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o UNITED STATESg,8 NUCLEAR REGULATORY COMMISSIONo

.- a REGION 11

#o, 101 MARIETTA ST., N.W., SulTE 3100

ATLANTA, GEORGIA 30303 |o.....

FEB 0 41982 |

Report No. 50-261/82-01

Licensee: Carolina Power and Light411 Fayetteville Street;

Raleigh, NC 27602

Facility Name: H. B. Robinson4

Docket No. 50-261

License No. DPR-23,

Inspection at H. B. Robinson site near Hartsville, South CarolinaQ . - j' /

Inspector: N' 8) NE/4/2;_; /-A84' .2'

.' L. A. Franklin ' Date Signed

| Approved by: 8 / / CPLK. P. Barf, Section Chief /Dat( SignedTechnical Inspection BranchEngineering and Technical Inspection Division

SUMMARY

Inspection on January 11-15, 1982

Areas Inspected

This routine, unannounced inspection involved 31 inspector-hours on site in theareas of training, personnel qualifications, posting and control, intrumentation,

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exposure control, respiratory program, and licensee action on previous inspection: findings.

Results

Of the seven areas inspected, no violations or deviations were identified.

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REPORT DETAILS4 -

1. Persons Contacted

Licensee' Employees.

*R. B. Starkey, Jr. , Plant General Manager*D. S. Crocker, Environmental and Radiation Control Manager*W. L. MacCready, Radiation Control Supervisor*C. L. Wright, Specialist, Regulatory ComplianceW. Skinner, Training AssistantM. Layton, Environmental Control Project SpecialistK. Traegde, Radiation Control SpecialistR. Denney,- Radiation Control ForemanD. Boan, Radiation Control ForemanW. T. Ritchie, Radiation Control Forercan

| J. Harness, Assistant to the Vice President of Nuclear Operations!

j Other, licensee employees contacted included three technicians, two! mechanics, and three office personnel.

NRC Resident Inspector.

S. Weise.

* Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on January 15, 1981, withthose persons indicated in paragraph 1 above. Three inspector identified -

items were acknowledged by tt: plant general manager. The inspector noted; that plant housekeeping and posting and control of radiological areas

appeared excellent.'

3. Licensee Action on Previous Inspection Findings

! (Closed) Violation 81-07-12. This item concerned the failure to perform! measurements necessary for timely detection and assessment of'

individual intakes of radioactivity. Two procedures have beeni completely revised, HP-7 (Special Radiation Work Permits) and

HP-32 (Personnel Whole Body Countir.g). The procedures were exam-ined and appear adequate. The inspector had no further questions.

(Closed) Violation 81-07-17. This item was a multi part violation con-cerning procedural violations. In all five parts of this vio-

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lation licensee action appears to have been proper. In two casest

i personnel reprimands were given, in one case the respirator partsinventory was reinstituted, and in the other two cases procedures

| were revised. The inspector had no further questions.

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(Closed) Violation 81-07-20. This item concerned the failure, by thelicensee, to assure only Class "D" air was used for breathing air.Procedure HP-6 has been revised and this annual test of breathingair is being done properly. The inspector had no further quest-ions.

(Closed) Violation 81-07-29. This item concerned a worker entering a highradiation area without a survey instrument. A memorandum was sentto all plant personnel stating that violations of plant procedureswould not be tolerated and in addition Administrative InstructionSection 11.5 was noted in this memorandum. The administrativeinstruction informs personnel regards disciplinary action whichcan be administered. The inspector had no further questions.

(Closed) Unresolved 50-325/80-39-01, 50-324/80-36-01, 50-261/80-27-01.This item concerned a TLD reader and system that was in use at theHarris Energy and Environmental Center, Raleigh, North Carolina.This equipment is no longer in use. The inspector had no furtherquestions.

4. Unresolved Items

Unresolved items were not identified during this inspection.

