ML20056E323

Insp Repts 50-348/93-16 & 50-364/93-16 on 930712-16. Violations Noted.Major Areas Inspected:Occupational Radiation Exposure

ML20056E323
Person / Time
Site:	Farley
Issue date:	08/09/1993
From:	Boland A, Forbes D, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20056E320	List: ML20056E319 ML20056E322 ML20056E323
References
50-348-93-16, 50-364-93-16, NUDOCS 9308230178
Download: ML20056E323 (17)

See also: IR 05000348/1993016

Text

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UNITED STATES

/, ja necg% NUCLEAR REGULATORY COMMISSION

3 "' 4 REGloN !!

$ E 101 MARIETTA STREET, N.W., SUITE 2900

j ATLANTA. GEORGI A 30323-0199

% s,..# AUG 12 I933  :

Report Nos.: 50-348/93-16 and 50-364/93-16

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Licensee: Southern Nuclear Operating Company, Inc.  !

600 North 18th Street

Birmingham, AL 35291-0400

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 l

Facility Name: Farley 1 and 2

Inspection Conducted: July 12-16, 1993

Inspectors: S.d. 9[9.3

D. B. Forbes Date S'igned  ;

D. B. MD /Jn

A. T. Boland

ekks .

Dat'e Signed

Approved by: Id.

William H~ Rankin, chi 99

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>k N/9!8

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Date Signed

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Facilities Radiation P 6tection Section >

Emergency Preparedness and Radiological [

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Protection Branch

Division of Radiation Safety and Safeguards

SUMMARY

Scope:

This routine, unannounced inspection was conducted in the area of occupational

radiation exposure. Specific areas examined included: organization and

management controls; audits and appraisals; training and qualifications;

planning and preparation; external exposure control; internal exposure

l control; control of radioactive materials and contamination, surveys and

monitoring; and maintaining occupational exposures As Low As Reasonably

Achievable (ALARA).

Results:

The Radiation Protection (RP) technician staff appeared knowledgeable and well

, trained. The licensee continued to implement effective internal and external

l exposure programs with all exposures less than 10 CFR Part 20 limits. The

audit and appraisal program was considered to be adequate in identifying

potential issues. Contamination control and overall housekeeping practices

were also considered adequate. Licensee efforts in the performance of ALARA

initiatives was determined by the inspector to be a program strength in

meeting ALARA goals. In the areas inspected, one violation was identified for

failure to label radioactive material as required by licensee procedure

(Paragraph 8.b), and one Inspector Followup Item was opened to review licensee

l 9308230178 930812

PDR ADOCK 05000343

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proce. dural changes, during a future inspection, for controlling and/or taping

vacuum nozzles / hoses when not in use (Paragraph 8.b). Based on records

review, plant inspections, and interviews with licensee management,

supervision, and personnel from station departments, the inspector found the  !

radiation protection program to be adequate in protecting the health and  !

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safety of plant employees.

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REPORT DETAILS

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1. Persons Contacted

Licensee Employees

• W. Bayne, Supervisor, Safety Audit Engineering and

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Review (SAER)

• J. Bouillon, Supervisor, Dosimetry  :

• G. Bouler, Health Physics Foreman

• C Buck, Technical Manager

! *M. Graves, Supervisor, Health Physics

! *R. Hill, General Plant Manager

• J. Kale, Superintendent, Chemistry and Environment

• M. Mitchell, Superintendent, Health Physics l

• J. Osterholtz, Assistant General Plant Manager  !

• B. Patton, Plant Health Physicist

• M. Stinson, Assistant General Plant Manager

J. Walden, Lead Auditor, SAER *

Other licensee employees contacted during this inspection included

craftsmen, engineers, operators, mechanics, security force members,  ;

technicians, and administrative personnel.

Nuclear Regulatory Commission  !

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• G. Maxwell, Senior Resident Inspector

• Attended July 16, 1993, Exit Meeting

2. Organization and Management Controls (83750)

Technical Specification (TS) 6.2.1 details, in part, the establishment

of onsite and offsite organizations for unit operation and requires that

the lines of authority, responsibility, and communication be established

and defined for the highest levels through intermediate levels to and

i including all operating organization positions.

The inspector reviewed changes made to the licensee's RP organization

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since the last NRC inspection of this area conducted during October 19-

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23, 1992, and documented in Inspectica Report No. 50-348,364/92-27.

