IR 05000213/1979006
| ML19262C229 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 07/31/1979 |
| From: | Crocker H, Jason White, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19262C225 | List: |
| References | |
| 50-213-79-06, 50-213-79-6, NUDOCS 8002080415 | |
| Download: ML19262C229 (29) | |
Text
I U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-213/79-06 Docket No.
50-213 License No.
DPR-61 Priority Category C
--
Licensee:
Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name:
Haddam Neck Plant Inspection At:
Haddam, Connecticut Inspection Conducted:
February 14-16, 26-28 and March 5-9, 1979 Inspectors:
~
'f S/
J.fr. White, RadiatMn Specialist
' date signed
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O.O b e
'7/3/ /79'
G. Pg. Y h7s, Radiation Specialist
'date si'gned cwuk
,bihn r/,/6/Gallina, Investigation Specialist visilr, date 'sigried RL LH R. L. Nimitz, Ra at on Specialist (Intern)
date' signed Approved by:
/hh iM Y /
It/W. Crocker, Actirig Chief, Radiation Support
'date signed Section, FF&MS Branch Inspection Summsry:
Inspection on February 14-16, 26-28 and March 5-9, 1979 (Report No. 50-213/79-06)
Areas Inspected:
Routine, unannounced inspection by regional based inspectors of the Radiation Protection Program during the 1979 refueling outage, including Radi-ation Protection Procedures, Advance Planning and Preparation, Training, Exposure Control, Posting and Control, Radioactive and Contaminated Material Control, and Surveys.
During the course of this inspection allegations concerning the adequacy of the Radiation Protection Program were made to the NRC.
These allegations were reviewed in this inspection and in the ensuing investigation (Inspection Report 50-213/79-07).
The inspection involved 112 inspector-hours by three regional based NRC inspectors.
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Region I Form 12 (Rev. April 77)
80020g0
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Results:
Of the seven areas inspected, nine items of noncompliance were identified in the following areas:
a.
Infraction - Failure to control high radiation areas between 100 and 1000 mrem /hr in accord with Technical Specification 6.13; b.
Infraction - Failure to control high radiation areas greater than 1000 arem/hr in accord with Technical Specification 6.13; c.
Infraction - Failure to perform surveys to assure compliance with 10 CFR 20.101; Failure to establish written procedures in accord with Technical Specification 6.8; d.
Infractior. - Failure to use precautionary procedures to limit exposure to airborne radioactivity in accordance with 10 CFR 20.103; Failure to perform surveys to assure compliance with 10 CFR 20.103; Failure to use suitable measurements of radioactivity in air in accordance with 10 CFR 20.103; e.
Infraction - Failure to instruct workers in accord with 10 CFR 19.12; f.
Infraction - Failure to limit personnel exposure in accord with 10 CFR 20.101; g.
Infraction - Failure to adhere to procedures in accord with Technical Specification 6.11; h.
Infraction - Failure to label containers of radioactive material in accord with 10 CFR 20.203; Failure to post a radioactive material storage area in accord with 10 CFR 20.203; and i.
Deficiency - Failure to adequately report workers exposure in accord with 10 CFR 20.408.
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DETAILS 1.
Inspection Scope and Chronology The purpose of this inspection was to observe, inspect and evaluate the performance of the health physics operation as it related to the January 1979 refueling outage.
Coincident with this inspection effort, written allegations of certain ir. adequacies in the licensee's health physics program were received by the Office of Inspection and Enforcement - Region I (Philadelphia).
Subsequently, an investigation of these allegations was initiated.
(Inspection Report 50-213/70-07)
The following chronology of events is provided for information.
Chronology of Inspection 50-213/79-06 Date/ Time Event 1-26-79/----
Haddam Neck Refueling Outage Commenced.
2-14-79/ * 2030 Inspection 50-213/79-06 Commenced (One inspector onsite; several apparent items of noncompliance were identified within the first 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of the inspection).
2-15-79/ * 0930 Station Superintendent was informed of initial inspection findings.
Telephone discussion between the licensee and Region I (Philadelphia) regarding immediate correctivo action.
Corrective action was initiated by the licensee.
2-16-79/ * 1000 Documentation confirming the licensee's under-standing of corrective actions to be taken was transmitted to Region I (Philadelphia) (Reference:
Letter from W. G. Counsil, Vice President, Northeast Utilities to B. H. Grier, Director, NRC Inspection and Enforcement, Region I dated February 16, 1979).
The inspector presented a status report to the licensee regarding Inspection 50-213/79-06.
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2-16-79/ ~ 1800 Inspector Offsite.
2-20-79/----
Region I (Philadelphia) received phone call from an individual regarding the performance of the health physics program at Haddam Neck Nuclear Power Station.
The individual indicated that he would send his allegation in writing to the NRC.
2-26-79/ * 1000 Inspector onsite for continuation of Inspection 50-213/79-06.
The licensee's efforts in performing the corrective actions described in the February 16, 1979 letter were reviewed.
2-28-79/ ~ 1800 Inspector reviews items of noncompliance with licensee representatives.
Inspector offsite.
3-1-79/----
Region I (Philadelphia) receives written allega-tions from an individual, regaroing the performance of the radiation protection program at Haddam Neck Nuclear Power Station (Reference:
Letter from an individual to the Regional Director, dated February 24, 1979).
3-5-79/ s 1000 Region I (Philadelphia) initiates an investi-gation to review the concerns expressed in the letter dated February 24, 1979 (Inspection 50-213/79-07), concurrent with Inspection 50-213/79-06.
3-9-79/ * 1600 Inspector conducted Exit Interview in regard to Inspection 50-213/79-06.
Inspection findings were reviewed with the licensee.
Status of Investigation 50-213/79-07 was also reviewed.
The licensee was informed of a Management Meeting to be held at Region I (Philadelphia) to discuss the performance of the radiation protection program at Haddam Neck.
Inspector offsite.
3-16-79/ * 1000 Management Meeting held at NRC Region I (Philadelphia) with Northeast Utilities, Connecticut Yankee Atomic Power Company and Haddam Neck Nuclear Power Station management to discuss the licensee's response to the inspection findings of Inspection 50-213/79-06.
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2.
