IR 05000250/1978011

IE Inspec Repts 50-250/78-11 & 50-251/78-11 on 780619-23 During Which 4 Items of Noncompliance Were Noted:Control of High Radiation Areas;Health Physics Procedures;Periodic Leak Test;Health Physics Retraining Program

ML17338A259
Person / Time
Site:	Turkey Point
Issue date:	10/24/1978
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17338A254	List: IR 05000250/1978011 ML17338A255 ML17338A257
References
50-250-78-11, 5000251-78-11, NUDOCS 7811030178
Download: ML17338A259 (18)

Text

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+ y**4 UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

230 PEACHTREE STREET, N. W. SUITE 1217 ATLANTA,GEORGIA 30303 Report Nos.:

50-250/78-11 and 50-251/78-11 Docket Nos.:

50-250 and 50-251 License Nos.:

DPR-31 and DPR-41 Licensee:

Florida Power and Light Company 9250 West Flagler Street Miami, Florida 33101 Facility Name:

Turkey Point Units 3 and

Inspection at:

Turkey Point Site, Homestead, Florida Inspection conducted:

June 19-23, 1978 Inspectors:

G. L. Troup

C.

M. Hosey R.

W. Zavadoski Approved by:

A. F. Gibson, Chief Radiation Support Section Fuel Facility and Materials Safety Branch Date Ins ection Summar Ins ection on June 19-23 1978 (Re ort Nos.

50-250/78-11 and 50-251/78-11)

Areas Ins ected:

Routine, unannounced inspection of radiation protection program including qualifications of health physics personnel, audits of the radiation protection program, training, procedure changes and compliance with procedures, instruments and equipment, exposure control, posting, labeling and control, surveys, notifications and reports and followup on previously identified items.

The inspection involved 96 inspector-hours on-site by three NRC inspectors.

Results:

Of the eleven areas inspected, no apparent items of noncompliance or deviations were identified in seven areas; four apparent items of non-compliance were identified in four areas (infraction control of high radiation areas (78-11-01); infraction compliance with health physics procedures (78-11-02); infraction periodic leak test of radioactive sources (78-11-04); infraction implementation of health physics retraining program (78-11-05)).

RII Report Nos. 50-250/78-11 and 50-251/78-11 DETAILS I Prepared by:

G. L.

ro p, Rad ation Specialist Radiation Support Section Fuel Facility and Materials Safety Branch Date Dates of Inspectio

Jun 9-23, 1978 Reviewed by:

AD F. Gibson, Chief Radiation Support Section Fuel Facility and Materials Safety Branch Date l.

Individuals Contacted-H. E. Yaeger, Plant Manager-J.

K. Hayes, Plant Superintendent, Nuclear-H. F. Storey, Corporate Health Physicist-R. J.

Spooner, Quality Assurance

- Operations Supervisor

+D.

W. Jones, Quality Control Supervisor

• D. W. Haase, Technical Supervisor

• J. S.

Wade, Jr.,

Chemistry Supervisor-E.

R. I,aPierre, Radiochemist-J.

M. Puckett, Health Physics Operations Supervisor-A. T. Hall, Results Assistant The inspector also talked with and interviewed other licensee employees, including health physics shift supervisors, radiation protection men, operations personnel and members of the technical staff.

Denotes those attending the exit interview.

2.

Iicensee Action on Previous Ins ection Findin s (Open)

Noncompliance (50-250/77-5; 50-251/77-5):

Controls for access to high radiation areas.

The licensee's actions as stated in FPSL's letter L-77-180 of June 16, 1977 and supplemented by FPSL's letter L-77-272 of August 31, 1977 have not been completed.

This item remains open.

(Closed)

Noncompliance (50-250/77-9; 50-251/77-9):

Surveys for airborne radioactivity in steam generators.

The licensee has completed the evaluation of charcoal filter efficiencies, has received supporting laboratory data and has factored the efficiencies into the

RII Report Nos. 50-250/78-11 and 50-251/78-11 I-2 plant procedures.

This completed the actions described in FPSL's letter L-77-227 of July 19, 1977.

This item is closed.

(Open)

Noncompliance (77-24-01):

Calibration of Steam Generator Blowdown Monitor Using Radioactive Sources.

