IR 05000003/1976012
| ML20050C020 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/22/1976 |
| From: | Knapp P, Neely D, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050C018 | List: |
| References | |
| 50-003-76-12, 50-247-76-25, 50-286-76-27, 50-3-76-12, NUDOCS 8204080024 | |
| Download: ML20050C020 (22) | |
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l IE:I For= 12 l
(Jan 75) (Rev)
i U. S. NUCLT_G REGUIATORY CCiciISSION
I 0FFICE OF INSPECTION AND ENF02CDENT
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REGION I
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50-03/76-12 50-03 50-247/76-25 50-247 IE Inspection Report No:
50-286/76-27 Docket No:
50-286 uta-3 Licensee:
Consolidated Edison Company of New York, Inc.
License No:
DPR-26 M K-o 4 4 Irving Place Priority:
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a.i,!R Safeguards Loca tion:
Buchanan, New York (Indian Point Units 1, 2, and 3)
Type of Licensee:
PWR, 615 MWt (B and W), PWR, 2758 MWt (W), PWR, 3025 MWt (W)
S ecial, Announced Type of Inspection:
P Dates of Inspection:
October 20 - November 25, 1976 Dates of Previous Inspection:
October 15, 1976 Reporting Inspector: 411 8 77"d%
/2 - 2 2.
'74 D. R. N' eely', Radiat pecialist DATE Acco=panying Inspectors:
/2 2# f t ge:
J. ft. White, Radiation Specialist DATE DATE
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DATE Other Accc-v.ng Person h W tk O ----
11 - TZ-h-K'. J. Knapp, Chief,
diatigt Support Section DATE t
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F@.1 Facility and terials Safety Branch Rsviewed By t
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! h-M - v 6 PNQ7pp, vnfef, Radiation Suppert Se'6 tion DATE Fuel Facility and Materials Safety Branch 8204080024 77ogk3 DR ADOCK 03Ooo PDR
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SUMMARY OF FINDINGS i
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Enforcement Action Items of Noncompliance A.
Violations None.
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3.
Infractions
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1.
76-25-01 - Control of High Radiation Areas
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Contrary to 10 CFR 20.203(c)(2)(iii), on November 11 and 12,
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1976, positive control was not maintained over each individual
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entry to the Unit 2 Vapor Containnent (a high radiation area, which did not have specified control devices and was not locked) in that persons were persitted to enter the area wi.thout the individual controlling the entries having verified that the entries were made under a valid Radiation Work Permit, which is the licensee's control method.
(Details, 4)
2, 76-12-01 - Egress From High Radiation Areas Contrary to 10 CFR 20.203(c)(3), on November 10, 1976, the door to the Purification Outlet Filter Room was equipped with a locking device which could be locked from the outside in such a way as to prevent an individual from leaving the high i
radiation area.
(Details, 5)
3.
76-12-02, 76-25-02, 76-27-01 - Surveys Contra: -
a 10 CFR 20.201(b):
a.
During the period November 11-13, 1976, individuals
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worked inside Steam Generators 23 and 24 where localized
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gamma radiation fields of up to 12 R/hr existed near tube sheet surfaces providing the potential for hand doses in
excess of 25 percent of the applicable value specified in i
10 CFR 20.101(a) and the survey made to determine whether i
extremity personnel monitoring was required, persuant to l
10 CFR 20.202(a)(1), was not adequate in that it failed
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to reveal the need for such monitoring as was subsequently
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discovered during a resurvey conducted November 13, 1976.
(Details, 14)
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b.
On November 12, 1976, individuals perfor ed an eperation involving the drumming of evaporator bottems in the Unit 1 Chem Systems Building drumming area and a survey was not made for the presence of airborne radioiodine to assure compliance with the requirements of 10 CFR 20.103(a).
(Details, 6)
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c.
During the period January through September,1976, evaluations adequate to assure compliance with 10 CFR 20.101(b) were not made when dosimeter results were disregarded and film badge results were used in determining quarterly accumulated exposures when no factual basis for disregarding dostneter results had been identified.
(Details, 7)
4.
76-12'-03, 76-25-03, 76-27-01 - Radiation Protection Procedures Contrary to Unit 2 and 3 Technical Specification 6.11 and Unit
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l Technical Specification 3.2.5:
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a.