Persons Contacted
- W. G. Counsil, Vice President, Nuclear Engineering and Operations (Northeast Utilities)
- J. Kufel, Superintendent, Nuclear Operations (Northeast Utilities)
- J. P. Cagnetta, Director, Nuclear and Environmental Engineering (Northeast Utilities)
- R. H. Graves, Station Superintendent, Haddam Neck Nuclear Power Station
- R. P. Traggio, Assistant Station Superintendent, Haddam Neck Nuclear Power Station
- R. C. Rogers, Supervisor, Radiological Assessment Group (Northeast Utilities)
- H. Clow, Health Physics Supervisor, Haddam Neck Nuclear Power Station
- P. Steinmeyer, Health Physics Foreman, Haddam Neck Nuclear Power Station
- denotes personnel attending the exit interview conducted on March 9, 1979.
The inspector also interviewed other station health physics, operations and maintenance personnel; and contracted health physics personnel from Westinghouse-Nuclear Services Division and Rad Services Incorporated.
3.
Advance Planning and Preparation The inspector identified the following in regard to pre-outage planning and preparations upon review of the licensee's efforts in this area:
a.
The station's Health Physics (HP) supervisor was unable to provide sufficient direction regarding planning and preparation due to
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illness; and was also unavailable for the duration of the outage for the same reason.
As an interim solution Connecticut Yankee Atomic Power Company (CYAPCO) Management installed the HP foreman as acting Health Physics Supervisor for the outage.
The inspector reviewed the qualifications of the HP foreman against the qualification requirements identified in Technical Specification 6.3.1.1 which states:
"The position of Health Physics Supervisor shall meet the following minimum qualifications:
a.
Academic degree in an engineering or science field or equivalent as per Section 6.3.1.1.c.
b.
Minimum of five years professional technical experience in the area of radiological safety, three years of which shall be in applied radiation work in a nuclear facility dealing with problems similar to those encountered in a nuclear power reactor.
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c.
Technical experience in the area of radiological safety beyond the five year minimum may be substituted on a one-for-one basis towards the academic degree requirement (four years of technical experience being equivalent to a four year academic degree).
d.
Academic and technical experience must total a minimum of nine years."
Contrary to part "b" of this requirement, the inspector learned from reviewing the individual's resume' and from interviews that the person had three years and one month professional technical experience in the area of radiological safety as of March 1, 1979.
Upon notification, the licensee's representative indicated that the HP foreman was filling this position only until the Health Physics Supervisor returned to duty.
The inspector noted that this area would be reviewed in a subsequent inspection to assure that the situation does not exist for an unreason-able length of time; and that the intent of the requirement is not superceded by unresolved organizational problems (50-213/79-06-01).
b.
The inspector noted that though the licensee had information that fuel clad integrity was degraded (i.e., significant I-131 radio-activity increases since the last refueling outage; the detection of loose surface alpha contamination in the Charging Pump Area of the Primary Auxiliary Building [PAB] on January 16, 1979; and increasing
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dose rates in the PAB pipe trench areas and Residual Heat Removal
[RHR] Valve Pit observed since October 1978), no special practices or efforts were planned in order to deal effectively with the potential problems that are associated with fuel clad failure, such as high radiation levels, high loose surface contamination due to alpha, beta and gamma activity; and consequently high levels of airborne radioactivity.
c.
No special training was utilized by the licensee to familiarize personnel with the radiological hazards associated with steam generator entries, i.e., such as mock-up training, which is usually utilized for such operations.
As a result the licensee experienced problems with personnel monitoring and contamination during the duration of steam generator eddy-current testing.
d.
No special equipment or processes were prepared to perform operations that had the potential for creating increased personnel exposure.
For example:
1) Containments were not utilized for steam generator work.
The use of such containments would have greatly reduced 1:44 153
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airborne radioactivity in the Reactor Building; 2) Instruments having the capability of measuring alpha radioactivity were not utilized until late into the outage.
A proportional gas alpha counter was not made available for use until February 18, 1979; 3)
No special process was considered for the decontamination of the reactor cavity even though the levels of loose surface radioactivity in the area warranted the initial use of a less severe method than that employed by the licensee, i.e., hydrolasing.
The initial hydrolasing effort of the reactor cavity caused needless exposure to personnel, and did result in the evacuation of personnel from the Reactor Building.
The inspector noted that, in regard to the radiation protection aspects, this outage was subject to minimal preplanning and preparation, particu-larly in view of the potential for increased radiological risks associated with fuel clad degradation.
Failure of HP to recognize and factor in the effect of fuel clad failure in terms of preplanning and preparation contributed largely to the negative findings and items of noncompliance identified in this report.
4.
Rg'i, tion Protection Procedures The inspector reviewed the licensee's radiation protection procedures and the implementation of the procedures during the outage against the require-ments of Technical Specifications 6.8, Procedures and 6.11, Radiation Protection Program.
It was noted, generally, that the procedures provided insufficient guidance and direction for conducting radiation protection activities in view of the magnitude of the radiological hazard associated with this outage.
The following was noted:
a.
Technical Specification 6.8, Procedures, states that written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Section 5.1 and 5.3 of ANSI N 18.7-1972, and Appendix "A" of USAEC Regulatory Guide 1.33, Quality Assurance Program Requirements.
Regulatory Guide 1.33, Appendix "A" specifies that procedures be developed for " Surveys and Monitoring."
Due to fuel clad failure, hicher levels of contamination than what would be normally expected i re found on many of the reactor associ-ated components and tools t. eat were being worked with oy personnel.
These included the steam generator inlet and outlet plenums, the reactor cavity, the fuel sipping equipment, ste.
This high radio-active contamination, a result of fission prodiicc deposition, was the prime contributor of the high level beta radiation problems experienced during this outage.
In addition, clad degradation was responsible for the exposure problems experienced due to transuranic (alpha emitter) radioactivity.
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The inspector noted that contrary to Technical Specification 6.8, as of February 14, 1979, the licensee had no written procedures estab-lished, implemented or maintained that provided direction and guidance for the detection, monitoring, survey and evaluation of either alpha or beta radioactivity sufficient to control internal and external personnel exposure.
Consequently, the licensee was unable to ade-quately ascertain, in a timely manner, the radiological status of the following areas or situations:
Job or Work Area Steam Generator Eddy Current Testing - Personnel entries into inlet and outlet plenums.