The licensee has approved and issued the procedure for calibration of the monitors (NC-29) and has performed the calibration of the Unit 3 monitor, as stated in FPGL's letter L-78-8 of January 4, 1978.

This item remains open pending calibration of the Unit 4 monitor.

(Open)

Unresolved Item (77-24-02):

Prerequisite Tests for HEPA Filters and Charcoal Adsorbers.

The licensee has completed the prerequisite tests for Unit 3 but has not performed the tests on the Unit 4 filter systems as yet.

This item remains open.

(Closed)

Noncompliance (77-24-03):

Unlocked Entrance to High Radiation Area.

The inspector verified that written instructions have been issued to operations personnel as stated in FPGL's letter L-78-8 of January 4,

1978 and also verified during plant tours that the appropriate doors were locked.

This item is closed.

3.

Unresolved Items No new unresolved items were identified during this inspection.

4.

Plant Tour a

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During the period of the inspection, the inspector toured various areas of the facility to observe radiological controls, work practices, housekeeping, instrumentation, etc.

The inspector noted one condition which was identified as an item of noncompliance.

b.

On June 19, the inspector reviewed the status board at the entrance to the North Filling Room in the Radwaste Building and noted that the highest radiation level posted was 400 mr/hr.

The inspector noted that the entrance to the room was not barricaded, nor was it posted as a

high radiation area as required by Technical Specification 6.13.l.a.

The inspector and a licensee representative reviewed the health physics survey records for the room; the survey record confirmed the 400 mr/hr reading.

The inspector stated that this was in noncompliance with the Technical Specifications.

(78-11-01)

RII Report Nos. 50-250/78-11 and 50-251/78-11 I-3 c ~

The inspector also noted that the housekeeping in several work areas did not appear to be consistent with good health physics practice.

The inspector noted several instances where shoe covers, rubber and cotton gloves and miscellaneous bags of waste were stacked in entrances to equipment rooms or left in the waste laydown area.

A licensee representative acknowledged this situation and stated that efforts were continuing to control the housekeeping.

5.

Instruments and E ui ment a

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Technical Sp'ecifications, Table 4.1-1, Item 18-B requires that the area radiation monitoring system be calibrated annually and tested monthly.

The annual calibration is performed in accordance with plant procedure OP 11207.1; monthly tests are performed in accordance with procedure OP 11204.1.

Additionally, health physics procedure HP-15, "Health Physics Responsibilities for Process and Area Monitors" required that a health physics representative conduct a monthly check of all radiation monitors in conjunction with the Operations Department monthly test.

The inspector reviewed the last calibration records and the monthly test records for February - May 1978 and determined that the tests were conducted as required by the operations procedure.

When the monthly test records indicated that problems were encountered, the inspector also reviewed the plant work orders and verified that corrective actions were taken.

b.

The inspector asked a licensee representative for the records of the monthly checks of the area monitors in accordance with HP-15.

The licensee representative stated these records were not available, as the checks had not been performed by health physics personnel.

The inspector stated that this was an example of failure to comply with approved health physics procedures as required by Technical Specifications Section 6.11 (78-11-02);

this comment was acknowledged by licensee management representatives.

During the period of the inspection a change was initiated and approved which cancelled procedure HP-15 as it was considered redundant to OP 11204.1.

c ~

Plant procedure HP-32, "Pocket Dosimeter Source and Drift Check" contains the requirements for periodic checks of pocket dosimeters.

Procedure HP-4 requires that these checks be performed on a

quarterly basis.

On June 22, the inspector selected ten dosimeters in use, or ready for issue, and verified from the dosimeter records that all ten dosimeters had been

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RII Report Nos. 50-250/78-11 and 50-251/78-11 I-4 checked with satisfactory results for the current quarter.

The inspector had no further questions.

d.

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1977.

The inspector had no further quests 6.

Iodine Monitorin in Gaseous Effluent Streams Plant procedure HP-4 requires that dose rate meters and count rate meters be calibrated on a

semi-annual basis.

The inspector observed approximately ten instruments at various locations in the plant and verified that all of the instruments had current calibration stickers.

The inspector also reviewed the instrument calibration records for these instruments and verified that the records were on file.

As the dose rate meters are sent to a

contractor for calibration, the inspector asked a

licensee representative what type of control they had over the calibration other than the calibration certificate which comes back with the instrument and any source checks which may be performed.