SAO 105 was not adhered to during the period November 10-12, 1976, in that two Continuous Air Monitors in the Unit 2 Vapor Containment, installed to monitor in the areas of Steam Generators Nos. 23 and 24, and one Continuous Air Monitor in the Unit 1 Chem Systems Building, installed to monitor the air during the drumming of evaporator bottoms
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did not have their high alarm points set at the specified levels required by the Radiation Work Permit issued for
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each job.
(Details, 8)
b.
The procedure entitled " Steam Generator Primary Water Box Entry" was not adhered to on Nove=ber 11, 1976, in that l
an individual who had been working in the upper tent area
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of Steam Generator No. 23 did not remove his outer Anti-C clothing prior to leaving the lower tent.
(Details, 9)
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c.
Health Physics Procedure 6, Revision 3, was not adhered to on November 9, 1976, when the beta activity on a l
particulate filter was greater than 1 X 10-9 uC1/cc and
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the filter was not counted on the alpha plateau and the beta / alpha ratio was not determined.
(Details, 10)
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d.
Contrary to General Administrative Directive RS-GAD-2,
Revision 1:
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(1)
On November 11, 1976, the blacktop roadway (an
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uncontrolled area) outside the Unit 1 dressing room I
was contaminated with radioactive material in excess
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of the specified lisit and was not roped off and contamination controls were not instituted.
(De-tails, 13)
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(2)
On November 11 and 12,1976, the laundry change room
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for Units 1, 2 and 3 had removable radioactive contamination in excess of tha specified limits and was not roped off and contamination controls were not instituted.
(Details, 14)
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e.
Contrary to Station Administrative Order No.120, during the period July 9 - November 6, 1976; (1) at least 3 individuals with cumulative indicated exposures (as shown by dosimeter) of 1250 mrem or more in a quarter were not restricted from the Controlled Area pending exposure verification and were permitted to enter the Controlled
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Area and receive cumulative indicated exposures as high as 1522 mren before being restricted from the Controlled i
Area and their fiLn badges re=oved for evaluation, and (2) an individual whose quarterly limit had been extended l
to 1700,mram received an additional 510 mres beyond the 1700 mrem limit without prior authorization from the Manager, Nuclear Power Generation, or his designated alternate.
(Details, 11)
C.
Deficiencies 76-12-04 - Posting of High Radiation Areas Contrary to 10 CFR 20.203(c)(1), on November 12 and 13,1976, a corridor accessible to personnel at the 70' elevation of the Unit 1 Chem Systems Building had radiation levels up to 200 mr/hr and was posted as a radiation area rather than a high radiation area.
(Details, 12)
l Licensee Action on Previousiv Identified Enforcement Action Not inspected.
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Design Changes Not inspected.
- i Licensee Events i
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Not inspected.
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Other Significant Findings l
A.
Current Findings
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1.
Acceptable Areas
I No inadequacies were identified during inspection of the following areas:
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- Plant Records.
(Details, 3)
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Unresolved Items None.
B.
Status of Previous 1v Identified Unresolved Items Not inspected.
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Management Interview I
A management interview was conducted at Buchanan, New York, (site) on November h
16, 1976.
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Persons Present
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E. Kessig, Acting Manager, Nuclear Power Generation Department E. McGrath, Manager, Nuclear Power Generation Department (Designee)
T. Law, Plant Manager i
S. Wisla, Radiation Safety Director
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Items Discussed i
A.
Purpose of the Inspection f
The inspector stated that the present inspection effort was part of an j
extended inspection of the health physics program and that dt. ring i
the inspection major areas of the program would be reviewed because of I
NRC concerns over program adequacy and implementation.
The inspector noted that among the specific areas that required review were (1)
access and control of high radiation areas, (2) dosimeter-film
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badge discrepancies, and (3) weaknesses in the Radiation Work (
Permit System.
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B.
Items of Noncompliance
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I The items discussed are as identified under the " Enforcement Action"
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section of this report.
The problems raised by the discrepancies between pocket dosimeter and film badge results were discussed.
It was l
emphasized that the discrepancies might indicate a significant problem i
in dose measurement and assignment and that an evaluation of the cause I
of the discrepancies would have to be done promptly.
C.
Other Items of Discussion The inspectors noted that during the inspection they had found that l
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housekeeping had improved considerably over the last 3 months. Manage-
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ment accepted the inspection findings and concerns in a positive manner.
Other items discussed are as identified under the "Other Significant Findings" section of this report.
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DETAILS i
1.