Remarks Initially, the licensee failed to perform evaluation of the beta component of the radiation field in this area.
The results of subsequent efforts to perform the evaluation (survey and personnel monitoring) were unreliable due to the instrumentation and techniques used; consequently, personnel were subject to beta exposure without adequate evaluation of the field strength and the suitability of the personnel monitoring and protective devices employed, (such as eye protection to limit exposure to the lens of the eye in accord with 10 CFR 20.101; and the placement of dosimetry devices sufficient to assure adequate monitoring of that organ).
Job or Work Area i
Fuel Lipping Operation - Personnel handling and using Fuel
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Handling Toul.
Remarks Initially, the licensee failed to perform evaluation of the beta component of the radiation being emitted from this tool.
Consequently, personnel were permitted to work in close proximity with the tool without any protection or monitoring being provided for the lens of the eyes, the organ that appeared to most susceptable to exposure.
Job or Work Area Steam Generator Eddy Current Testing; Reactor Cavity Hydrolase Operation; Inner Annulus and Steam Generator Decontamination Activities.
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Remarks The performance of these activities caused the generation of airborne radioactivity containing alpha emitters.
Since the procedures were non-existent with regard to this subject, the licensee did not sufficiently:
1) perform adequate surveys for alpha activity; 2) recognize and identify the alpha component; 3) perform meaningful evaluation of personnel exposure to alpha activity; and 4) provide assessment of personnel exposure to airborne alpha radioactivity.
The inspector identified that failure to establish, implement and maintain written procedures in accord with Technical '
Specification 6.8 constitutes an item of noncompliance (50-213/79-06-02),
and is associated with the item identified in Detail 9.1 (50-213/
79-06-16).
The licensee's failure to establish and implement adequate procedures in this area contributed to other items of noncompliance that are identified later in the report.
b.
The inspector reviewed the licensee's performance of the following procedures against the requirements of Technical Specification 6.11, Radiation Protection Program, which states, " Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."
Procedure Number Title
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ADM 1.1 - 40 Radiation Exposure Control Revision 2 Date:
November 13, 1978 ADM 1.1 - 37 Radiation Work Permit Completion Revision 7 and Flow Control Date:
Dec3mber 4, 1978 1.
ADM 1.1-40 states in Section 5.6, " Permission for personnel exposure in excess of 2,750 mrem [per quarter] shall not be granted."
Contrary to this procedure, the licensee permitted an individual to exceed this administrative limit without any authorization.
The individual had previously been administratively authorized to receive 2,500 mrem per quarter in accordance with ADM 1.1-40 but was permitted to accumulate 2,930 mrem in the first quarter 1979.
The person had been issued successive film badges in the following order as determined from the licensee's records:
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1979
- Result -
Result -
Badge No.
Wear Period Film Badge Pocket Ion Chamber (FB)
(PIC)
8306 1/28 - 1/31 530 mrem 80 mrem 8315 2/1 - 2/5 500 mrem 645 mrem 8542 2/5 - 2/8 900 mrem 915 mrem 8645 2/9 - 2/20 840 mrem 775 mrem 9029 2/21 - 2/23 160 mrem 205 mrem Total:
2930 mrem
- Used for Personnel Exposure Record The licensee administratively follows personnel exposure during any given quarter from the accumulative value of the previous film badge results for that quarter plus the Pocket Ion Chamber indication of the current Wear Period.
As can be seen, on February 20, 1979 the licensee had indication that the individual had received about 2,705 mrem for the quarter (i.e., 530 mrem (FB) + 500 mrem (FB) + 900 mrem (FB) + 775 mrem (PIC) = 2,705 mrem).
Therefore, 2705 mrem was the value assigned as the individual's
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exposure in the interim period pending the evaluation of Film Badge #8645.
Since the individual was administratively limited to 2,500 mrem, further exposure of this individual should have been prevented unless specifically authorized in accordance with ADM 1.1-40, and then not to exceed 2,750 mrem.
However, the individual was issued a new Film Badge (#9029) on February 21, 1979, and was permitted to enter a high radiation area in support of steam generator eddy-current testing between February 21 and 23, 1979, resulting in an additional 160 mrem exposure.
Total accumulate quarterly dose was 2,930 mrem.
2.
ADM 1.1-37 states in Section 5.6 " Specific completion of the RWP [ Radiation Work Permit] shall be as follows:.. 20.
Per-sonnel listed on the RWP initials and acknowledges require-ments, complies with instructions on the form."
On February 16, 1979, the inspector identified several cases in which personnel who had been listed on certain RWP's, did enter radiologically controlled areas to perform work in accordance 1:44 157
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with the RWP, but failed to demonstrate that they knew and understood the radiological status and specific requirements for working in the area by initialing the form.
The following cases were identified.
Number of individuals failing RWP#
Title to acknowledge the RWP 791389
" Eddy Current" 2 individuals
- 2 S.G.
791385
" Fuel Shuffle" 1 individual 791401
"RCP Oil Switches" 1 individual 791397
" Sludge Lance" 3 individuals
- 4 S.G.
The inspector noted that while no regulatory limit had been exceeded, the failure of the licensee to adhere to and operate in accordance with these procedures as required by Technical Specification 6.11 was indicative of a breakdown in the licensee's ability to properly administer the radiation protection program, and increased the potential for. the development of more serious problems.
Therefore, the inspector identified that failure to adhere to procedures in accord with Technical Specification 6.11 constituted an item of noncompliance. (50-213/79-06-03)
5.
Training The inspector examined the training program that personnel were subject to against the requirements specified in 10 CFR 19.12, " Instructions to workers."
10 CFR 19.12, " Instructions to workers," states, in part, "All individuals working or frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portions of the restricted area; shall be instructed in the health protection problems associated with exposure to such radio-active materials or radiation, in precautions or procedures to minimize exposure, and in the purposes.and functions of protective devices employed...
The extent of these instructions shall be commensurate with potential radiological health protection problems in the restricted area."
On February 16, 1979, the inspector reviewed the general employee indoc-trination course that is given to all personnel who are expected to work in radiologically controlled areas.
The course, a combination of lecture and audio visual presentations, appeared to be sufficient to familiarize
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perr.,nel with the basic directions, practices and controls that they would be subject to when working in a radiologically controlled area.