The licensee representative informed the inspector that audits are periodically conducted of the contractor by the corporate quality assurance staff and that the last audit was performed in August ons

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a

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An incident occurred at a nuclear facility when an iodine monitor in a

gaseous effluent stream indicated high release rates of iodines, resulting in evacuation of the facility.

Subsequent analyses determined that the indicated high release was due to adsorption of radioactive noble gases on the charcoal filter in the monitor and the resulting anomalous readings were due to the operating characteristics of the monitor system.

b.

The inspector discussed this situation with a

licensee repre-sentative and reviewed the monitoring systems for gaseous effluent streams and the containment atmosphere.

The inspector determined that the licensee does not use an iodine monitor as the sole monitoring method on any of the effluent paths, but rather a

separate gas monitor in conjunction with iodine monitors, or uses a

gas monitor by itself.

The inspector had no further questions.

7.

IE Circulars and Bulletins a.

Bulletin 78-07

"Protection Afforde'd b Air-Line Res irators and Su lied Air Hoods This bulletin described test results which indicated that the protection factor actually provided by certain types of

RII Report Nos. 50-250/78-11 and 50-251/78-11 I-5 respirators and hoods is actually less than previously determined and as specified in Regulatory Guide 8.15, Table 1.

The bulletin outlined actions to be taken by licensees and reports to be submitted to the NRC.

The inspector discussed this bulletin with licensee representatives and was informed that air-supplied respirators are not used in the demand-mode, nor are supplied-air hoods used; consequently the licensee has determined that the actions required by the bulletin do not affect the respiratory protection program.

The inspector stated that he had no further questions.

b.

Circular 78-03

"Packa in Greater than e A uantities of Low S ecific Activit Radioactive Material for Trans ort" This circular provided clarification of the NRC requirements for shipping Low Specific Activity (LSA) radioactive material in accordance with 10 CFR 71.

The inspector discussed this circular with licensee representatives, especially as 10 CFR 71 relates to the plant procedures for shipping radioactive materials.

A licensee representative stated that procedure HP-40,

"Shipping and Receiving Radioactive Materials" will be reviewed and any necessary changes will be initiated by July 15.

The inspector stated that he would review any changes during a

subsequent inspection.

(78-11-03)

8.

ualifications of Health Ph sics Technicians a.

Technical Specifications Section 6.3.3.1 requires that all facility staff members meet or exceed qualifications as specified in ANSI N18.1-1971,

"Standard for Selection and Training of Personnel for Nuclear Power Plants."

For technicians, the standard specifies minimum qualifications of two years working experience in their speciality and suggests an additional year of technical training.

The inspector reviewed the qualifications of three technicians (radiation protection men)

added to the Health Physics staff during the previous year.

The review included an examination of resumes and discussions with the Health Physics Operations Supervisor.

The inspector determined that the qualifications of the three individuals met or exceeded the minimum requirements'he inspector had no further questions.

b.

In addition to the staff personnel, the licensee is utilizing several contract personnel.

The licensee requires that these personnel have a

minimum of two years actual work experience, successfully pass a written test on various aspects of health

RII Report Nos. 50-250/78-11 and 50-251/78-11 I-6 physics work and complete an oral examination/review.

The inspector reviewed the examination and discussed the review program with the Health Physics Operations Supervisor.

The inspector had no further questions.

9.

Audits and Reviews of the Radiation Protection Pro ram a

~

Technical Specification Section 6.5.2.8.a requires that the Corporate Nuclear Review Board "audit the conformance of facility operation to all provisions contained within the Technical Specifications and applicable license conditions at least once per year."

These audits are conducted by the Quality Assurance Operations group in accordance with the corporate Quality Assurance Manual, procedure QP 18.2.

The inspector reviewed audit reports QAO-PTP-77-10-146 dated October 26, 1977 and QAO-PTP-78-03-167 dated April 28, 1978 which were conducted concerning various aspects of the health physics program and verified by review that the findings were documented and reviewed.

These audits appeared to meet the requirement of the Technical Specifications; the inspector had no further questions.

b.

Paragraph 3.6 of the Corporate Health Physics Manual requires that the Corporate Health Physicist shall conduct a formal review of the plant radiation protection program at least annually.

The inspector reviewed the report of the last annual review conducted July-September 1977 and the status of the findings listed in the report.