Persons Contacted i
T. Law, Plant Manager R. VanWyck, Manager, Nuclear Services A. Cheifetz, Health Physicist i
J. Makepeace, Director, Technical Engineering W. Monti, Plant Engineer
B. Moroney, Chief Operations Enginee.
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S. Wisla, Radiation Safety Director
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J. Cullen, Director, Health Physics
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G. Liebler, Radiological Engineer G. Imbimbo, Health Physics Supervisor
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J. Perrotta, Health Physics Supervisor i
P. Gaudio, Health Physics Supervisor I
J. Kelly, Station Chemistry Director J. Odendahl, Senior Electrical Technician, Radiac in Safety Steward S. Sadlon, Health Physics Technician C. Stajura, Health Physics Technician
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R. Selman, Health Physics Supervisor, Institute of Resource
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Management N. Junk, Health Physics Supervisor, Institute of Resource Management
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R. McGinley, Technician, Institute of Resource Management B. Swafford, Technician, Institute af Resource Management R. McCullers, Technician, Institute of Resource Management j
G. Policastro, Technician, Institute of Resource Management
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2.
Purpose and Scope of the Inspection This continuing special inspection of the implementation of the health physics program was announced during a corporate management meeting on October 15, 1976.
It is being conducted because of continued
concern about the licensee's health physics program.
Special attention has been directed to the licensee's failure to adequately implement i~
corrective action regarding high radiation area control.
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The scope of the inspection consisted of a review of selected air sample records, Radiation Work Permits, survey records, exposure l~
control records, personnel dosimetry reports, and inspecticas of
the Unit 1. Unit 2, and Unit 3 controlled Areas.
In addition,
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during steam generator work in progress at the time the inspector
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examined the radiation safety effort to determine its adequacy.
This examination consisted of reviewing access controls for high radiation l
areas, survey records, contamination coatrol, Radiation Work Permits,
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exposure control, mechanical and radiation protection procedures, and interviews with plant personnel.
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3.
Plant Records The inspector reviewed the following records for the periods indicated
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and found that they appeared to be acceptable.
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a.
NRC Form 4's - January 1976 - present.
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b.
NRC Form 5's - January 1976 - present.
c.
Exposure authorizations - January 1976 - present.
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4.
High Radiation Area Control
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Regarding control of high radiation areas, licensee representatives
stated that the method employed to comply with the 10 CFR 20.
203(c)(2)(111) for controlling high radiation areas within the
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reactor containment (referred to as vapor containment or VC), is to
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establish a control point at the entrance to the VC and to assure i
that persons entering are authorized by Radiation Work Permit (RWP)
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to work within specified high radiation areas inside the VC.
The
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Unit 2 VC is posted as a high radiation area.
The control point
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individual must determine that the authorized persons have been provided with all necessary protective clothing and equipment and l
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are otherwise assured of meeting all RWP require =ents.
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On November 11, 1976, the inspector visited the entrance to the Unit 2
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VC and observed the performance of the person assigned to maintain positive control over each individual entry.
It was reported to the inspecter that this individual, was a guard-who was temporarily
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filling in for a technician who was on break.
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The inspector observed that when a worker entered the VC and listed an RWP number, the guard did not check the records to determine whether the
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corresponding RWP was valid, and to establish what forms of protective i
clothing and equipment were required.
The guard, when questioned by the inspector, stated that he did not know what an RWP was and that he had not been instructed to check RWP validity or requirements.
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This matter was called to the attention of the Radiation Safety Director I
whc responded immediately by issuing written procedures specifying the
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method of maintaining positive control.
These instructions were placed
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at the entry to the VC.
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On November 12, 1976, the inspector returned to the VC entry point and reviewed the licensee's effort to maintain positive control.
The inspec-
tor noted from the entry log that two individuals had entered the VC
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citing RWP-214, "Relamping," and the inspector asked the assigned
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individual to demonstrate that he had verified that RWP-214 was'a valid i
work permit.
The individual had no copy of RWP-214 at the control point.
l The inspector noted that copies of all valid RWP's for VC entry were to l
be retained at the entry point in order that an individual's authoriza-
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tion could be verified.
The control point individual reported that he had not verified that RWP-214 was valid and did not know what radiation protection requirements it contained.
Further review revealed that another individual had entered the VC on f-RWP-256 on the same date and that a copy of this RWP was not available
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at the entry point.
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The inspector informed the licensee that these examples indicated that
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personnel were allowed to enter the VC without RWP validation.
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inspector identified this as noncompliance with 10 CFR 20.203(c)(iii).
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(76-25-01)
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The licensee took immediate action to reinstruct appropriate personnel
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in the necessity of maintaining positive control.
