IR 05000269/1985042
| ML20214D731 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/11/1986 |
| From: | Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20214D712 | List: |
| References | |
| 50-269-85-42, 50-270-85-42, 50-287-85-42, IEIN-85-006, IEIN-85-007, IEIN-85-012, IEIN-85-046, IEIN-85-060, IEIN-85-081, IEIN-85-087, IEIN-85-092, IEIN-85-12, IEIN-85-46, IEIN-85-6, IEIN-85-60, IEIN-85-7, IEIN-85-81, IEIN-85-87, IEIN-85-92, NUDOCS 8603050453 | |
| Download: ML20214D731 (9) | |
Text
Sa [tig'D UNITED STATES o
NUCLEAR REGULATORY COMMISSION
/
- , *
y
.
.
n REGION la y.
,j 101 MARIETTA STREET, N.W.
- I
- ' *
ATLANTA, GEORGI A 3o323 O
%,.. * ',G FEB 191986 s
Report Nos.:
50-269/85-42, 50-270/85-42, and 50-287/85-42 Licensee:
Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-269, 50-270, and 50-287 License Nos.: DPR-38, DPR-47, and DPR-55 Facility Name: Oconee 1, 2, and 3 Inspection Conducted:
December 16-20, 1985
/
- 4__
Inspector:
u-T. R. Collins Oate' Signed Accompanying Personne :, T. G. Lee Approved by:
'O 4 I.Vl< M N
C. M. Hosey, Section Chief Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection entailed 38 inspector-hours onsite during regular hours inspecting the radiation protection program including training and qualification of personnel, internal and external exposure control, radioactive material control, posting and labeling, and the program for maintaining exposures as low as reasonably achievable (ALARA).
Results: One violation for failure to provide positive access control for two high radiation areas.
.
0603050453 060219 PDR ADOCK 05000269 O
_--._
__
. _... _
.
_. _ _ _ _ _ _
.. _
_ _ _, _ _ _ _ -
_ -. _ _ _ _.. _. ___
_.
_-
-
.
>
.
.
REPORT DETAILS
!
L 1.
Persons Contacted Licensee Employees M. S. Tuckman, Station Manager i
i
- T. S. Barr, Superintendent, Technical Services i
- R. T. Bond, Compliance Engineer l
C. Yongue, Station Health Physicist
,
'
- R.
Rodgers OSRG j
- E. Brown, Associate Health Physicist
[
- R. J. Brackett, Senior QA Engineer I
- C.
L. Harlin, Health Physics Coordinator T. C. Matthews, Regulatory Compliance Specialist
i D. Davidson, QA Specialist i
'
M. D. Thorne, Health Physics Coordinator
!,
L. D. Garrett, Technical Associate
,
r l
Other licensee employees contacted included technicians, operators,
]
mechanics, security force members, and office personnel.
i NRC Resident Inspectors
i j
K. Sasser, Resident Inspector l
L. King, Resident Inspector
!
'
- Attended exit interview
-
2.
Exit Interview
,
The inspection scope and findings were summarized on December 20, 1985, with l
those persons indicated in Paragraph 1 above.
The following issues were
'
discussed in detail:
an apparent violation for failure to provide positive I
access control to high radiation areas, with two examples (Paragraph 8); an
!
unresolved item concerning MPC-hour tracking (Paragraph 9); and an
!
un esolved item concerning an air sample taken in an airborne radioactivity j
area (Paragraph 9). The licensee did not identify as proprietary any of the j
materials provided to or reviewed by the inspector during this inspection.
l 3.
Licensee Action on Previous Enforcement Matters
!
(Closed)
Violation 50-269/270/287/85-30-01 Containers of radioactive l
material were not properly labeled. The inspector reviewed and verified the i
corrective action as stated in Duke Power Company's letter of November 13, l
1985.
i
!
i i
!
i
,
-_
.- - -
._
.
-... -.
.--
--
--.--
.
..
. _ -.
!.
.
.
e
4.
Training and Qualifications (83723)
j I
a.
Basic Radiation Protection Training I
!
