IR 05000335/1978019

IE Inspec Rept 50-335/78-19 on 780821-22 & 24-25 During Which 2 Items of Noncompliance Were Noted:Containers of Rad Matl Not Properly Labeled & Inadequate Posting of Notices to Workers

ML17206A526
Person / Time
Site:	Saint Lucie
Issue date:	09/27/1978
From:	Jackson L, Jenkins G, Sutherland J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17206A522	List: IR 05000335/1978019 ML17206A521 ML17206A523 ML17206A524 ML17206A525
References
50-335-78-19, NUDOCS 7811240013
Download: ML17206A526 (16)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATI.ANTA,GEORGIA 30303

+g~g4 Report No.:

50-335/78-19 Docket No.:

50-335 License NoeI DPR-67 Licensee:

Florida Power and Light Company 9250 West Flagler Street P. 0.

Box 013100 Miami, Florida 33101 Facility Name:

St. Lucie

Inspection at:

St. Lucie Site, Hutchinson Island, Florida Inspection conducted:

August 21-22 and 24-25, 1978 Inspectors:

G. R. Jenkins L. L. Jackson Reviewed by:

~

~

. F. Gibson, Chief Radiation Support Section Fuel Faciltiy and Materials Safety Branch Dat Ins ection Summa Ins ection on Au ust 21-22 and 24-25 1978 (Re ort No. 50-335/78-19)

Areas Ins ected:

Routine, unannounced inspection of radiation protection program, radioactive effluent monitoring instrumentation, reactor coolant chemistry and radiochemistry, neutron monitoring practices; followup on licensee reported events and IE circulars and bulletins.

The inspection involved about 48 inspector-hours on site by two ÃRC inspectors.

Results:

Of ten areas inspected, no apparent items of noncompliance or deviations were identified in eight areas; two apparent items of noncom-pliance were identified in two areas (Deficiency: Containers of radioactive material not properly labeled (78-19-01); Deficiency: Inadequate posting of notices to workers (78-19-02)).

k

RII Rpt.

No. 50-335/78-19 DETAILS I Prepared by:

F~m7Z

. J ns, Radiation Specialist Date Radiati Support Section Fuel Facility and Materials Safety Branch a7 7Z L. L.

kson, Radiation Specialist Radiatron Support Section Fuel Facility and Materials Safety Branch ate Dates of Inspection:

August 21-22 and 24-25, 1978 Reviewed by:

A. F. Gibson, Chief Radiation Support Section Fuel Facility and Materials Safety Branch ate l.

Individuals Contacted-C.

M. Wethy, Plant Manager-J

~ H. Barrow, Operations Superintendent C. A. Moore, Project Manager (Special Assignment)

-R. J. Frechette, Acting Chemistry Supervisor-H. M. Mercer, Acting Health Physics Supervisor P. Fincher, Training Supervisor H. F. Storey, Corporate Health Physicist (by telephone)

-C. A. Wells, Operations Supervisor G.

M. Green, Operating Health Physics Coordinator-L. F. Breshears, Senior Health Physics Technician A.

W. Bailey, gA Operations Supervising Engineer

• N. G. Roos, Acting gC Supervisor 2 Health Physics Technicians 2 Reactor Operators 2 Chemistry Technicians 2 gC Representatives-Denotes those present at exit interview.

2.

Licensee Action on Previous Ins ection Findin s

Not Inspected

RII Rpt.

h'o. 50-335/78-19 I-2 3.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.

An unresolved item disclosed during this inspection is discussed in paragraph 16 (78-19-03).

4.

Plant Tour The inspectors toured the auxiliary building and the controlled area outside the auxiliary building on August 21, 1978.

Items observed included posting and control of radiological areas, and control of radioactive and contaminated material.

Other than those discussed below, the inspectors identified no problems during the tour.

b.

The licensee had established a radioactive material storage area under the ramp leading to the containment building maintenance hatch.

The area was posted as a radiation area.