Cognizant licensee representatives stated that the overall reporting

chain and management structure for the RP program had remained

unchanged. One engineering position had been added to the RP group to

assist in the research and development of technical issues and projects. ,

l One Health Physics (HP) Support Foreman position was vacant, however the l

! licensee stated that the position would be filled in the near future.

l The health physics staff employed approximately 46 personnel.

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The inspector discussed with licensee representatives the planned

staffing for the upcoming Unit 2 Refueling Outage - 9 (U2RF0-9)

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scheduled to begin in September 1993. Licensee representatives stated

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that approximately 20 junior and 73 senior contractor technicians were l

being considered to supplemeat the plant organization during the outage.

This level of additional technician support is consistent with previous

outages; however, the overall adequacy of final staffing to support the

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specific Unit 2 outage activities will be reviewed during a future

l inspection. Cognizant licensee personnel stated that Farley (FNP) was

anticipating an HP contractor returnee rate of 50 to 75 percent.

Based on discussions with licensee representatives and observations of

activities in progress, no concerns were identified regarding the

licensee's organization and staffing which was adequate to support

ongoing activities.

No violations or deviations were identified.

3. Audits and Appraisals (83750)

TS 6.5.2.8 requires audits of facility activities to be conducted under

the Manager, Safety Audit and Engineering Review (SAER) encompassing the

conformance of facility operation to the provisions contained within the

TS and applicable license conditions at least once per 12 months.

a. Audits l

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The inspector reviewed the SAER audits related to the RP program j

1 conducted since June 1992. Those particular audits reviewed i

included the following:

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Radiological Controls, SAER-WP-02, dated July 30, 1992, and

I conducted June 1 through July 30, 1992;

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Radioactive Waste Management, SAER-WP-31, dated November 3,

1992, and conducted August I through November 2, 1992;

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Spot Outage Activities, SAER-WP-21, dated December 21, 1992,

and conducted September 21 thorough December 15, 1992; and

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Surveillance Testing - Health Physics, SAER-WP-02, dated

January 8,1993, and conducted September 1,1992 through

January 5, 1993.

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The inspector noted the audits fulfilled the TS required frequency

for audits of the RP program, and at the time of the onsite

inspection a comprehensive audit of the RP program was underway.

Through review of the SAER audits and selected associated

checklists (SAER-WP-02, Appendix A) used to evaluate the RP

l Program, the inspector determined that the audits were detailed ,

and were sufficient in scope to include the major radiation

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protection functional areas. Discussions with one of the auditors

involved in the current audit as well as previous audits noted

that the evaluation included both review of documentation as well

as field observations. Further the inspector was informed that

during the current audit additional emphasis was being placed on

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field observations and walk-downs. With respect to the completed

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audits, no issues similar to the current inspection findings were

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noted. Non-compliances as well as areas for improvement (i.e.,  :

i " comments" in the audit reports) were documented, reported to i

licensee management, and tracked for completion of corrective "

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actions. The inspectors noted that actions on selected deficient >

areas were both appropriate and timely. The inspector informed

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licensee representatives that the results of the on-going audit

would be reviewed during future inspections. ,

Based on the review of this program area, the inspector concluded

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that the audit program related to the RP function was adequate to

identify program deficiencies and was conducted in accordance with

TS requirements.

j No violations or deviations were identified.

b. Radiological Incident Reporting System

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i The inspector reviewed the licensee's RP internal program for

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identifying and correcting deficiencies and weaknesses related to i

radiation exposure and the control of radioactive material. The

program consisted of the Radiation Incident Report (RIR) and the

Radiation Incident Warning (R W) administered through Radiation

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Control Procedure FNP-0-RCP-10, Revision (Rev.) 22. The inspector

reviewed this procedure and discussed the program with cognizant

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licensee personnel. Procedure FNP-0-RCP-10 provides specific

criteria for the generation of RIRs which includes events such as:

(1) violation of Radiation Work Permit (RWP) requirements;

(2) mispositioning of dosimetry resulting in oceater than a

25 percent deviation in dose; (3) exceeding administrative

exposure limits by a specified margin; (4) personnel contamination ,

i events (PCEs) of 2 5000 disintegrations per minute per 100 square {

centimeters (dpm/100 cm2); and (5) failure to secure exclusion i

area doors. The RIR program includes a structure for documentation

of the events, assessment of the event severity, management

review, and followup. The RIW program includes identification and  ;

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documentation of lower threshold events similar to those noted i'

, above (i.e., PCE 2 1000 dpm/100 cm2). Repetitive individual RIWs

result in the issuance of an RIR. At the time of the inspection,

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licensee was in the process of implementation a change to the RIW

i program to provide a means of also documenting good or improved

i work practices performed by individuals or groups.