The licensee was required by 10 CFR 19.12 to provide basic radiation i
protection training to workers.
Regulatory Guides 8.27, 8.29, and l
8.13, outlined topics that should be included in such training.
Chapters 12 and 13 of the FSAR contained further commitments regarding
!
training. The inspector discussed the initial and refresher general
'
employee radiation protection training (GET) with the Training Supervisor and attended GET training sessions for selected topics where I
the program had been changed. During tours of the plant, the inspector
'
discussed topics from the GET training with maintenance personnel to
-
determine the effectiveness of the training, l
b.
Radiation Protection a.id Chemistry Technician Qualification j
l The licensee was required by Technical Specification 6.1.1.4 to qualify radiation protection and chemistry technicians in accordance with
<
ANSI /ANS-3.1-1978.
The inspector discussed with the training
,
coordinator the training and qualification program.
The inspector
reviewed the training records for selected technicians to assure all
'
!
topics were completed. The inspector discussed, with one radiation j
protection technician-in-training, the qualification program and
!
assignments to assure that they had not been assigned to work independently and had been qualified for assigned tasks.
i I
The inspector reviewed the program for qualification of contract i
radiation protection technicians.
The inspector also discussed the j
training and qualification program the licensee had provided, what limits had been placed on their activities, and controls that should be
'
established for one task they were qualified to perform.
c.
Staffing l
Technical Specification 6.1 specified minimum plant staffing.
Chapters 12 and 13 outlined further details on staffing. The inspector i
discussed authorized staffing levels vs. actual on-board staffing with the Radiation protection Supervisor.
The inspector examined shift
,
i staffing for the day shift on December 17, 1985, to determine if it met minimum criteria for radiation protection.
No violations or deviations were identified.
5.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring
j (83726)
The licensee was required by 10 CFR 20.201(b), and 20.401 to perform surveys
.
i to show compliance with regulatory limits and to maintain records of such
!
surveys.
Chapter 12 of the FSAR further outlines survey methods and I
instrumentation.
Technical Specification 6.4 required the licensee to I
follow written procedures. Radiological control procedures further outlined j
survey methods and frequencies.
,
)
i i
_ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ - - _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ -
___
__
- _ _ _ _ _ _ _ _ _ _ _ _ _.
-
,
.
/
a.
Surveys The insoector observed, during plant tours, surveys being performed by
'.
radiation protection staff.
The inspector reviewed selected Radiation
-
Work Permits, to determine if adequate controls were specified.
The j
inspector discussed the controls and monitoring with the radiation protection technicians assigned.
The inspector performed independent radiation level surveys.
During plant tours, the inspector observed radiation level and contamination survey results outside selected cubicles.
The inspector
.
performed independent radiation level surveys of selected areas and compared them to licensee survey results.
The inspector reviewed selected survey records for the month of December 1985 and discussed with licensee representatives their methods used to disseminate survey results.
b.
Frisking i
During tours of the plant, the inspector observed the exit of workers
and movement of material from contamination control to clean areas to i
determine if proper frisking was performed by workers and that proper
direct and removable contamination surveys were performed on materials.
j The inspector reviewed records of skin contamination occurrences and
resulting evaluations and corrective actions. During 1985, tnere were j
241 skin contaminations noted.
Records and discussions with licensee representatives showed contamination had been promptly removed from the
,
l workers using routine washing techniques. Subsequent whole body counts j
showed less than detectable internal deposition of radioactive
{
material.
3 c.
Instrumentation
!
During plant tours, the inspector observed the use of survey
instruments by plant staff and compared plant survey meter results with
'
results of surveys made by the inspector using NRC equipment.
The i
l inspector examined calibration stickers on radiation protection
'
i instruments
.n use by licensee staff and stored in the radiation j
protection laboratory.
The inspector discussed with radiation
protection technicians the methods for doing instrument source check.s l
prior to each use and instrument calibration methods, j
,
d.
Release of Materials for Unrestricted Use
<
l l
The inspector discussed, with a radiation protection technician, the I
program for release of items from contaminated areas and reviewed the
,
j procedures for such release.
