ML16148A761
| ML16148A761 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 03/25/1993 |
| From: | Pharr E, Rankin W, Shortidge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16148A757 | List: |
| References | |
| 50-269-93-07, 50-269-93-7, 50-270-93-07, 50-270-93-7, 50-287-93-07, 50-287-93-7, NUDOCS 9304130163 | |
| Download: ML16148A761 (11) | |
See also: IR 05000269/1993007
Text
010A REGI
UNITED STATES
o
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W;
ATLANTA, GEORGIA 30323
APR
2 1993
Report Nos.:
50-269/93-07, 50-270/93-07, and 50-287/93-07
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.: 50-269, 50-270, 50-287
License Nos.:
Facility Name:
Oconee 1, 2, and 3
Inspection Conducted: March 1-5, 1993
Inspectors:
.
/
T
R. B. Sh rtri ge
Date Sig
E. B. Ph r
Dat Sited
Approved By .
L
CA
-5
W. H. Rankin, Chief
D te Si ned
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 area of occupational
radiation safety and included a review of the program elements of organization
and management controls, training and qualification, audits and appraisals,
external exposure control, internal exposure control, control of radioactive
material, surveys and monitoring, and the program to maintain personnel
collective dose as low as reasonably achievable (ALARA). The inspector also
reviewed previously identified items tracked by the NRC for possible closure.
Results:
The inspector found the radiation protection (RP) program at Oconee to be
adequate in protecting the health and.safety of the public and plant
employees. The licensee's program to maintain collective dose as low as
reasonably achievable (ALARA) continues to be a strength. However, during the
inspection apparent violations of NRC regulations were noted. One apparent
violation was for failure to post a radioactive materials area and a
contaminated area in accordance with procedures. The second apparent
violation was for failure to label radioactive material in the radiologically
controlled area (RCA) of the plant in accordance with;10 CFR 20.1904(a)
9304130163 930402
ADOCK 05000269
0
requirements and licensee procedures, with four examples identified. Lastly,
the inspection identified a concern that the program to followup correct self
identified radiological deficiencies was not assuring timely corrective
actions in some issues. This inspection identified that under the Problem
Investigation Process (PIP), radiological deficiencies received a low priority
for correction and many were not corrected in a timely manner. At the time of
the onsite inspection, a large number of PIP deficiencies did not have
corrective actions assigned. This issue will be tracked by the NRC as. an
Inspector Followup Item (IFI).
Both violations identified in this report were preceded by similar violations
within the last two years.
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- B. Baron, Plant Manager
- T. Patterson, Compliance Engineer, Regulatory Compliance
- C. Yongue, Manager, Radiation Protection
Other licensee employees contacted during the inspection included
craftsmen, technicians, and administrative personnel.
Nuclear Regulatory Commission
- B. Desai, Resident Inspector
- P. Harmon, Senior Resident Inspector
- Attended Exit Interview conducted on March 5, 1993
2.
Organization and Management Controls (83750)
The licensee is required by Technical Specification (TS) 6.1.1.1 to
establish clear lines of authority, responsibility, and communication
from the highest management levels through intermediate levels including
the operating organization. The inspector reviewed staffing levels and
lines of authority as they related to the Radiation Protection (RP)
program and discussed the organization with the RP Manager. The
inspector verified that the licensee had not made changes that would
adversely affect their ability to implement critical elements of the RP
program.
No violations or deviations were identified.
3.
Audits and Appraisals (83750)
The inspector reviewed the licensee's program for self-identification
and correction of program inadequacies and weaknesses. The inspector
noted that at the time of the onsite inspection the licensee had
initiated 47 Problem Investigation Process Reports (PIPRs) since
January 1, 1992. The inspector noted that this process was used by all
work groups to identify and investigate plant-related problems. The
inspector noted that the PIPRs identified procedural inadequacies, non
ALARA components/areas and work practices,.zand lost, drifting, and/or
offscale dosimetry. Following review of the 47 PIPRs identified since
January 1, 1992, the inspector noted that 23 remained open and forJ17of
those remaining open corrective actions had not been proposed
The inspector also noted problems in the followup and closure of a PIPR
involving a problem with control of radioactive sources. The PIPR
(identified on April 21, 1992) which documented the loss of two sources
-had proposed appropriate corrective actions to maintain future-control
of radioactive sources. However, at the time of the onsite inspection
the PIPR remained open, awaiting the concurrence and approval of the
3
final PIPR reviewer. Following discussions with the individual to whom
the PIPR was assigned for resolution, the inspector noted that there was
confusion as to who was actually responsible for final PIPR review and
closure. Therefore, the PIPR remained open although all corrective
actions had been successfully implemented. The inspector also noted
that as early as November 13, 1991 a problem with mislocation of sources
was identified and during a Quality Assurance (QA) audit, NG-92-03 (ON),
conducted January 6-20, 1992, the auditors recommended that procedural
guidelines be established to assure positive control of radioactive
sources during temporary movements. No action was planned however,
since no sources had .been lost at the time of the QA audit.