On November 13, 1976,
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the inspector returned to the VC entrance and noted that positive control at this entry appeared to be adequately established.
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5.
Egress From H* zh_,Padiation Areas
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l 10 CFR 20.203(c)(3) requires that devices used to control access to high
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radiation areas be established in such a way that no individual _will be
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prevented from leaving the high radiation area.
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On November 10, 1976, during an inspection of the Unit 1 Controlled Area, f
the inspector observed that the Purification Outlet Filter Rocm was posted
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as a high radiation area and locked.
In addition, the room was posted to
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reflect the results of surveys conducted on August 26, 1976, specifing
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radiation levels up to 840 mr/hr at 18" from the filter casing and general js area radiaition fields of 300 mr/hr.
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The inspector noted that two types cf locking devices had been installed-
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on the door at the entrance to the room; one type could not be
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operated from inside the room.
This particular device was identified
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by the licensee representative as a KIRK interlock system and tha licensee r
stated that five such systems in the facility were connected to the
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Control Room.
The licensee representative further stated that when a door equipped with the interlock system was opened, the Control
Room would receive.an alarm which would alert them to any entries
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being made.
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ls The inspector asked the licensee representative whether a person ~ could s
be inadvertantly locked in a room equipped with this type of control
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device.
The licensee representative statad that as long as the key was
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in the interlock the door would remain ajar and could not be locked. Ee.
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further stated that if the key wa,s removed by someone outside the room, i
an individual wculd be locked in the h,1gh radiation area and that there,
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j were no other provisions to preven { such-an occurrence.
~l The inspector noted thEI the contiol, device was established lat such a way
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that an individual could be prevented from leaving the'high-radiation area
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and that this constituted noncompliance with 10 CFR 20.203(c)(3). (76-12-01).
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6.
Drumming cf Evaporator Nottoms
On November 12, 1976, during an inspection of the Unit 1 facility, the'
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inspector observed a rad waste operation in progress which involved;the i
drumming of waste evaporator, bottoms.
The inspector observed steam
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individuals working over the top of the drum without respiratory protec-
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tion.
The inspector further observed'that a hose was positioned over the
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drum and was connected to a Continuous Air Monitor (CAM) located approxi-j mately 20' away from the drnmning operation.
The inspector noted that the g
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CAM was sampling for particulase airborne c_ontamination but noted that no
provision had been made for sampling for airborne radiciodine.
The
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' ;_ inspector asked a licensee representative if there was any radioactive iodine present in the evaporator bottoms being processed.
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licensee representative stated that there was no radiciodine present 3, ',
in the evaporator bottoms because during the gas stripping process i
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'liTheinspectorlaterreviewedtheisotopicanalysisperformedonsamgles
of evaporator bott ms, processed February 1976, which reiealed an I l
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131 level of 3.4 X 10- uC1/cc.
The inspector discussed the presence of 1
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current batch of evaporator bottems would be immediately sampled and an j
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isotopic analysis performed.
The result of the sample analysis revealed
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3.4 X 10-2 uC1/M1 of 1131 present in the evaporator bottoms being
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p processed.
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The licensee representative, when informed of the sample results, made
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arrangements to obtain a sample which was representative of what the
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breathing zone air would have been and analyzed it for radioiodine to l
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determine if a problem existed.
The sample analysis indicated
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iodine concentrations of 2.90 X 10-11 uCi/cc and a particulate l
activit'y of 1.3 X 10-9 uCi/ce, levels well below the regulatory
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limits.
In addition, thyroid counts were obtained from individuals
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who performed the drumming operation, and these counts revealed
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that radioiodine uptake had not occurred.
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The inspector noted that failure to conduct the necessary air surveys
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to establish if an iodine problem existed and to assure compliance
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with 10 CFR 20.103(a) (exposure to airborne concentrations of
radioactive materials) constituted noncompliance with 10 CFR 20.201(b).
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(76-12-02)
h Prior to completion of the inspection, the inspector noted that the p
Radiation Work Permit previously issued to cover the drumming of
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evaporator bottoms was reissued in a form which specified that
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sampling for iodine was to be done in addition to sampling for s
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particulate activity.
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7.
Exposure' Discrepancies
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Station'Adninistrative Order No. 120, Revision 3, " Control of Personnel I
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,Whole Body Radiation and Airborne Radiation Exposure - Issuance of Film
Badges," dated September 1, 1974, requires that film badge results which
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i differ from dosimeter results by 2 20" be reviewed by the Health j
Physics Supervisor before additional film badges are to be issued.