The inspectors reviewed the RIRs for 1993, and noted no

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significant trends or indicators of programmatic problems. Only i

two RIRs had been written in 1993. For the cases reviewed,

corrective actions appeared adequate, and the appropriate level of '

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attention appeared to be given to identified deficiencies. Based

on the low number of RIRs, the inspector discussed with cognizant

licensee personnel, the threshold for identifying an RIR.

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l No violations or deviations were identified. ,

l 4. Training and Qualifications (83750)

During processing into the FNP facility, the inspector was provided  :

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training normally given NRC personnel for site access. The inspector j

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reviewed the General Employee Training (GET) Handbook provided by the

j licensee, and training in FNP site specific aspects of the handout was '

provided by cognizant plant personnel. Practical abilities training on

i donning and removal of protective clothing (PCs) as well as other

requirements specified for entering and exiting Radiologically

1 Controlled Area (RCA) such as logging into areas using Digital Alarming

i Dosimeters (DADS), reviewing RWPs, and performing a whole body frisk  ;

! were included. The inspector also reviewed licensee procedure FNP-0-AP- '

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45, Farley Nuclear Plant Training Plan, Rev.12, dated May 26,- 1993,

which provided the training requirements for various elements of the i

program including, radiation worker training, continuing training, and i

RP technician and supervisory training. Overall program content, l

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frequency of retraining, and the required level of proficiency

j demonstration were addressed. No concerns were noted.  !

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The inspector also discussed training on the new 10 CFR Part 20 with  !

health physics personnel. This training was included as part of a  !

continuing training program to prepare health physics personnel for

procedural changes to be implemented January 1, 1994. Based on these

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discussions licensee activities in this area appeared appropriate.

No violations or deviatior : were identified. i

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5. Planning and Preparation (33750)

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During the onsite inspection, the inspector observed briefings conducted

for workers prior to entering the RCA to perform a filter change out on

a refueling pool portable pump used to maintain water clarity, a resin

i transfer evolution, and a resin charging evolution, all of which

a involved entrance by workers into posted Exclusion Areas (a locked High

Radiation Area at FNP constitutes an Exclusion Area). The pre-job

briefings included reviews of current radiation surveys with emphasis on

high dose areas and low dose waiting areas. The interaction during the i

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pre-job briefings between RP and the workers entering the RCA, in this '

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regard, was considered adequate. The planning and preparation for these '

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evolutions and the work documents used during the evolutions were

discussed with licensee representatives. The inspector observed the i

radiological controls exercised by workers during the performance of the i

resin transfer to be in accordance with the pre-job briefing and RWP

requirements. The inspector did not observe the other two evolutions

being performed; however, review of the survey documentation upon

, completion of the evolutions noted no concerns,

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The inspector discussed the planning and preparation for the upcoming

'J2RFC- 9. Specific areas discussed included increases in staffing,

special training, equipment and supplies, health physics involvement in

outage planning, licensee control over health physics technicians, dose

reduction methods to be employed, and the major work scope to be

performed. Steam generator repairs and inspections will be the major

dose contributor during U2RF0-9. The licensee is evaluating steam

generator work enhancements in an effort to reduce dose. These

enhancements would include decontamination of steam generator channel

heads and the future use of robotics to minimize exposure during nozzle

dam installation.

No violations or deviations were identified.

6. External Exposure Control

10 CFR 20.101 requires that no licensee shall possess, use, or transfer

licensed material in such a manner as to cause any individual in a

restricted area to receive in any period of one calendar quarter a total

occupational dose in excess of 1.25 rem to the whole body, head and

I trunk, active blood forming organs, lens of the eyes, or gonads; 18.75

l rem to the hands and forearms, feet and ankles; and 7.5 rem to the skin

of the whole body.

l a. Personnel Dosimetry

10 CFR 20.202(a) requires each licensee to supply appropriate

j monitoring equipment to specific individuals and requires the use

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of such equipment.

10 CFR 20.202(c) requires that dosimeters used to comply with 10

CFR 20.202(a) shall be processed and evaluated by a processor

accredited by the National Voluntary Laboratory Accreditation '

Program (NVLAP) for the types of radiation for which the

individual is monitored.