The inspector discussed the actions with licensee personnel regarding the evaluation of the health physics organization and was informed that the evaluation had been completed and was being reviewed at the corporate level.

The second finding in the report dealt with changes to plant health physics procedures.

The inspector reviewed the findings and noted that twenty procedures had been identified as requiring changes and that only two of the procedures had been changed.

The inspector emphasized to licensee management representatives that a delay of nine months in implementing these changes did not appear to be a

timely response.

Licensee management representatives acknowledged this comment and stated that changes to the procedures would be initiated to correct this finding.

10.

Health Ph sics Procedure Chan es Technical Specification Section 6.11 states

"Procedures for personnel radiation protection shall be prepared consistent.

with the requirements of 10 CFR 20 and shall be approved, maintained and adhered

RII Report Nos. 50-250/78-11 and 50-251/78-11 I-7 to for all operations involving personnel exposure."

Technical Specifications Section 6.8.2 states, in part,

"Each procedure and administrative policy

.

.

.

and changes thereto shall be reviewed by the PNSC and approved by the Nuclear Plant Superintendent prior to implementation

.

.

.,"

The inspector reviewed the changes made to thirteen health physics procedures in calendar year 1978 and verified that they had been reviewed and approved in accordance with the Technical Specifications and reviewed the areas changed in seven procedures to verify that the changes were consistent with 10 CFR 20 and the Technical Specifications.

The inspector had no further questions.

Notices to Workers

CFR 19.11 requires that Form NRC-3 and certain documents be posted or that a notice be posted stating where the documents may be examined.

Such documents shall be posted where they can be observed on the way to or from any licensed activity location.

The inspector observed that Form NRC-3 and the notice were posted at the entrance to the radiation controlled area and at two other locations, and that Form NRC-3 was also posted at various locations around the facility.

The inspector had no further questions.

12.

S ent Fuel Rack Dis osal The licensee recently installed new spent fuel storage racks in Units 3 and 4 to increase the site fuel storage capacity.

The inspector discussed the disposition of the old racks with licensee representatives.

A licensee representative stated that the old fuel racks were dissassembled, packaged as radioactive waste in wooden boxes and shipped to a burial site.

In response to the inspector's question, a licensee management representative stated that none of the racks were disposed of in a manner other than shipment for burial as radioactive waste.

The inspector had no further questions.

13.

Exit Interview At the conclusion of the inspection on June 23, the inspector met with licensee representatives (denoted in paragraph 1).

The inspector summarized the scope and findings of the inspection.

Mr. Yaeger, Plant Manager and Mr. Hayes, Plant Superintendent, Nuclear, acknowledged the inspector's comments on the items of noncompliance" and observations during the inspectio RII Rpt.

Nos. 50-250/78-11 and 50-251/78-11 DETAILS II

/

prep ared by:

pi 7 C.

M. Hosey, adiatio Specialist Radiation Support Se ion Fuel Facili and Ma erials Safety ranch Date P~/ie/s R.

W.

a oski, Ra iation Specialist Date Radiation Support S ction Fuel Facility and Materials Safety Branch Dates of Inspec

J 19-23, 1978 e

Reviewed by:

A.

A.

. Gibson, Chief Radiation Support Section Fuel Facility and Materials Safety Branch

~</oh'ate 1.

Persons Contacted-H. E. Yaeger, Plant Manager-J.

K. Hays, Plant Superintendent, Nuclear J.

S.

Wade, Jr.,

Chemistry Supervisor-E. R. Lapierre, Radiochemist-J.

M. Puckett, Health Physics Operations Supervisor-V. B. Wager, Nuclear Operations Supervisor-A. T. Hall, Technical Support-D.

W. Haase, Technical Supervisor-R. L. Logston, Nuclear Chemistry

• G.

G. Jones, Plant Supervisor, Corporate

"-H. F. Story, Corporate Health Physicist The inspectors also talked with and interviewed several other licensee employees, including members of the technical staff, health physics, ISC and operations personnel.

• Denotes those attending the exit interview.

2.

Licensee Action on Previous Ins ection Findin s

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RII Rpt. Nos. 50-250/78-11 and 50-251/78-11 II-2 See Details I paragraph 2.

3.

Unresolved Items No new unresolved items were identified during this inspection.

4.

Leak Test of Sealed Sources a

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Technical Specification 4.13 states, in part, that each sealed source

.