Another PIPR documented problems encountered while sluicing a
Purification Demineralizer on November 22, 1992. During discussions
with licensee representatives, the inspector noted that this sluicing
process usually expended approximately 100 millirem (mrem) of exposure
but due to an inadequate procedure which did not reflect recent
modifications to the system the process instead expended 870 mrem.
During discussions with licensee personnel which were assigned
resolution of the PIPR, the inspector was informed that lack of
resources and higher priority items had delayed procedural revisions
which were the proposed corrective actions.
The inspector reviewed procedural guidance as documented in the Oconee
Nuclear Site Directive 4.2.1, Problem Investigation Process (PIP), dated
February 11, 1993. The directive provided a mechanism in which to
identify, document, and respond to PIPRs with a level of effort and
timeliness commensurate with their significance. The directive stated
that for less significant events the responsible individual assigned to
propose a resolution to the PIPR must establish a corrective action due
date within 90 days of the discovery date, or at management's
discretion. Additionally, once all planned corrective actions were
completed or had received a work request/order number, an approver was
required to sign a final and overall approval for these less significant
events within 90 days, or at management's discretion. Following
discussions with licensee management, the inspector was informed.that
for all the radiologically-related PIPRs reviewed by the inspector,
most were placed in a low priority category for followup. Therefore,
these did not require proposed or implemented corrective actions within
90 days of the discovery date if management felt that higher priority
items should be resolved instead.
The inspector noted that this was the third inspection in a year that
had identified concerns regarding licensee followup on the
el
identification of radiological deficiencies. Inspection Report
(IR) 92-06, dated March 6, 1992, reported that Radiological Work
Practice Deficiency Reports (RWPDRs) .findings were substantive but so
few were written that trending was not possible., Four of seventeen
RWPDRs did not have any root cause listed. Root cause determination was
normally a result of the investigative process. In four of the RWPDRs,
two had late notices sent on two different occasions to department
managers for failure to list a corrective action and two more had late
4
notices sent three times for the same reason. IR 92-06 characterized
the problem as the failure of plant management to be aggressive in
following up on the resolution of radiological deficiencies. IR 92-17,
dated November 20, 1992, reported on a new system of Radiological
Deficiency Reports (RDRs) that was replaced mid year by PIPRs. The
inspector found that 15 PIPRs had been written during the months from
April to November 1992, and included a general range of radiological
performance problems. However, nine of the 15 had not been corrected at
the time of the inspection.
During the onsite inspection, the inspector informed licensee
representatives that corrective actions for licensee identified problems
did not always appear to be timely and that the recurrence of these
problems was a concern. This issue will be tracked by the NRC as an
Inspector Followup Item (IFI) 50-269, 270, and 287/93-07-03 and reviewed
during a future inspection.
No violations or deviations were identified.
4.
Training and Qualifications (83750)
10 CFR 19.12 requires, in part, that the licensee instruct.all
individuals working in or frequenting any portions of a restricted area
in the health protection aspects associated with exposure to radioactive
material or radiation; in precautions or procedures to minimize
exposure; in the purpose and function of protection.devices employed; in
the applicable provisions of the Commission regulations; in the
individual's responsibilities; and in the availability of radiation
exposure data.
The inspector reviewed training provided to licensee employees in
preparation for the licensee's change on January 1, 1993, to the revised
10 CFR Part 20 requirements. During discussions with licensee
personnel, the inspector was informed that prior to implementation the
licensee provided a general training overview to introduce employees to
the new terminology and exposure limits of the revised regulations. The
inspector reviewed the training outlines and accompanying training
videos and noted that the new limits and terms were appropriately
presented to licensee employees and offered a generalized overview of
how the revised regulations would affect day to day plant activities,
i.e. postings, decreased respirator usage, and the declared pregnant
female policy. The training also introduced workers to the resulting
changes with the Electronic Dose Capture (EDC) system and its
interaction with the digital alarmii g dosimeters.- The inspector noted
that the training appropriately addiessed the licensee's new TLDs, the
purpose of the EDC system, how to access the system, the basis for the
alarming dosimeter's alarm setpoints, the different alarms,-and the
correct response to each alarm. The training also stressed the worker's
responsibility for knowing Radiation Work Permit'(RWP) requirements,
dose rates in the work area, and for periodically checking the
cumulative dose on the alarming dosimeter.