The inspectors observed a large quantity of materials stored in clear plastic bags; with a few exceptions, the bags were not tagged, labeled, or otherwise identified as containing radioactive material.

The inspectors cited this as noncompliance with 10 CFR 20.203(f)

which requires, in part, that each container of licensed material bear a label identifying the radioactive contents and providing sufficient information to permit individuals handling the containers, or working in the vicinity, to take precautions to avoid or minimize exposures (78-19-01).

Both an inspector and a licensee representa-tive performed a spot-check survey of the bags.

A maximum radiation level of about 200'rem/hr at contact was identified.

An inspector noted that there also were no "hot spot" tags used in this area, although Procedure HP-20 specifies that surface readings of greater than 100 mrem/hr will be so identified.

At the exit interview, licensee management stated that all of the bags had been properly labeled.

c ~

While making independent radiation surveys during the tour, an inspector noted that radiation levels exceeding 5 mrem/hr extended several feet beyond a rope barrier around radioactive material shipping casks stored on a paved area outside the auxiliary building.

Radiation area signs were posted on the rope, and a

licensee representative said that the rope boundary had apparently been moved closer to the casks since the survey.

Later during the inspection, a licensee representative stated that the barrier had been reestablished to coincide with the radiation area boundary.

The inspectors had no further questions on this ite RII Rpt. No. 50-335/78-19 I-3 5.

Followu on Licensee Event Re orts Two reportable occurrences (RO 78-13, March 28, 1978, and RO 78-24, June 25, 1978) which involved exceeding Technical Specifications 3.4.8.a.

dose equivalent I-131 limit of 1.0 pCi/gram in the primary coolant were reviewed by an inspector.

The inspector verified that the reports contained the information required by T.S. 3.4.8.

The inspector reviewed the isotopic analysis data for the samples associated with each event and verified that the reported dose equivalent I-131 (DEQ) values were accurate.

The inspector identified one error in RO 78-13 where the March 28, 1978, 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> sample result for I-132 concentration was transcribed erroneously (6.7E-l pCi/gram vice 3.0E-l pCi/gram), but the resultant DEQ was not affected.

The inspector had no questions regarding the sampling, analysis, and actions associated with these events.

6 ~

Reactor Coolant Chemistr and Radio Chemistr An inspector reviewed the reactor coolant chemistry sample results for January through July, 1978, and verified that sampling for chloride, fluroide, and dissolved oxygen met the frequency specified in T. S.

Table 4.4-3, and that the results were all within the limits of T.S.

Table 3.4.-1.

The inspector reviewed reactor coolant radiochemistry sample results for January through July, 1978, and verified that the sample and analysis program had been conducted in accordance with T.S. Table 4.4-4.

A licensee representative stated that a reactor trip occurred on August 10, 1978, and that reactor coolant sample required by T.S.

Table 4.4-4, Item 4.(b) was not taken within the specified 2-6 hours.

A licensee event report (LER) was being prepared for submittal to RII.

The licensee representative said that there is an automatic alarm system which alerts the reactor operator when a thermal power change exceeds 15~ of the rated thermal power within a one hour period.

He stated that the alarm functioned properly on August 10, but due to other problems in the control room at the time of the trip, the operator failed to notify a chemistry technician that the sample was required.

The inspector stated that this event would be reviewed further after the LER is received.

Other than the two cases discussed in paragraph

above, the inspector found no indication that primary coolant activity had exceeded the limits specified in T.S. 3.4.8.

7.

Effluent Control Instrumentation a

~

By review of records and discussions with licensee representatives, an inspector verified quarterly calibrations, monthly functional tests, and daily instrument checks for liquid and gaseous effluent monitors in accordance with Environmental Technical Specifications

RII Rpt. No. 50-335/78-19 I-4 (ETS) 2.4.2.f.

and 2.4.4.d.

Monitors included in this review were the plant vent monitor, fuel building exhaust montior, waste gas monitor, and liquid effluent monitor'.