.

. shall be tested for leakage and or contamination at intervals not to exceed six months.

b.

An inspector reviewed the leak test and inventory records of selected sealed sources and discussed the results with a licensee representative.

The review of leak test records revealed that the sealed sources installed in the process radiation monitoring system monitors RM-14, RM-15, RM-16 and RM-17 had not been leak tested at least every six months as required by Technical Specification 4.13.

These sources had last been leak tested in June 1977.

The leak test log indicated the sources were not accessible in January 1978.

A licensee representative stated that the sealed sources in monitors RM-14 through RM-17 were not accessible; however, on the previous leak test the nearest accessible surfaces had been wiped for loose contamination, and that this practice should have been used in January 1978.

The licensee representative was advised that, if the survey was impracticable, a

technical specification change should be requested.

The inspector stated that failure to perform leak test at least every six months was in noncompliance (78-11-04) with Technical Specification 4.13.

5.

T~rainin a.

Technical Specification 6.4.1 states, in part,

"a retraining and replacement training program for the facility staff shall be maintained

.

.

.

and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971

.

.." Section 5.5.1 of ANSI N18.1-1971 states, in part, "the retraining program shall include

.

.

. radiation safety."

Plant Procedure HP-81

"Health Physics Training" establishes the administrative procedures for a

retraining program.

Paragraph 8.1.6 of Procedure HP-81 specifies that retraining for Radiation Protection Men will consist of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of lecture, demonstration and practical exercises in all aspects of health physics activitie.

RII Rpt. Nos. 50-250/78-11 and 50-251/78-11 II-3 b.

An inspector discussed the training and retraining program for Radiation Protection Men (RPM) with a licensee representative and reviewed selected training records for RPMs employed for more than two years.

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The review of RPM training records revealed that a retraining program had not been maintained as required by Technical Specifi-cation 6.4.1.

The only formal retraining received by RPMs employed more than two years was a two hour seminar on the methods for handling a

specific radiological control problem.

This training did not meet the definition of retraining specified in plant procedure HP-81.

A licensee representative stated that a

new health physicist had been assigned the task of developing a

formal retraining program for RPMs.

The inspector stated failure to perform retraining of radiation protection men is in noncompliance (78-11-05) with Technical Specification 6.4.1.

d.

Through discussions, review of the plant's

"General Plant Orientation" videotape and review of selected training records for plant maintenance and security personnel, an inspector verified that radiation protection training for non-health physics personnel appeared to be in compliance with Technical Specification 6.4.1.

6.

Res irato Protection Pro ram a

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By review of records, observations, and discussions with licensee representatives, an inspector evaluated the program for air sampling, bioassay, engineering controls, MPC-hour controls, respirator medical evaluation, training, fitting, operational testing, maintenance, issuance controls, and determined that the respiratory protection program appeared to be in compliance with 10 CFR 20.103.

b.

Plant Procedure HP-65 "Respiratory Equipment Maintenance Program" requires that the fixed contamination levels on respiratory equipment be less than 10,000 dpm prior to returning the equipment to service.

On June 21, an inspector surveyed several respirators in the ready-for-issue bin and found respirators with fixed contamination between 50,000 and 150,000 dpm.

The contamination levels were verified by a licensee representative.

When the inspector requested to see the survey records for the respirators, licensee representative stated that survey records were not maintained for respirators.

The inspector commented that the maintenance of survey records of respirators would make

RII Rpt. Nos. 50-250/78-11 and 50-251/78-11 II-4 possible management review of the survey results and would possibly insure a

more thorough survey.

A licensee representative agreed to review the policy of not maintaining survey records of respirators.

The inspector stated that failure to follow Plant Procedure HP-65 is in noncompliance (78-11-02)

with Technical Specification 6.8.1.

7.

Neutrons Monitorin Pro ram a

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An inspector reviewed the licensee's personnel neutron dosimetry program.

The licensee uses an albedo TLD for personnel neutron monitoring.

Each individual entering containment during power operations is required to wear a neutron TLD.

Discussions with licensee representatives revealed that individuals are not instructed in how to wear the neutron TLD, althrough the orientation of the albedo TLD in relation to the body is extremely important if accurate neutrons doses are to be determined.

A licensee representative acknowledged the necessity for instructing workers in the methods for wearing the neutron TLD and stated that this instruction would be given in the future.

