IR 05000269/1987042
| ML16161A910 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/06/1987 |
| From: | Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16161A909 | List: |
| References | |
| 50-269-87-42, 50-270-87-42, 50-287-87-42, NUDOCS 8711190226 | |
| Download: ML16161A910 (10) | |
Text
pp NUCEA UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-269/87-42, 50-270/87-42, and 50-287/87-42 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 Nuclear Station Inspection Conducted:
Oc ber 26-30, 1987 Inspector T_ N._
__
__
Wri"h F. N. Wright
,.-.~
ate Sgne Approved by:
1"77 C. M. Hosey, Section Chief Date Signe Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection of the radiation protection program included:
previous enforcement matters; internal exposure control; solid waste processing; transportation of radioactive material; and control of radioactive materials and contamination, surveys, and monitorin Results:
No violations or deviations were identifie PDR ADOCK 05000269 Q
REPORT DETAILS 1. Persons Contacted Licensee Employees C. B. Adams, Radwaste Chemistry Specialist
- E. Brown, Nuclear Production Health Physicist
- R. J. Brackett, Senior Quality Assurance Engineer
- R. Brock, Instrument Electrical Engineer S. D. Couch, Health Physics Specialist
- S. A. Coy, General Supervisor Health Physics
- J. M. Davis, Superintendent of Technical Services L. A. Davis, Health Physics Specialist P. V. Grant, Health Physics Supervisor
- C. L. Harlin, Compliance Engineer R. H. Ledford, Quality Assurance Surveillance Supervisor
- T. C. Mathews, Compliance Engineer S. L. Morgan, Supervisor, Health Physics Instrument Support W. E. McAlister, Instrument Electrical Technical Support Engineer H. B. Nicholson, Health Physics Specialist G. T. Powell, Associate Engineer Health Physics J. H. Schulte, Associate Engineer, Radwaste Emergency Section, Nuclear Technical Services T. A. Smith, Health Physics Supervisor
- R. L. Sweigart, Superintendent of Operations E. M. Swayngham, Radwaste Supervisor
- M. D. Thorne, General Supervisor Health Physics
- M. S. Tuckman, Station Manager C. T. Yongue, Station Health Physicist Other licensee employees included five health physics technicians, four craft employees, and one traine Nuclear Regulatory Commission
- J. Bryant, Senior Resident Inspector
- L. D. Wert, Resident Inspector
- Attended exit interview 2. Exit Interview The inspection scope and findings were summarized on October 30, 1987, with those persons indicated in Paragraph 1 above. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio. Internal Exposure Control and Assessment (83725)
a. Air Sampling 10 CFR 20.103(a) establishes the limits for exposure of individuals to concentrations of radioactive material in air in restricted area This section also requires that suitable measurements of concentrations of radioactive materials in air be performed to detect and evaluate the airborne radioactivity in restricted area While touring the licensee's facility the inspector observed the use of low volume portable air samplers in operational area The inspector reviewed the calibration status of the air sampler In the Unit 1 and 2 Spent Fuel Pool Cooler Room the inspector found an idle air sampler with a calibration due date approximately one week old. The inspector asked licensee representatives if the sampler had been used since its calibration date had expire The inspector determined that the licensee had no way to trace air sample results with the equipment utilized to collect and measure the quantity of sampled air. The inspector discussed the inability of the licensee to correlate measured air sample results with calibrated air sampling equipmen Licensee representatives agreed to establish a system that would enable the licensee to trace air sample results with air sampling equipment, which would enable the licensee to demonstrate the accuracy of its airborne radioactivity monitoring progra The inspector stated a review of the licensee's method for correlating air sample results with air sampling equipment would be reviewed in a future inspection as an inspector followup item (50-269/87-42-01, 50-270/87-42-01, and 50-287/87-42-01).