Monthly functional tests for the period January through June, 1978, were verified for each of the monitors by review of completed checklists or waste release permits.

(}uarterly calibration records for all of 1977 and first two quarters, 1978, were reviewed for each of the monitors.

All were completed except for the fuel building exhaust monitor, which was calibrated in January, 1977; April, 1978; and July, 1978; the fuel building ventilation system was not in service during most of 1977 and early 1978; i.e., during the period between the fuel reconstitution and the first refueling.

Originally, the fuel building exhaust system consisted of two separate flow paths with a common monitor which cycled back and forth.

During the refueling outage (Spring, 1978),

these two paths were brought together in a common exhaust plenum, and a

temporary exhaust monitor was installed which included an iodine monitoring channel.

The Acting Chemistry Supervisor stated that a permanent Nuclear Measurements Corporation 3-channel monitor for the fuel building exhaust is on order and is expected to be received and installed in September, 1978.

b.

In reviewing the calibration (chemistry) procedures for effluent monitors, the inspector noted that, in most cases, the specific isotopic button sources used for calibration are not identified, even though Ba-133 and Cs-137 sources are consistently used.

The Acting Chemistry Supervisors stated that the source identities

'ould be included in the procedures during the next review and change cycle.

The inspector had no further questions.

c ~

The inspector reviewed documentation where two rotometers for use on the plant vent monitor were calibrated in April, 1978 by a contractor.

The rotometers were compared with a mass flowmeter traceable to NBS, with all measurements within + 20$.

d.

An inspector reviewed data and curves and discussed with the Acting Chemistry Supervisor the licensee's program for correla-tion of effluent monitor readings with known concentrations.

In conjunction with the initial calibration of the steam generator blowdown monitor and the condenser air ejector monitor, known concentrations were introduced into each monitor and response curves were plotted.

The monitors on systems where activity is routinely present (plant vent gas, waste gas, liquid effluent)

have had correlation curves plotted based on sample results obtained prior to actual releases.

These correlation curves are posted in the control room, and chemistry personnel periodically verify that no significant change in sample v.s. monitor reading has occurred.

The Acting Chemistry Supervisor stated that the

RII Rpt.

No. 50-335/78-19 I-5 calibration of the permanent fuel building exhaust monitor, when received and installed, will include the use of a known gas concentration for correlation.

The inspector stated that this would be reviewed during a subsequent inspection (78-19-04).

e.

An inspector discussed with a licensee representative an event which occurred at another facility involving the condenser air ejector monitor.

As a result of a significant leak in a steam generator tube, the monitor spiked momentarily but then went downscale due to saturation of the G-M detector.

The licensee representative said that the St. Lucie gaseous monitors use beta scintilation detectors.

The inspector also discussed an event at another facility wherein a continuous iodine stack monitor gave erroneous readings due to the adsorbtion of noble gases on the charcoal cartridge.

St. Lucie has continuous iodine monitor channels for the plant vent and the fuel building exhaust.

The Acting Chemistry Supervisor stated that they are aware of the adsorbtion of noble gases on the charcoal cartridge and recognize that the iodine monitors respond to noble gases during any high gaseous activity release.

The inspector stated that silver zeolite adsorbers could be used to minimize that effect.

The Supervisor said that the use of silver zeolite would be investigated.

The inspector had no further questions.

8.

Environmental Technical S ecification Errors An inspector noted that Environmental Techninical Specification (ETS)

2.4.4.e.

contains two erroneous references to tables pertaining to gaseous waste sampling and analysis and locations of gaseous monitors.

Table 2.4-2 should read Table 2.4-4; Table 2.4-4 should read Table 2.4-5.

Licensee management stated that they were aware of the errors, and their application of ETS 2.4.4.e.

involved use of the correct tables.

9.

Neutron Monitorin Practices a

~

An inspector reviewed the licensee's program for evaluating and assigning personnel neutron exposures'adiation surveys conducted during initial startup testing (1976) indentified high neutron

'ose rates in the reactor containment building due to a gap between the reactor vessel and the biological shielding.

