates the radiation dose rate in the area. On January 28, 1986, while touring the auxiliary building with a HP Supervisor, the inspector observed a radiation worker dismounting a ladder in the Triangle Room. The door to the room was locked and was posted, "High' Radiation Area," " Contaminated Area," and "RWP Required for Entry." Questioning of the worker by the inspector revealed that the individual had not had a dose rate meter in his possession while working in the High Radiation Area. The worker stated that he had signed in on RWP No. 86-0019 and review of RWP timesheets confirmed that he had done so. The worker stated that he had entered the room to inspect insulation work performed by his crew and that his total time in the area had been less than one minute. His pocket chamber read zero. The accompanying HP Supervisor called the HP Office and had an HP technician escort the worker from the Radiation Control Area and file a Radiological Safety Incident Report (RSIR). Examination of the licensee's survey . map of the room showed that 'the highest dose rate in the room had been 350 mrem / hour and that the worker had not been in the vicinity of this dose rate. The inspector stated that entry of a worker into a High Radiation Area without a radiation monitoring device to indicate the dose rate in the area was an apparent violation of T.S. 6.12.1 (50-302/86-06-01).
. . .. .-- .. . _ . . 5 , 8. Internal Exposure Control and *.ases' ment (83725) s 4 The licensee was required by 10 CFR ~20.103, 20.201(b), 20.401, 20.403 and 20.405 to control uptakes of radioactive material, assess such uptakes, and keep records of and make reports of such uptakes. FSAR chapter 12 also includes commitments regarding internal exposure control and assessment. ' During plant tours, the inspector observed the use of temporary ventilation systems, containment enclosures and ' respirators. The inspector discussed the use of this equipment with workers and HP technicians. The inspector observed _the cleaning and maintenance of respirators with a HP technician assigned the task. The inspector observed the~ storage of respirators and verified that storage conformed to manufacturer's recommendations. Additionally, calibration data for pressure gauges utilized for maintaining proper air flow for supplied air hoods were examined. The licensee stated that increased emphasis was being placed on the use of engineering controls to control contamination so as to reduce the use of respirators by workers. As an example, the facility for sorting worn contaminated clothing had been modified by placement of a hood over the
sorting table which had a face velocity of 175 feet / minute. Air samples in the area while sorting clothing with the hood running averaged 1 X 10 12 to '
1 X 10 28 microcuries/ml which permitted sorting without wearing a respirator. The HP Supervisor stated that plans were underway to evaluate the possibility to supplying a similar ventilation system for the drum compacting area. No violations or deviations ~were identified. 9. Radiation Protection Staffing The RPM stated that the turnover rate of the HP staff was low and that only one HP technician had left the plant in the past three years. He stated - that all authorized positions were filled at five assistant HP technicians, 14 HP technicians, four chief HP technicians and 4 HP supervisors. At the time of the inspection, 39 contract HP technicians were onsite to help with the unscheduled outage and they were anticipating the arrival of 10 additional HPs. For routine operations, the RPM stated that 10-15 contract HP technicians were onsite. No violations or deviations were identified. 10. -Solfd Waste (84722) 10 -CFR 20.311 required ' that the. licensee maintain a tracking system for radioactive waste shipments to verify that shipments have been received without undue delay by the intended recipient. The inspector reviewed the tracking methodology utilized by the licensee and examined the documented receipt acknowledgements in the shipping files for selected shipments made in 1985 and 1986.
.. 4 . 6 - 10 CFR 61.56 specified the waste characteristic and stability requirements for low level radioactive waste. Through discussions with licensee representatives the inspector ~ determined that waste stability, when required, was achieved by use of approved containers. Waste solidification had not been performed at the site since 1983 but it was anticipated that some solidifications would be performed in 1986. Solidification would be j performed by a contractor and included formation and testing of a demonstration product prior to processing. 10 CFR 20.311 required a licensee who transfers radioactive waste to a land disposal facility to prepare all wastes so that the waste is classified i according to 10 CFR 61.55. 10 CFR 61.55(a)(8) stated that the concentration of a radionuclide may be determined by iridirect methods such as the use of scaling factors which relate the inferred concentration of one radionuclide to ancther that is measured if there is reasonable assurance that the indirect methods can be correlated with actual measurements. . The inspector reviewed licensee procedae WP-101, " Packaging, Storing, and Shipping of Radioactive Materials," Revi sien 10, November 25, 1985.. Enclosure 13, " Methods for Determining Curie Content," specified that the isotopes Tc-99, I-129, Transuranics (TRU), Pu-241, Cm-242 were to be calculated using correlation factors (scaling factors) to Cs-137 obtained from an vendor paper dated 11/83 or obtained from a computer program (Isoscale). Discussions with licensee representatives disclosed that neither set of scaling factors were currertly being used for determining concentrations of difficult to. measure radionuclides. The licensee stated that four waste streams were bsing sampled and sent to an offsite vendor for quarterly analysis. The licensee stated tnat the sample types were as follows: (1) reactor coolant which was assumed to be indicative cf the isotope distribution of reactor coolant cleanup resin; , (2) reactor coolant crud - each week a two liter saople of reactor coolant was obtained and filtered through a three micron millipore >;1ter. At the end of the quarter, this filter was sent .for analysis and was , assumed to represent system filters; (3) Miscellaneous Waste Storage Tank (MWST) liquid - this sample was i assumed representative of waste resin and dry active waste (DAW); (4) spent fuel pool liquid - this sample was assumed representative of l . spent fuel pool filter and resin. , Licensee representatives stated that for the shipments of waste that had been made in 1985 and 1986 the scaling factors for calculation of inferred ! nuclides had been obtained from actual sample measurements by dividing the concentration of the difficult to measure nuclide ~by the concentration of i . . . . - ,_ - -. - - . - - .._.. . _ _ __ . - - _ - . _ -- - - . , - . - - _- -- .