5. Licensee Action On Previous Inspector Identified Items

(Closed) IFI 81-07-01. This item concerned the lack of a formal review ofthe plant environmental and radiation control activities by thecorporate heai;h physics staff. A memorandum from R. L.Mayton , Jr. , of the Corporate Staff, to D. S. Crocker, Manager,Environmental and Radiation Control dated December 7, 1981 statesthat formal reviews will be accom.olished with Corporate HealthPhysicists beginning calendar year 1982. The inspector had nofurther questions.

(Closed) IFI 81-07-18. This item concerned the individual, responsible forthe respiratory protection program not being a member of the plantstaff. This responsibility has been reassigned to a member of theplant staff. This individual is a Radiation Control Foreman witheight years of experience in the health physics field and appearswell versed in respiratory programs, regulations, etc. Theinspector had no further questions.

(Closed) IFI 81-07-23. This item concerned what appeared to be an inade-quate number of personnel friskers throughout the plant. Fivefrisker locations have been added, including one additionalstation at the RCA exit and the " hot" machine shop. Based on theinspectors observations no furtoer questions were necessary.

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(Closed) IFI 81-07-24. This item concerned a lack of specific surveyinformation for radiation work permits. Procedure HP-7 has beenrevised and in Section 3.10.2 this information is specificallyrequired. The inspector had no further questions.

(Closed) IFI 81-07-25. This item concerned a lack of review and trendanalysis for routine health physics surveys. Procedure HP-I hasbeen revised and Section 5 specifically requires review by radi-ation control foreman and by the radiation control supervisor.The precedure appears adequate. The inspector had no furtherquestions.

(Closed) IFI 81-07-26. This item concerned the lack of thorough radi-ological surveys of the secondary steam side of the plant.Procedure HP-2 has been completely revised and specifically coverssecondary side routine surveys which are performed on a monthlybasis. This procedure appears adeonate. The inspectar had nofurther questions.

(Closed) IFI 81-07-27. This item concerned the surveillance program oftools, equipment, and materials leaving the controlled area.Procedure HP-39 has been revised and appears to adequately coverthis inspection item. The inspector had no further questions.

(Closed) IFI 81-07-35. This item concerned accountability of secondaryside effluent. Procedure E.5.-2 titled " Radiation Control andProtection Manual" has been revised and the section pertaining toeffluent waste disposal appears adequate. The inspector had nofurther questions.

(Closed) IFI 81-07-43. This item concerned the protective clothing doserate allowed by the licensee. The Radiation Control and Pro-tection Manual, Volume B, which had a limit of 5 mrem /hr has beenrevised and dose limits for protective clothing have been reducedto 0.5 mrem /hr. The procedure change appears adequate. Theinspector had no further questions.

(Closed) IFI 81-07-45. This item concerned the calibration of portableinstruments in accordance with ANSI N 323. Procedure HP-11 titled" Survey Instrument Calibration" has been generally revised andappears to meet the ANSI standard. The inspector had no furtherquestions.

6. Personnel Qualifi; cations

Licensee Technic'al Specification 6.3.1 states that each member of thefacility staff shall meet or exceed ANSI N18.1-1971 with regard to theminimum qualifications for comparable positions. The inspector reviewedresumes for all staff members of the radiation control group tc determine iftechnicians and supervisors satisfy the requirements of the standard. All

| personnel appear to meet or exceed this requirement.|

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7. Training

The inspector selectively reviewed the training records of radiation controlpersonnel and maintenance personnel. These records included basic radiationsafety training, retraining, and respiratory protection training. Therecords appeared to be in good order and the training appears adequate tocover the requirements of 10 CFR 19, and Appendix A to Regulatory Guide 8.13concerning exposure to radiation during pregnancies.