The inspector reviewed and discussed the licensee's dosimetry

program with site personnel and determined licensee dosimetry was

being processed under NVLAP certification by plant personnel on a

monthly bases. The licensee was currently evaluating processing

dosimetry on a quarterly bases in lieu of monthly processing. The

licensee employed a 3 chip, TLD-700 card thermoluminescent

dosimetry (TLD) system for assessment of the dose of record and a

real-time DAD system as a secondary dosimeter for all persons

entering the RCA. For the DADS, the licensee had implemented four

warning alarm set-points at 25, 50, 75, and 90 percent of the ,

allowable Radiation Work Permit (RWP) dose for an entry, the  !

l latter of which required manaatory personnel r.xit from the area. '

During tours -of the plant the inspector observed personnel wearing

appropriate monitoring devices on the location of the body as

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specified by the RWPs.

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For determining neutron whole body exposure the inspector noted

that the licensee primarily utilized portable instrumentation

measurements and stay-times to calculate the correrponding whole 1

body dose. However, if quarterly neutron doses were expected to I

exceed the administrative limit of 270 millirem (mrem), the

licensee also had provisions for obtaining neutron dosimetry from

l a vendor. Licensee representatives stated that no neutron

dosimetry had been issued during the last year. During the

inspection an at-power containment entry was made under Special i

RWP 2-93-0337-A, Local Leak Rate Testing of the Auxiliary  !

Personnel Hatch. Review of associated surveys and documentation l

noted that appropriate neutron surveys were performed and  ;

resultant doses calculated. For this specific evolution the j

maximum neutron whole body dose assigned was 5 mrem.  ;

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No violations or deviations were identified.

b. Whole Body Exposure l

The inspector reviewed and discussed with licensee representatives

external exposures for plant and contractor employees for the  ;

period October 1, 1992 through June 30, 1993. Through review of l

dose information, the inspector confirmed _that all whole body 1

exposures assigned during the period were within 10 CFR Part 20 )

limits. For the fourth quarter 1992 and the first and second '

quarters of 1993, the maximum cumulative doses for individuals i

employed at the site were as follows: l

l 4th Quarter 1st Quarter 2nd Quarter ,

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1992 1993 1993 l

Whole Body (WB) 1103 mrem 380 mrem 194 mrem

l Dose

WB Skin Dose 1224 mrem 600 mrem 465 mrem

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l Extremity Dose 2588 mrem 1930 mrem 1163 mrem

Neutron WB Dose 31 mrem 47 mrem 28 mrem

As of June 30, 1993, the licensee's person-rem exposure was

approximately 25.5 person-rem for the year and was 65~ percent of

the year-to-date projection. The dose was primarily attributable

to normal operational conditions; however, it also included

exposure expended during two forced outages, approximately 4.1

person-rem for the Unit 2 pressurizer. safety valve work and

approximately 0.550 person-rem for the Unit I conoseal repair

work. In addition, approximately 2.4 person-rem had been expended

!- to replace the bladders on two reactor hold-up tanks (RHTs). The

licensee had established an annual-1993 person-rem goal of

l approximately 337 person-rem which included the tentative work  ;

scope included in U2RF0-9. 4

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Based on the review, the inspector noted no concerns regarding

individual doses nor the licensee's management of collective dose.

Overall, dose expended appeared commensurate with the state of

operation and work performed.

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No violations or deviations were identified

c. Exposure to the Skin

Licensee Procedure FNP-0-RCP-190, Skin Dose Assessment Due to

Contamination on Personnel Skin or Clothing, Rev. 6, dated March

22, 1993, requires that a skin dose assessment be performed if a

contamination event results in an exposure of 0.198 microcurie-

hours ( Ci-brs). In addition, this procedure provides guidance on

the methodology to be employed for assessment of the dose,

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including the use of the VARSKIN code.

The inspector reviewed selected contamination events for the

l period November 1, 1992 through July 14, 1993. For the events

! reviewed, the inspector noted that dose assessments were performed

and exposure records updated, as required. In most cases the

exposures were relatively minor. The maximum dose assigned from a

skin exposure was 1.659 rem associated with a hot particle

exposure to the forehead (Report No.92-112) for a worker involved

in local leak rate testing. Review of the licensee follow-up

actions and assessments for this event noted no concerns regarding

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the methodology employed or the dose assigned.

No violations or deviations were identified.