The course was concluded with the comment that it did not present all of the training and information that might be necessary for every situation; and that the in plant health physics personnel would provide additional direction and training as necessary to assure the radiological health and safety of workers.
The inspector noted that this concluding comment was a basic tenet in the field of radiation protection, and examined it's implementation by the licensee's in plant health physics organization.
It was found that contrary to the requirements of 10 CFR 19.12 and the licensee's general employee indoctrination course, the instructions that were provided to workers were not commensurate with the potential radio-logical health protection problems that the personnel were subject to in the radiologically controlled area.
From interviews and observations the inspector learned that between February 5 and March 1,1979, individuals working in the Reactor Contain-ment to support steam generator eddy-current testing, reactor cavity and inner annulus decontamination, and steam generator hydrolasing operation were not adequately instructed by the in plant health physics personnel in the precautions and procedures necessary to minimize exposures in the work areas or in the health pratection problems associated with such exposure.
The majority of the personnel interviewed by the inspector indicated that they perceived the in plant Health Physics technicians to be confused and unsure of the radiological conditions in the work areas
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and unable to answer questions as to the radiological status of the areas in regard to the potential for alpha and beta exposure.
The inspector made observations during the course of the inspection that indicated that this perception was valid.
(The inspector's observations are identified in other sections of this report.)
As evidenced by several significant skin contamination incidents (* 50 were documented by the licensee as of March 5, 1979) workers were not adequately instructed by in plant Health Physics technicians as to the methods to be utilized to minimize exposure in highly contaminated areas.
One worker was contaminated to 90 mrem /hr on his skin and had to undergo 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> of continuous decontamination.
He was not given instructions N
by any Health Physics technician as to how to remove protective clothing or how to minimize contamination spread.
He was also observed smoking in the controlled area while his hands were contaminated to 12 mrem /hr, in full view of several Health Physics technicians.
The inspector identified that failure to provide instructions to workers commensurate with the potential radiological health protection problems to which the workers were subject in accordance with 10 CFR 19.12 con-stituted an item of noncompliance. (50-213/79-06-04)
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6.
Exposure Control The inspector reviewed the licensee's exposure control program against the requirements specified in the following:
10 CFR 20.101, " Exposure of individuals to radiation in restricted
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areas."
10 CFR 20.102, " Determination of accumulated dose."
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10 CFR 20.103, " Exposure of individuals to concentrations of radio-
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active materials in air in restricted areas."
10 CFR 20.104, " Exposure of minors."
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10 CFR 20.408, " Reports of personnel exposure on termination of
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employment or work."
10 CFR 20.409, " Notification and reports to individuals."
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No items of noncompliance were noted by the inspector in regard to the requirements specified in 10 CFR 20.102 and 10 CFR 20.104.
However, the following was noted concerning 10 CFR 20.101, 10 CFR 20.103, 10 CFR 20.408 and 10 CFR 20.409:
a.
10 CFR 20.101, " Exposure of individuals to radiation in restricted areas," states in part, "Except as provided in paragraph (b) of this section, no licensee shall possess, use, or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter from radioactive material and other sources of radiation in the licensee's possession
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a dose in excess of...[the following limit]:
Whole body; heac' and trunk; active blood-forming organs; lens of eyes; or gonads.................................... 1 [ rems]
Paragraph (b) permits exposure in excess of this limit, not to exceed 3 rems per calendar quarter provided that the... " licensee has determined the individuals accumulated occupational dose to the whole body on Form NRC-4, or on a clear and legible record contain-ing all the information required in that form; and has otherwise complied with the requirements of S 20.102."
On February 15, 1979, the inspector reviewed the personnel exposure records of 14 individuals selected at random, who had accumulated greater than Ik rems (1,250 mrems) in the current calendar quarter.
It wa, found that in the case of three of these individuals, the 1744 160
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licensee had not determined their accumulated occupational dose to the whole body on Form NRC-4 or on a clear and legible record con-taining all the information required in thet form; and otherwise complied with the requirements of 10 CFR 20.102.
At the time of this observation the individuals had the following exposure for the current quarter:
Individual A 2,020 mrem Individual B 1,480 mrem Individual C 1,680 mrem The inspector noted that since D e licensee failed to evaluate these individuals' previously accumulated occupational exposure in accord with 10 CFR 20.101, the individuals were exposed to radiation in excess of the regulatory limit.
The inspector identified that failure to adhere to the requirements of 10 CFR 20.101 constituted an item of noncompliance. (50-213/79-06-05)
Upon notification of this failure to adhere to the requirements of 10 CFR 20.101, the HP Supervisor indicated that a memo sent to all department personnel on February 13, 1979 identified this problem and established corrective action.
The inspector reviewed this memo which stated only, "As of 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> February 14, 1979, no upgrade sheet will be issued unless record clerks have signed the upgrade sheet in the appropriate place after checking records;" and determined that the memo did not specifically identify this problem nor did it specify effective corrective action.
It was observed by the inspector that as of February 15, 1979, the individuals had not been restricted from receiving further radiation exposure, until brought to the HP Supervisor's attention by the inspector.
b.
10 CFR 20.103, " Exposure of individuals to concentrations of radio-active materials in air in restricted areas," states in part, "(a)(1)
No licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a quantity of radioactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentra-tions of radioactive material in air specified in Appendix B, Table I, Column 1...(a)(3) For purposes of determining compliance with the requirements of this section the licensee shall use suitable measure-ments of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, shall use measurements of radioactivity in 1944 161
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the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
It assumed that an individual inhales radio-active material at the airborne concentration in which he is present unless he uses respiratory protective equipment pursuant to para-graph (c) of this section.
When assessment of a particular indi-vidual's intake of radioactive material is necessary, intakes less than those which would result from inhalation for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any one day or for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> in any one week at uniform concentrations speci-fled in Appendix B, Table I, Column 1 need not ae included in such assessment, provided that for any assessment in excess of these amounts the entire amount is included."
On March 5, 1979, the inspector reviewed 910 air samples that were collected by the licensee in support of work activities in the Reactor Containment for the period between January 29 and March 1, 1979 (this accounts for almost all of the air samples that were collected during that period).
