ML20133Q398
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| ML20133Q398 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/08/1985 |
| From: | Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133Q380 | List: |
| References | |
| 50-302-85-34, NUDOCS 8511010530 | |
| Download: ML20133Q398 (8) | |
See also: IR 05000302/1985034
Text
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Report No.: 50-302/85-34
Licensee: Florida Power Corporation
3201 34th Street, South
St. Petersburg, FL 33733
Cocket No.: 50-302 License No. OPR-72
Facility Name: Crystal River 3
Inspection Conducted: August 26-30, 1985
Inspector: bk
W. T. Coodef
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Date Signed
Approved by: b fhM //[[[[I
C.M.Hdshy,SectponChief Date Signed
Division of Radiation Safety and Safeguards
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SUMMARY
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Scope: This routine, unannounced inspection dritailed 33 inspector-hours onsite
in the areas of external exposure control and personal dosimetry, internal
exposure control, solid waste processing and storage, the licensee's actions to
maintain occupational radiation exposures as low as reasonably achievable (ALARA)
and Surveys, Monitoring and Control of Radioactive Material.
Results: Two violations - failure of personnel to frisk properly (paragraph 7)
and failure to have a procedure for calculation of MPC-hrs for cases of
radioactive material ingestion (paragraph 5).
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REPORT DETAILS
1. Persons Contacted
Licensee Employees
*P. McKee, Plant Manager
*W. Rossfeld, Site Nuclear Compliance Manager
*K. Lancaster, Manager, Site Nuclear Quality Assurance
*P. Skramstad, Nuclear Chemistry / Radiation Protection Superintendent
*L. Hill, Manager, Site Nuclear Services
*G. Clymer, Nuclear Waste Manager
*V. Roppel, Manager, Plant Engineering and Technical Services
*F. Bailey, NOM
*S. Powell, Senior Nuclear Licensing Engineer
*B. Komara, Nuclear Quality Control Supervisor
*A. Kazemfar, ALARA Specialist
*P. Breedlove, Nuclear Records Management Supervisor
"J. Bufe, Nuclear Compliance Specialist
A. Clemons, Nuclear Compliance Engineer
R. Roberts, Health Physics Supervisor
S. Long, NQC Supervisor
M. Johnson, ALARA Specialist
R. Browning, Health Physics Suoervisor
R. Clark, Radiation Protection Manager '
L. Lockhart, Nuclear Operations Superintendent
Other licensee employees contacted included three construction craf tsmen,
three technicians, two security force members, and four of fice personnel.
NRC Resident Inspector
*J. Tedrow
* Attended exit interview
2. Exit Interview
The inspection scope and findings were summarized on August 30, 1985, with
those persons indicated in paragraph 1 above. The apparent violation for
inadequate frisking practices (paragraph 7) was discussed in detail with
! licensee management. Licensee management acknowledged the apparent
violation and took no exceptions. The inspector also discussed the uptake
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of radioactive material by one licensee employee during the last refueling
outage and the requirement that uptakes by ingestion must be evaluated as
required by 10 CFR 20.103(a)(1) footnote 4 (paragraph 5).
In a telephone conversation on October 1,1985, between V. Panciera of the
Region II office and G. Westafer, Manager, Nuclear Operations Licensing and
Fuel Management, the licensee was informed that the item concerning MPC-hour
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calculation for cases of radioactive material ingestion initially identified
as an inspector follow-up item (IFI) in the exit interview was being changed
to a violation of Technical Specification 6.11.
The licensee did not identify as proprietary any of the material provided to
or reviewed by the inspector during this inspection.
3. Licensee Action on Previous Enforcement Matters
(Closed) Violation (53-302/85-12-03) This violation concerned the failure to
properly label bags containing racicactive material with a radiation caution
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The inspector reviewed and verified the corrective actions as stated in
Florida Power - Corporation's letter of June 21, 1985, and supplemental
response on August 15, 1985.
(Closed) Violation (50-302/85-12-04) This violation concerned failure to
conspicuously post notices as required by 10 CFR 19.11.
The inspector reviewed and verified the corrective actions as stated in
Florida Power Corporation's letter of June 21, 1985, and supplemental
response on, August 15, 1985.