7. Internal Exposure Controls (83750)

10 CFR 20.103(a)(1) states that no licensee shall possess, use, or

transfer licensed material in such a manner as to permit any individual

in a restricted area to inhale a quantity of radioactive material in any

period of one calendar quarter greater than the quantity which would

result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform

l concentrations of radioactive material in air specified in Appendix B,

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10 CFR 20.103(b) requires that when an individual exceeds 40 Maximum

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Permissible Concentration-hours (MPC-hours) in any consecutive seven day

period, the licensee shall make such evaluations and take such action

necessary to assure against recurrence.

a. Bioassay and Exposure Tracking

10 CFR 20.103(a)(3) requires, in part, that the licensee, as

appropriate, use measurements of radioactivity in the body,

measurements of radioactivity excreted from the body, or any

combination of such measurements as may be ncc2ssary for timely

detection and assessment of individual intakes of radioactivity by

exposed individuals.

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Licensee Procedure FNP-0-RCP-10, Radiation Incident Reports, PCEs, l

and Radiological Warnings, Rev. 22, dated February 2,1993, j

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requires that follow-up whole body analyses be performed whenever .

contamination is identified in the ares of the mouth or if  !

positive nasal or wound contamination is identified. Review of ,

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selected PCEs for the period November 1, 1992 through July 14, '

1993, reporting positive facial contamination, the inspector

verified that whole body analyses were performed as required by

procedure. For the cases reviewed, the bioassays indicated that'  !

uptakes were all less than three percent of the maximum j

l permissible organ' burden (MP0B), the licensee's administrative  ;

threshold for further follow-up. Additionally, the inspector was  ;

informed that to date in 1993, no positive whole body analyses had' i

been identified. l

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Licensee Procedure FNP-0-DOS-301, Bioassay Sampling and Analyses, l

Rev. 3, dated November 6,1992, also provides guidance for the '

routine bicassay sampling and analyses for potential tritium

uptakes associated with workers handling primary reactor coolant.

The procedure provides for quarterly sampling of selected

personnel and established an action level of.3 percent maximum

permissible body burden (MPBB). Review of recent quarterly

information noted that approximately 11-12 personnel were selected

each quarter for participation in the program, and no. results in

excess of the 3 percent MPBB were identified. No concerns were

noted with the licensee implementation of this aspect of the

bioassay program.

The inspector also reviewed the licensee program for tracking and

assigning Maximum Permissible Concentration-hour (MPC-hr)

exposure. The inspector noted that the licensee reported

cumulative weekly and quarterly MPC-hr exposure by individual on

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the daily dose report, and that the weekly exposures were tracked

on a rolling seven-day period, as required. Review of fourth

quarter 1992 and 1st and 2nd quarter 1993 data determined the

maximum individual quarterly exposure assigned was' l.2 MPC-hrs,

. well below the 40 MPC-hr control limit requiring additional

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The inspector also reviewed and discussed with licensee l

representatives the operation and maintenance of the whole body

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- counting system. The licensee employees a stand-up geometry

counter. located at the dosimetry office as well as a chair l

geometry counter located at the-Training Center. Review of

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trended' calibration check and background data for the standup

geometry counter noted no concerns regarding system operation or

stability. The inspector noted that' appropriate _ quality-control

checks were performed during the week of the inspection in

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) accordance with procedure FNP-0-DOS-301, Operation of and

Standardization of the Canberra Nuclear Standup Whole Body

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g Counter, Rev. 10, dated August 25, 1992.

Based on the above, the inspector noted that the licensee was

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appropriately controlling internal exposures.

! No violations or deviations were identified.

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b. Respiratory Protection Equipment and Breathing Air Quality

30 CFR 11.121 requires that compressed, gaseous breathing air

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meets the applicable minimum grade requirements for Type 1 gaseous

air set forth in the Compressed Gas Association (CGA) Commodity

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Specification for Air, G-7.1 (Grade D or higher quality).

The inspector examined respiratory equipment for physical

integrity which included selected compressors, breathing air

manifolds, respirators, and bubble hoods. The inspector observed

gauges in use were currently calibrated and carbon monoxide

monitoring was being performed. In addition, the inspector

further noted that the supplied air hoods, fittings, and hoses

available for use were compatible per manufacturer's instructions.

Selected training records, medical qualifications, and fit test ,

records for individuals qualified to wear respiratory equipment I'

were also reviewed by the inspector. An individual's

qualifications for wearing respiratory equipment are provided on a

computer screen at the respiratory issue station. Discussions

were held with licensee representatives on testing and qualifying

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breathing air as Grade D. For the tests reviewed, breathing met

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Grade D requirements.

! No violations or deviations were identified.

4 B. Control of Radioactive Material and Contamination, Surveys and

Monitoring (83750)

a. Surveys l

The licensee is required by 10 CFR 20.201(b), 20.401, and 20.403

to perform surveys and to maintain records of such surveys

necessary to show compliance with regulatory limits.

