ML20236E213
| ML20236E213 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/08/1989 |
| From: | Gloersen W, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236E207 | List: |
| References | |
| 50-348-89-04, 50-348-89-4, 50-364-89-04, 50-364-89-4, IEIN-88-008, IEIN-88-032, IEIN-88-034, IEIN-88-063, IEIN-88-079, IEIN-88-101, IEIN-88-32, IEIN-88-34, IEIN-88-63, IEIN-88-79, IEIN-88-8, NUDOCS 8903240017 | |
| Download: ML20236E213 (12) | |
See also: IR 05000348/1989004
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
o,
REGION 11
g
101 MARIETTA ST., N.W.
+,,,,
ATLANTA, GEORGIA 30323
MAR 0 89
Report Nos.: 50-348/89-04 and 50-364/89-04
Licensee: Alabama Power Company
600 North 18th Street
Birmingham, AL 35291-0400
Docket Nos.:
50-348 and 50-364
License Nos.:
Facility Name:
Farley 1 and 2
Inspection Con ucted:
February 6-10,
989
Inspector:/d/I
x_f e
S/7/d7
W.~B. Gloersen*
Dhte Signed
~
Approved by:
b
If,
3 / /// 9
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J. P./P tter, Chief
Date' Signed
9
Facilmes Radiation Protection Section
Emergency Preparedness and Radiological
Protection Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope
This routine, unannounced inspection was conducted in the areas of: radiation
protection preparation for the Unit 2 refueling outage scheduled for
March 24-April 26,1989; licensee responses to information notices; licensee
event reports; and followup on previous enforcement matters.
Results
In the areas inspected, one licensee identified violation (LIV) was identified.
The licensee's radiation protection program was assessed to be adequate in the
areas covered during the inspection.
Extensive efforts by the licensee in
securing existing high radiation areas with locking devices and identifying
potential high radiatior, areas, so that measures could be taken to secure those
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areas, were noted.
The licensee's three-year collective dose average
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(1985-1987) was below the national average for that same time period for a
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pressurized water reactor (PWR).
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REPORT DETAILS
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Persons Contacted
Licensee Employees
- S. Fulmer, Supervisor - Safety Audit and Engineering Review
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M. Graves, Health Physics Sector Supervisor
- D. Grissette, Chemistry and Environmental Supervisor
J. Higginbotham, Computer Services Supervisor
- R. Livingston, Environmental Supervisor
. N. Maddox, Senior Instructor, Technical Training
- M. Mitchell,.HP and Radwaste Supervisor
- D.'Morey, General Manager - Nuclear
~*C.'-Nesbitt, Technical Manager.
- J. Osterholtz, Manager - Operations
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P. Patton, Plant Health Physicist
- *D. Tedin, Sector Supervisor - Technical Training
J. Walden, Radwaste Supervisor, Safety Audit and Engineering Review
- L. Williams', Training Manager
Other licensee employees contacted during this inspection included
engineers, operators, technicians, and administrative personnel.
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Nuclear Regulatory Commission
G. Maxwell, Senior Resident Inspector
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- Attended exit interview
Occupational Exposure During Extended Outages (83729)
2.
Organization and Management Controls
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a.
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The health physics (HP) organization, staffing levels, and lines of
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authority as related to outage radiation protection activities were
The HP organization
discussed with licensee representatives.
consisted of an HP supervisor who reported directly to the' Technical
[
The Technical Manager, in turn, reported directly to the
Manager.
Manager of Plant Operations.
A Radwaste
Assistant GeneralSector Supervisor, and 'a Plant Health Physicist
Supervisor, HP
The remainder of the organization
reported to the HP Supervisor.
consisted of three radwaste and decontamination foremen, five HP
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foremen, an ALARA technician, two instrument technicians, one
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respirator technician, one surveillance technician, 23 senior HP
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technicians and one assistant technician, two radwaste technicians,
five radiation detection men, and 32 individuals who performed
During the upcoming outage,
painting and decontamination activities.the licensee plans to supple
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adding 66 . senior HP (ANSI qualified) technicians, 20 junior
technicians, and 30 laundry technicians.