(Closed) Violation (50-302/85-12-02) This violation concerned failure to
establish and implement procedures which prescribe the requirements for
adequate personnel frisking techniques.
The inspector reviewed and verified the corrective actions as stated in
Florida Power Corporation's letter of June 21, 1985, and supplemental
response on August 15, 1985. This violation was similar to a violation-
which is discussed in paragraph 7 of this eport.
4 External Occupational Dose Control and Personal Dosimetry (83724)
During plant tours, the inspector checked the security of the locks at three
locked high radiation areas and observed the posting of survey results and
the controls specified on four radiation work permits (RWPs).
I a. Use of Dosimeters and Controls
The licensee was required by 10 CFR 20.207. 20.201(b), 20.101, 20.102,
20.104, 20.402, 20.403, 20.405,19.13, 20.407, and 20.408 to maintain
worker's doses below specified levels and keep records of and make
reports of doses. The licensee was required by 10 CFR 20.203 and
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Technical Specification 6.12 to post and control access to plant areas.
! FSAR Chapter 12 also contained commitments regarding dosimetry and dose '
controls. During observation of work in the plant, the inspector
observed the wearing of TLDs and pocket dosimeters by workers. The
inspector discussed the assignment and use of dosimeters with health
physics supervisors and health physics technicians. During plant
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tours, the inspector observed the posting of areas and made independent
measurements of dose to assure proper posting. The inspector reviewed
recent changes to plant procedures regarding the use of TL0s and
dosimeters.
b. Review of Licensee Administrative Overexposure
The inspector reviewed a licensee evaluation for an administrative
overexposure which was identified on May 21, 1985. The incident
occurred during work to rewire motor operated valves in the letdown
cooler room on the 95 foot elevation of the reactor building. The
licensee was using self reading dosimeters (SRD) to monitor external
exposure in lieu of performing daily TLD analysis. SRD placement was
made based on an evaluation performed by a health physics supervisor
(HPS). Due to a shortage of SRDs during this work evolution, an SRD
was not placed at each TLD location. The evaluation performed by the
HPS indicated that the highest dose rates could be expected in the
region of the right thigh and an SRD was subsequently placed at that
location. The licensee analysis of TLDs on May 21, 1985, indicated an
exposure to the left thigh for the period May 1-21, 1985, of 2,538 mR.
This resulted in a second quarter 1985 dose of 2,591 mR. A licensee
representative stated that the employee possibly bumped a lead
shielding blanket during his work, causing the blanket to be displaced
and exposing his left thigh to the higher-than exrected dose rates.
The ir.spector discussed this case with selected involved personnel and
reviewed the licensee's corrective actions.
No violations or deviations were identified.
5. Internal Exposure Control and Assessment (83525)
The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403, and
20.405 to control uptakes of radioactive material, assess such uptakes, and
keep records of and make reports of such uptakes. FSAR Chapter 12 also
includes commitments regarding internal exposure control and assessment.
Technical Specification 6.11 required that procedures for radiation
-~_ protection be prepared consistent with the requirements of 10 CFR 20 and
shall be approved, maintained and adhered to for all operations involving
personnel radiation exposure.
a. Control-Measures
During plant tours, the inspector observed the use of temporary
ventilation systems, containment enclosures, and respirators. The
inspector discussed the use of this equipment with workers and
radiation protection technicians. The inspector reviewed recent
changes to respirator maintenance and issue procedures.
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No violations or deviations were identified.
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b. Uptake Assessment
The inspector observed the operation of the whole body counter and
discussed its operation with the Dosimetry Supervisor. The inspector
reviewed a licensee evaluation of an uptake which occurred in May 1985.