The inspector observed release surveys
' performed by radiation protection technicians, and documentation of
results. During tours of plant areas, the inspector observed labeling
,
of containers and performed independent surveys to determine if
!
)
containers of radioactive material were properly identified.
'
I f
No violations or deviations were identified.
I
'
-
-
-
-
- _ - - - _ - -
. -.--._- - - - - -.
.-
-
!
.
i
.
'
t I
j
i j
6.
Facilities and Equipment (83727)
!
FSAR Chapters 1 and 12 specified plant layout and radiation protection
!
t facilities and equipment. During plant tours, the inspector observed the
operation of the contaminated clothing laundry, the flow of traffic through
,
change rooms, the use of temporary shielding, glove bags, and ventilated l
containment enclosures.
l
{
No violations or deviations were identified.
j
'
7.
Audits (83723,83724,83725,83726,83728)
The licensee was required by Technical Specification 6.1 to perform audits
of radiological controls and chemistry operations.
The inspector reviewed i
audits of the radiation protection operations dated January 1985, to
,
Decemoer 1985; the responses to these audits; and the status of selective I
corrective actions resulting from the audits.
The inspector discussed the i
results of these audits with licensee representatives.
These audits i
identified several items needing corrective action.
Corrective action had been initiated for all items.
The audits were conducted using staff with technical backgrounds in radiologice.1 controls and chemistry.
!
]
No violations or deviations were identified.
!
i i
8.
External Occupational Dose Control and Personal Dosimetr., (83724)
l During plant tours, the inspector checked the security of the locks at
l thirty locked high radiation areas and observed posting of survey results
!
and the use of controls specified on three radiation work permits (RWPs).
j
!
I a.
Use of Dosimeters and Controls l
The licensee was required by 10 CFR 20.202, 20,201(b), 20.101, 20.102, 20.104, 20.402, 20.403, 20.403, 20.405,19.13, 20.407, and 20.408 to
.
'
!
maintain worker's doses below specified levels and keep records of and I
make reports of doses.
The licensee was required by 10 CFR 20.203 to
!
l post and control access to plant areas. FSAR Chapter 12 also contained
'
!
commitments regarding dosimetry and dose controls. During observation I
of work in the plant, the inspector observed the wearing of TLDs and l
pocket dosimeters by wnrkers.
During plant tours, the inspector i
observed the posting of areas and made independent measurements of dose
to assure proper posting,
,
b.
High Radiation Area Access Control 10 CFR 20.203(c)(2)(iii) required each entrance or access point to a i
high radiation area to be maintained locned except during periods when access to the area is required with positive access control over each
!
Individual entry.
10 CFR 20.203(c)(1) required that each high
'
radiation area be conspicuously posted with a sign or signs bearing the
j radiation caution symbol and the words " Caution or Danger, High
j Radiation Area."
10 CFR 20.203(c)(4) permits the substitution of direct surveillance to prevent unauthorized entry for the controls
}
i
!
,
~__
._._.
__
- _. _ _ _. _ _
_
_ _ _ _ _ _ _. _. - _ _ _ _
- - - -
-
_
- - - _..
.
-
.
,
f required by 20.203(c)(2) if the high radiation area is established for a period of 30 days or less.
During a plant tour, the inspector observed that scaffolding in the high pressure injection /lcw pressure injection hatch area permitted access to the HPI/LPI area, an area
controlled oy the licensee as a high radiation area. Licensee surveys
'
,
taken on December 11, 1985, indicated radiation levels in the area j
ranged up to 1 R/hr 18 inches from some piping.
Failure to maintain
the entrance or access point to the high radiation area locked was identified as an apparent violation of 10 CFR 20.203(c)(2) (50-269,
270,287/85-42-01).
I Af ter touring the Auxiliary Building and proceeding to the North exit
]
(elevation 796), the inspector exited the building to find himself
'
!
inside a roped boundary of a high radiation area. The exit door used
!
by the inspector was not posted as a high radiation area.