From interviews with several Health Physics technicians who had collected these samples; and observation by the inspector, it was learned that none of the 910 air samples collected were representative of the concentrations of radioactive material in the breathing zone of workers, and therefore were not suitable measurements of the concentrations of radioactive materials in air for detecting and evaluating personnel radiation exposure to airborne radioactivity.
According to the technicians interviewed, the majority of the samples were taken in general areas within the Reactor Containment at various locations or in the vicinity of work in progress; none of the technicians could recall any sample taken in a workers' breathing zone.
On February 27, 1979, the inspector observed Health Physics techni-cians performing air sampling to support work activities described by RWP 792066, "RHR-MOV-781-Replace Valve Bonnet." The job entailed opening the component (a Residual Heat Removal Motor Operated Valve, having a dose rate of 200 mrem /hr on contact; and from which high levels of loose surface contamination were expected as well as the potential for airborne radioactivity).
The personnel performing the work, though in close proximity to the open system, were not wearing any type of respiratory protection equipment.
The air sample used to assess their exposure to radioactive materials in air was taken at least 10 feet behind their work area.
According to the Health Physics technician in the work area, this was the normal method utilized for air sampling.
Other examples in which the concentration of airborne radioactivity was known to be high, but air samples representative of the air in workers' breathing zones were not taken, include the following:
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Approximate Reported Work In Air Sample Distance. from Workers Activity Date Progress Location Breathng Zone (uCi/ml)
2/5/79
- 1 Steam Generator # Steam
- 8 ft 1.85 E-8 Eddy Current Test Generator Support Skirt Area 2/20/79 Reactor Cavity Reactor s 20 ft 6.9 E-7 Hydrolasing Charging Floor The inspector identified that failure to use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating personnel exposure to airborne radioactivity in accordance with 10 CFR 20.103(a)(3) constituted an item of noncompliance (50-213/
79-06-06), and is associated with the items identified in Details 6.c (50-213/79-06-07) and 9.2 (50-213/79-06-17).
c.
10 CFR 20.103, " Exposure of individuals to concentrations of radio-active materials in air in restricted areas," states in part, "(b)(2)
...other precautionary procedures, such as increased surveillance, limitation of working times, or provision of respiratory protective equipment, shall be used to maintain intake of radioactive material by any individual within any period of seven consecutive days as far below that intake of radioactive material which would result from inhalation of such material for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform concentrations specified in Appendix B, Table 1, Column 1 as is reasonably achievable."
On February 15, 1979, the inspector noted that the licensee, though utilizing respiratory protection equipment, did not take credit for such equipment since its program (Respiratory Protection) was not completely in accord with 10 CFR 20.103(c) which requires that such a program meet the specifications of Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection," and had not informed tm Commission of any intent to make allowances for such equipment as specified in 10 CFR 20.103(e).
Therefore, the licensee had intended to control exposure to airborne concentrations of radioactivity by continuously assessing the intakes of personnel for the purpose of establishing a " limitation of working times" as specified in 10 CFR 20.103(b)(2).
The licensee's method to establish this limitation was described by the Temporary Procedure Change to RAP 6.1-4, Revi-sion 3, " Determining Airborne Radioactive Concentrations and the Allowable Stay Time."
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The inspector observed that the licensee initially implemented RAP 6.1-4 and maintained the associated MPC [ Maximum Permiss ble Concen-i tration] Exposure Log up to February 11, 1979.
From tha. time on, no such log was maintained; and consequently the licensee did not provide any precautionary procedure to assure that intakes of radio-active material by any individua' rithin any period of seven consec-utive days was below the 40 MPC-hour contrt' measure specified in 10 CFR 20.103(b)(2).
As a result, the inspector identified that at least 11 persons had exceeded the specified 40 MPC-hour control measure by an unknown extent.
The inspector identified that failure to use precautionary pro-cedures to maintain intakes of radioactive material by any indi-vidual within any period of seven consecutive days constituted an item of noncompliance (50-213/79-06-07), and is associated with the item identified in Details 6.b (50-213/79-06-06) and 9.2 (50-213/
79-06-17).
The inspector further noted that without the implementation of the precautionary procedure to establish the limitations of working times, the licensee could not ascertain if any individual had inhaled a quantity of radioactive material in excess of the regulatory limit specified in 10 CFR 20.103(a)(1).
Upon notification of these concerns, the licensee initiated action to immediately evaluate all personnel who were subject to airborne radioactivity and subsequently assess their intakes and exposure.
The inspector identified that such an evaluation is required to
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include the individual's exposure to airborne alpha activity, since this component (alpha) was not initially recognized as a contributor to personnel exposure.
The licensee indicated that such evaluation would be completed by April 30, 1979.
The inspector indicated that the subject of personnel exposure was unresolved pending review of the licensee's evaluation (50-213/79-06-08).
d.
10 CFR 20.408, " Reports of personnel monitoring on termination of employment or work," states in Paragraph (b)"... When an individual terminates employment with a licensee... or an individual assigned to work in such a licensee's facility but not employed by the licensee, completes work assignment in the licensee's facility, the licensee shall furnish to the Director of Management and Program Analysis, U.S. Nuclear Regulatory Commission, Washington, D.C., 20555, a report of the individual's exposures to radiation and radioactive material, incurred during the period of employment or work assignment in the licensee's facility, containing information recorded by the i?44 164
licensee pursuant to 9 20.401(a)"... [which] requires the licensee to maintain records of exposures to radiation for whom personnel monitoring was required; and that such records will be kept on Form NRC-5 in accordance with the instructions contained on that form, including the recording of external exposure to (1) the whole body; (2) skin of the whole body; (3) hands, forearms; (4) feet and ankles.
Such information is also required to be submitted to the individual in accordance with 10 CFR 20.409."
On March 7, 1979, the inspector reviewed the licensee's system for reporting personnel monitoring in accordance with 10 CFR 20.408 and found that though the reports were being made, complete exposure information was not being submitted according to the regulatory requirement.