. _ _ _ _ _ . . _ _ ' . . 7 . the easy.to measure radionuclide and using the resulting quotient as the. scaling factor. The inspector asked to review the data which indicated that the various. waste streams of the p' ant were adequately characterized by the four sample types listed above. The licensee stated that such an evaluation had not been performed. The inspector stated that in choosing a sample type for analysis that is different from the waste stream that is being classified and shipped, verification that the sample was representative of the waste stream was necessary. The inspector reviewed two waste shipments of compacted DAW, No. 85-57 shipped on September 26,1985 and No. 86-06 shipped on January 23, 1986. A licensee representative reviewed with the inspector the calculation of the radioactive content of the two shipments. It was determined that the scaling factors used for determining the concentration of the difficult to measure radionuclides for DAW had not been derived from the MWST as stated . previously, but instead, the scaling factors had been derived from reactor coolant activity. The licensee stated that in doing so, the final inferred activities should be more conservative since the concentration of
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radionuclides was greater in reactor coolant than in MWST liquid. The inspector stated that in developing scaling factors for a waste stream, the ratics of the concentrations of the various radionuclides to one another were the determining factors rather than the absolute concentrations of the nuclides. Failure to demonstrate that the radionuclide distribution of DAW was similar to that of MWST liquid or reactor coolant, was identified as an apparent violation of 10 CFR.20.311 (50-302/86-06-02). 11. Statistics a. Solid Waste During 1985_ the licensee had made 43 shipments of radioactive waste consisting of 17,643 cubic feet of waste containing 4595 curies of activity. At the time of the inspection, the waste inventory onsite was 2646' cubic feet. ] -b. Contaminated Areas i The licensee did not begin tracking.centaminated areas in the facility
until October 1985. On October 1,1985, approximately 21,000 square
feet of the plant were maintained as contaminated. As of January 1, 1986, this area had decreased to 12,500 square feet which represented approximately 18 percent of the total plant area. c. Collective Dose , I For 1985, the collective dose for the facility as measured by TLD was 646 man-rem. A collective dose of approximately 500 man-rem had been projected for 1985 but the length (24 weeks) and nature of the- outage resulted in an overshoot of the projection. . 4 w= - ,_ . y , _ _ . . _ _ . _ , _ _ _ _ . , _ _ _ . . _ _ _ , . ._ . _ . .
.- . 8 12. IE Information Notices (92717) The following IE Information Notices were reviewed to ensure their receipt and review by appropriate licensee management: IN-85-46 Clarification of Several Aspects of Removable Radioactive Surface Contamination Limits for Transport Packages. IN-85-43 Radiography Events at Power Reactors IN-85-42 Loose Phosphor in Panasonic 800 Series Badge Thermoluminescent Dosimeter (TLD) Elements IN-85-07 Contaminated Radiography Source Shipments IN-85-06 Contamination of Breathing Air Systems 13. Allegation Follow-up On September 28, 1984, a telephone call was received at Region II alleging that non-contaminated waste from the Crystal River facility was being dumped in the woods near the site rather than being taken to the land fill. The allegar expressed concerned about the possibility of ' improper disposal of contaminated ~ material. Follow-up of this concern by the licensee and by the State of Florida revealed that the owner of the property where the trash had been dumped had authorized disposal of the material o r, his land. Independently, the licensee and members of the State of Florida Health Department went to the area where material had been dumped and performed radiological surveys of the material. The results of both surveys revealed that there were several items with dose rates slightly above background, e.g., a piece of cinder block that read 25 microroentgens per hour and a piece of pipe that read 15 microroentgens per hour. The licensee identified these materials as waste from the two fossil units onsite along with a quantity of fly ash. The licensee stated that the practice at Crystal River was to assume that all material that entered the Radiation Controlled Area was contaminated and that all such waste was sent for disposal by land burial. The RPM stated that trash was never surveyed out of the RCA and released to unrestricted areas. He further stated that the licensee program focused on not carrying excess material into the RCA to begin with. Since trash is not released from the RCA, and since the two independent surveys of the dumped material did not corroborate the alleger's concern, improper disposal of contaminated material could not be demonstrated. The allegation was not substantiated. }}