The inspector informed licensee representatives that this training
appeared to be appropriate for introducing workers to changes in
terminology and plant activities due to the revised 10 CFR Part 20
regulations. The inspector also noted that the training appropriately
made workers aware of their continued responsibility to be knowledgeable
of RWP requirements, dose rates, and cumulative dose when utilizing the
licensee's new dosimetry system and not to become complacent with the
added exposure limiting features of the new system.
No violations or deviations were identified.
5.
External Exposure Controls (83750)
10 CFR 20.1601(a)(3) requires the licensee to ensure that.each entrance
or access point to a high radiation area has entryways that are locked,
except during periods when access to the areas is required, with
positive control over each individual entry.
The inspector performed radiation surveys to confirm selected radiation
and high radiation areas were posted in accordance with licensee
procedures. The inspector did not note any deficiencies. The inspector
reviewed the licensee's methodfor locking several high radiation areas
with dose rates greater than 1 Rem/Hour measured at 30 centimeters. The
inspector toured the High Pressure Safety Injection (HPSI) and Low
Pressure Safety Injection (LPSI) pump rooms and noted that the licensee
had placed a bar that facilitated locking, across the entryway to the
pump room, to prevent inadvertent entry to the high radiation areas.
Infrequent access to the pump room is necessary to permit operation of
valves primarily for resin transfers during which rad levels up to 30
Rem/hr may occur for short periods. The inspector observed that the
lockable bar, when employed in conjunction with the numerous pipe runs
through the access area, effectively controlled access in a positive
manner against inadvertent entry. An individual would have to climb
over these positive access controls at considerable effort to defeat the
access controls. As an additional measure to warn personnel not to
enter the area the licensee placed a large high radiation area sign on
the lockable bar at the entry point. The inspector obtained pictures of
the area before and after placement of the sign on the bar and discussed
with the licensee the proposed method of control,. Based on the
discussions and a review of the pictures, the licensee's locks, signs,
and barriers, the inspector determined that the licensee's efforts to
warn personnel of the radiations hazards in the area were reasonable and
appropriate to preclude inadvertent entry.
No violations or deviations were noted.
6.
Internal Exposure Controls (83750)
10 CFR 20.1204 statesthat for purposes of assessing dose used to
determine compliance with occupational dose equivalent limits,;the
licensee, when required to monitor internal exposure, shall take
suitable and timely measurements of concentrations of radioactive
6
materials in air, quantities of radionuclides in the body, quantities of
radionuclides excreted from the body, or combinations of these
measurements. When specific information on the.behavior of the material
in an individual is known that information may be used to calculate the
Committed Effective Dose Equivalent (CEDE).
The inspector reviewed internal exposure records for selected
individuals associated with a power entry into the Unit 3 Containment
Building on January 20 and 21, 1993. The inspector noted that for the
selected individuals reviewed none had worn respirators during the
entries and based on air sample data, Derived Air Concentration-hours
(DAC-hrs) were not assigned.' During discussions with licensee
representatives, the inspector was informed that followup body burden
analyses (BBAs) were performed and iodine-131, -133 activity was
detected. The inspector noted that based on a maximum iodine activity
of 17.3 nanocuries (nCi) from a BBA performed approximately 50 minutes
after the uptake, DAC-hrs assigned to the individual resulted in a CEDE
of less than 1 mrem. The inspector verified that no exposures in excess
of the 2000 DAC-hr annual control measure had occurred since January 1,
1993.
No violations or deviations were identified.
7.
Control of Radioactive Materials and Contamination, Surveys, and
Monitoring (83750)
10 CFR 20.1902(e) requires posting areas or rooms in which licensed
material is used or stored. The licensee shall post each area or room
in which there is used or stored an amount of licensed material
exceeding 10 times the quantity of material specified in Appendix C to'
10 CFR 20.1001-20.2401 with a conspicuous sign bearing the radiation
symbol and the words "Caution, Radioactive Material," or "Danger,
Radioactive Material."
TS 6.4.1 requires that the station be operated and maintained in
accordance with approved procedures.