It should be nated that the
Licensee
licensee operates three washers and dryers at the facility.
personnel will maintain supervision over the HP contract personnel to
assure procedure compliance and that an acceptable quality of work is
maintained.
The licensee's ALARA organization consisted of the plant HP and an
ALARA technician.
The ALARA committee was chaired by the plant .HP
.and ' consisted of representatives from the following departments:
maintenance, electrical maintenance, instrument and
mechanical
calibration, HP chemistry. reactor engineering, operations, systems
and-
performance, outage planning, training, security, storeroom,
The ALARA committee met at least six times per year to
corporate.
- discuss items such as ALARA goals, collective dose for .each major
department, ALARA action items (such as the out-of-core source
reduction program), and major radiation exposure jobs scheduled for
the upcoming outage.
No violations or deviations were identified.
b.
Audits-
The inspector reviewed the following audits conducted by the Safety
Audit and Engineering Review (SAER) Department:
HP Surveillance Test Procedures, conducted December 14,
1987-January 29, 1988
Radiation Work Permit (RWP), conducted March 30-June 10, 1988
Radiological Controls, SAER-WP-02, Appendix A,
conducted
July 18-September 19, 1988
Radioactive Waste Management, SAER-WP-31, Appendix A and B,
conducted August 29-October 18, 1988
Radioactive Material Shipment #88-49, SAER-WP-21, Appendix A,
conducted October 6-18, 1988
During this review, the inspector noted that the licensee tracked
deficiencies and noncompliance as Corrective Action Reports (CARS).
It was observed that all CARS were being tracked and were either
The inspector also observed
closed or in the process of closecut.
that the licensee's audit organization had acquired an individual
from the HP department to conduct audits in the radwaste and the HP
In general, the auditors were given three-year assignments
programs.
with the SAER Department and then they were rotated back into the
plant, not necessarily back to their original job.
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Although it appeared i. hat the licensee's audit program met the
minimum requirements, the inspector and the licensee discussed how an
HP program appraisal conducted by an independent organization (for
the corporate office), would provide a program
example from The licensee acknowledged the inspector's comments.
enhancement.
No violations or deviations were identified,
Training and Qualification (83723)
c.
The qualification process for a contract HP senior technician began
with the licensee reviewing the applicant's resume to determine that
the individual had either a four-year science degree with two years
experience in applied radiation protection or a two-year science
The licensee did not count
degree with three years experience.
as experience.
Before the HP contractor
decontamination work
training process commenced, the licensee required the individual to
pass an HP contract entrance examination on basic radiological
The minimum passing grade was 70 percent (%).
The period
physics.
The
of training for a new contractor was approximately 1.5 weeks.
involved the successful completion of
qualification process Each task required a review and discussion of
53 job-related tasks.
the applicable procedures and actual performance of all the steps of
Based on qualification records, the inspector observed
the job task.
that all senior contract HP technicians met or exceeded the minimum
qualification specified in ANSI N18.1-1971.
No violations or deviations were identified.
d.
Planning and Preparation
The inspector reviewed representative records and discussed outage
planning with licensee representatives to verify that necessary plans
and preparation were being made and that management support for
radiation protection was evident. Management support for specialized
The inspector observed that the licensee was
training was noted.
sending at least three individuals to the Westinghouse facility in
Pittsburgh, PA, for special training on the " super probe" used for
detailed ultrasonic testing of the steam generator (SG).
The
indicators of management support were also
following (additional
noted:
1) approvals of budgeted items (such as portable
instruments, vacuum cleaners for decontamination work, manway
shields, and lead blankets) needed for radiation protection during
the outage; (2) approval of visits by the radiation protection staff
to observe outage activities at other sites; and (3) inclusion of
radiation protection staff during outage planning meetings.
