ML16127A298
| ML16127A298 | |
| Person / Time | |
|---|---|
| Site: | Oconee, 07008902  |
| Issue date: | 02/17/1989 |
| From: | Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16127A296 | List: |
| References | |
| 50-269-89-02, 50-269-89-2, 50-270-89-02, 50-270-89-2, 50-287-89-02, 50-287-89-2, NUDOCS 8902270390 | |
| Download: ML16127A298 (10) | |
See also: IR 05000269/1989002
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101.MARIETTA ST., N.W.
ATLANTA, GEORGIA 30323
FEB 1 6 1989
Report Nos.:
50-269/89-02, 50-270/89-02, and 50-287/89-02
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.: 50-269, 50-270,
License Nos.: DPR-38, DPR-47, and
and 50-287
Facility Name:
Oconee 1, 2, and 3
Inspection Conducted: January 9-13, 1989
Inspector:
oe
.
h
r
R. B. Shortri dge
D-ate
ined
Approved by:
!ve l
eJ. P.' Potter, Chief/
Date SVgned
Facilities' Radiatio~i Protection Section
Emergency Preparedness and Radiological
Protection Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope: This routine, unannounced inspection was conducted in the areas of
occupational exposure,
shipping, transportation,
and followup on previous
inspector identified items.
Results:
The inspection coincided with the early start of a refueling outage
due to a fire in a reactor coolant pump switch gear panel in the turbine
building.
This placed a heavy demand on the health physics staff to support
the full scope of the outage activities without planned vendor support.
The
inspector observed health physics job coverage and initial refueling outage
activities and noted that the outage activities were supported by health
physics efficiently. During the inspection, personnel were not knowledgeable
of the dose rates while working in high radiation areas,
nor were they
monitoring their self-reading pocket dosimeters.
Additionally, the licensee
failed to label radiation hot spots on piping after the shielding was
installed. Within the scope of this inspection, one violation was identified:
-
Failure to adequately inform workers of radiation in a work area in the
Unit 1 reactor building.
.C 1PC
REPORT DETAILS
1. Persons Contacted
Licensee Employees
- S. Coy, General Supervisor Health Physics
- C. Harlin, Compliance Engineer
- E. LeGette, Shift Supervisor, Nuclear Compliance
- M. Thorne, General Supervisor, Health Physics
- M. Tuckman, Station Manager
Other licensee employees contacted during this inspection included
craftsmen,
engineers,
operators,
mechanics,
technicians,
and
administrative personnel.
Nuclear Regulatory Commission
- L. Wert, Resident Inspector.
O *Attended exit interview.
2. Occupational Exposure During Extended Outages (83750)
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 6.1-1.
The inspector reviewed the licensee's organization
staffing level and lines of authority as they relate to outage
radiation protection programs and verified that the licensee had not
made organizational changes which would adversely affect their
ability to implement critical elements of its radiation protection
program.
The station health physicist had a staff of 92 in support of the
radiological protection program at the station.
Twelve section
supervisors reported to three general supervisors.
Additionally,
there were three ALARA supervisors.
Six technical staff personnel
reported to the supervising scientist and four administrative clerks
reported to an administrative supervisor. The licensee stated that
54 of 62 health physics (HP)
technicians were ANSI/ANS 3.1 -
1978Property "ANSI code" (as page type) with input value "ANSI/ANS 3.1 -</br></br>1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.
qualified and that approximately 75 HP contract technicians were
currently in training to support the Unit 1 refueling outage.
The
scheduled outage date of January 28, 1989, was moved to January 11,
1989, when a fire occurred on January 10,
1989, in the 6,900 volt
switch gear for reactor coolant pumps, shutting Unit 1 down.
The
inspector noted that office supervisors and staff were assigned to
field operations, while additional support vendor personnel were in
2
training, and that necessary support for the outage was provided in a
smooth and efficient manner.
b.
Training and Qualification
The licensee is required by 10 CFR 19.12 to provide radiation
protection training to workers including contractors.
Regulatory
Guides 8.13, 8.27. and 8.29 outline topics that should be included in
such training.
(1) Steam Generator Mock up Training
The inspector observed a training session conducted by vendor
personnel on a mock up of the once through steam generator
(OTSG)
lower channel head.
The training consisted of the
installation and removal of robotics equipment utilized in the
testing and repair of OTSGs.
Installation and removal of the
robotics equipment required only partial entry of a person into
the high dose lower channel head area.
When installed, the
robotic arm was fitted with specific tool heads that perform
different operations,
such as,
eddy current testing or tube
plugging.
All manipulation of the assembly was controlled
remotely by computer located in a low dose area.
The licensee
stated that use of robotics on high dose jobs had resulted in
the savings of. hundreds of person-rem.