Radiation Protection Section Manual, Section 4.2, Posting of
Radiologically Controlled Areas (RCAs) and Materials, dated January 1,
1993, requires in step 3.2.4.1 that all radiologically controlled zones
(RCZs) outside of the RCA where radioactive materials are located/stored
be posted as a Radioactive Material Area.
Oconee Procedure, HP/O/B/1000/07, Procedure for Roping Off, Barricading,
Posting and Controlling Radiation Protection Control Zones, Revision 23,
dated January 1, 1993, requires in step 4.1.6 to establish a
contaminated area when removable contamination levels exceed
1,000 disintegrations per minute per 100 centimeters square
(1,000 dpm/100 cm2) beta-gamma or 20 dpm/100 cm, alpha in any area.
7
During routine tours of the Auxiliary and Radwaste Buildings, the
inspector noted several areas that were not posted in accordance with
licensee procedures. Radwaste Valve Room #325,.a contractor storage
area, had a posting on the door that no source of radioactive material
was in the room. The inspector found a contaminated vacuum cleaner
stored in the room that was labeled 8,000 counts per minute at one-half
inch. The suction nozzle was noted to be open to' the atmosphere. The
inspector notified RP and a technician promptly posted the room as a
radioactive materials area.
Additionally,.the inspector performed random contamination surveys
during routine fours. The inspector found an area in the health physics
(HP) laboratory that had loose surface contamination of
3,000 disintegrations per minute (dpm)/smear. The smear was from the
collar surrounding a sink drain. Again RP was notified and the area was
posted as a contaminated area. The licensee was informed that the
failure to post the radioactive materials area and the contaminated area
in accordance with the referenced procedures was an apparent violation
of 10 CFR 20.1902(e) and licensee procedures.
10 CFR 20.1904(a) requires the licensee to ensure that each container of
licensed material bear a durable, clearly visible label bearing the
radiation symbol and the words "Caution, Radioactive Material," or
"Danger, Radioactive Material." The label must also provide sufficient
information (such as radionuclides present, an estimate of the quantity
of radioactivity, the kinds of materials, and mass enrichment) to permit
individuals handling or using the containers or working in the vicinity
of the containers, to take precautions to avoid or minimize exposures.
Radiation Protection Section Manual, Section 5.1, Movement of
Radioactive Materials Within the Controlled Area, dated January 1, 1993,
step 3.1.2.1, requires that all radioactive materials (except tools from
the hot tool crib or satellite storage contaihers and hand held items)
within the Radiologically Controlled Area (RCA) shall be: 1) surveyed;
2) containerized as appropriate for contamination control; and
3) labeled per reference 2.4 (Posting of RCAs and Materials) or attended
by an individual who takes precautions to prevent exposure of any
individual to radiation or radioactive materials in excess of limits
established by 10 CFR Part 20 until the material is either stored.per
step 3.1.5, or placed into a RCZ for maintenance, testing, etc. per
reference 2.4, or properly disposed of per reference 2.7.
During tours of the RCA, the inspector :noted that there were items with
radioactivity that were not labeled as prescribed-by the above
procedure. A high volume air sampler, #H809-6199, was reading
100,000 counts per minute (cpm) as measured by a RM-14 with a HP-210
probe. The air sampler was stored in a radioactive materials storage
bin with other contaminated air samplers that had attached radioactive
material labels. The inspector requested a RP technician to survey the
air sampler and label it properly. During tours the following day, the
inspector noted the same air sampler (#H809-6199) was in the same area
but had not been labeled as requested the previous day. The inspector
8
located a different RP technician and requested the air sampler be
surveyed and labeled. The second technician properly surveyed and
labeled the item. The inspector requested a RP-supervisor to perform a
test on several high.volume air samplers with very high contamination
levels by sampling the exhaust to determine if the contamination was
loose. This was done and the results indicated that the contamination
was not loose or free to be dispersed in the exhaust.