The inspector reviewed fiLn badge results that were outside the t
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20% span during the period January through September 3976.
During
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I the review,.the inspector noticed many cases of significant discrepancies
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I between film badge results and doses indicated by pocket dosimeters.
The inspector asked a Health Physics Supervisor if the film badge
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discrepancies were reviewed.
The Health Physics Supervisor stated
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that he did'not have enough time to conduct in-depth evaluations of j
the film badge discrepancies and that, when calculating an individual's l
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accumulated exposure for the calendar quarter to determine whether the
exposure limits of 10 CFR 20.101(b) were exceeded, he never considered
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or used pocket dosimeter results.
He said that only film badge results
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were used when performing this evaluation.
He further stated that in
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all cases film badge results were used to adjust the exposure records and' doses indicated by pocket dosimeters were discarded.
I The inspector reviewed radiation exposure records and noted 126 cases j
where the doses indicated by the pocket dosimeters were discounted
in favor of icwer doses shown by film badge reports.
Table 1
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summarizes thosa 126 cases during the period January through September 1976 where a reported monthly accumulation of 200 mrem or more was discarded.
Of those, 27 cases involved discarding doses in the range of 300 - 400 mrem, 19 cases involved discarding doses in the range of 400 - 500 mrem, 4 cases involved discarding doses in the range of 500 - 600 mrem, 2 cases involved discarding doses in the range of 600 - 700 mrem and in one instance each, 719 and 840 i
millirem were discarded.
The inspector determined that, when the discarded dose. was added to the individual's accumulated exposure, there were no cases where a person exceeded the 10 CFR 20 whole
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body dose limit of 3000 mrem per calendar quarter.
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The inspector stated that in making a determination of accumulated quarterly exposure all dose information must be considered *.
He stated that the higher doses indicated by pocket dosimeter could not be discarded in 'f avor of lower film badge results unless a i
sound factual basis for the lower dose assignment could be developed.
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The inspector identified the licensee's failure to consider the i
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higher doses indicated by pocket dosimeter when determining whether I
the exposure limits of 10 CFR 20.101(b) were exceeded as noncompliance
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vith 10 CFR 20.201(b).
He pointed out that this was the case even f
though subsequent evaluation by the inspector revealed that the addition of the pocket dosimeter results produced no case where the exposure limits were exceeded, because this was a chance occurrence
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and on actual overexposure coe'd just as well have happened.
(76-12-02),
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(76-25-02), (76-27-01)
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TABLE 1 l
h Instances Where Dose Indicated by Pocket Dosimeter was Discarded in Favor of Lower i
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Dose Shown By Film Badge Reports
Range of Discarded Number of Instances During Each Month j
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j Exposures (mrem)
January February March April May June July August September Total (]
201-300
7
7
10
8
72
.I 301-400
2
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5
2
27 l
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401-500
2
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6
1
19 501-600
0 1*
0 3*
0
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601-700
0
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801-900
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- Actual difference between film badge and pocket dosimeter readings:
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510, 580, 585, 590, 620, 654, 719 and 840 mrem.
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The inspector further observed that the existence of so =any discrepancies
[
suggested that there may be some problem with the personnel monitoring i
program.
He stated that the discrepancies were a source of concern
'
because, unless they could be explained, there was a possibility that the doses received by individuals were not being accurately determined or assigned.
He stated that the matter has to be resolved and a rational explanation of the discrepancies obtained.
This matter will be reviewed during a subsequent inspection.
!
8.
Continuous Air Monitors j
t l
The inspector reviewed the Radiation Work Permits (RWP) for operations f
l
'
involving water box entry for Steam Generators 23 and 24.
The RWP specified that the Constant Air Monitor (CAM) alarm points were to be set at 2000 counts per minute above background.
The actual CAM alarm points were found to be as follows:
Steam Generator 23 - 15,000 counts per cinute above background on November 10, 1976.
Steam Generator 24 - 3500 counts per minute above background on November 11, 1976.
The inspector observed that health physics technicians were in attendance during the periods when the CAMS were observed and a licensee
'
representative reported that they were continuously observing the CAM readings.
However, the inspector interviewed the technicians regarding
.
l CAM use and alarm set point requirements and found that one technician
!
had an understanding of how to interpret and use CAM readings and
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alarm set points which conflicted with the understanding of the
!
technician who had provided coverage on the same job before him.
