IR 05000348/1992027

Insp Repts 50-348/92-27 & 50-364/92-27 on 921019-23.No Violations or Deviations Noted.Major Areas Inspected: Occupational Radiation Exposure During Extended Outages,Mgt Controls,Audits & Appraisals & Control of Radioactive Matls

ML20128E586
Person / Time
Site:	Farley
Issue date:	11/18/1992
From:	Pharr E, Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128E524	List: IR 05000348/1992027 ML20128E520
References
50-348-92-27, 50-364-92-27, NUDOCS 9212080130
Download: ML20128E586 (9)

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HOV 2 0 W Report Nos.: 50-348/92-27 and 50-364/92-27 Licensee: Alabama Power Company 600 North 18th Street Birmingham, AL 55291-0400 Docket Nos.: 50 348 and 50-364 License Nos.: NPF-2 and NPT-8 facility Name: f arley 1 and 2 Inspection Conducted: 0tober19-2p,1992 Inspectors: $ M~ 4 ' A '

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jm W. H. RiiikT4 ChTef facilities Radiation Protection Section ef) Radiological Protection and Emergency Preparedness Branch > Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection was conducted in the area of occupational radiation exposure during extended outages. Specific elements of the program examined during the inspection incluJed organization and management controls, audits and appraisals, external and internal exposure control, control of radioactive materials and contamination, surveys and monitoring, and maintaining occupational exposures as low as reasonably achievable (ALARA).

Results: In the areas inspected, no violations or deviations from NRC regulations were identified. The licensee's routine external and internal exposure programs were effectively implemented. Personnel exposures were less than 10 CFR Part 20 limits. Strengths were noted in the licensee's program for maintaining personnel exposures ALARA during outage activities by way of dose reduction-initiatives. The inspector observed the conduct of operations in Unit 1 l l l 9212000130 921120 gDR ADOCK 05000348 PDR

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containment and noted that the radiological performance of both health physics technicians and craftsmen was good. An additional licensee strength was noted in the posting and labeling of radioactive materials throughout the Radiation Controlled Area (RCA). Overall, the licensee's radiation protection 3rogram was functioning adequately to protect the health and safety of the pu)11c and plant personne . r,, w --se-r-e--.m-,..ee- +w.-,, v ,-m,e -c-- - - - ---ve-rw w. v----.-e.---y- e--e -v, -, -, -# b.,-wwr e-.<y ,- , rm.,-,v w. , e rm.v.,yer r y-- 4 -' 's '--ve'+ y

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REPORT DETAILS Persons Contacted Licensee Employees

* Bouler, Acting Plant Health Physicist
*S. freeman, Auditor, Safety Audit and Engineering Review (SAER)
*M. Graves, Supervisor, Radwaste
*P. Harlos, Auditor, SAER
* Mitchell, Health Physics (HP) Superintendent
*C. Nesbitt, Manao 4 On9 rations
* Osterholtz, Two ' ; Manager
*K. Patton, Site Services Manager, Westinghouse
* Stinson, Assistant Gtneral Manager, Operations
*J. Thomas, Manager, Maintenance
*J. Walden, HP Supervisor Other licensee employees contacted included engineers, technicians, and office personne Nuclear Regulatory Commission
*N. Economos, Region II Inspector
*G. Maxwell, Senior Resident Inspector
*M. Morgan, Resident Inspector
* Attended October 23, 1992 Exit Meeting Organization and Management Controls (83729)

The inspector reviewed the radiation protection (RP) program during the Unit 1, cycle 11, refueling / maintenance outage. The licensee's outage exposure goal was 362.726 person _-rem. At the time of the onsite - inspection the licensee was mairLining their cccumulated dose below the - projected dose goals. The licensee was performing eddy current testing in three steam generators (S/Gs) in parallel, sludge lancing, and refurbishing the head seating surface of the reactor vessel flange during the inspection. In addition, in-service-inspection (l;I) was in-progress on reactor coolant pumps. The inspector attended several outage planning meetings and-aoted that radiological concerns were discussed with what appeared to be the proper emphasis and prfority, with management fully supportive of the RP progra The inspector reviewed the licensee's RP organization staffing levels and lines 'of authority as they related to the refueling / maintenance outage .and verified that the licensee had not made changes that would-adversely affect their ability to implement critical elements of the RP progra No violations or deviations were identified

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l 2 Audits and Appraisals (83729) The iicensee utilizes several methods to internally identify problem areas and initiate corrective actions as management tools to maintain a-highly efficient RP program. The primary method is in the form of audits performed by their Safety Audit and Engineering Review (SAER) group. In discussions with the lead RP auditor the inspector noted that an audit of the RP program was in progress at the time of the inspection. The inspector reviewed Radiological Controls Audit, SAER-WP-02, dated June 1, 1992 through July 30, 1992 and found the audit to be performance based with the findings substantive and corrective actions performed in a timely manne Based on previous inspector comments regarding root cause determination the licensee evaluated the adequacy of FNP-0-RCP-10, Radiation Incident Reports, Per onnel Contamination Events, and Radiological Warnings, Revision 20, and made changes to effect better evaluation and documentation of radiological deficiencies. Event description forms-now have ample room for the description of the event and requires more information than the old forms. Licensee representatives stated that the more comprehensive information collected now allows for better evaluation by management at a later date. The inspector's review of the radiation incident reports (RIRs) generated since implementation of the