A water bag shield was designed and was scheduled to be installed during the first refueling outage (Spring, 1978);- fit problems were encountered, however, and present plans call for the installation to be made during the second refueling outage (Spring, 1979) or possibly during a short outage in October, 1978.

RII Rpt.

No. 50-335/78-19 I-6 b.

Due to the high neutron dose rates, no entries to the containment building operating deck are permitted during power operation.

Routine, bi-weekly entries are made to other levels by reactor operators.

These are always accompanied by a health physics technician with a remmeter for neutron surveys.

All personnel who enter the containment building during power operations wear TLD badges which include neutron-sensitve TLD cards.

These cards include a chip of LiF enriched in Li (TLD-600 from Harshaw Chemical Company)

and a chip of LiF enriched in ~Li (TLD-700 from Harshaw).

The TLD-700 responds primarily to gamma radiation.

The TLD-600 responds primarily to gamma radiation and thermal and epithermal neutrons; the latter are produced primarily by moderation of fast neutrons in the body of the individual.

The TLDs are routinely read monthly at the General Office in Miami.

The evaluation of neutron exposure involves taking the difference in readings from a TLD-600 behind a

cadimum strip and a TLD-700 behind an alumimum disk.

That difference is multiplied by a correction factor to get the neutron dose equivalent.

A correction factor of 0.6 is currently used; this value was derived from earlier measurements at the Turkey Point plant.

Licensee representatives said that no thorough correlation of TLD neutron results with estimated neutron doses based on survey results and stay times had been done at the St. Lucie plant, but that a

program for such correlations has now begun.

The inspector stated that the licensee's neutron monitoring program appeared to conform with Regulatory Guide 8.14, but that the above correlations, as well as additional measurements of the particular neutron energy spectra and TLD response in the containment building, were important parameters.

A licensee representative said that FPSL had a contract with Battelle Northwest Laboratory to expose TLD badges to thermal, intermediate, and fast neutrons of known flux and spectral values.

Some of the data have been analyzed, but additional exposures are to be made soon.

The Corporate Health Physicist stated that these test results would be used to develop new correction factors for neutron TLD results.

C.

At the request of an inspector, a licensee representative reviewed the monthly exposure reports for 1977 and determined that 146 individuals received neutron exposure.

The total neutron man-rem for 1977 was 45.36 rem.

d.

In reviewing neutron monitoring practices, the inspector noted that Procedure HP-30, "Personnel Monitoring", did not address the personnel neutron monitoring methods currently employed.

The Acting Health Physics Supervisor stated that the procedure would be revised for that purpose (78-19"05).

RII Rpt. No. 50-335/78-19

~

~

I-7 10.

Shi ments of Low S ecific Activit Radioactive Material An inspector discussed IE Circular 78-03 with licensee repre-sentatives, who stated that a review of radioactive material shipment records revealed no cases where LSA shipments of greater than Type A quantity were made in non-specification containers.

The inspector determined that Procedure HP-40,

"Shipment and Receipt of Radioactive Material," does not specifically address or caution against such an occurrence.

The Acting Health Physics Supervisor said that the procedure would be changed to include such a caution (78-19-06).

IE Bulletin 78-07-Protection Afforded b Air-Line Res irators and Su lied-Air Hoods An inspector discussed FPSL's letter of August 11, 1978, in response to the subject bulletin.

Neither supplied air hoods nor respirators in the demand mode are used at the St. Lucie plant.

The inspector had no further questions.

12.

IE Bulletin 78-08-Radation Levels From Fuel Element Transfer Tube An inspector discussed FPSL's letter of August ll, 1978 in response to this bulletin.

Licensee representatives stated that the fuel transfer tube area was surveyed during the Spring, 1978, refueling (this was also discussed in RII Rpt. No. 50-335/78-10, Details I), but that documentation of the survey results could not be located.