On November 12, 1976, the inspector observed an operation in the Unit 1 i
Chem Systems Building involving the drawing off of sludge from the
,
liquid waste evaporators into a 55 gallon drum.
The RWP for the j
operation specified that the CAM alarm set point was to be at 1000 j
counts per minute above background.
The inspector noted that the
'
actual alarm set point was 16,000 counts per minute above back-ground.
The inspector interviewed the Health Physics technician t
who was assigned to cover the operation and found that the technician i
was unaware of the set point.
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I The inspector identified these instances of failure to follow RWP require-ments as noncompliance with Technical Specification 6.11.
(76-12-03)
'
(76-25-03)
,
9.
Steam Generator Procedure On October 29, 1976, Unit 2 was shut down for the purpose of conducting
!.
inspections to ascertain the condition of tubes and flow slots in Steam
!
Generators 23 and 24.
The health physics staff established and imple-mented a procedure entitled " Steam Generator Primary Water Box Entry,"
.
,
to provide radiation protection coverage during preparation for entries to the primary water box for eddy current testing and tube
!
plugging.
- Sections 4.8 and 4.9 of the procedure specify the protective clothing requirements for steam generator work and the specific procedural steps
to be adhered to when leaving the tent area.
Section 4.9.3 of the procedure specifies, " Note:
All Anti-C clothing specified in 4.9 shall be renoved and placed in plastic bags before exiting the tent."
.
On November 11, 1976, the inspector observed that an individual who had been working in the upper tent area of Steam Generator 23 did not remove the Anti-C clothing specified in Section 4.9 prior to leaving the tent area as required by the procedure.
,
The inspector brought the event to the attention of a licensee representa-
'
tive who took i=nediate action to correct the situation.
The corrective
!
action consisted of (1) re-instructing the health physics technicians j
covering the job regarding the significance of having personnel adhere
-
to procedures. (2) issuing instructions for health physics personnel to
!
read the procedure carefully and sign-off to indicate that it had been
done and (3) issuing instructions that the procedure covering the steam i
generator work could not be changed without authorization by the Radiation
!
Safety Director or his designated alternate.
l t
The inspector noted that failure to follow the procedure constituted non-I compliance with Technical Specification 6.11 which requires that procedures p
be adhered to.
(76-25-03)
'
10.
Counting of Filters to Determine Beta / Alpha Ratio I
t The licensee has established procedures to assist in determining radio-i. _
logical controls and monitoring requirements necessary to maintain
'
personnel exposure from airborne contamination to a minimum and to comply
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with the requirements of 10 CFR 20.
The provisions of these procedures
,
are found in Procedure HP-6, Revision 3, " Guidelines for Determining
.
Radiological Controls and Monitoring Requirements to Minimize Personnel
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Exposure from Airborne Contamination,"-dated March 1, 1976.
!
Specific steps to be followed under Section 5.3.2, of Procedure HP-6, Revision 3, are as follows:
Whenever a particulate filter is removed or changed, it should be counted
immediately. Filters should be counted initially on the beta plateau of a proportional counter and the resultant activity calculated.
If the calculated activity is greater than 1 X 10-9 uCi/ce, the filter shall be immediately counted on the alpha plateau and the beta / alpha ratio deter-
,
mined.
If the beta / alpha ratio is between 4 to 7:1 (indicative of radon, i-thoron dattr,hter products), the filter shall be set aside and recounted a
,
minimum of four (4) hours later.
Recounting shall be done on the beta-f plateau and the activity recalculated and recorded on the survey sheet in uC1/ce.
!
,
-
.
During the course of inspection, the inspector reviewed air sample records j
for the period October 31 - November 12, 1976, which revealed that on t
j November 9,1976,agarticulateairfilterhadacalculatedbetaactivity e
'
greater than 1 X 10- uCi/cc and was not counted on the alpha plateau as
',
required in order to determine the beta / alpha ratio.
In addition, the
[
inspector identified several other air sample results indicating that the
!
beta activity was greater than 1 X 10-9 uCi/cc and these s.re not counted for alpha.
The inspector rechecked the air sample calculations and noted that improper factors had been used.
By assigning the correct factors the beta activity was found to bs below 1 X 10-9 uCi/ce; therefore, alpha counting was not required for these air samples.
i The inspector informed a licensee representative of the discrepancies in i'
air sample data and noted that there were at least 8 examples were
[-
improper factors were used.
The improper factors resulted in discrepancies in air sample data by as much as a factor of 10.