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procedure improvements, verified that the new RIR forms are more comprehensive in their evaluation and documentation of event No violations of deviations were identifie . External Exposure Control (83729) 10 CFR 20.101 requires that no licensee possess, use, or transfer licensed mhterial 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 rems to the whole body, head and trunk, active blood forming organs, lens of the eyes, or gonads; 18.75 rems to the hands, forearms, feet and ank us; and 7.5 rems to the skin of the whole bod CFR 20.202(c) requires, in part, that dosimeters used to comply with 10 CFR 20.202(a) shall be processed and evaluated by a dosimetry processor hclding current accreditation from the National Voluntary Laboratory Accreditation Program (NVLAP) for the types of radiation for which the individual is monitore The inspector reviewed the licensee's investigations and exposure assessments relating to two external contamination incidents which'

 ~ occurred during the Unit 1 outage. During a September 30, 1992 incident a contract worker was ' performing a local leak rate test (LLRT) on the pressurizer steam sample valves when the test hose ruptured, spraying the contractor with Reactor Coolant System (RCS) water from the pressurizer sample line. HP surveys detected general contamination dispersion on the individual's skin and clothing with the maximum
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contamination being 600,000 disintegrations per minute per a 100 square centimeter area (dpm/100cm'). During an October 19, 1992 incident, an individual performing work on the containment water chillers alarmed the contamination monitors located at the Unit I control point after exiting the containment buildin Subsequent HP surveys revealed a 250,000 dpm hot particle on the individual's elbo For the individual contaminated during the LLRT the licensee ! decontaminated the worker to a localized 3000 dpm/ probe area prior to ;

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his release from site on September 30, 1992 and as of October 19, 1992 the licensee detected 1000 dpm/ probe area on the individual's scal Whole body counts during the period from September 30, - October 19, were not indicative of an internal exposure and the assigned whole

 'in exposure during the same period, based on an exposure to 58 (Co-58), was 53 millirem (mrem). The individual contaminated e hot particle was assigned an extremity dose of 2.88 rem. The s based on a 0.295 microcurie-hour (uCi-hr) exposure to the lual's elbow by beta emitting isotopes identified by an isotopic fs of the captured particle and a stay time encompassing the time
 .ndividual entered the RCA until the particle was remove Following review of the incidents, the inspector determined that the licensee used appropriate HP controls prior to and following the incidents. During both incidents HP appropriately surveyed the individuals to determine the sources of exposure and then continued proper followup monitoring to assess the individuals' total exposure .

The inspector concluded that the licensee monitored whole body sk.in and * extremity doses adequately and that the individuals' assigned external exposures were within 10 CFR 20 limit The inspector also noted that since the previous NRC inspection conducted April 6-10, 1992,. a NVLAP audit had been conducted for renewal of the licensee's accreditation for the Personnel Radiation Dosimetry Laboratory Accreditation Program. The licensee holds'NVLAP certification as a sub-facility of a major vendor of dosimetry service During the audit, concerns and deficiencies were identified which the vendor and the licensee sub-facility responded to in order to maintain NVLAP accreditation. The inspector reviewed the audit and found it to , be thorough with many of the identified issues being administrative in nature. Following discussions 'ith licensee representatives the inspector was informed that m- af these administrative issues were resolved during a subsequent . .editation audit of the vendor. During review of the vendor's response to the audit findings the inspector noted.that appropriate actions had been initiated by both the vendor and licensee to satisfactorily resolve NVLAP concerns so that the licensee's sub-facility was granted accreditation renewa No violations or deviations were identified.

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Internal Exposure Control (83729)

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5 '. 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 hours per week for 13 weeks at uniform concentrations of radioactive material in air specified in Appendix.. Table 1, Column 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 necessary for timely detection and assessment o individual intakes of radioactivity by exposed individual CFR 20 Appendix A, Footnote (d), requires adequate respirable air of the quality and quantity in accordance with NIOSH/MSHA certification

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described in 30 CFR Part 11 to be provided for the atmosphere-supplying respirator CFR 11.121 requires that compressed, gaseous breathing air aeet-the applicable minimum grade requirements for Type 1 gaseous air set forth in the Compressed Gas Association (CGA) Commodity Specification for Air, G-7.1-(Grade D or higher quality).

