IR 05000269/1991024
| ML16148A550 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 09/12/1991 |
| From: | Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16148A549 | List: |
| References | |
| 50-269-91-24, 50-270-91-24, 50-287-91-24, NUDOCS 9109240276 | |
| Download: ML16148A550 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 SEP 1 3 V1 Report Nos.: 50-269/91-24, 50-210/91-24, and 50-287/91-24 Licensee:
Duke Power Company 422 South Church Street Charlotte, N. C. 28242 Docket Nos.:
50-269, 50-270 License Nos.:
DPR-38, DPR-47, and 50-287 and DPR-55 Facility Name: Oconee 1, 2, and 3 Inspection Conducted: August 26-30, 1991 Inspector:
,
R. B. Shortridge D te Signed Accompanied by:
John P. Potter Approved by:
J. P. Potter, Chief
/Date Signed Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of occupational exposure during extended outages and followup on enforcement issue Results:
Based on observation of work in the Auxiliary and Containment Buildings, records review, and interviews with plant personnel, the radiation protection program continues to be effective in protecting the health and safety of the workers. A strength was noted in the timeliness of obtaining design changes to support dose reduction. Two apparent violations were identified and corrected during the inspection therefore they were not cited. One was failure to post an airborne radioactivity area and the second involved the failure of vendor personnel to comply with radiological postings (see Paragraph 2.c).
9109240276 910913 PDR ADOCK 05000269
REPORT DETAILS 1. Persons Contacted Licensee Employees
- A. Barron, Station Manager
- T. Curtis, Manager, Compliance
- Davis, Superintendent, Technical Services
- B. Dolan, Manager, Onsite Design
- W. Gibson, Supervisor, Quality Assurance
- B. Milsaps, Manager, Maintenance Engineering
- S. Perry, Technical Assistant, Compliance
- C. Yongue,.Manager, Radiation Protection Other licensee employees contacted during this inspection included technicians, maintenance personnel, and office personne Nuclear Regulatory Commission
- K. Poertner, Resident Inspector
- Attended exit interview 2. Occupational Exposure During Extended Outages a. Organization and Management Controls The licensee is required by Technical Specification (TS) 6.1.1.3 to implement the minimum operating shift requirements specified in Table 6.1-Responsibilities, authorities, and other management controls were further outlined in Chapters 12 and 13 of the Final Safety Analysis Report (FSAR).
The inspector reviewed the staffing levels and lines of authority as they relate to the radiation protection (RP)
program and discussed the organization with the Radiation Protection Manager. The inspector verified that the licensee had not made organizational changes that would adversely affect their ability to implement critical elements of the RP progra b. External Exposure Controls and Personnel Dosimetary TS 6.4.1 requires the licensee to have written procedures, including the use of radiation work permits (RWPs).
The FSAR also contains commitments regarding dosimetry and dose contro The inspector reviewed selected RWPs for appropriateness of the RP requirements based on on work scope, location, and condition During the observation of work in the plant, the inspector noted that personnel wore either self reading dosimeters with thermoluminescent dosimeters (TLDs) or electronic reading digital dosimeters and TLDs depending on the amount of dose control require The inspector discussed the assignment and use of dosimeters with workers, RP technicians, and RP supervisor During tours of the radiologically controlled areas (RCA) of the plant, the inspector made independent radiation measurements to verify licensee barricade postings and information contained on posted radiation survey maps. The inspector did not note any weaknesses in the use of dosimetry, the control of personnel exposure, or licensee radiation posting The inspector observed the use of a yellow flashing light in the Unit 1 containment to denote very high radiation areas (greater than 1,000 millirem per hour at 18 inches). A 55 gallon drum, located on the lower level of containment used for collection of radioactive waste, was not locke The lead lined drum had radiation levels of 10 Rem per hour inside and 350 millirem per hour contact on the outsid The inspector reviewed Information Notice (IN) 88-79; Misuse of Flashing Lights for High Radiation Controls (issued October 1988) for applicabilit Although the top of the drum was not locked or mechanically restrained as required by procedure, the weight of the lead lined lid would prevent inadvertent entry. The licensee took immediate action to install the drum restraining ring and also installed a chain and lock on the drum/lid to ensure the contents were secure in the event of turning over or attempted unauthorized entr C. Control of Radioactive Material and Contamination, Surveys, and Monitoring 10 CFR 20.203 specifies posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactivity areas, and radioactive material TS 6.4.1 requires that the station be operated and maintained in accordance with approval procedure Oconee Nuclear Station Directive 3.3.4, dated May 28, 1991, requires that personnel entering an RCA or radiologically controlled zone (RCZ)
are required to read and comply with all radiation warning sign In addition, General Employee Training (GET) instructs individuals on the failure and consequences to comply with posted radiological requirement During tours of the Unit 1 containment made over a three day period, the inspector observed vendor personnel disregarding radiological requirements in two areas on the refuel floo The licensee established tool staging and laydown areas above A and B Reactor
Coolant Pump Cavities and posted each as "contaminated area" and
"notify HP prior to entry."