The inspector reviewed selected records of radiation and

contamination surveys performed during 1993 and discussed the

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survey results with licensee representatives. During tours of the

plant the inspector observed health physics technicians performing

radiation and contamination surveys. No concerns were identified.

During facility tours, the inspector independently verified

radiation and/or contamination levels in selected areas of the

Radwaste Building, the Auxiliary Building, and radioactive

material storage areas. With the exceptions noted in the

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following paragraph, the inspector noted that all containers,

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material, and areas were properly labeled, posted, and/or

j safeguarded in accordance with the radiation hazard present.

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No violations or deviations were identified.

i b. Posting and Labeling ,

l 10 CFR 20.203(f)(1) and (2) require, in part, for containers,

except as provided in Paragraph (f)(3), that each container of

licensed material shall bear a durable, clearly visible label

i identifying the radioactive contents. The label is to bear the

radiation symbol and the words " CAUTION RADI0 ACTIVE MATERIAL" or

" DANGER RADI0 ACTIVE MATERIAL." It shall also provide sufficient ,

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information (as appropriate, the information will include '

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radiation levels, kinds of materials, estimate of activity, etc.)

to permit individuals handling or using the containers, or working i

in the vicinity there of, to take precautions to avoid or minimize  !

j exposure.

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3 TS 6.11 states that procedures for radiation protection shall be

i prepared consistent with the requirements of 10 CFR Part 20 and

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shall be approved, maintained and adhered to for all operations ,

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involving personnel radiation exposure.

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During tours of the plant and selected outside radioactive

material storage areas, the inspector noted that radioactive '

i material areas were appropriately posted; however, multiple

i examples of the failure to label radioactive material in

accordance with licensee procedures was identified by NRC

inspectors.

Licensee procedure FNP-0-RCP-57, Radioactivity and Potentially

Radioactive Material Handling, Rev.18, requires, in part, the

i following: (1) Paragraph 3.0 - Items are considered radioactive

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when the items / materials do not meet the Unrestricted Area Release

Criteria of licensee procedure FNP-0-RCP-29, when the

items / material arrive onsite marked as radioactive material, or

when directed by an HP Supervisor; (2) Paragraph 3.1 - Containers

which have items / materials that have been determined to be

radioactive by a HP-representative shall be identified as

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radioactive material using the appropriate bags, tags, labels,

signs and/or the use of orange paint (e.g. orange paint on tools,

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mop buckets, etc.); (3) Note: Plastic bags, items wrapped in poly,

tool boxes, drawers and drums are considered containers; and

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(4) Note: Installed Plant equipment is exempt from the requirement

of being identified as. radioactive material unless otherwise

specified by procedural requirements or HP Supervision. ,

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Licensee procedure FNP-0-RCP-0, Paragraph 6.1 specifies the use of

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yellow material with symbols indicating Radiological Use, (e.g. '

bags, plastic, and herculite shall be restricted for RCA use ,

purposes only to reduce a potential radiological problem.

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Contrary to the above procedures, the inspector identified  !

• containers / material (e.g. four unlabeled bags of used contaminated

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protective clothing, one open laundry size bag of contaminated

rags, a contaminated personnel safety sling / hook wrapped in

plastic, and a wrench with fixed contaminatior.) which required

labeling / marking in accordance with FNP-0-RCP-57 because the

containers / material did not meet the Unrestricted Release Criteria

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specified in FNP-0-RCP-29. Although the items were contained  !

"

within yellow material / containers, they were not labeled as

radioactive material in accordance with FNP-0-RCP-0. Licensee

representatives were informed these examples constituted a

violation (VIO) for failure to label containers of radioactive

material as required by licensee procedures (VIO 50-348,364/93-

16-01). The licensee initiated immediate corrective action to

label the containers / material.  ;

In addition, during the inspection the inspector identified six

internally contaminated vacuum cleaners with open inlet nozzles in

the RCA. The licensee's procedure required tira vacuum

' nozzles / hoses to be taped after use in the contaminated Area to

prevent contamination from breaching the vacuum cleaner canister

into non-contaminated areas. But, the procedure did not

specifically address the issue of covering the vacuum

nozzles / hoses after use in the RCA. Two internally contaminated

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vacuum cleaners were observed in the RCA with taped inlet nozzles. l

Discussions concerning the procedural intent for covering the '

vacuum nozzles / hoses varied among HP personnel based on the

individual's interpretation of the procedure. Cognizant licensee

HP personnel -informed the inspector the procedure would be revised

for clarity to insure the procedural intent of taping vacuum

' nozzle / hoses after use in contaminated areas /RCAs is clearly

understood. The inspector informed licensee representatives that

procedural changes to clarify taping of vacuum cleaner

nozzles / hoses after use in an RCA would be tracked as Inspector

Followup Item (IFI: 50-348,364/93-16-02).