Therefore, the survey will be repeated and documented during the Spring, 1979 refueling.

The inspector identified this as an open item to be followed up at that time (78-19-08).

13.

Termination Re orts RII Rpt.

No. 50-335/78-10, Details I discussed a concern with the lack of internal dosimetry information in termination reports.

The termina-tion report now includes a statement that internal exposure is "within normal limits" if all results are less than 5g maximum permissible organ burden (MPOB).

A licensee representative stated that, should results greater than 5X MPOB be obtained, the report would include an attachment with the isotopes and quantities identified.

The inspector had no further questions.

14.

ualifications of Health Ph sics Technicians Technical Specification 6.3.1 states that each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

An inspector reviewed the resume's of two technicians

RII Rpt.

No. 50-335/78-19

~

~

I-8 (Radiation Protection Men) added to the Health Physics staff in the previous year and determined that the individuals met the requirements of the ANSI Standard.

In addition, an inspector reviewed the resume's of two supervisory members of the Health Physics staff and found that these individuals also met the requirements of the ANSI Standard.

There were no further questions in this area.

15.

Audits and Reviews of the Radiation Protection Pro ram a

~

Technical Specification 6.5.2.8.a.

requires that audits of facility activities be performed under the cognizance of the Corporate Nuclear Review Board (CNRB).

One of the areas encompassed is the conformance of facility operation to all provisions contained within the Technical Specifications and applicable license conditions.

This area shall be audited at least once per 12 months.

An inspector reviewed the results of Management Audit QAO-PSL-77-08-111 and discussed and reviewed the scheduling of audits with the gA Operations Supervising Engineer.

The inspector determined that the requirements of Technical Specification 6.5.2.8.a are being met.

b.

The Health Physics Manual Section 3.6 states that a formal review of plant Health Physics operations will be conducted at least annually.

An inspector reviewed the results of the last corporate Health Physic Audit, PRN-HP-78-41.

This audit was conducted over the period 2/78-6/78.

The inspector had no further questions in this area.

c ~

An inspector reviewed the activities of the plant Operations (}uality Control Staff and determined that the gC staff has an ongoing program of inspections involving health physics activities.

There were no further questions in this area.

16.

~Trainin Technical Specification 6.4.1 requires the licensee to maintain a

retraining and replacement training program for the facility staff which meets or exceeds the requirements and recommendations of Section 5.5 of ANSI N18.1-1977.

In addition, Section 3.3.3 of the Health Physics Manual contains certain training 6 retraining (refresher)

requirements for non-plant and plant personnel.

An inspector reviewed the training records (radiation protection training only) of several individuals on the health physics staff and the maintenance staff.

For three of the individuals selected,,

there were no records that the individuals had completed the training course and/or the examination required by HP Manual Section 3.3.3.2.3 a.

For one individual, the refresher training required by HP Manual Section 3.3.3.2.3.c.

had not

RII Rpt. No. 50-335/78-19

~

~

I-9 been completed within the two year time period.

The individual was trained in June 1975 and retrained in March 1978.

A representative of plant management stated that radiation protection training records were being computerized and that this would provide greater control over the records, as well as providing the capability to obtain listings of all plant personnel requiring a particular type of training for any given month.

The same representative stated that training records would be.screened and any individual who has no record of completing the examination required by 3.3.3 '.3.a will be retested.

The inspector stated that the area of radiation protection training and training records will be carried as an unresolved item.

(78-19-03).

17.

Health Ph basics Procedures

'echnical Specification 6.11 states that procedures for personnel radiation protection shall be prepared consistent with the require-ments of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

An inspector reviewed nine procedures which had been revised since the last inspection.

(HP lp HP 4 HP 6y HP lOCy HP lip HP 12)

HP 13Hp HP-13J and HP-22).

These procedures appeared adequate.

In reviewing HP-32,

"Source and Drift Check Pocket Dosimetry," an inspector noted that the procedure was not in accordance with guidance given in ANSI N13.5, Section 9.3 which is referenced by Regulatory Guide 8.4.