The following examples were noted:
Information Reported Period of Ex-Information Determined by to the Commission Individual posure (1979)
the Licensee *
and Individual A
2/10 - 2/28 1660 mrem (WB)
1660 mrem (WB)
1170 mrem (Hand)
0 mrem (Skin)
B 2/1 - 2/17 1700 mrom (WB)
1700 mrem (WB)
7940 mrem (Hand)
0 mrem (Skin)
C 1/29 - 2/19 690 mrem (WB)
690 mrem (WB)
1890 mrem (Hand)
0 mrem (Skin)
D 1/29 - 2/19 2500 mrem (WB)
2500 mrem (WB)
3290 mrem (Hand)
0 mrem (Skin)
- As. recorded on Form NRC-5 or equivalent Note:
(WB) Whole Body; (Skin) Skin of the Whole Body; (Hand) Hand Extremity The inspector identified that failure of the licensee to report complete exposure information in accordance with 10 CFR 20.408 and 10 CFR 20.409 constituted an item of noncompliance. (50-213/79-06-09)
7.
Posting and Control The inspector reviewed the radiological posting and control of restricted areas against the specifications identified in the following regulatory requirements:
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10 CFR 20.203, Caution signs, labels, signals and controls.
-
Technical Specification 6.13, High Radiation Areas.
-
The following examples of noncompliance with these requirements were identified:
a.
Technical Specification 6.13, "High Radiation Area," states in the first paragraph, "In lieu of the ' control desice' or ' alarm signal'
required by Paragraph 20.203(c)(2), each high radiation area in which the intensity of radiation is 1000 mrem /hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Exposure Authorization [ Radiation Work Permit (RWP)].
An individual or group of individuals permitted to enter such areas shall be provided with one or more of the following:
a.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
b.
A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset inte-grated dose is received.
Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made know-ledgable of them.
c.
A health physics qualified individual (i.e., qualified in radiation protection procedures) with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and who will perform periodic radiation surveillance at the frequency specified in the REA [RWP].
The surveillance frequency will be established by the Health Physics Supervisor."
In reviewing the licensee's method for controlling High Radiation Areas, the inspector was informed by the HP Supervisor that the licensee utilized the option provided by subparagraph "a" of the requiremerit.
On February 14, 1979, the inspector observed that two individuals performing hydrolancing of the secondary side of Steam Generator #2 were occupying areas that ranged from 40 to 3000 mrem /hr (Whole Body) but were not provided with continuously indicating dose rate instruments.
It was noted by the inspector that the RWP used for the performance of this activity (RWP #791307) required that such instruments be used.
At the time of this observation, the personnel were unaware that they were standing in a 150 mrem /hr radiation field until informed by the inspector.
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'.
'
The inspector identified that failure to provide a continuously indicating dose rate instrument in accordance with the requirements of Technical Specification 6.13 constituted an item of noncompliance (50-213/79-06-10).
b.
Technical Specification 6.13, "High Radiation Area," states in the second paragraph, that a high radiation area in excess of 1000 mrem /hr shall be provided with locked doors to prevent unauthorized entry into such areas, and the keys shall be maintained under the administrative control of the shift supervisor on duty.
In reviewing the radiological areas within the plant on February 14 through 15, 1979 (11:00 p.m. to 3:00 a.m.) the inspector identified several High Radiation Areas (greater than 1000 mrem /hr) that were not locked or otherwise controlled in accordance with the require-ment.
These areas included the following:
Primary Auxiliary Building (PAB)
Accessible Area Dose Rate Status Residual Heat Removal 200 to 1500 mrem /hr Not Locked (RHR) Pit Access Pipe Trench Access
>1000 mrem /hr Not Locked in Blowdown Room
.
Pipe Trench Access
>1000 mrem /hr Not Posted as in Valve Operating Room High Radiation Area; Not Locked Pipe Trench Access
>1000 mrem /hr Not Locked Reactor Conta ent Building Accessible Area Dose Rate Status Inner Annulus from 3 100 to 35000 mrem /hr Not Locked Access Points in Lower Level Containment Inner Annulus from 4 100 to 35000 mrem /hr Not Locked; Circular Stairway Not Posted as Access Points on the High Radiation Charging Floor of Area Containment i?44 167
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As noted from the above, two of the areas v 1 not identified as being access to High Radiation Areas (i.u., not posted in accordance with the first paragraph in Technical Specification 6.13).
The inspector noted that High Radiation Areas identified in the Reactor Containment Building (Lower Level, Inner Annulus) were due primarily to the fact that the steam generator plenums were opened, allowing unrestricted direct access to fields as high as 35000 mrem /hr.
Upon notification that these areas were uncontrolled, the licensee initiated interim action to immediately provide locked doors to these High Radiation Areas or otherwise make them inaccessible.
Following e.his, the licensee initiated other corrective action to provide lockable access gates to the plenum areas of each steam generator, thereby prohibiting uncontrolled direct access to the areas while allowing less restricted access to the Lower Level, Inner Annulus area in containment.
The inspector identified failure to control High Radiation Areas greater than 1000 mrem /hr in accordance with Technical Specification 6.13 constituted an item of noncompliance (50-213/79-06-11).
8.
Control of Contaminated and Radioactive Material The inspector reviewed the control of contaminated and radioactive material against 10 CFR 20.203, " Caution signs, labels, signals and controls."
The following examples of noncompliance in this area were noted:
a.
10 CFR 20.203, " Caution signc, labels, signals and controls," states in part, in Paragraph (f)... "each container of licensed material shall bear a durable, clearly visible label identifying the radio-active contents...[the] label shall bear the radiation caution symbol and the words " CAUTION, RADI0 ACTIVE MATERIAL" or " DANGER, RADI0 ACTIVE MATERIAL."
It shall also provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures... *[As appropriate, the information will include radiation levels, kinds of material, estimate of activity, date for which activity is estimated, mass enrichment, etc.]"
- Footnote 1 to 10 CFR 20.203 In reviewing the status of the facility on February 15, 1979, the inspector toured the Spent Fuel Building and noted that the lower level of the building was used to store and perform work on various reactor components in support of the outage.
It was noted that i?44 168
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three pressurizer code safety valves that had been recently removed from the reactor system were stored in this location to undergo maintenance.
Each valve was in a 55 gallon open steel drum container (the containers were used to support the valves in an upright posi-tion).
The valves (and drums) were noted to be uncovered (open to the atmosphere), and unposted as to the radiological status.