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One NRC-identified violation (VIO) was identified.

c. High Radiation Areas

TS 6.12.1 requires, in part, that each High Radiation Area (HRA)

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with radiation levels greater than or equal to 100 mrem /hr but

less than or equal to 1000 mrem /hr be barricaded and conspicuously

posted as a HRA. In addition, any individual or group of

individuals permitted to enter such areas are to be provided with

or accompanied by a radiation monitoring device which continuously

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indicates the radiation dose rate in the area or a radiation

monitoring device which continuously integrates the dose rate in

the area, or an individual qualified in radiation protection

procedures with a radiation dose rate monitoring device.

During tours of the Auxiliary Building and the Radwaste Building,

the inspector noted that all HRAs and locked HRAs were locked

and/or posted, as required. The inspector performed independent

radiation surveys at the boundaries of selected HRAs and locked  ;

HRAs verifying licensee survey results. The licensee's posting of

the affected areas was conservative and appropriate.

No violations or deviations were identified,

d. Personnel and Area Contamination *

The inspector reviewed the licensee's program to control

contamination at its source. The licensee maintained

approximately 138,000 square feet (ft*) of floor space as

radiologically controlled, excluding the containment. According

to licensee representatives, at the time of the inspection,

I

approximately 7 percent of this floor space was considered

contaminated. This area is similar to that level of contaminated

floor space maintained by the licensee during 1992.

!

As of July 14, 1993, approximately 13 PCEs had occurred during the

year. The rate of occupance represented improved performance with

respect to 1992 in which approximately 285 PCEs occurred. Review ,

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of selected contamination events for the period November 1, 1992,

through July 1, 1993, noted that licensee documentation and

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followup on the individual events was appropriate.

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During facility tours, the inspector noted that contamination

control and general housekeeping practices were adequate.

No violations or deviations were identified. ,

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e. Radiation Detection and Survey Instrumentation  !

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During facility tours, the inspector noted that survey

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instrumentation and continuous air monitors in use within the RCA  !

were operable and displayed current calibration stickers. The

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inspector further noted an adequate number of survey instruments

were available for use, and background radiation levels at

personnel survey locations were observed to bE within the

licensee's procedural limits.

No violations or deviations were identified.

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9.

Operational and Administrative Controls (83750)

a.

Radiation Work Permits (RWPs)

The inspector reviewed selected routine and special RWPs for

i adequacy of the radiation protection requirements based on work

scope, location, and conditions. For the RWPs reviewed, the

inspector noted that appropriate protective clothing, respiratory

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protection, and dosimetry were required. During tours of the

plant, the inspector observed the adherence of plant workers to

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the RWP at

workers requirements

the job site.and discussed the RWP requirements with plant

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The inspector reviewed radiological status boards used to enhance

RWP survey information. These status boards are posted at the

' access to the RCA. The status boards contained current survey

information and were color coded to emphasize particular l

radiological areas such as high radiation areas and locked high  !

radiation areas.

The inspector found the licensee's program for RWP implementation

to adequately address radiological. protection concerns, and to

provide for proper control measures.

No violations or deviations were identified.

b. Notices to Workers

10 CFR 19.ll(a) and (b) require, in part,- that the licensee post

current copies of 10 CFR Part 19, Part 20, the license, license

conditions, documents incorporated into the license, license

amendments and operating procedures, or that a licensee post a

notice describing these documents and where they be examined.

10 CFR 19.11(d

to Employees. ) Sufficient copies of the requited forms are to

posted to permit licensee workers to observe them on the way to or

from licensee activity locations.

During the inspection, the inspector verified that NRC Form-3 was

posted properly at plant locations permitting adequate worker

access.

In addition, notices were posted referencing the location

where the license, procedures, and supporting documents could be

reviewed.

No violations or deviations were identified.

10.

Program for Maintaining Exposures As Low As Reasonable Achievable

(83750) 1

10 CFR 20.l(c) states that. persons engaged in activities under licenses

issued by the NRC should make every reasonable effort to maintain

radiation exposures as low as' reasonably achievable.