(78-11-06).

b.

The licensee's neutron TLDs are evaluated by the health physics group at the corporate office.

The calibration factor required to convert instrument response to neutron dose equivalent (mrem) was determined by the TLD reader vendor and has been verified by exchange of neutron TLDs between the licensee and a Department of Energy Laboratory.

Ce An inspector reviewed the initial shield survey results for Units 3 and 4 and discussed the results of the surveys with a licensee representative.

No significant neutron radiation levels were recorded for areas outside of secondary containment for either unit.

If containment entries are required during power operations a health physics technician or radiation protection man with a

neutron survey instrument (rem meter)

escorts the individuals making entry and continually monitors the work area for neutron radiation.

Neutron doses are estimated based on neutrons radiation levels and time spent in the area.

The exposure estimates are recorded and used to determine the total whole body exposure until the TLDs are read.

The inspector had no further questions concerning neutrons survey RII Rpt.

Nos. 50-250/78-11 and 50-251/78-11 II-5 8.

Termination Re orts In reviewing termination reports submitted in accordance with.l0 CFR 20.408 and 10 CFR 19.13, an inspector noted that the reports were being sent to the individual and the NRC which stated "significant bioassay results - none" prior to the return of the bioassay results.from the corporate office (whole-body counting) or the contractor (urinalysis).

A licensee representative stated that separate bioassay reports are sent to the individual and the NRC when the results are available.

These reports are sometimes sent several months later.

The licensee had erroneously determined that they only had 30 days to furnish the report to the individual and to the NRC once the TLDs used to monitor external radiation exposure had been processed without regard to the internal exposure information.

A licensee representative stated that the procedures would be revised to furnish a complete report within the time frame required by 10 CFR 20.408 (78-11-07).

9.

External Ex osure Control a.

An ins ector revie P

wed the licensee's program for external exposure control, including review of selected procedures and records, discussions with personnel and observation of work practices.

Specific areas inspected were:

(1)

Personnel monitoring required by 10 CFR 20.202a (2)

Permissible doses of 10 CFR 20.101a, and (3)

Exposure records required by 10 CFR 20.40la.

The inspector had no further questions on the licensee's program in these areas.

b.

CFR 20.101b permits an individual to receive extended doses provided an NRC-4 Form is completed and an exposure history is obtained.

An inspector reviewed selected personnel exposure records for individuals who had received extended doses and verified that a

completed NRC-4 form was on file.

An inspector also verified that there were no unreported cases of personnel exposure above the limits of

CFR 20.

The inspector had no further questions on the licensee's program in these areas.

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An inspector discussed the employment of minors at the facility with licensee representatives.

The licensee representative informed the inspector that company policy prohibits the employ-

RII Rpt. Nos. 50-250/78-11 and 50-251/78-11 ment of minors at generating facilities.

The inspector had no further questions in this area.

10.

Postin Labelin and Control a

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An inspector reviewed the licensee's posting for radiation areas (10 CFR 20.203b),

high radiation areas (10 CFR 20.203c), airborne radioactivity areas (10 CFR 20.203d), radioactive materials areas (10 CFR 20.203e)

and container labeling (10 CFR 20.203f).

Accompanied by a licensee's representatives on June 21, 1978, an inspector randomly surveyed several areas for radiation level in the radiation controlled area.

The inspector found two unposted, unmarked 55 gallon drums reading in excess of 100 mr/hr, but less than 1000 mr/hr.

The licensees representat'ives verified the results and promptly marked the area as a high radiation arear'n the same date, in the outdoor storage area an inspector found a

discarded vacuum cleaner and a liquid filter from the spent fuel pool reading in excess of 100 mr/hr, but less than 1000 mr/hr, in the vicinity of each item.

The licensees representatives verified the results and promptly marked each area as a high radiation area.

The inspector stated that failure to post high radiation areas was in noncompliance (78-11-01) with Technical Specification 6.13.1A.

The inspector had no further observations or questions in the area of posting and labeling.

b.

An inspector reviewed with licensees representatives the controls they have over radioactive materials as required by 10 CFR 20.203c for high radiation areas, and 10 CFR 20.207 for storage areas.

An inspector also reviewed the use of Radiological Work Permits (RWP's)

and the control measures for radioactive or contaminated areas and equipment as required by procedures.