Additional)y, the inspector noted that during the fourth quarter
1988, the licensee had purchased several portable auxiliary
ventilation systems in order to minimize the need to use respiratory
protection equiptent.
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The inspector reviewed the significant radiological ' activities
The following
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planned for the Unit 2 sixth cycle refueling outage.
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activities were considered to.be the major radiation' exposure jobs:
Table 1
Estimated Dose (person-rem)
Activity
11
SG, Nozzle Dams
Installation / Removed
34
100% Eddy Current: Testing of
all'Three SGs including
4
Tube Plugging .
.
10
.SG "2C" Removal of Two Tubes
and Weld in Plugs
9
Secondary Side Sludge Cleaning
Sequence on all Three SGs
12
Reactor Head Disassembly /
Reassembly.
12
Snubber Inspection and Testing
25
Inservice Inspection (non--
destructive testing)
10
Containment Decontamination
9
Remov.e/ Replace Manways and
Diaphregms on Primary Side
of SGs
10
General Valve Maintenance
in Containment
The. licensee projected that approximately 275 person-rem would be
The licensee allowed
expended for the 1989 Unit 2 refueling outage.
In.
approximately 35 person-rem for increases' in the work scope.
contrast, the licensee estimated a collective dose of 340 person-rem
for the 1988 Unit 1, cycle 8 refueling outage. The actual collective
The 91 person-rem differential was
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dose was 431 person-rein.
attributed to unscheduled jobs and increases in the work scope, such
as, eddy current testing and tube plugging on the SGs, incore work,
reactor coolant pump motor inspections, and SG nozzle dams
installation and removal.
Additionally, the inspector compared the licensee's 1988 Unit i
refueling outage collective dose for several outage high-dose jobs
with the averages (for a Westinghouse' PWR) presented in Table 3-3,
NUREG/CR-4254, Occupational Dose Radiation and ALARA at Nuclear Power
Study on High-Dose Jobs, Radwaste Handling, and ALARA
Plants:
The following comparisons were made and discussed with
Incentives.
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the licensee:
Table 2
Collective Dose
(person-rem)
NUREG-4254 (Avg.)
Licensee
Job Title
1.
Snubber Inspection and Repair
110
31
.
50
44-
2.
3.
Reactor Disassembly / Assembly
- 48
18
47
4.
SG Tube Plugging
5.
In-service Inspection
46
24
6.
Plant Decontamination
45
17
30
13
7.
Primary Valve Maintenance
and Repair
8.
Scaffold Installation / Removal
30
9
9.
Reactor Coolant Pump Seal
17
6
Replacement
16
15
10. SG Manway Removal /
Replacement
12
5
11. . Instrumentation Repair and
Calibration
11
18
12. Secondary Side SG
Inspection and Repair
13.
Fuel Shuffle / Sipping Inspections
9
7
7
15
14. Operations-Surveillance Routines,
and Valve Lineups
6
2
15. Cavity Decontamination
16. Pressurizer Valve Inspection,
6
1
Testing, and Repair
17. Radwaste System Repair, Operation
5
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- This dose was included in SG eddy current testing category.
It should be noted that the licensee compared favorably with the
NUREG-4254 averages listed in Table 2.
The licensee exceeded these
averages in only two cases, namely secondary side SG inspection and
repair (11 person-rem vs. 18 person-rem) and operations-surveillance,
routines, and valve lineups (7 person-rem vs. 15 person-rem).
No violations or deviations were identified.
e.
Radiation Dose Goals
The inspector discussed with licensee representatives collective dose
In
statistics for 1988, and collective dose estimates for 1989.
1988, the licensee estimated a collective dose for both units of
490 person-rem (or 245 person-rem per unit).
The actual collective
dose for 1988 was 552 person-rem (or 276 person-rem for unit).
Since
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1983, the licensee's collective dose has been declining as
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illustrated in Table 3 below.