ANSI N13.5 specifies that the drift check start from zero on the dosimeter scale and that the drift not exceed two percent of full scale in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

HP-32 apparently allows the drift check to start at the point on the scale which is determined by exposure to a source for calibration purposes.

In addition, HP-32 sets the acceptance criteria at three percent of full scale instead of two percent as recommended.

A licensee representative stated that HP-32 would be revised to conform to the drift check specifications of ANSI N13.5 (78-19-07).

18.

Postin of Notices (10CFR19.11)

CFR 19.11(a) states that each licensee shall post current copies of the following documents:

(1) The regulations in 10 CFR 19 and

CFR 20 (2) The license, license conditions or documents incorporated into a license by reference, and amendments thereto; (3) the operating procedures applicable to licensed activities, etc'nder provisions of 10 CFR 19.11(b), if posting of a document specified in 10 CFR 19.11(a)

(l),(2) or(3) is not practicable, the licensee may post a notice which describes the document and states where it may be examined.

CFR 19.11(c)

requires that form NRC-3, "Notice to Employees,"

be posted by each licensee wherever individuals work in or frequent any portion of a restricted area.

CFR 19.11(d) requires that documents, noctices or forms posted pursuant to 10 CFR 19.11 shall appear in a sufficient

RII Rpt. No. 50-335/78-19 I-10 number of places to permit individuals engaged in licensed activities to observe them on the way to or from any particular licensed activity location to which the document applies, shall be conspicuous and shall be replaced if defaced or altered.

An inspector observed that only the Form NRC-3 was posted at the access control point near the Health Physics Station of the reactor auxiliary building.

None of the documents referenced in 10 CFR 19.11(a),

nor a notice per

CFR 19.11(b)

were posted.

A bulletin board in the hallway leading from the maintenance shop in the service building to the yard between the turbine building and service building contained a

copy of Form NRC-3 and a letter referencing some but not all of the documents listed in 10 CFR 19.11(a).

It was also noted that personnel can and do routinely report to work in the auxiliary building without using this hallway.

A third bulletin board located on the second floor of the service building was checked and found to contain a

letter referencing some, but not all, of the documents required by

CFR 19.11(a).

There was no Form NRC-3 on this bulletin board.

The inspector stated that failure to provide complete postings at a

sufficient number of places to permit individuals engaged in licensed activities to observe the postings on their way to and from licensed activities constitutes noncompliance with 10 CFR 19.11 (78-19-02).

Licensee management indicated that an appropriate notice would be posted in the entrance foyer to the reactor auxiliary building.

19.

~Surve s

a.

CFR 20 paragraph 20.201(b) requires that each licensee shall make, or cause to be made, such surveys as may be necessary for him to comply with the regulations in this part.

'In addition, paragraph 20.401(b) requires that each licensee shall maintain records in the same units used in 10 CFR 20 showing the results of surveys required by 20 '01(b).

An inspector determined that surveys are being conducted on a routine basis with special surveys being conducted as needed.

An inspector reviewed the records of several surveys and determined that the records were adequate and that the survey status board, located at the Access Control Point, contained current survey information.

b.

CFR 20 paragraph 20.103(a)(3)

requires the licensee to use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas'n inspector reviewed the records of several airborne activity surveys.

The surveys considered both particulates and halogens and appeared adequat RII Rpt.

No. 50-335/78-19

~

~

I-11 c ~

Technical Specification 3/4.7.9, Sealed Source Contamination, requires that sealed sources containing in excess of 100 microcuries of beta and/or gamma emitting material or 5 micro-curies of alpha emitting material be periodically leak tested.

An inspector reviewed the records of the most recent leak tests and found the records and the results to be satisfactory.

20.

Exit Interview The inspectors met with management representatives (denoted in paragraph 1) on August 25, 1978, and summarized the scope and findings of the inspection.

Items discussed included the two items of noncom-pliance and one unresolved item included in this inspection report.