i 8. Respiratory Protection Program

By review of records, observation by the inspector, and discussionsa.with licensee representatives the inspector evaluated the respiratoryprotection program for compliance with 10 CFR 20.103, Regulatory Guide8.15, NUREG 0041, and plant procedures. Technical Specification 6.11requires that procedures for personnel radiation protection be con-sistent with the requirement of 10 CFR 20 and be maintained and adheredto for all operations involving personnel radiation exposure. Records ,

of air samples, bioassays, MPC-hours, medical evaluations, training,and respirator maintenance and fit tests were selectively reviewed andappeared to be adequate.

b. The inspector discussed certification of regulators for self contained4

breathing apparatus (SCBA) with licensee representatives. Normallythese regulators require annual recertification however the SCBA model

; in use at this facility.is a new model and the requirement is not known'

at this time. A licensee representative agreed to check with themanufacturer and take appropriate action (82-01-02).

9. Exposure Controls

The inspector selectively reviewed records of personnel exposures. Dataindicated that no worker was exposed to levels of radiation in excess of theapplicable regulatory limits in 10 CFR 20.10.. The inspector noted thatextremity dosimeters were issued when appropriate. Radiation work permits,

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and pertinent radiological surveys were selectively examined for the periodNovember 1, 1981 to January 13, 1982. These records appeared to be in good'

order, however one area of concern was noted. Licensee procedure HP-7requires a designated escort be noted on each radiation work permit issuedfor entry to high radiation areas. The primary purpose of the designatedescort is to assure a dose rate instrument is used. An exception can be<

I made to this requirement if continuous coverage is provided by radiationcontrol personnel. Two radiation work permits were examined for entry tohigh radiation areas on which no designated escort was noted. As these

' entries require continuous use of a survey instrument the instrument issuelog was examined. This log requires the name and work location for instru-i

ment issue. None of the personnel on the two work permits in question were- '

. issued a survey instrument. A licensee representative explained that! radiation control personnel covered this work, however an examination of the

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work permits for radiation control personnel and examination of the instru-ment issue log failed to verify that these jobs received coverage. Theinspector informed licensee representatives that this procedure needsrevision in order to provide verification that procedures are being followed(IFI 82-01-03).

10. Instrumentation

a. An inspector reviewed the supply, calibration, alarm set points, andoperability of selected portable survey instruments. During theinspection survey instruments in use at the health physics laboratory,radwaste, and exits from various areas, were found to have currentcalibrations and appeared to be in good operating condition. Alarm setpoints, including friskers, appeared to be proper and in keeping withlicensee procedures. The inspector did note the dose rate instrumentsappeared to be in short supply and was informed that additional instru-ments have been purchased and will be available soon.

b. Licensee procedure HP-11 titled " Survey Instrumentation Calibration"requires a survey instrument inventory be performed in the first weekof each month. During the course of this inspection the inspectorrequested that this inventory record be made available for examination.A licensee representative informed the inspector that the inventory hadnot been completed but was nearly ready for inspection. The inspectordetermined that this has not been a problem in the past but did informthe licensee that this record snould be available. The inspectorfurther informed the licensee that this would be a specific inspectorfollowup item (82-01-01).

11. Posting and Control

a. The inspector reviewed the licensee's posting and control of radiationareas, high radiation areas, airborne radioactivity areas, contamina-tion areas, radioactive material areas, and the labeling of radioactivematerial during tours of the plant. No violations or deviations wereobserved.

b. The posting of notices, as required by 10 CFR 19.11, was examined bythe inspector and appears to meet the requirements.

12. Bulletins, Circulars and Notices

IE Information Not ~ 1 Number 81-26 was discussed with the Radiation ControlSupervisor. A memcrandum will be issued shortly by the Radiation ControlSupervisor to the Plant General Manager. However, the memorandum was notready for inspection at this time. Considerable time was spent in discus-sion of Part 3 of this notice. It was explained by the inspector thatthis information, regarding the placement of personnel monitoring devices,was not a change of policy but simply to remind licensees of the need toassess and provide multiple badging when necessary. The inspector furtherexplained that the notice would perhaps prevent overexposures of the typethat can occur in steam generator work.

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