After
{
discussions with the licensee and observations by the inspector, it was determined that the area nad been posted as a high radiation area on
[
l three sides as a result of loading 55 containers of low specific
'
,
!
activity (LSA) radioactive waste into a CNS 14-195 shipping cask.
The
!
licensee had not locked the door nor, was the licensee maintaining positive access control over each entry.
The exception permitted by
'
10 CFR 20.203(c)(4) to the requirement that entrance to high radiation
I i
area be locked was not applicable since the licensee was not
maintaining direct surveillance to prevent unauthorized entry into the i
j area.
Failure to maintain the entrance to the high radiation area
locked and to maintain oositive access control over each entry was
'
{
identified as another example of an apparent violation of
10 CFR 20.203(c)(2) (50-269, 270, 287/85-42-C1).
- i L
i c.
Dosimetry Results
!
'
The inspector reviewed the TLD results for 1985. For four individuals who received greater than 1.25 rems in one quarter, the inspector j
examined each individual's dosimetry file to determine if NRC Form 4's j
had been completed, d.
Management Review of Dosimetry Results
{
j The inspector reviewed records of administrative dose control
extensions for the year of 1985 and discussed the extensions with i
selected supervisors and staf f.
The inspector reviewed records of
'
cases where workers exceeded administrative controls without dose extensions. The inspector discussed these cases with selected involved individuals and reviewed corrective actions.
'
]
9.
Internal Exposure Control and Assessment (83725-) -
l The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403, and l
20.405 to control uptakes of radioactive material, assess such uptakes, and i
!
i
!
i
. -_
___
. _ _ - -.
_. - _ _ - _. --._ _
-
---
__
.
. - -
. _ _ _
_
i
.
- .
1 keep records of and make reports of such uptakes.
FSAR Chapter 12 also included commitments regarding internal exposure control and assessment.
{
a
a.
Control Measures
!
During plant tours, the inspector observed the use of temporary l
ventilation systems, containment enclosures, and respirators.
The inspector discussed the use of this equipment with workers and radiation protection technicians.
The inspector reviewed recent i
!
changes to respiratory protection procedures.
'
i
,
b.
Respiratory Maintenance and Issue i
The inspector observed the issuance of respirators and reviewed records l
for selected workers who were issued respirators to determine if they were qualified for the respirators issued.
The inspector reviewed l
!
recent changes to respirator maintenance and issue procedures.
'
!
J c.
Uptake Assessment l
l
!
l The inspector observed operation of the whole body counter and
,
discussed its operation and results with the counter operator.
The
inspector reviewed the results of the analyses performed for selected individuals for 1985.
The inspector discussed the assessment and
corrective actions with the supervisors of these personnel.
The
'
inspector reviewed the Maximum Permissible Concentration-hour
'
(MPC-hour) log for 1985 and discussed actions taken by the licensee for personnel that received greater than 2 MPC-hours in a day and 10 MPC hours in a week, j
l The inspector reviewed the MPC-hour logs for 1985 and noted there were l
no personnel listed with greater than 40 MPC-hours during a quarter, i
However, through review of additional records the inspector noted that i
from March P1-28 an indiviaual had apparently exceeded the weekly j
40 MPC-hour control measure. On the March 28, with a current MPC-hour exposure of 34 MPC-hours the individual in question entered on SRWP i
!85-590 and 85-0015 where airborne radioactive materials existed in concentrations from 3 to 7 times MPC and remained in these areas for a
'
total time of 10.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. His apparent MPC-hour exposure of 31.5 was
'
not recorded on the MPC-hour log which would have alerted the licensee to his apparent total of 65.5 MPC-hours.
There were no additional
assessments of this individual's exposure as required by 10 CFR 20.103.
!
In addition MPC-hour log entries were not made for similar entries made on March 30 and 31, when the apparent exposures were for less than 2 MPC-hours in a day, a requirement of 10 CFR 20.103(a)(3). The licensee stated that these were general area RWPs where the concentrations of
airborne radioactivity in certain areas was below 25 percent of MPC.
t
'
The licensee further stated he would provide more detailed air sampling
,
!
survey records to substitute his contention.