The inspector also noted that seven stanchions were staged outside the
Unit 3 RP office. The stanchions were used for supporting barriers for
RCAs. One was appropriately labeled, however, three were found to have
fixed contamination levels greater than 10,000 dpm as measured by a RM
14 and HP-210 probe. In addition, a mop bucket reading 10,000 dpm and
an electrical extension cord reading 35,000 dpm were also located in the
clean area of the Auxiliary Building. -Both were noted to have fixed
contamination and were not labeled. The inspector notified RP of the
items and all were promptly surveyed and properly labeled. The
inspector informed the licensee that the failure to label these items in
accordance with requirements was an apparent violation of
10 CFR 20.1904(a) and licensee procedures.
The inspector informed the licensee that the above events were repeats
of previous violations. IR 91-24, dated September 13, 1991, contained a
non-cited violation (NCV) for failure to post a component maintenance
area and an airborne radioactivity area on the refueling floor. IR 92
06, dated March 6, 1992, contained an NCV for failure to label a
contaminated lead brick and a pair of pliers in the primary chemistry
laboratory. IR 92-17, dated November 20, 1992, contained a violation
for failure to post an airborne radioactivity area in the Unit 3
Containment Building and.contaminated areas in the primary chemistry
laboratory. Also, a violation was cited for failure to label a tool box
found in the-primary chemistry laboratory and a radioactive air'sampler.
The concern for the repetition of the violations was discussed with
licensee management both during the inspection and.at the exit
interview.
The licensee continues to maintain approximately 93-94 percent of the
RCA as a non-contaminated area. The inspector noted that contaminated
areas in the RCA were not extensive and did not appear to hinder
management or worker access to job sites.
Two apparent violations were identified involving (1) the licensee's
failure to post a radioactive materials area and a contaminated area in
accordance with 10 CFR 20.1902(e) requirements and referenced procedures
(VIO 50-269, 270, and 289/93-07-01); and (2)
the:licensee's failure to
label radioactive items in accordance with 10 CFR 20.1904(a)
requirements and licensee procedures (VIO 50-269; 270, and 289/93-07
02).
9
8.
Program to Maintain Collective Dose As Low As Reasonably Achievable
(ALARA) (83750)
The inspector was requested by the resident inspector to review the
details surrounding recent entries to all three Containment Buildings at
power to perform the venting of a Reactor Coolant: Makeup Pump
Accumulator (RCMPA). The licensee provided mock-up training for the job
prior to the work being performed. The licensee reduced reactor power
to 54 percent for the work in Units 1 and 3. However, the entry and
operation on the RCMPA in Unit 2 was performed at 100 percent power.
The inspector commented to the licensee that additional information
regarding projected person-rem prior to the operation would be a
desirable ALARA practice.
A review of the dose rates in the area of the accumulators, with Unit 2
ranging from 3 Rem/hour to 10 Rem/hour, suggested the need for multiple
dosimetry due to the non-uniform fields of radiation. Due to an
unscheduled power reduction in Unit 1, the inspector was able to make a
power level entry into the unit at 16 percent power. The inspector wore
multiple digital alarming dosimeters and observed and surveyed the work
area used to effect the venting in Unit 1. The inspector did not
receive a differing dose to the thigh area or the arm area. The
inspector also interviewed the RP technicians that performed the
operations in Units 2 and 3 and found that in lieu of multibadging the
workers were positioned such that the radiation field was uniform.
Licensee representatives were informed that, based on the inspector's
review, multibadging dosimetry was no longer a concern. However, the
inspector discussed the importance of using good administrative controls
for operations where radiological risks were increased.
No violations or deviations were identified.
9.
Review of Previously Identified Inspection Findings (92702)
(Closed) VIO 50-269, 270, 287/92-17-03:
Failure-of two employees to
access a RWP before performing work.
The licensee had implemented a
combined system for accessing RCAs and
RCZs which was expected to minimize/prevent the recurrence of this
problem. To access one of these areas, required the automated setting
of a digital alarming dosimeter in conjunction with accessing the RWP to
be worked. During the onsite inspection, -the inspector monitored for
the recurrence of -personnel in the.RCA or in RCZs without .being on n
RWP and did not have any concerns. This item
is
considered closed.
10
10.
Exit Meeting
The inspector met with licensee representatives.denoted with an asterick
in Paragraph 1 on March 5, 1993. The inspector discussed the examples
of inadequate posting of RCZs as an apparent violation, as well as, the
apparent violation for failure to label radioactive material in the RCA.
The inspector also discussed the fact that both violations were repeats
of violations identified in the past two years. In addition, the
inspector discussed the significance of the weakness in the program for
identifying and correcting radiological deficiencies.
The inspector did not receive any proprietary material or dissenting
comments.
Item Number
Description and Reference
50-269, 270, 287/93-07-01
VIO - Two examples of failure to
adequately post RCZs (Paragraph 7).
50-269, 270, 287/93-07-02
VIO - Failure to label Radioactive
Material (Paragraph 7).
50-269, 270, 287/93-07-03
IFI - Question of timely correction
of radiological deficiencies
(Paragraph 3).