Table 3
Year
Collective Dose Per Reactor (person-rem)
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1983
478
1984
451
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1985
399
1986
429
1987
299
1988
276
The licensee's three-year (1985-1987) collective dose average was
below the national average for that same time period for a PWR
(376 person-rem vs. 297 person-rem).
For 1989, the licensee
projected a total collective dose of 772 person-rem.
Although this
projection was much higher than the 1988 projection, it should be
noted that the licensee has scheduled two refueling outages for 1989.
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No violations or deviations were identified.
f.
ALARA Goals and Initiatives
The inspector discussed with licensee representatives, several
methods for reducing out-of-core radiation sources and fields which
would offer the greatest potential for continued reductions in
occupational radiation exposure.
The licensee was in the process of
performing feasibility studies on the use of industry-developed
methods of controlling out-of-core radiation sources and fields.
Some of the methods discussed included:
(1) use of Zircaloy grids
(or low cobalt grids) in replacement fuel; (2) replacement of wearing
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valves with cobalt free alternatives; (3) upgrading of the component
valve packing program; (4) use of ultrafiltration techniques and
(5) control of crud transport (that is, water chemistry control
program).
The inspector also discussed the ALARA goals with licensee
representatives, including contamination control. The radiation dose
goals have been discussed in Section 2.e of this inspection report.
As of February 4,
1989, the licensee controlled approximately
11,412 square feet (ft2) out of a total area of 114,182 ft2 as
contaminated areas. This contaminated area represented approximately
9.9% of the total plant.
The licensee's goal was to keep the total
contaminated area below 10%.
In the containment, typical
contamination levels ranged from 2,000-4,000 disintegrations per
minute per 100 square centimeters (dpm per 100 cm2).
Additionally,
the inspector discussed personnel contaminations with licensee
representatives.
In 1988, the total number of skin and clothing
contaminations was 120.
This number was six times greater than the
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established by the licensee.
During 1987, the licensee
goal
experienced only 33 skin and clothing contaminations.
Although the
licensee's 1988 goal was established to improve upon the previous
For 1989,
year's performance, it was apparently an unrealistic goal.
the licensee established a personnel contamination goal of 100.
During 1988, the licensee did experience some personnel
contaminations involving discrete radioactive particulate
(that is,
" hot particles"); however, in all cases the contaminations were on
the clothing and involved insignificant skin doses.
The particles
were a mixture of activation products and fission products and
probably could be attributed to the failed fuel experience during
1982-1983.
No violations or deviations were identified,
g.
Transportation
,
10 CFR 71.5 requires that licensees who transport licensed material
outside the confines of its plant to other places of use, or who
deliver licensed material to a carrier for transport, shall comply
with the applicable requirements of the regulations appropriate to
the mode of transport of the Department of Transportation (DOT) in
49 CFR Parts 170 through 189.
The inspector reviewed selected portions of the follewing radwaste
shipments for the period January 14, 1988 through February 1, 1989:
Media
Shipment No.
Charcoal
88-16
88-28
Resin
88-44
Resin
Charcoal
89-03
The inspector determined that the licensee's selection of packages,
shipping manifests, vehicle surveys, and tracking of shipments were
The licensee has shipped a total of
performed as required.
122 shipments since the last violation which occurred in May 1985.
No violations or deviations were identified.
3.
Licensee Event Reports (92700)
The inspector reviewed Licensee Event Report (LER) 88-15, " Contractor
Received Total Dose of 1,252 millirem (mrem) for the Second Quarter 1988,"
to ascertain that the licensee's report and stated corrective actions were
timely and appropriate, that the licensee determined the cause of the
event, and that the licensee's Quality Assurance (QA) program practices
and procedures, when appropriate, were strengthened to prevent recurrence.
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16, 1988, when a Dosimetry Foreman, while
An event occurred on May
reviewing exposure reports for terminated radiation workers, noticed that
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a contractor who had performed work:at the licensee's Farley facility from
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May 6-12, 1988, had been extended beyond 1,250 mrem for the second quarter
1988 without a permanent record of his dose history.