The inspector noted that in some cases the improper factors resulted in the air sample results being conservative.
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-16-The inspector noted that discrepancies in air sa=ple results were related
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to:
Applying a " hose factor" of 5 when not appropriate.
a.
b.
Neglecting to apply a " hose fnetor" of 5 when required.
!
c.
Counting of only 1/3 of a sample and then failing to multiply the
.
net count by 3.
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d.
Mathematical errors.
,
The inspector noted that failure to follow procedure HP-6 in conducting j
alpha counts constitued an item of noncompliance with Technical i
Specificatien 6.11. (76-25-03)
11.
Control of Personnel Whole Body Radiation In order to assure that personnel radiation exposures are controlled to
!
within the administrative limits set by the Nuclear Facility Safety Committee, the licensee utilizes an. administrative policy which is
!
described below.
I Station Administrative Order No. 120 " Control of Personnel Whole Body
!
Radiation and Airborne Radiation Exposure - Issuance of Film Badges,"
.
Revision 3, dated September 1, 1974, specifies the action requirements
!
for administrative limits as follows:
[
l a.
Individual personnel film badges shall be routinely changed at i
the end of each month.
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.
b.
When an individual's indicated exposure (as shown by dosimeter l _
readings) reaches 1250 mrem for the quarter, the individual shall
!
be restricted from further entry into the Controlled Area until F
the exposure is verified.
Upon verification of the exposure the i
individual may be issued a badge if he is below the 1250 mrem /qtr.
or 5000 mrem / year level or if the exposure limit is raised by authorization of the Manager, Nuclear Power Generation or his
,
designated alternate.
I During the course of this inspection, the inspector reviewed personnel exposure records for the period January - October 1976. The inspector noticed that on several occasions individuals had accumulated i
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I exposur' s, as indicated by dosimeter, in excess of 1250 mrem for the qua.ter before they were restricted from the Controlled Area
!
and their film badges removed for exposure verification.
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Table 2 indicates the dates exposures were received by individuals and the dates of the authorizations to exceed the 1250 mri, limit.
i In addition to the cases presented in Table 2, the inspector also j.
determined that an individual, who had obtained the Nguired I
authorizations to exceed 1250 mr a, us xthorized to receive a
!'
cumulative exposure of 1700 mrem for the thid quarter.
On July 9, 1976, the individual had accumulated an exposure of 1720 mram (film
,
badge plus dosimeter) and was not restricted from further entry
'
'
into the Controlled Area.
On July 10, 1976, the individual was
l permitted.to enter the Controlled Area and received an additional l
510 mrem before he was restricted and his film badge removed for j
evaluation.
On July 12, 1976, based on exposure verification and
having obtained the required authorization, the individual's
'
quarterly exposure limit was raised to 2500 mram.
The inspector noted that failure to obtain-the required exposure
'
authorization prior to accumulating additional exposures and
,
failure to restrict access to the controlled area upon accumulation i
of 1250 mrem constituted noncompliance with Technical Specification j
l 6.11 which requires that these procedures be adhered to.
(76-12-03),
'
(76-25-03), (76-27-02)
i'
12.
Posting of High Radiation Areas 10 CFR 20.203(c)(1) requires that each high radiation area shall be conspicuously posted with a sign or signs bearing the radiation i
i caution symbol and the words, " Caution', High Radiation Area."
!
!
,
Contrary to the above, on November 12, 1976, during an inspection
!
,
of the Unit 1 Controlled Area, the inspector observed that waste
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l drums were being stored in a corridor on the 70' elevation adjacent
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,
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to the Chem-Systems Storage Area.
The inspector noted that the area was barricaded and posted as a radiation area and that there i-was no one present in the area.
I A licensee representative stated that dose rates up to 200 mR/hr, accessible to personnel, existed in the area.
The inspector noted
,
that radiation levels in the area were such that an individual could receive a dose in excess of 100 mrem in any one hour to-a
major portion of the body.
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TABLE 2
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Individuals With Exposure in Excess of 1250 mrem Who Were Not Restricted From the Controlled Area, Pending Exposure Verification il
.
Indicated Exposure Indicated Exposure AuthatIzed Below 1250 mrem Above 1250 arem Date Authorized Limit Individual Date (arem)
Date (mrem)
to Exceed 1250 mren (arem)
.
/ '3 A
7/15/76 1232 7/16/76 1522 7/23/76 2000
'
B 7/12/76 1005 7/13/76 1520 7/14/76 2000
-
t c
11/ 3/76 285 11/ 4/76 1675
_
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Film badges for Individual C were removed on November 3 and 4, 1976, for verification.