Health Physics Procedure HP-41,

"Movement of. Material Inside the Radiation Controlled Area,"

dated February 17, 1978, states:

(1)

in Section 8.3'.2

"In all cases, materials shall be packaged or contained to the extent that there is very little possibility of spreading contamination":

(2)

in Section 8.3.7,

"Tools and equipment used in contaminated areas should be surveyed prior to removal from the area or should be considered as contaminated and placed in double plastic bags until they can be surveyed and released";

(3) in Section 8.4.1, "All radioactive material that is to be stored should have a radioactive material "Caution" tag affixed, FPL Form 5715:

(i) This tag shall be filled out and signed by the Health Physics Department and shall be completed prior to move@eat; (ii) This tag alerts all personnel as to what the material actually is, (may not be visible inside bag) as well

Qi RII Rpt. Nos. 50-250/78-11 and 50-251/78-11 II-7 as radiation and contamination levels"; (4) in Section 8.4.3 "The bag openings should be twisted closed, taped, twisted again, folded back and taped a second time to prevent the released of any radioactive contamination";

and (5) in Section 8.4.4 "Materials that do not lend themselves to bagging shall be placed in suitable containers approved by Health Physics prior to movement or storage."

An inspector, in the presence of licensees representatives, on June 21, 1978 observed numerous instances where (1) contaminated and/or radioactive tools and equipment were not contained or their plastic bags were open to the atmosphere (2) only single plastic bags with a

single closure were used to contain contaminated wastes and contaminated tools and equpment (3) bags of radioactive material in the outdoor storage areas did not have

"Caution" tags affixed to them.

The inspector stated that failure to follow procedures for containing and labelling radioactive material was in noncompliance (78-11-02)

with Technical Specification 6.11.

The inspector had no further observations or questions in the area of control.

11.

~Surve s

An inspector reviewed the licensees program for surveys of contaminated areas, including review of selected procedures and records, discussion with personnel and observation of work practices.

Specific areas inspected were:

(1)

Permissible doses discussed in 10 CFR 20.101 and 10 CFR 20.104.

(2)

Exposure to airborne concentrations discussed in

CFR 20.203 and CFR 20.104.

(3)

Posted areas discussed in 10 CFR 20.203 (4)

Radiation in unrestricted areas discussed in 10 CFR 20.105b.

No items of noncompliance were identified and the inspector had no further questions on the licensees program in these areas.

12.

Filtration S stems The inspector reviewed the licensees program for ensuring compliance with the Technical Specifications Section 4.7.1 on Emergency Contain-ment Filtering System.

The inspector reviewed the following operating procedures:

C RII Rpt. Nos. 50-250/78-11 and 50-251/78-11 II-8 (1)

Operating Procedure 4704.4, November 30, 1976,

"Emergency Containment Filter Systems Absorber Cells Performance Test" (2)

Operating Procedure 4704.3, November 30, 1976,

"Emergency Containment Filter Systems HEPA Filters Performance Test."

(3)

Operating Procedure 10304.1, November 30, 1976,

"Control Room Post MHA Air Conditioning System HEPA Filter Performance Test" (4)

Operating Procedure 10304.2, November 30, 1976,

"Control Room Post MHA Air Conditioning System Adsorber Cell Performance Test" (5)

Operating Procedure 5504.2, November 30, 1976,

"Post Accident Containment Vent System Adsorber Cell Performance Test" (6)

Operating Procedure 5504.3 November 30, 1976,

"Post Accident Containment Vent System HEPA Filter Performance Test."

In addition, the inspector reviewed the results of the elemental iodine laboratory test on the charcoal surveillance specimen and the air capacity, velocity, air aerosol mixing uniformity and adsorber residence time tests and calculations for Unit //3.

No items of non-compliance were identified and the inspector had no further questions.

13.

Exit Interview At the conclusion of the inspection on June 23, 1978, the inspectors met with licensee representatives (denoted in paragraph 1).

The inspectors summarized the scope and findings of the inspection.

With regard to the noncompliance item concerning leak test of sealed sources, J.

M. Puckett, Health Physics Operations Supervisor, committed to look for ways to leak test the sources.

With regard to the noncompliance item concerning retraining of radiation protection people, J.

K. Hays, Plant Superintendent, stated that retraining of radiation protection people would be undertake V

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