The Form NRC-4 used
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to document the worker's dose history contained estimates by pocket ion
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chamber from two other licensee facilities.
The apparent cause of this
event was cognitive personnel error in that the HP Sector Supervisor who
approved an extension from 1,250 mrem per quarter for an " undocumented"
worker to 2,000 mrem per quarter for a " documented" worker failed to
follow HP procedures and performed an inadequate review of the dose
extension form. The licensee defined an " undocumented" worker as a. person
who provided only an estimated dose.
A " documented" worker.was one who
The contractor received 330 mrem
provided an actual record of his dose.
at the licensee's Farley facility w(hich, when added to his permanent
record dose from previous licensees received on May 18,1988) brought.his
dose to 1,252 mrem for the second quarter 1988.
Upon fur.ther review by
the licensee, it was determined later that the contractor *s home' office
apparently had. in its possession the documented radiation dose record of
' the worker, but delivered to the licensee the " undocumented" exposure
The
record of the worker for the first and second quarters of 1988.
licensee stated that there were no known previous similar events in the
last several years.
The licensee's corrective actions included counseling the HP Sector
Supervisor regarding this event.
Additionally, the licensee took the
following actions to prevent recurrence:
Licensee Form 942, of Procedure FNP-0-RCP-925, was revised so that
the phrase " undocumented worker" was highlighted on the top of the
,
Also highlighted on the form was that an undocumented
form.
individual could not exceed 1,250 mrem whole body dose per quarter
under any circumstances.
The plant's administrative limit was changed to 900 mrem per quarter.
To exceed the limit, an approval frem the General Manager was
required.
The licensee's computerized dose tracking system was revised so that
once an " undocumented" individual was logged into the system, the
computer program would not allow the system user to extend the
" undocumented" individual's dose beyond the 1,250 mrem per quarter
limit.
including the contributing causes, the
After reviewing this event,
inspector categorized this area as an apparent violation of 10 CFR 20.101,
Radiation Dose Standards for Individus1s in Restricted Areas, for
exceeding the whole body quarterly dose limits specified in the standard.
This regulation states, in part, that a licensee shall not cause an
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individual in a restricted area to receive in any period of one calendar
quarter a total occupational dose in excess of 1,250 mrem except as
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provided in 10 CFR 20.101(b).
The licensee did not meet the exceptions
specified in 10 CFR 20.101(b). This apparent violation was discussed with
.the licensee and Regional personnel and, since all of the requirements
-specified in 10 CFR Part 2, Appendix C, Section V.G. were satisfied, this
violation was not cited (LIV 50-348/89-04-01).
4.
Information Notices (92717)
The inspector determined that the following Information Notices (ins) had
been received by the licensee, reviewed for applicability, distributed to
appropriate personnel, and that action, as appropriate, was taken or
scheduled:
Chemical Reactions with Radioactive Waste Solidification
Agents
Misuse of Flashing Lights for High Radiation Area Controls
At the time of this inspection, the licensee was in the process of
preparing responses to the following ins:
Prompt Reporting to NRC of Significant Incidents Involving
Radioactive Material
Nuclear Material Control and Accountability of Non-fuel
Special Nuclear Material at Power Reactors
High Radiation Hazards from Irradiated Incore Detectors and
Cables
IN 88-101:
Shipment of Contaminated Equipment Between Nuclear Power
Stations
Licensee Actions on Previous Inspection Findings (92702)
5.
(Closed) Violation 50-348/87-28-01 and 50-364/87-28-01: Failure of a
licensee employee to wear the protective clothing required by a radiation
work permit.
The inspector reviewed the licensee's response provided in a letter to the
NRC dated December 8,1987.
Additionally, the inspector reviewed the
licensee's Corrective Action Report No.1443, dated November 30, 1987,
which also included a description of the adverse condition, sequence of
events, cause of adverse condition, and corrective actions.