Verification j
revealed an accumulated exposure of 2740 mrem for the quarter. Discussion with this worker revealed b that he was not authorized additional exposure prise to or after exceeding 1250 mrem.
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-19-i The inspector stated that the area was required to be posted as a high
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radiation area and that direct surveillance had to be maintained to l
prevent unauthorized entt?,
The licensee representative stated i
that a health physics technician was supposed to be providing f
continuous coverage during the drum transfer operation but must have
temporarily left the area.
-
t The inspector returned to the storage area again on November 13, 1976, and again found that the area containing the waste drums was not posted as a high radiation area but that personnel were assigned to the area for the purpose of direct surveillance ever the high radiation
,
area.
It was stated to the inspector that direct surveillance was i
being naintained 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day since the area could not be locked.
'
The inspector noted that failure to post the area as a high radiation area constituted noncompliance with 10 CFR 20.203(c)(1). (76-12-04)
Prior to completion of the inspection, actions were taken to correct this item of noncompliance in that the licensee removed the waste drums from the corridor and stored them in an area that was locked and posted as a
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i 13.
Contamination Control
,
,
i General Administrative Directive RS-CAD-2, Revision 1, " Radiological
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Health and Safety Procedures," dated February 24, 1975, requires
that areas be roped off and contamination control instituted when removable contamination exceeds 1000 disentegrations per minute (dpm) per 100 square centimeters.
a.
Contrary to the above, on November 11, 1976, the blacktop roadway (an uncontrolled area) outside the Unit 1 dru= ming room had removable contamination levels up to 1975 dpm per 100 square centimeters and the j
area was not roped off and contamination controls were not instituted, i
b.
Contrary to the above, the laundry / change room for Units 1, 2 and 3 had removable contamination levels up to 1252 dpm per 100 square centimeters on Nove=ber 11, 1976 and up to 2100 dpm per 100 square i
centimeters on November 12, 1976 and was not roped off and contamina-tion controls were not instituted.
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i In the above instances, swipes in the areas were taken by the
,
inspector and the contamination levels determined by the licensee, i
The inspectors noted during the inspection that the licensee took
,
corrective actions consisting of (1) roping off the roadway area and instituting contanination co'ntrols, and (2) decontaminating the I
laundry / change room each day after removable contamination had been
identified as being present.
L The inspector identified these instances as items of noncompliance
- -
with the Technical Specification requirements to follow procedures j
for Units 1, 2, and 3. (76-12-031, (76-25-03), (76-27-02)
!
I'
14.
Extremitv Monitoring On November 13, 1976, the inspector reviewed documentation associated --
with the Steam Generator 24 water box entries made for eddy current test-
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ing. The inspector noted that the tube sheet survey dated November 10, 1976, indicated 7-9 R/hr at 45 inches from the tube sheet.
The inspector discussed the survey with the health physics technician who conducted the survey and deternined that the technician was unable to obtain direct
-
contact readings on the tube sheet due to interference caused by eddy
current equipment.
'
The inspector noted that personnel had made entries into the water box since November 11, 1976, and that extremity monitoring was not performed i
'
based on the November 10 survey.
The inspector interviewed personnel associated with the steam generator tube tasting operation and found that personnel could make direct hand contact with the tube sheet when working inside of the water box.
Since the survey of November 10 was inadequate to evaluate personnel
,
extremity exposures at direct contact with the tube sheet, the licensee
!
performed a more detailed survey on November 13.
Results of the November
'
,
13 survey indicated radiation levels as high as 12 R/hr at contact with
the tube sheet.
The inspector stated that, considering personnel j
occupancy times in the water box and the contact radiation levels, j
individuals had the potential to receiving exposure in excess of 25% of f
the limits specified in 10 CFR 20.101(a) for hands and forearms; there-
,
fore, extremity monitoring was required.
The licensee amended the l'
Radiation Work Permit issued for steam generator water box entries to
[
include extremity monitoring.
The licensee also adjusted the exposure
- .
records of personnel who had made previous entries to indicate extremity
[
exposure as derived from whole body dose rate and occupancy times.
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-21-l The inspector noted that the inadequacy of the survey of November 10,
!
1976, in identifying radiation levels which required extremity monitoring i
'
per 10 CFR 20.202(a)(1) constituted noncompliance with 10 CFR 20.201(b).
,
(76,-25-02)
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