No violations or deviations were identifie b. Process and Engineering Controls 10 CFR 20.103(b)
requires the licensee to use process or other engineering controls, to the extent practicable, to limit concentrations of radioactive material in air to levels below that specified in 10 CFR Part 20, Appendix B, Table 1, Column 1 or limit concentrations when averaged over the number of hours in any week during which individuals are in the area, to less than 25 percent of the specified concentration The use of process controls and engineering controls to limit airborne radioactivity concentrations in the plant was discussed with licensee representatives and the use of tents and high efficiency particulate air filters were observed in the licensee's hot machine shop and solid waste compacting roo No violations or deviations were identifie *
c. Respiratory Protection 10 CFR 20.103(b) requires that when it is impracticable to apply process or engineering controls to limit concentrations of radioactive material in air below 25 percent of the concentrations specified in 10 CFR 20, Appendix B, Table 1, Column 1, other precautionary measures should be used to maintain the intake of radioactive material by an individual within seven consecutive days as far below 40 Maximum Permissible Concentration (MPC)-hours as is reasonably achievabl CFR 20.103(c)(2) provides that the licensee may make allowance for the use of respiratory protective equipment in estimating exposures of individuals to radioactive material in air provided the licensee maintains and implements a respiratory protection program that includes, as a minimum, written procedures regarding supervision and training of personnel and issuance of record The licensee had just recently revised its Station Directive Procedure 3.3.7 which describes the licensee's respiratory protection progra The directive was consistent with regulations, Technical Specifications and good health physics practice However, the inspector did identify a lack of detail in implementing procedures for the respiratory protection progra American National Standard, ANSI Z88.2-1980, Practices for Respiratory Protection, recommends that compressed gaseous air meet at least the requirements of the specification for Type I-Grade D breathing air as described in American National Standard Commodity Specification for Air, ANSI Z86.1-197 Licensee Procedure HP/0/B/1010/05, Breathing Air Analysis Using Drager Using Multi Gas Detector, Revision 1, dated July 1, 1981, describes one of the methods utilized by the licensee to evaluate the quality of breathing air supplied by the licensee's compressor used to fill breathing air tanks and air supplied by the plant breathing air system. However, the procedure does not specify the sampling frequency for evaluating breathing ai The inspector determined through interviews with licensee representatives that none of the licensee's respiratory protection procedures specified a sampling frequency for breathing air to evaluate the quality to Grade D specification The inspector also determined that in addition to the breathing air field test described in Procedure HP/0/B/1010/05 the licensee samples the breathing air for the utilities Industrial Hygiene Staff which also evaluates the quality of the breathing ai However, this sampling procedure is not described in written approved procedures. The inspector determined that the licensee was utilizing both sampling processes, sampling the air at several locations each mont The inspector reviewed the results of the breathing air sampling program and verified that the air met the requirements for Grade D breathing ai Licensee Procedure HP/O/B/1010/04, Selection of Proper Respiratory Protective Equipment, Rev. 4, May 6, 1987, required that the breathing air be sampled quarterly for cross contamination of radioactive materia The instruction required a gamma isotopic analysis of the breathing air. The inspector reviewed the results of 1987 radiological evaluations of breathing air systems and determined that the analysis were performed monthly and that the analysis included an isotopic evaluation of gas, particulate and charcoal samples; alpha contamination; and tritium. The evaluations were more detailed than required by the licensee's procedures. The inspector discussed the lack of detail in licensee procedures to reflect actual activities with licensee representative Many of the licensee's procedures were last revised six years earlie Licensee representatives agreed to review the adequacy of the respiratory protection procedures to ensure current activities were adequately defined and reflected current practices. The inspector stated that a review of the licensee's evaluation of its respiratory protection procedures would be reviewed in a future inspection as an inspector followup item (50-269/87-42-02, 50-270/87-42-02, and 50-287/87-42-02).
Individuals participating in the licensee's respiratory protection program are required to attend respiratory protection training annuall The training includes a qualitative fit-tes The licensee utilizes a irritant smoke as a challenge atmospher Students were required to don a tight fitting face piece equipped with high efficiently particulate air (HEPA)
filter and enter a chambe The instructor cautioned the workers to keep their eyes closed and to breath very shallowly at the beginning of the tes The instructor talked the workers through a series of movements to simulate actual working condition The inspector observed several students through the test procedure No leaks were reported from the students observed by the inspecto The inspector determined that the licensee's qualitative fit test procedure utilized the recommendations and precautions of NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Materials-197 The inspector determined that the licensee has ordered a respirator fit test booth that will allow for quantitative fit testing in the futur The licensee utilizes a radiological respirator issue card and a computer data base to authorize the issuance of respirator The card is also used to track the status of the respirator and document respirator return survey The inspector toured the respirator issue, storage, and maintenance facilit The respirator facility was organized and appeared to be adequately stocked with respirators and spare part The inspector observed licensee representatives preparing respirators for reissue in accordance with licensee procedures and technicians verifying individual qualifications prior to respirator issuanc CFR 20, Appendix A, Footnote stated in part that when air supplied hoods are used and a protection factor credit is taken during the use, calibrated gauges or flow measuring devices shall be used to ensure that proper air flow rates are maintained. During the review of the respiratory protection program, the inspector determined that the licensee had used supplied air hoods for the first time during the 1987 Unit 1 refueling outage. The inspector determined that the licensee had used a distribution unit with calibrated pressure gauges to control air from the breathing air system to the supplied air hood The licensee has a breathing air (BA)
system to provide respirator quality ai The BA system compressed air is provided by four (4)
compressors. Three water cooled and one using oil for lubricating, cooling, and sealin The oil cooled compressor has a carbon monoxide (CO)
monitor on the discharge of the compresso This monitor provides a stat alarm to the Unit 1 Control Roo The inspector reviewed the licensee's Alarm Response Manual for operator actions in the event of an alarm signa ISA-18/C-3, Breathing Air Carbon Monoxide High, dated June 19, 1987, requires operations to announce over the plant PA system to discontinue use of the breathing air until samples indicate levels are appropriate for breathing and to dispatch an operator to investigate operation of the compressor and acknowledge local alar The inspector determined that the monitor had recently been out of service for about a week for maintenanc The inspector determined that licensee procedures for operating the BA system did not address administrative controls to be placed on the operation of the oil cooled compressor while the units CO monitor was out of service. Licensee representatives agreed to evaluate operating procedures and define BA system controls when the oil cooled compressor CO monitor was out of servic The inspector stated that a review of the licensee's controls for the BA system would be reviewed in future inspections as an inspector followup item (50-269/87-42-03, 50-270/87-42-03, and 50-287/87-42-03).