The
licensee's response and corrective actions were adequate. Therefore, this
item is considered closed.
(Closed) Violation 50-348/88-02-01 and 50-364/88-02-01:
Failure to
control adequately access to a high radiation area (two examples).
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An enforcement conference was heid on February 17, 1988, to discuss the-
violation noted above.
Additionally, the inspector reviewed the
licensee's response provided in a letter to the NRC dated April 6,1988.
Example 1 of the violation involved the failure of two decontamination
workers to have in their possession one of the radiation monitoring
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devices required by Technical Specification 6.12.1 and failure to have a
HP qualified individual accompany the decontamination workers to maintain
positive control over the workers' activities.
Example 2 of the violation
involved the failure of the licensee to provide locked doors for a
radiological exclusion area as required by Technical Specification 6.12.2.
The licensee had used instead three yellow and magenta ropes, radiological
Upon review of the licensee's
warning signs, and a flashing red light.
response, it was determined by record review and direct observation that
the licensee's corrective actions were adequate. This item is considered
,
closed.
(Closed) Violation 50-348/88-02-02 and 50-364/88-02-02:
Failure to follow
28, 1987, (1) a decontamination worker
procedures in that on December
entered a high radiation / exclusion area with dose rates up to 150 rems per
hour at 18 inches from the spent fuel pool demineralized without having a
,
special RWP prior to entry; and (2) two individuals entered a high
to perform routine decontamination of articles and
radiation area
equipment without high range dosimeters'as required by the RWP.
An enforcement conference was held on February 17, 1988, to discuss the
violation noted above.
Additionally, the inspector reviewed the
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licensee's response provided in a letter to the NRC dated April 6, 1988.
The inspector and licensee representatives verified that all exclusion
areas outside containment were either locked or tagged in an inaccessible
It was observed that the licensee had made several plant
/
condition.
modifications to expand exclusion a ea boundaries whenever possible such
that access could be controlled by a locked door.
.The licensee had
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developed a priority list which identified additional areas in the plant
that could be controlled by a locked door to prevent unauthorized entries.
Exclusion area key control procedures were described in FNP-0-RCP-0,
16, 1989,
General Guidance to Health Physics Personnel, Rev.15, January
The HP foreman maintains custody of the key to
Section G-9, Key Control.
Exclusion area keys were kept in the HP key locker and
the HP key locker.
The procedure
only issued to qualified HP technicians by the HP foreman.
specified that exclusion area keys could not be exchanged between HP
Additionally, an
technicians without the permission of the HP foreman.
This item
inventory of exclusion area Keys was performed once per shift.
is considered closed.
50-348/88-02-04 and 50-364/88-02-04:
Failure to
(Closed) Violationinstruct adequately individuals working in or frequenting a restr
area.
An enforcement conference was held on February 17, 1988, to discuss the
t
violation noted above.
Additionally, the inspector reviewed the
licensee's response provided in a letter to the NRC dated April 6,1988,
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determined that the response was acceptable.
The licensee's
and
corrective actions included training on exclusion area controls for both
and contractors.
This training was conducted in
licensee personnel
The licensee incorporated exclusion area control procedures
January 1988.
into radiation worker basic training and retraining.
This item is
considered closed.
6.
Exit Interview
The inspector met with licensee representatives (denoted in Paragraph 1),
at the conclusion of the inspection on February 10, 1989.
The inspector
summarized the scope and findings of the inspection, including the LIV.
The inspector also discussed likely informational content of the
inspection report with regard to documents or processes reviewed by the
inspector during the inspection.
The licensee did not identify any such
documents or processes as proprietary.
Dissenting comments were not
received from the licensee.
Item Number
Description and Reference
50-348/89-04-01
LIV - violation of 10 CFR 20.101 for exceeding
the whole body quarterly dase limits specified in
the standard (Paragraph 3).
Licensee management was informed that the four violations discussed in
Paragraph 5 were considered closed.
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