Licensee representatives stated that the uptake occurred during work
being performed on the steam generators during the last refueling
outage. Personnel were entering the steam generator area through tents
erected to control airborne radioactive material . The tents were
contructed such that movement toward the steam generator manway would
be from an area of lower to nigher contamination. At some point during
the work evolution, the low contamination tent became contaminated. A
licensee representative stated that he was unsure when the uptake
occurred but felt that it was during the time when the contract worker
was removing his bubble suit. The individual frisked himself and found
himself to be contaminated in the facial area. Health Physics
personnel sent the individual to be whole body counted, and it was
found that the maximum count was 7.63 percent of the maximum
permissible body burden (MPBB). During the review of the licensee
evaluation of this uptake, the inspector found that the licensee was
not calculating maximum permissible concentration-hours (MPC-hrs) for
cases of radioactive material ingestion. 10 CFR 20.103(a)(1) footnote
4 required that such intakes must be evaluated and accounted for by
techniques and procedures as may be appropriate to the circumstances of
the occurence. Exposures so evaluated shall be included in determining
whether the limitation on individual exposures in 20.103(a)(1) has been
exceeded. Failure to h' ave a procedure in place to ensure compliance
with 10 CFR 20.103, Footnote 4, was identified as an apparent violation
of Technical Specification 6.11 (50-302/85-34-01).
6. Maintaining Occupational Doses ALARA (83728) -
10 CFR 20.1(c) specifies that licensees should implement programs to keep
worker's doses ALARA. FSAR Chapter 12 also contains licensee commitments
regarding worker ALARA actions.
a. Worker and Supervisor Actions
The inspector discussed dose control measures with three workers on the
job and one maintenance supervisor to determine their degree of
involvement in dose reduction. The inspector also discussed actions to
set dose goals for tasks, methods used to reduce doses, and techniques
used to monitor performance against goals.
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b. ALARA Reviews
The inspector reviewed the ALARA review documentation for selected
, activities and discussed resulting actions with the ALARA Coordinator. !
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c. ALARA Reports
The inspector reviewed the ALARA Report for 1984 and the second quarter
1985 ALARA summary report and discussed the results with the ALARA
Coordinator. The sumnary of tasks estimate for 1985 was 500 man-rems.
The total cumulative dose for 1985 as of July 31 was 572.5 man-rems.
No violations or deviations were identified.
7. Control of Radioactive Materials and Contamination, Surveys, and Monitoring
(83526)
The licensee was required by 10 CFR 20.201(b), 20.403, and 20.401 to perform
surveys to show compliance with regulatory limits and to maintain records of
such surveys. Chapter 12 of the FSAR further outlines survey methods and
instrumentation. Technical Specification 6.8 required the licensee to
follow written procedures. Radiological control procedures further outlined
survey methods and frequencies,
a. Surveys
The inspector observed, during plant tours, surveys being performed by
radiatjon protection staff. The inspector reviewed two radiation work
permits, one for decontamination of equipment and one for operation of
the cask loading system, to determine if adequate controls were
specified. The inspector discussed the controls and monitoring with
the radiation protection technician assigned. The inspector performed
independent radiation level surveys.
During plant tours, the inspector observed radiation level and
contamination survey results. The inspector performed independent
radiation level surveys of selected areas and compared them to licensee
survey results. The inspector reviewed selected survey records for the
month of August 1985 and discussed with licensee representatives
methods used to disseminate survey results.
b. Frisking
During tours of the plant, the inspector observed the exit of workers
and movement of material from contamination control to clean areas to
i determine if proper frisking was performed by workers and that proper I
direct and removable contamination surveys were performed on materials.
Technical Specification 6.8.1 requires that written procedures be
established, implemented and maintained for certain activities
including applicable procedures in Appendix A of Regulatory Guide 1.33,
1972. Appendix A of Regulatory Guide 1.33, November 1982 requires
procedures for surveys and monitoring. Chemistry and Radiation
Protection Procedure RSP-101, Basic Radiological Safety Information and
Instructions for Radiation Workers, required that a whole body frisk be
performed when exiting the auxiliary building radiction controlled area
(RCA). Specific guidelines for conducting a whole body frisk were
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delineated ir Section 3.3. The inspector observed licensee personnel
exiting the tuxiliary building RCA on August 27-29, 1935. The
inspector ustd the criteria as stated in procedure RSP-101,
Section 3.3. The inspector observed approximately 100 licensee
personnel exit ng the RCA at various times during the three day period.