Inde-pendent measurements by the inspector indicated that the valves produced dose rates as high as 400 mrem /hr at contact, and 100 mrem /hrat*8";lgosesurfacecontaminationwasmeasuredashighas 400,000 dpm/100 cm.
It was noted by the inspector, that though the components were located in a room that was identified as a radiation area, they presented a radiological hazard to the individuals working in the area (in terms of the potential for personnel contamination and external exposure).
The valves were not contained sufficient to present inadvertent contamination nor labeled sufficient to advise personnel handling, or using the containers, or working in the near vicinity, of the fact that the contents were radioactive, the type and intensity of the radioctive contents and other information as appropriate so that personnel had the opportunity to minimize exposure.
The inspector identified that failure to provide labels of containers of radioactive material in accordance with the requirements of 10 CFR 20.203 constituted an item of noncompliance (50-213/79-06-12),
and is associated with the item identified in Detail 8.b (50-213/
79-06-13).
b.
10 CFR 20.203, " Caution signs, labels, signals and controls," states in Paragraph (e)... " Additional requirements.
Each area or room in which licensed material is used or stored and which contains any radioactive material (other than natural uranium or thorium) in an amount exceeding 10 times the quantity of such material specified in Appendix C of this part shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
CAUTION, RADI0 ACTIVE MATERIAL (S)."
On February 15, 1979, the inspector observed that the Spent Fuel Building an area used by the licensee for the storage and use of licensed radioactive material, contained several spent fuel assemblies in the spent fuel pool having several thousand curies of radioactive material, and other reactor system components (including the pressurizer code safety valves mentioned in Detail 7.c).
The inspector noted that the spent fuel and the other reactor components contained radioactive material in excess of 10 times the quantity specified in 10 CFR 20, Appendix C, but the building and areas or rooms within the building were not posted or identified as containing such material as is required by 10 CFR 20.203(e).
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The inspector identified that failure to post areas containing radioactive material as specified in 10 CFR 20.203(e) constituted an item of noncompliance (50-213/79-06-13), and is associated with the item identified in Detail 8.a (50-213/79-06-12).
9.
Surveys The inspector reviewed the licensee's performance of radiological evalu-ations (surveys) against the requirements of 10 CFR 20.201, " Surveys."
10 CFR 20.201, " Surveys," states:
"(a) As used in the regulations in this part, ' survey' means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive material present.
(b) 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."
1.
The following examples of failure to perform surveys sufficient to assure compliance with 10 CFR 20.101 were identified:
a.
On February 16, 1979, the inspector observed fuel sipping operations in the Spent Fuel Building.
In the performance of this activity, an individual manipulated a fuel assembly handling tool used to position the spent fuel assemblies under water in the spent fuel pool.
The individual, dressed in protective clothing, (excepting face and eye protection) was working in very near proximity to the handling tool (i.e., his face and eyes were generally within 3" to 12" of the tool).
When the inspector inquired about the radiological status of the tool the licensee representative indicated that no surveys had been taken.
At the inspector's request the licensee made measurements on the tool and found that the device had activity as high as 25 mrem /hr, gamma (at contact), and 400 to 600 mrad /hr, beta (at contact).
Through interviews with the Health Physics Supervisor and other persons, the inspector learned that no evaluation had been made to determine the extent of exposure to the lens of the eye that l?44 170
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.
personnel may receive from operating the tool in close proximity to their eyes; or if eye protection was required to assure that the regulatory limits of 10 CFR 20.101 were not exceeded.
Personnel monitnzing to determine exposure to the lens of the eye was not utilized.
The inspector identified that at least three individuals were subject to such exposure from operating this tool.
In response to this concern, the licensee required eye protection for further operation with the tool until an evaluation was performed to identify the significance of the radiological hazard; and indicated that the personnel exposures of the individuals previously subject to exposure from the tool would be re-evaluated.
The inspector indicated that the subject of personnel exposure would remain unresolved pending the licensee's evaluation (50-213/79-06-14).
b.
On February 3, 1979, surveys sufficient to determine compliance with 10 CFR 20.101, " Exposure of individuals to radiation in restricted areas," were not performed prior to allowing personnel to enter the No.1 Steam Generator (Primary Side, Channel Head), in accordance with RWP 790599 in that no surveys to determine beta dose rates were performad prior to subjecting personnel to exposure; and no evaluation was performed to estimate exposure to the lens of the eye of the individual
.
involved.
Subsequent measurements of the beta dose rate in the steam generator indicated that levels may have been as high as 370,000 mrad /hr in the general area within the channel head.
In further review of this item, the inspector learned the following:
Prior to any personnel entry into the Primary Side Channel Head (plenum area), a survey was performed (February 3, 1978) to measure the gamma radiation in the plenum.
Beta surveys were not performed.
Gamma dose rates between 22000 and 25000 mrem /hr were measured.
Based on this data, an individual was given a 2 minute stay-time and entered the steam generator.
On exiting from the steam generator, his dosimetry devices were read-out and found to indicate the following:
Self Reading Dosimeters (SRD); 0-200 mR; 0-500 mR; 0-1R
-
Result:
All off-scale SRD:
Two 0-10 R Result:
2.2R and 2.8R Film Badge Result:
p, 4450 mrad y, 1130 mrem i?44 171
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.
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Since this dose was significantly higher than what the licensee expected, the steam generator plenum was re-evaluated in an effort to ascertain the beta radiation levels.
Since the licensee had no procedures available as to the perform-ance of beta surveys, the technicians involved used a multiple of different techniques and instrumentc which resulted in beta levels being estimated betweer * 35,000 mrad /hr and 370,000 mrad /hr depending on the method of determination employed.
As of March 9, 1979, the inspector noted that the licensee was still unable to produce credible beta survey information on the steam generator.
In reviewing the survey techniques employed, the inspector learned that on February 3, 1979 a Health Physics technician, in an effort to make dose rate measurements on the steam generator tube sheet, taped two PIC-6 dose rate instruments to a stick inserted the " device" through the steam generator manway to the tube sheet.
Since the meter read-outs were out of sight in the generator, the method required the technician to retract the instruments rapidly and observe the rate at which the indicating needle on the dose rate meters feil; and then extrapolate the probable indication when the instrument was in contact with the steam generator tube sheet.