The BA system distributes the air through headers into manifolds equipped with quick disconnect fittings for connecting individual respirator The inspector obtained controlled drawings of the systems flow diagrams and manifold locations and spot checked the manifolds at various locations in the auxiliary buildin The inspector determined that the licensee's drawings did not show the BA system as constructed. The inspector found BA system manifolds that were not shown on the licensee's drawing (Manifold in Unit 2 Auxiliary Building on Elevation 783'-9" to the south of radiation monitor RIA-36).
The inspector also found a manifold that had a pressure gauge that was not shown on the drawings or listed in the licensee pressure gauge calibration procedure IP/0/B/255/1B, Compressed Air System Breathing Air Instrumentation, revision dated
October 26, 1987 (manifold in Unit 1 Auxiliary Building on Elevation 783'-9" north wall of 212 corridor).
The inspector reviewed licensee procedure for testing the breathing air system pressure gauge The inspector determined that licensee Procedure IP/O/B/255/1B did not specify the testing frequency of the manifold pressure gauges. However, licensee representatives reported that the gauges were on an annual testing frequency. The inspector reviewed the 1985 and 1986 test/calibration data sheets for all of the BA system pressure gauges that are shown on licensee drawing The pressure gauges had been tested in November 1985 and 1986 with the exception of those located in the three containment buildings (Pressure Gauges 371-397).
The 1985 and 1986 test/calibration data sheets had "N/A" recorded in the required reading, as found reading, and as left reading columns for the 27 BA system pressure gauge The inspector discussed the condition of the BA system drawings and pressure gauge testing with licensee representatives. The inspector stated that had the licensee not used calibrated pressure gauges for hoods used during the Unit 1 outage and the licensee had relied on the BA system pressure gauges in containment for ensuring an adequate flow to supplied air hoods the licensee would have violated the requirements of 10 CFR 2 However, the inspector had not found the condition of the BA system to be in violation of any requirements including the licensee Licensee representatives agreed to investigate the conditions of the BA system plant drawings and to set the BA system pressure gauges in containment on a refueling cycle testing program to ensure gauge accessibility. The inspector stated that a review of the licensee's evaluation of BA system drawings and the establishment of a refuel cycle test for BA system pressure gauges located in containments would be identified as an inspector followup item to be reviewed during a future inspection (50-269/87-42-04, 50-270/87-42-04, and 50-287/87-42-04).