The largest sa ipling was on August 28. 1985, from 1100 hours to
1200 hours in vhich 73 licensee personnel were observed. Of this
sampling, the :p:ctor found that of the 73 personnel surveyed, 48
failed to perform an adequate frisk based on the licensee criteria in
that, the operability of the frisker was not checked by any of the 73
personnel, the frisker probe was generally kept i n contact with the
skin, clothing and shce surfaces, and the frisker probe was moved so
fast that excessive contamination levels would have to be present in
order for the instrument's audible response to indicate a need for
I additional frisking in that area. Also, the noise level in the ) frisking area due to equipment and crowd noise was such that licensee
personnel could not readily detect an audible count rate increase.
The failure to comply with the procedural requirements of procedure
RSP-101 that a whole body frisk be performed in accordance wi'th the
stated guidelines was identified as an apparent violation of Technical
Specification 6.8.1 (50-302/85-34-02). This acparent violation was
identified as being similar to Item 1 contained in a Notice of
Violation sent to the licensee in a letter dated March 24, 1985.
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8. Solid Waste (84722)
10 CFR 20.311 requires a licensee who transfers radioactive waste to a land
i disposal facility to prepare all waste so that the waste is classified in . accordance with 10 CFR 61.55 and meets the waste characteristic requirements , i '
of 10 CFR 61.56. It further establishes specific requirements forf
conducting a quality control program and for maintaining a manifest tracking
system for all shipments.
The inspector reviewed the following plant procedures for the pa,ckaging,
classifying, and tracking of radioactive waste shipped to low-level waste
, burial facilities:
WP-101: Packaging, Storing, and Shipping of Radioactive Materials
WP-102: Radioactive Shipment Certificates of Compliance
WP-110: Radioactive Waste Disposal Data Requirements
WP-301: Radioactive Waste Solidification and Process Control Program
(PCP) '
WP-401: Waste Compacting System
CH-445: Radioactive Waste Handling and Disposal Reporting
The inspector reviewed the methods used by the licensee to assure that waste
was properly classified, met the waste forms and characteristics required by
10 CFR 61 and met the disposal site license conditions and discussed the use
of these methods with licensee representatives.
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The inspector reviewed the licensee's storage of letdown filters in the
radwaste building. The entrance to the storage room was controlled as a
- locked high radiation area. The room was divided by a 7 foot high shield
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wall which extended through the center of the room. Loading of radwaste
liners and other radwaste work was carried out on one side of the shield
wall. Letdown filters were stored on the opposite side of the wall. At the
time of the inspection, the licensee had approximately 56 letdown filters
stored in the area. Dose rates measured at the top of the shield wall
approximately five feet from the filters was 3 Rem per hour. A magenta and
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yellow rope bearing high radiation area placards was attached to the shield
j wall.
The inspector discussed access controls to this area with licensee
personnel. Licensee personnel stated that the large number of filters
stored on site was due ta a major crud burst which occurred prior to the
outage in March 1985. The licensee is storing the letdown filters to allow '
decay so T.nat the filters may be shipped as Class C type waste. A licensee
representative stated that additional controls to notify personnel of the
high dose rates in this area would be evaluated.
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No violations or deviations were identified.
9. Licensee Audits and Surveillance (83722, 83723, 83724, 83725, 83726, 83728,
84722 and 86721)
The inspector reviewed selected audits from 1983 and 1984 related to
radiation protection, radioactive waste management and transportation of
radioactive material . The audits performed by Quality Assurance appeared
comprehensive and thorough in scope.
No violations or deviations were identified. .
10. Inspector Followup Items (92701)
(Closed) Inspector Followup Item (50-302/85-12-01) the licensee had taken
action to insure the company physician reviewed and approved each employee's
medical qualifications prior to the first use of respiratory protection
equipment.
l 11. Solid Waste Statistics !
During 1984 the licensee shipped 14,709.8 cubic feet of solid radwaste
containing 1,144.81 Curies of activity. The solid radwaste target volume
! for 1985 is 19,000 cubic feet. As of August 26, 1985, approximately l 10,537.5 cubic feet of radwaste containing 3,862 Curies of activity had been
shipped by the licensee.
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