After successfully
completing the hands on training and a written examination, the
instructor certified the trainees as qualified to perform the
operation in plant.
(2) Contractor Health Physics Technician Training and Qualification
The inspector discussed training of contractor HP technicians
with licensee representatives and observed the licensee testing
of contractor
HP technicians that completed site-specific
training.
Contract HP technicians that have previously worked
at Oconee were allowed to challenge the test for general
employee training (GET)
and site-specific training.
For first
time HP technicians, the licensee required attendance at the
classroom sessions for both GET and site-specific training. The
site-specific training consisted of three days of classroom
instruction based on requirements in station directives, HP
operation procedures, system HP manual,
- training manual,
ALARA manual and hot particle training.
The
objective of the course was to enable HP technicians to perform
related duties during the refueling outage.
The course
incorporated eight case studies of industry radiological events
that covered diagnostics, changing radiological conditions, and
lessons learned.
The inspector reviewed lesson plans and noted
that enabling objectives. were adequately covered and were
measured by questions on the examination.
3
c. External Exposure Control
(1) Personnel Dosimetry
10 CFR 20.202 requires each licensee to supply
appropriate
personnel monitoring equipment to specific individuals and
requires the use of such equipment.
During plant tours of the Unit 1 Reactor Building (U1RB),
the
inspector observed that self-reading pocket dosimeters (SRPDs)
were frequently worn under protective clothing. This practice
increases the potential of personnel contamination.
The
inspector discussed this with licensee representatives and
informed them that a similar item, the placement of thermo
luminescent dosimetry.(TLDs) in protective clothing relative to
beta attenuation, had been previously identified as a problem by
the resident inspector.
Licensee representatives stated that
they would reevaluate the placement of SRPDs when several sets
of protective clothing were required.
The inspector informed
the licensee that this issue will be reviewed during subsequent
inspections and tracked by the NRC as IFI 50-269/89-02-01.
During tours of the facility, the inspector observed personnel
working in radiation areas and high radiation areas in U1RB that
were not reading their SRPDs.
The inspector informed licensee
representatives of this situation.
(2) Personnel Exposure Control
10 CFR 20.203 specifies posting and control requirements for
radiation areas, high radiation areas, airborne radioactivity
areas, radioactive material areas, and radioactive material. In
addition to the signs and labels. prescribed, the licensee may
provide on or near such signs and labels any additional
information which may be appropriate in aiding individuals to
minimize exposure to radiation or radioactive material.
10 CFR 19.12 requires that all individuals working in or
frequenting any portion of a restricted area shall be kept
informed of radiation in such portions of the restricted area
and shall be instructed in precautions or procedures to minimize
exposure.
TS 6.4.1 states that the station shall be operated and
maintained in accordance with approved personnel radiation
protection procedures.
HP Section Manual 4.2, Paragraph 3.2.2.2 states that if a hot
spot is shielded to levels below the hot spot limits, the hot
4
spot label shall be affixed to the shielding and state the
conditions under the shielding.
During a tour of the U1RB basement, the inspector observed that
numerous areas of the drain lines for the steam generator "J"
legs and letdown cooler lines were shielded with lead blankets.
The inspector noted that high radiation areas were properly
posted at the rope boundaries but hot spot labels had not been
posted on the shielded piping as required by HP Manual 4.2. The
inspector, accompanied by a licensee HP technician, performed
radiation surveys on the shielded "J" leg and letdown cooler
piping and found contact radiation levels on the shielding.
ranging from 350 mrem/hr to 5,000 mrem/hr. Radiation levels at
18 inches from different hot spot areas of the shielded pipe
ranged from 50 mrem/hr to 1,000 mrem/hr. The inspector informed
the licensee that failure to post hot spot labels on the piping
after shielding was installed prevented workers from knowing
radiation hazards present and was considered an apparent
violation of 10 CFR 19.12 requirements (50-269,270,287/89-02-01).
Over a two day period,
the inspector monitored licensee
personnel performing routine outage maintenance in the.U1RB
basement. The licensee stated that the entrance to the U1RB was
controlled as an high radiation area and was considered locked
or guarded when access was required to the area.
Positive
control over the many high radiation areas in the reactor
building was provided by requiring personnel to check in at the
HP office at the reactor building control point where area dose
rate information was provided.
Personnel were then instructed
to check in with the HP stationed on a specified level in the
reactor building before going to work. The inspector questioned
personnel that were observed moving through 'and working in
different high radiation .areas and determined that personnel
were not knowledgeable of dose rates in their work areas.
In
addition, personnel were not always checking in with HP as
required so HP could provide dose rate information for a
specific work area.