4. Surveys, Monitoring, and Control of Radioactive Material (83726)
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 the regulations and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be presen The inspector surveyed radiation and high radiation areas to verify the results of licensee surveys in the radwaste and auxiliary buildings using a licensee portable radiation survey instrumen The inspector surveyed the boundaries of radiation areas in the auxiliary building and contaminated material storage facilities inside the licensee's protected areas using a Commission survey instrumen The inspector did not identify any discrepancies in the licensee's posted survey results or identify any areas that were improperly zoned or poste The inspector observed licensee employees moving contaminated clothing and trash through the facility and question the licensee employees on their responsibilities for transporting radioactive material No violations or-deviations were identifie. Solid Waste 10 CFR 20.311 requires a licensee who transfers radioactive waste to a land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.5 The inspector reviewed the licensee's solid radioactive waste management program and observed licensee employees compacting dry active waste and dewatering spent resi The inspector discussed with licensee employees the facilities and procedures for the solid waste processing program. The inspector reviewed the licensee's procedures for sampling and classifying radioactive waste streams and reviewed the classification documentation for two radioactive waste shipments observed during the inspectio The inspector reviewed licensee Station Directive 3.3.3, Radioactive Waste Management, revision dated October 9, 1986, and HP/O/B/1007/04, Operating Procedure for Contaminated Waste Compactor, Revision 8, dated July 26, 198 The inspector observed licensee employees compacting dry active waste (DAW)
in accordance with licensee procedure Health Physics provided continuous health physics coverage for the operatio The licensee was in the process of building a new radioactive waste sorting and compacting facility. The new facility will be adjacent to the interim radwaste building. The licensee plans to operate the new facility in 198 The facility will have a new sorting device to screen and monitor potentially contaminated tras The goal of the facility is to reduce the DAW compacted and shipped for buria The proposed facility and the equipment purchased to monitor and compact DAW represent a strong management commitment to reduce the total volume of radioactive waste shippe The inspector reviewed licensee Procedure CP/O/B/5400/10, Dewatering Procedure for CNSI 24-inch Diameter Vessels Containing Activated Carbon and Ion Exchange Resins, revision dated February 14, 1987. The inspector observed the operation of dewatering equipment for the process filters and discussed dewatering activities with licensee representative The licensee's waste classification program was developed by the licensee's corporate health physics staf The licensee's waste classification program is described in 10 CFR Part 61, Waste Classification and Waste Form Implementation Program Manua The manual includes the results of the current waste stream scaling factors and the sample results from which they were derived. The licensee has sampled and determined the scaling factors on an annual basis. The inspector reviewed
the waste classification documentation for the two radioactive waste shipments that were made during the inspection period and determined that the waste had been properly classified and met the waste characteristic requirements of 10 CFR 6 No violations or deviations were identifie. Transportation (86721)
10 CFR 71.5 requires that licensees who transport licensed material outside the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts 170 through 18 The inspector reviewed the shipping procedures for transporting radioactive material and radioactive waste, reviewed the preparation for shipment of two radioactive waste shipments, and the associated shipping papers for the two shipment The inspector reviewed licensee Procedures HP/0/B/1006/01, Procedure for Packaging and Shipment of Radioactive Materials, revision dated November 26, 1986, and HP/0/B/1006/01/A, Procedure for Packaging and Shipment of Radioactive Waste. The licensee's procedures refer the user to applicable sections of 49 CFR 172 and 173 and 10 CFR 7 The inspector verified that the licensee had a current copy of the regulations in the radioactive waste staff's working area for use with the licensee's procedure The inspector observed the preparations for two radioactive waste shipments one consisting of three liners of dewatered resin and one of compacted dry active waste (DAW)
in steel boxe The inspector observed the loading of the dewatered resin shipment. While reviewing the loading of a flat bed trailer of low level radioactive waste the inspector observed some confusion on behalf of the licensee employees assigned to secure the radioactive packages. The three packages of dewater resin each weighing approximately six tons were braced around each base with 2X4 inch wood blocks and strapped down to the bed utilizing the trailers straps and tightening devices. The way in which each strap was positioned around the packages was not consistent and some of the tightening devices were placed only a few inches above the vehicles tires. The driver of the vehicle, a radwaste vendor, recommended to the radwaste supervisor that the strap be repositioned and the tightening devices moved away from the wheels. The radwaste supervisor ensured that the drivers recommendations for securing the packages was complete The inspector determined that the crew assigned to secure the packages was not the normal crew utilize The inspector determined that the licensee's planning section supplied the personnel to support the radwaste loading activitie The inspector discussed the potential problems associated with an unsecured load of radioactive material on the highway with licensee representative Licensee representatives agreed to evaluate the training and
- qualifications of persons assigned bracing and securing responsibilities for radwaste shipment The inspector stated that the training and qualifications of persons assigned load securing responsibilities would be identified as an inspector followup item to be reviewed during a future inspection (50 269/87-42-05, 50-270/87-42-05, and 50-287/87-42-05).
The inspector made independent surveys of the packages and vehicles and verified that the radiation levels for both shipments packages and vehicles were within acceptable limits for the mode of transport and shipment classification; that the packages were properly labeled; and that the vehicles had been properly placarded prior to shipmen The inspector reviewed the associated shipping papers for the two shipments and verified that the shipping papers were prepared consistent with 49 CFR requirement No violations or deviations were identified.