The inspector discussed with licensee representatives and reviewed-internal exposures during the ongoing Unit I refueling outage. The inspector noted the results of the. licensee's internal dose assessment efforts and determined that no exposures in excess of the 40 Maximum Permissible Concentration-hours (MPC br) weekly control measure had occurred during outage activitie The inspector also reviewed licensee procedures and records for sampling of breathing air to-ensure compliance with Grade D specifications. The inspector determined that the licensee provided appropriate procedural l guidance for sampling breathing air to verify Grade D compliance of the service air system during routine operations, as 'well' as for startup, periodic checks, und shutdown of the containment breathing air syste The inspector verified that, in accordance with the applicable-procedures, appropriate sampling was conducted and all results met Grade D specification No violations or deviations were identifie . Surveys, Monitoring, and Control of Radioactive Material and Contamination (83729) 10'CFR 20.201.'(b) states that each licensee shall make or cause to be made such. surveys as (1) may be necessary for a licensee to comply with-regulations in this part,' and:(2) are reasonably under the circumstances to evaluate the extent of radiation hazards that may be present;

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5 During tours of the Unit I containment and the auxiliary building the inspector performed radiation and contamination surveys and compared the results with surveys performed by the licensee. No discrepancies were noted. The inspector also examined and verified that no radiation protection instrumentation was out of calibratio The inspector reviewed records of personnel contamination events (PCEs) and noted that the licensee had experienced 35 PCEs since the start of the outage with 18 being hot specks or hot particles. Licensee representatives stated that preventative measures were in place to minimize the extent of hot particle contaminations. These measures included utilization of paper suits over protective clothing, hot particle work zones, and routine removal of personnel from work areas at prescribed intervals to allow personnel monitoring to ensure the time - element would be minimized. Th total number of PCEs to date this year have been 43 which appeared to oe low compared to the time in the year and the workscope completed. The licensee continues to maintain an aggressive contamination control program as approximately 94 percent of the 114,197 square foot radiologically controlled area (RCA) is maintained as clean or less than 1,000 disintegrations per minute per 100 centimeters square (1000 dpm/100 cm2), 10 CFR 20.203 (f) requires each container of licensed radioactive material to bear a durable, clearly visible label identifying the contents when quantities of radioactive material exceeded those specified in Appendix The inspector noted during tours of the Unit I containment and auxiliary building that all containers with radioactive material were clearly and visibly marked with a radioactive materials label. A previous inspection report identified this area a weakness and the licensee made appropriate procedure changes and took effective actions to correct the proble The improvements in this area was also noted by NRC Region II management

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during previous tours of the RC No violations or deviations were identifie . Program for Maintaining Exposures As low As Reasonably Achievable (ALARA) (83729) 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 achievabl The inspector reviewed the licensee's program to maintain occupational exposures ALARA. During discussions with licensee representatives the-inspector was informed-that the cumulative dose through the third . quarter of 1992 was 466.162 person-rem, with the licensee projecting an annual site _ cumulative. dose goal of 848 person-rem. The inspector was also informed that the licensee's cumulative dose goal for the ongring Unit 1 outage was 362 person-rem. As of outage day 27 of the projected

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54 day outage the licensee's collective dose for the outage was 164.878 person-rem whereas the projected outage-to-date dose goal was 184 person-re The licensee further informed the inspector that as of the end of outage day 26 the licensee was approximately 60 hours behind schedul The inspector discussed with licensee representatives the outage work scope to date. During discussions with licensee representatives and plant workers the inspector was informed that dose rates in the containment building appeared to be lower than previous outage Licensee representatives informed the inspector that this reduction could, in part, be attributed to the removal of the resistance temperature detectors (RTD) during the previous Unit 1 outage and a _ successful crud burst and cleanup during reactor shutdown, which removed approximately 1300 Ci of Co-58 from the RCS. The licensec continues to reduce the out of core source term since performing lithium / boron coordinated chemistry. Dose rates in the S/G channel heads are approaching 50 percent of what they were when forced oxidation was performed at mid-plane of the reactor vessel nozzle During discussions with licensee representatives and review of records ' the inspector noted that the work activities to remove pits in the seating surface of the reactor flange were expected to be completed with dose accumulation being as projected. Normally, the dose rates at the reactor flange were approximately 1.2 rem /hr. However, after installation of a shielding designed particularly for the flange work, dose rates were reduced to approximately 60 mrem /hr. Additionally, remote tooling was used in the actual repair of the flange seating surface and the inspector observed workers utilizing additional shielding in the reactor cavity when not actively involved in performing flange related work activities. The licensee projected a total dose accumulation of 14 rem following completion of all work activities - relating to reactor flange repair Licensee representatives stated that at the time of the onsite inspection the only unexpected dose accumulation was due to 10 full steam generator bowl entries. These entries were made in response to problems with robotic installation of the nozzle dams and at the time of the onsite inspection had contributed to accumulation of 4.23 ra Additionally, the inspector was informed that at the time of the inspection only one Radiation Work Permit (RWP) had exceeded 100 percent of the total job projected dose. This RWP was related to the MOVATS work scope and since the particular RWP did not account for valve packing but this work was performed under the RWP, the projected dose had been exceeded. Licensee representatives informed the inspector that although the RWP dose was currently 103 percent of the projected dose, this dose was still expected and projected for, but under a different RWP.

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The inspector informed licensee representatives that_ their program -for maintaining personnelf exposures ALARA during' outage activities appeared to be functioning adequatel No violations or deviations were identifie . Exit Meeting The inspector met with licensee representatives denoted in Paragraph-1 at the conclusion of the' inspection on October 23, 1992. The. inspector summarized the scope-of the inspection and did not receive any dissenting comments. The licensee did not identify any documents given to the inspector as proprietar , w }}