The inspector informed the licensee that
workers in high radiation areas were not observed to read their
SRPDs,
always check in with HP in containment,
were not
knowledgeable of dose rates in their work areas,
and that
workers were not adequately .informed of dose rates in areas with
radi.ation hot spots.
The inspector discussed the potential for
an unplanned exposure with licensee representatives and licensee
management,
and identified this as an exposure' control program
weakness. The inspector informed the licensee that the failure
to inform workers of radiation and precautions or procedures to
minimize exposure was a second example of an apparent violation
of 10 CFR 19.12 (50-269, 270, 287/89-02-01).
5
d. Internal.Exposure Control and Assessment
(1) Intake Assessment
establishes the limits for exposure of
individuals to concentrations of radioactive materials in air in
restricted areas.
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 areas and that appropriate bioassays be performed
to detect and assess intakes of radioactivity.
The inspector reviewed selected results of general in-plant air
samples taken during the refueling outage.
The inspector also
reviewed selected records of body burden analyses.
No
discrepancies were observed.
(2) Respiratory Protection
Previous inspections identified problems with the breathing air
(BA) system.
The inspector reviewed the licensees operations
procedures for the BA system and noted that the licensee had not
updated drawings to reflect the as-built conditions for. BA
The licensee stated that current
plans are to update plant drawings by June 30,
1989. During
tours in U1RB, the inspector observed workers using air supplied
hoods fed from the plant BA systems.
footnote h states, in part, that a protection factor of 2,000
may be taken when using tested and certified supplied-air hoods
when a minimum air flow rate is greater than 6 cubic feet per
minute and calibrated flow measuring devices are used.
The
inspector reviewed the calibration data for the BA system and
found that the gauges had not been calibrated.
The licensee
provided the inspector with a copy of Nuclear Station Work
Request 57258E, that requested BA instrumentation be calibrated
at the beginning of each outage. The licensee also stated that
the calibration of the BA gauges was in progress and that the
work request would be revised to reflect that BA system
instrumentation calibration would be performed prior to the
first use at the beginning of each refueling outage.
The
inspector verified that .the BA pressure gauges were calibrated
prior to completing the inspection.
(3) Engineering Controls
10 CFR 20.103(b)(1) requires that the licensee use process or
other engineering controls to the extent practicable to limit
concentrations of radioactive materials in air to levels below
those which delineate an airborne radioactivity area as defined
6
During plant tours, the inspector observed various engineering
controls to limit the concentrations of airborne radioactive
material.
These included temporary ventilation systems equipped
with high efficiency
particulate filters, containment
enclosures, and air supplied respirators. Selected records were
reviewed by the inspector to ensure that personnel wearing
respirators were medically qualified and had been fit tested.
e. Control of Radioactive Materials and Contamination,
Surveys. and
Monitoring
(1) Surveys
The licensee was required by 10 CFR 20.201(b)
and 20.401 to
perform surveys and to maintain records of such surveys
necessary to show compliance with regulatory limits.
During.tours of. the auxiliary building and U1RB,
the inspector
performed radiation and contamination surveys and compared the
results with surveys performed
by
the .licensee.
No
discrepancies were noted. The inspector also examined licensee
radiation protection
instrumentation
and verified that
instruments were-in current calibration.
(2) Caution Signs, Labels and Controls
10 CFR 20.203(f) requires each container of licensed radioactive
material to bear a durable, clearly visible label identifying
the contents when quantities of radioactive material exceeded
those specified in Appendix C.
During plant and restricted area yard tours, the inspector
verified containers of radioactive material
were properly
labeled when required.
(3) Area and Personnel Contamination
The inspector reviewed records of skin contamination occurrences
for 1988.
The licensee identified 266 skin and clothing
contaminations.
The inspector noted that the analysis and
trending of personnel contamination events were not resulting in
recommendations for correcting problems.
The investigation of
events did not always identify the root cause and the categories
for cause of the event were
too general.
Licensee
representatives stated that the process for analysis and
trending of personnel contamination events was currently being
revised.
The inspector informed the licensee that this issue
will be reviewed during subsequent inspections and tracked by
the NRC as an inspector followup item (IFI 50-269/89-02-02).
7
The licensee maintains approximately 107,750 square feet (ft
2 )
of. the auxiliary building as controllable for decontamination
purposes.
The goal for 1988 was to .attain 90% of the radio
logically controlled areas as clean.
By December 1988, 93%
of controllable area was maintained as clean.
The licensee
stated that, adequate resources for decontamination, material
condition of the plant, and maintenance and managements support,
were the major contributors to their aggressive decontamination
program in 1988.
f. Program for Maintaining Exposures As Low As Reasonably Achievable
(ALARA)
(1) ALARA Program
10 CFR 20.1(c) states that persons engaged in activities under
licenses issued by the NRC should make every reasonable effort
to maintain radiation exposure ALARA. The recommended elements
of an ALARA program were contained in Regulatory Guides 8.8,
Information Relevant to Ensuring That Occupational Radiation .