The inspector observed that barricades and the postings were down at each entry point to the areas. After discussing this with roving health physics (HP)
technicians the barriers were placed across the entry point for each are Over the next several days the inspector noted that vendor personnel routinely left the barricades down and exited the areas without performing any action to minimize the spread of contaminatio After discussing these events with HP supervisors, the inspector was told that the areas were established to facilitate the vendor and were not contaminated to levels above the rest of the Unit 1 Containment Building. The licensee then removed the "contaminated area" inserts from the posting On the succeeding day the inspector noted that the.barriers were once again down and informed HP supervision that the action to "notify HP prior to entry," was a radiological procedure requirement and that vendor personnel still were not maintaining the barrier and complying with the required action. HP supervision took the corrective action to dismantle radiological controls at each area. In addition, the licensee instructed vendor management and supervision on the,necessity of following RP requirement The inspector informed the licensee that the failure of vendor personnel to comply with radiological procedures was an apparent violation of TS 6.4.1 and Station Directive 3. However, since the non-compliance was low in safety significance and the licensee corrected the root cause of the problems during the inspection, this will be considered a non-cited violation (NCV) (NCV-91-24-01).
HP Section Manual 4.2, step 3.4.1, requires that areas with airborne concentrations of radioactive materials greater than 25 percent of maximum permissible concentration or areas with this potential (normally due to work being performed in the area) shall be posted as Airborne Radioactivity Area HP Section Manual Section 4.2, step 3.4.3, requires that for areas posted as Airborne Radioactivity Areas shall also be posted to
"Notify HP prior to entry."
The inspector noted that during removal of position indicator tubes (RWP 1674) on the reactor vessel head, that personnel were required to wear full face respirators but the area was not. posted as an airborne radioactivity are In addition, an area established for the decontamination of the equipment used to perform ultrasonic testing of the reactor vessel was posted incorrectl While the area was posted as an Airborne Radioactivity Area, HP failed to required that HP be notified prior to entry. The inspector pointed out these non-compliances to containment HP personnel and both discrepancies were corrected immediatel The inspector informed the licensee that the failure to correctly post Airborne Radioactivity Areas was an apparent violation of TS 6.4.1 and HP Manual Section 4.2,
steps 3.4.1 and 3. However, since the non-compliance was low in safety significance (workers were wearing respirators, no unauthorized entry was made),
and the licensee corrected the problem during the inspection, this will be considered a NCV (NCV 91-24-02).
The licensee continues to maintain approximately 94 percent of the RCA as clean and has experienced 197 personnel contamination events (PCEs) to dat d. Maintaining Exposure As Low As Reasonably Achievable (ALARA)
10 CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain exposures ALAR The recommended elements of an ALARA program are contained in Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures ALAR The inspector reviewed the licensee's program to maintain exposure ALARA and found the program continues to be an aggressive element in the radiation protection program. The licensee has been proactive in reducing collective dose through modifications and design changes and has been able to approve major changes to reduce dose in a short time perio The inspector reviewed this process in some depth and found that the ALARA program benefited from other plant programs in place to maintain reliability of plant component Maintenance Engineering, a group of approximately 40 electrical and mechanical engineers stationed at the plant, perform failure analysis for plant component When replacement is identified through trending, the group performs an ALARA review if the component is in the RCA. The Manager of Maintenance Engineering stated that exempt changes also speed the process for approving component replacements. Maintenance Engineering has established a listing of substitute components for frequently replaced component The Manager of Maintenance Engineering stated that they have averaged 600-700 exempt changes per yea Currently the licensee has approved a major modification for replacement of the reactor vessel cavity drain lines in the Unit 2 containment basement (a major source of high radiation).
The inspector noted that the modification was generic for Units 1 and 3 als The ALARA group has instituted a new method to create ALARA awareness and acknowledge personnel for exceptional performance in dose reductio The ALARA group posts ALARA messages on the station's extensive computer network for recognition of, and to inform, station personnel of challenges to overcome regarding special projects as well as other information regarding exposure reduction. The licensee considers this new innovation an integral part of their program to keep station personnel well informed of work scope and create ALARA awarenes Through August 27, 1991, the licensee was projected to have 185 person-rem but was actually at 124.5 person-rem. The collective dose goal for 1991 with two refueling maintenance outages is less than 462 person-re Two NCVs were identifie. Licensee Actions on Previously Identified Inspection Findings (92701)
(Closed)
VIO 50-269, 270, 289/91-0-01, Failure to control radioactive materia A previous inspection identified that radioactive material was found outside the restricted area of the plan To correct the problem the licensee developed and distributed a communications package to plant personnel on their responsibility to ensure that tools and equipment are surveyed prior to their return to the tool roo Information on the violation and proper methods of returning radioactive equipment was and will be presented in GET.through May 25, 199 Information on the violation was added to the mechanical orientation lesson plan No. MM-C-MOT-00 HP increased surveys outside of the restricted area of the plant. This action was placed on the Project 2 computer progra This item is considered close. Exit Meeting The inspector and the Facilities Radiation Protection Section Chief met with licensee representatives (denoted in Paragraph 1) on August 30, 199 The inspector summarized the scope and findings of the inspection and discussed in detail the items listed below. Dissenting comments were not received from the license Proprietary information is not contained in this repor Item Number Description and Reference 50-269, 270, 287/91-24-01 NCV - Failure of vendor personnel to comply with radiological postings (Paragraph 2.c).
50-269, 270, 287/91-24-02 NCV - Failure to correctly post airborne radioactivity areas (Paragraph 2.c).