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Regulatory Guides 8.8 and 8.10 provide information relevant to attaining

goals and objectives for planning and operating light water reactors and

provide general philosophy acceptable to the NRC as a necessary basis

l for a program of maintaining occupational exposures as low as reasonably

achievable (ALARA).  ;

The inspector reviewed the following procedures associated with ALARA  ;

program implementation:  ;

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FNP-0-RCP-8, Radiation Control and Protection Procedures, Rev. O,

dated April 28, 1992

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FNP-0-RCP-14, ALARA Suggestions and Evaluations, Rev. 4, dated  !

January 1, 1993

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FNP-0-RCP-19, Pre and Post Job Planning For Work In Radiation

Controlled Areas of the Plant, Rev. 7, dated January 1,1993  ;

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FNP-0-AP-90, ALARA Policy and Implementation, Rev. O, dated June

16, 1992

The inspector reviewed and discussed with cognizant licensee

representatives ALARA program implementation and initiatives for U2RF0-9

and operations during non-outage periods. The licensee has formulated

an Exposure Reduction Plan by which FNP plans to achieve their projected

exposure goals through 1997. The plan identifies objectives and l

l specific actions that can accomplish exposure reduction goals. The l

! exposure reduction plan emphasizes reduction of exposure in three basic 1

l categories which include overall outage exposure, exposure incurred for

j maintenance by station maintenance personnel and particularly contract

maintenance personnel during outages, and exposure incurred associated

with steam generator work during outages.

Discussions with ALARA personnel and workers involved in U2RF0-9

l

activities revealed several dose reduction efforts. Some of these

efforts included: (1) increased use of temporary shielding based on

engineering analyses; (2) increased use of video such as cameras and

expanding the surrogate tour and including Unit I for briefing

personnel; (3) improved teledosimetry and computer tracking usage to

better monitor individual doses during specific high dose evolution;

(4) ordering and scheduling replacement of valves containing stellite "

with non-stellite valves to reduce the cobalt source term in the plant;

(5) chemical decontaminations of isolated systems; (6) use of water

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shields, (7) Increased use of robotics such as mini submarines used in

pools and reactor vessels during inspections; (8) improved soft chemical

shutdown procedures; (9) sub-micron filtration; (10) replacement of fuel

bundles with inconnel fuel spacers rather than materials containing

cobalt; (11) improved plant chemistry including elevated ph with

Boron / Lithium Management; and (12) nickel / cobalt removal during plant

startup. Other ALARA initiatives are being implemented or evaluated by

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the licensee for future use. The licensee is actively pursuing the use

1 of zinc injection during operation to reduce source term activity in the

! reactor plant piping. The licensee is evaluating installing the nozzle

'

ports for the zinc injection during the next refueling outage.

Further, the inspector reviewed ALARA/RWP packages for selected work

i activities associated with the two forced outages as well as the RHT

l bladder replacement project. ALARA personnel are responsible for review

and approval of all special RWP to ensure appropriate evaluations are

performed and protective requirements incorporated. In particular, for

the bladder replacement, the inspector noted that appropriate measures

were implemented to reduce exposures to the extent possible, and

3

improvement items for incorporation into future evolutions were well

documented for incorporation into similar, future evolutions. Based on

the limited review, no concerns were noted regarding ALARA involving in

'

work planning.

1 The inspector reviewed selected ALARA Committee Meeting minutes held by

j the licensee to discuss performance indicators year to date, ALARA

suggestions, assignment of action items, and completion of action items.

The inspector also reviewed ALARA Committee Meeting attendance rosters

and verified management involvement in the overall ALARA process. The

l inspector discussed with cognizant . licensee representatives FNP plans to

improve ALARA training and implement programs to increase ALARA

awareness among workers.

In general, based on the above, the inspector found ALARA initiatives to

be a program strength in support of ongoing' operations and future dose

reductions, particularly during outages.

No violations or deviations were identified.

11. Exit Meeting (83750)

At the conclusion of the inspection on July 16, 1993, an exit meeting

, was held with those licensee representatives indicated in Paragraph 1 of

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this report. The inspector summarized the scope and findings of the

inspection. One potential violation and one Inspector Followup Item

, were identified. The licensee did not indicate any of the information

provided to the inspectors during the inspection as proprietary in

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nature.

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Item Number DescriAtion and Reference

50-348,364/93-16-01 VIO - Failure to label radioactive

material as required by licensee procedure

(Paragraph 8.b).

50-348,364/93-16-02 IFI - Review procedural changes to clarify

requirements for taping vacuum cleaner

nozzles / hoses (Paragraph 8.b).