Failure to perform an evaluation and to take corrective actions to prevent a recurrence when the 40 MPC-br control measure is exceeded would be a violation of 10
!
CFR 20.103(b)(2). The inspector stated that pending receipt and review j
I
l
-
- -
-
__
__
___
_ _ - _ _.
_ _ _ _ _ _ __
_..- __.. _
_ _ _ _. _. _
_. _
._
.
l
-
of these records the item would be listed as an unresolved item *
>
I (85-42-02).
!
10 CFR 20.103(a)(3) requires the licensee to use suitable measurements
,
i of concentrations of radioactive materials in air for determining and
!
evaluating airborne radioactivity in restricted areas.
10 CFR 20.201(b) requires each licensee to make or cause to be made
'
such surveys as (1) may be necessary for the licensee to comply with j
the regulations in this part and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be
'
present.
During review of the licensee's radiological occurrence i
investigations the inspector noted that on March 29, 1985, a health physics technician received an uptake of 146 nC1's of I-131 while
!
performing surveillance of a heat exchange plugging operation. The HP
!
technician was working under RWPs 652 and 657. The inspector requested
.
the results of air samples taken during the work. Failure to perform airborne radioactivity surveys would be a
violation of 10 CFR 20.201(b).
This item will be tracked as an unresolved item
pending the licensee furnishing the required air sample data
,
(85-42-03).
I 10. Maintaining Occupational Doses ALARA (83728)
.
10 CFR 20.1(c) specified that licensees should implement programs to keep workers' doses ALARA.
FSAR Chapter 12 also contained licensee commitments l
regarding worker ALARA actions.
a.
Worker and Supervisor Actions The inspector discussed with ALARA personnel their actions to reduce individual and collective doses, concentrating particularly on staff members with highest doses.
The inspector also discussed the actions
.
to set dose goals for tasks, methods used to reduce doses, and
'
techniques used to monitor performance against goals, b.
ALARA Procedure Changes The inspector reviewed recent changes to administrative procedures that implemented the elements of ALARA.
The inspector discussed these changes with the ALARA Coordinator, c.
ALARA Reviews l
The inspector reviewed the ALARA review documentation for selected activities during 1985 and discussed resulting actions with the ALARA Coordinator.
,
i
- An unresolved item is a matter about which more infurmation is required to determine whether it is acceptable or may involve a violation or deviation.
,
i
)
i
.. _ _
. -.
-
.
.
d.
ALARA Reports The inspector reviewed the ALARA Reports for 1985 and discussed the results with the Radiation Protection Manager.
The summary of tasks estimated for 1985 was 1098 man-rems.
Through December 17, 1985, the total was 1296 man-rems. The increased exposure was primarily a result of exceeding the original estimate of outage days and underestimate of man-hours in radiation areas.
The licensee does not revise the original estimates made at the beginning of the year.
No violations or deviations were identified 11.
Problem Reports and Radiological Deficiency Reports The inspector examined the Prublem Reports and Radiological Deficiency Reports and resulting corrective actions for the period January through December 1985 and discussed selected reports with involved workers.
No significant findings were noted.
No violations or deviations were identified.
12.
IE Information Notices (92717)
The following IE Information Notices were reviewed to ensure their receipt and review by appropriate licensee management:
IN-85-06, Contamination of Breathing Air Systems IN-85-07, Contaminated Radiography Source Shipments IN-85-12, Recent Fuel Handling Events IN-85-46, Clarification of Several Aspects of Removable Radioactive Surface Contamination Limits for Transport Packages IN-85-60, Defective Negative Pressure, Air Purifying Full Facopiece Respirators IN-85-81, Problems Resulting in Erroneously High Reading With Panasonic 800 Series Thermoluminescent Dosimeters IN-85-87, Hazards of Inerting Atmospheres
IN-85-92, surveys of Waste Before Disposal From Nuclear Reactor Facilities
%
-
-
- - -
-
-
-
- -
-