Exposure at Nuclear Power Stations will be ALARA,
and 8.10,
Operating Philosophy for Maintaining Occupation Radiation
Exposure ALARA.
The inspector discussed the ALARA program with licensee
representatives.
In 1988, the station's collective dose goal
for three units was 1,000 person-rem.
This was reestablished
from the 1,100 person-rem goal by the station manager.
With
completion of refueling outages for Units 2 and 3, the
collective dose for 1988 was 877.8 person-rem.
Personnel from
the ALARA group stated that steam generator maintenance and
in-service-inspection would be the major dose contributors for
the current Unit 1 outage and that the collective outage dose
goal was established at 251 person-rem. ALARA personnel stated
that management support for the ALARA program, use of mockups in
training, and maintenance planning had been a major part in
keeping the station's collective annual dose at or below the
national average for pressurized water reactors.
Also that
station management had recently required each support group to
be responsible for the planning and use of their allotment of
annual collective dose. The inspector noted that management was
kept informed of progress toward the annual dose goal by
information formated by the ALARA group to show each support
group's performance against their dose goal on a weekly basis.
g. Solid Waste
Licensee representatives stated that approximately 25,581 cubic feet
of solid waste containing 14,172 curies had been shipped, in 93
shipments, to a disposal facility in 1988. The relatively high curie
8
total for 1988 was attributed to shipping process resins and
irradiated components from the spent fuel pool.
h.
Transportation
10 CFR 71.5 requires that a licensee who transports radioactive
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 regulation's
appropriate to the mode of transport of the Department of
Transportation in 49 CFR Parts 170 through 189.
The inspector reviewed selected records of radioactive waste and
material shipments performed during 1988.
The shipping manifests
examined were prepared consistent with .49 CFR requirements.
The
radiation and contamination survey results were within the limits
specified for the mode of transport and shipment classification. The
inspector reviewed the licensee's calculations of composition of
nuclides and verified that the shipments
had been properly
classified.
3. Action on Previous Inspection Findings (92701)
a. (Closed) Inspector Followup Item (IFI) 50-269/88-27-01: Followup on
licensee criteria for contents of vendor retraining program for
contract HP technicians.
The inspector discussed this
issue with licensee representatives and
verified that HP Section Manual 3.6 was changed to require
site-specific training for each HP vendor who had not worked at
Oconee for a period of one year.
The change also required vendor
retraining. The change was approved on November 3, 1988. This item
is considered closed.
(b) (Closed) IFI 50-269/88-27-02:
Follow up on licensee's procedures and
requirements for determining the operability of off-scale
self-reading pocket dosimeter.
The inspector discussed the issue with license representatives and
verified that HP procedure 0/B/1000/59,
Personal Dosimetry,
was
.
reviewed to requi-re documenting all offscale, abnormal,
and lost
dosimetry. This item is considered closed.
4. Followup on Information Notices (92717.)
The inspector determined that the following Information Notices (INs)
had
been received by the licensee, reviewed for applicability, distributed to
appropriate personnel, and that action, as required/appropriate, was taken
or scheduled.
9
o IN 87-31: Blocking, Bracing, and Securing of Radioactive Materials
Packages in Transportation'.
o
Control of Hot Particle Contamination at Nuclear Power
SPlants.
o
Prompt Reporting to NRC of Significant Incidents Involving
Radioactive Material.
o
IN 88-62:. Recent Findings Concerning Implementation of Quality
Assurance Programs by Suppliers of Transport Packages.
o
High Radiation Hazards from Irradiated Incore.Detectors and
Cables.
5. Exit Interview
The inspection scope and findings were summarized on January 13,
1989,
with those persons indicated in Paragraph 1. The inspector described the
areas examined and discussed in detail the inspection findings listed
below and the weakness observed in the exposure control program.
The
licensee did not identify as proprietary any of the materials provided to
or received by the inspector during this inspection.
The licensee was
informed that .the items discussed in Paragraph 3 were considered closed.
Item Number
Description and Reference
50-269, 270, 287/89-02-01
Violation - failure to relabel
radiation hot spots on pipihg
that
had
been
shielded
(Paragraph 2.c(2)).
50-269, 270,
Violation (second example)
failure to inform workers
of radiation and instruct
them in precautions and pro
cedures to minimize exposure
(Paragraph 2.c(2)).
50-269/89-01-01
IFI - positioning of SRPDs on
inside
layers
of protective
clothing (Paragraph 2.c(1)).
50-269/89-02-02
IFI -
Establish trending and
analysis of personnel contamination
reports (Paragraph 2.e(3)).