The " survey" thus performed, was documented and used for dose rate evaluation.
The survey form indicated that the beta gamma dose rate at the tube sheet was
"s60-100 R/hr" based on this method.
The inspector noted that the utilization of such a dubious method for dose rate determination was evidence that the licensee lacked suitable procedures and adequate management direction for the performance of such surveys.
Since it was evident that there was not sufficient information in which to ascertain the exposure to the individual who made the initial entry into the steam generator, the licensee indicated that the individual's exposure would be re-eveluated.
The inspector noted that the subject of personnel exposure in this instance would remain unresolved pending the licensee's evaluation of the individual's exposure (50-213/79-06-15).
c.
On March 7, 1979, the inspector requested the licensee to perform a random test of certain portable radiation detection instruments that were in-service and utilized to perform surveys.
The following instruments were tested on the licensee instrument calibration source:
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Instrument Serial No.
Remarks Teletector 34198 Responded to + 100% of the actual vaTue PIC-6 1499 Meter movement was not functional Based on these two failures, the licensee performed similar tests on all of the remaining instruments that were normally used for radiation protection (three other instruments).
These instruments were also demonstrated to be either not functioning properly or significantly out of calibration.
The inspector requested that the instrument (Teletector No.
11068) that was being utilized to provide radiological evalua-tion for RWP 792396, " Clean-out Flux Thimbles," (dated February 7, 1979) be also tested.
The licensee tested the instrument with the following results:
Actual Source Strength Instrument Response 431 R/hr 250 R/hr 61 R/hr 7 to 15 R/hr 2 R/hr 1.2 R/hr The inspector indicated that since the instrument was found to produce significantly inaccurate and unreliable information
<
when used to measure various radiation intensities, the surveys performed with it were not sufficient to assure compliance with the requirements of 10 CFR 20.101.
The inspector identified that these samples of failure to perform surveys in accordance with 10 CFR 20.201 sufficient to assure com-pliance with 10 CFR 20.101 constituted an item of noncompliance (50-213/79-06-16), and is associated with the item identified in Detail 4.a (50-213/79-06-02).
2.
The following examples of failure to perform surveys sufficient to assure compliance with 10 CFR 20.103 were identified:
a.
On February 27, 1979 personnel working in accordance with RWP 792066 opened up a portion of the primary system (RHR-MOV-781),
a system component having radiation levels as high as 200 mrem /hr at contact (indicative of a high potential for airborne lS44
.
.
radioactivity), for the purpose of replacing the valve bonnet gasket.
The RWP required continuous coverage by Health Physics technicians, but the technicians were not present during the performance of this evolution; and consequently surveys of the concentrations of radioactive material in air to which the personnel were exposed were not performed in accordance with 10 CFR 20.103, " Exposure of individuals to concentratians of radioactive materials in air in restricted areas."
The inspector observed that when the Health Physics technicians did become available to cover this work evolution, the job was essentially completed (i.e., the system had been opened; the valve bonnet gasket was replaced; and the system closed).
No respiratory protection was required for this evolution.
b.
On February 3, 1979, personnel entered No. 1 Steam Generator (Primary Side, Channel Head) in accordance with RWP 790599, an area having loose surface contamination as high as 250 mrem /hr 100cm);(indicativeofahighpotentialforairborneradio-(gamma and 3000 mrad /hr (non penetrating radiation) per activity), but surveys to determine compliance with 10 CFR 20.103; " Exposures of individuals to concentrations of radio-active mattrials in air in restricted areas" were not made in the area in which personnel were working, in that no air samples were taken iii the plenum area in which personnel were working.
The details of this event are described in paragraph 9.1.b.
~
The inspector identified that failure to perform surveys in accordance with 10 CFR 20.201 sufficient to assure compliance with 10 CFR 20.103 constituted an item of noncompliance (50-213/79-06-17), and is associated with the item identified in Details 6.b (50-213/79-06-06)
and 6.c (50-213/79-06-07).
10.
Unplanned Liquid Release of Radioactive Material On March 8, 1979, during a routine tour of the facility, the inspector noted that water was issuing from the base of the facility stack at the rate of * 20 gallons per minute.
A High Radiation Sign affixed to the stack indicated 230 mrem /hr at contact with the stack.
The water was observed to flow from the stack (at a leak in a gasket on the access cover), to the asphalt walkway, to a storm sewer drain approximately 30 feet away.
The inspector notified the following personnel in order and noted their response:
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o Personnel Notified Response Operations Shift Supervisor The individual indicated that he was aware of the spill; and that there was no problem.
He stated that the water was sourced from the steam generator blowdown con-densate which was clean.
No action was taken to stop the spill.
Plant Chemistry Technician The individual indicated that he was aware of the spill and that samples were being taken periodically for the
duration.
The results werg *Ci/ml
uCi/ml at the stack; * 10 u
at the outfall from the storm sewer.
He stated that dilution flow in the estuary (* 50,000 gpm) was sufficient to assure that the concentration was below 10 CFR 20, Appendix B limits prior to release to an unrestricted area.
No action was taken to stop the spill.
HP Sa:ervisor The individual indicated that he was aware of the spill; and that the area on the walkway was barricaded and posted to prevent personnel access.
He stated that this was a Chemistry Department problem; and as such, Chemistry Department was responsible for control.
No action was taken to stop the spill.
Station Superintendent The individual indicated that he was not aware of the spill, but that he would investigate and hie acticn as necessary.
Action was takp pk spill was
subsequently st.jpec.
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....
The inspector reviewed this release against the requirements specified ir 10 CFR 20, WASTE DISPOSAL Part 20.301, " General Requirement;" 10 CFR 20.106, " Radioactivity in Effluents to Unrestricted Areas;" Technical Specification 2.4.1, Specification for Liquid Waste Effluents; Technical Specification 2.4.2, Specifications for Liquid Waste Samoling and Monitoring.
No items of noncompliance were identified, however the inspector noted that the response to this occurrence by the personnel contacted (excluding the Station Superintendent) was inappropriate and could have led to a more serious situation if proper action was not immediately taken.
11.
Exit Interview The inspector met with licensee representatives (as denoted in Paragraph 2) at the conclusion of the inspection on March 9, 1979.
The inspector summarized the purpose and scope of the inspection and the findings.
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