ML16154A629
| ML16154A629 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 07/07/1994 |
| From: | Wade Loo, Rankin W, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16154A630 | List: |
| References | |
| 50-269-94-18, 50-270-94-18, 50-287-94-18, NUDOCS 9407290065 | |
| Download: ML16154A629 (25) | |
See also: IR 05000269/1994018
Text
HREG
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report Nos.:
50-269/94-18, 50-270/94-18, and 50-287/94-18
Licensee: Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.: 50-269, 50-270,
and 50-287
and DPR-55
Facility Name: Oconee Nuclear Station
Inspection Conducted: June 6-10, 1994
Inspectors:
Ap7b9
F. N.' right
Date S gne
W, T. Loo
Date/SDgned
Approved by:
c
/7 A
W. H. Rankin, Chief
Dite Signed
Facilities Radiation Protection Section
Radiological Protection and Emergency Preparedness Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection of the licensee's radiation protection (RP)
program involved the review of occupational exposures and implementation of
new 10 CFR Part 20 requirements. The occupational exposure review included:
audits and self-assessments; changes to the program; outage planning and
preparation; training and qualifications; external and internal exposure
controls;,control of radioactive materials, contamination surveys and
monitoring; and maintaining occupational exposure As Low As Reasonably
Achievable (ALARA). The implementation of the new 10 CFR Part 20 requirements
was evaluated utilizing Temporary Instruction 2515/123, "Implementation of the
Revised 10 CFR Part 20."
The review focused primarily on the areas of:
high
and very high radiation areas; Total Effective Dose Equivalent (TEDE)/ALARA
program implementation; planned special exposures; and dose to the
embryo/fetus for declared pregnant women.
9407290065 940708
PDR ADOCK 05000269
Resul ts:
Based on interviews with licensee personnel, records review, and observation
of work activities in progress, the inspector found the RP program to be
adequately managed. Internal and external exposure control programs were
effectively implemented with all exposures within 10 CFR 20 limits.
Revisions to the RP program incorporating new requirements of 10 CFR Part 20
were made effective January 1, 1993. The new requirements, as focused by the
inspection procedures, were appropriately incorporated into the RP program.
One Unresolved Item (URI) and one Inspector Follow-up Item (IFI) were
identified:
1) Unresolved item concerning the licensee's corrective action
and response to audit findings (Paragraph 3); and 2) IFI concerning
documentation of the licensee's procedures and radiation exposure policy for
declared pregnant women (Paragraph 9).
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
D. Berkshire, Senior Scientist, RP
- E. Brown, Scientist, RP
T. Cherry, RP Supervisor, ALARA
G. Courtney, Technical Manager, RP, General Office
D. Davis,.Instructor, Training Division
- B. Dolan, Manager, Safety Assurance
- H. Dummeyer, Coordinator,'QV, SR
- A. Jones-Young, Regulatory Compliance
D. Kelly, Instructor, Training Division
J. Long, General Supervisor, Station Sciences, RP
D. Mei, Senior Engineer, Corporate Office
B. Murphee, Administrative Supervisor, RP
- B. Peele, Station Manager
B. Pursley, Scientist, RP
H. Smith, RP Supervisor, ALARA
S. Spear, General Supervisor,.Station Sciences, RP
- M. Thorne, Supervising Scientist, RP
D. White, Supervisor, RP
0. White, Instructor, Training Division
- L. Wilkie, Manager, Safety Review
00
C. Yongue, Manager, RP
Other licensee employees contacted during the inspection
included scientists, technicians, maintenance personnel, and
administrative personnel.
Nuclear Regulatory Commission
- . Harmon, Senior Resident Inspector
G. Humphrey, Resident Inspector
K. Poertner, Resident Inspector
- Attended Exit Meeting
Abbreviations used throughout this report are defined in the last
paragraph.
2.
Audits, Appraisals and Effectiveness of Licensee Controls (83750)
10 CFr2.111(c) requires that the licensee periodically review the RP
program content and implementation at least annually.
DPC's QA Program for the safe and effective design, construction,
operation, and modification ofit's nuclear stations was described in
the Topical Report, Amendment 16, dated December 16, 1993.
2
Section 17.3.3.2.2, "Internal Audits," of the Topical Report stated:
"Within thirty days after receipt of the audit report, responsible
management replies in writing to the Manager, Audits Section,
describing corrective action and an implementation schedule. When
necessary, after receipt of the management reply, a re-evaluation
is made to verify implementation of corrective action. This re
evaluation is documented. The audit is closed with a letter to
the responsible management. All pertinent correspondence,
checklist, and reports related to the audit are filed."
Section 17.3.2.13, "Corrective Action," of the Topical Report stated:
"Procedures require that conditions adverse to quality be
corrected and action be taken to preclude repetition."
Section 17.0.2, "Quality Assurance Standards and Guides," of the Topical
Report, stated that the DPC Quality Assurance Program conforms to
Appendix B of 10 CFR Part 50, applicable NRC Regulatory Guides and
approved ANSI Standards. Table 17.0-1 addressed the QA program
conformance to the referenced standards.
Table 17.0-1, "Conformance of Duke Power Program to Quality Assurance
Standards, Requirements, and Guides," stated that Duke QA Program
conforms to ANSI N45.2.12 -1977 for internal external audits except
Section 4.4.6. Section 4.4.6 concerned recommendations for correcting
program deficiencies. Section 4.5 of the ANSI standard addresses
follow-up. Section 4.5.1, By Audited Organization, stated:
"Management of the audited organization or activity shall review
and investigate any adverse audit findings to determine and
schedule appropriate corrective action including action to prevent
recurrence and shall respond as requested by the audit report,
giving results of the review and investigation. The response
shall clearly state the corrective action taken or planned to
prevent recurrence. In the event that corrective action cannot be
completed within 30 days, the audited organization's response
shall include a schedule date for the corrective action. The
audited organization shall provide a follow-up report stating the
corrective action taken and date corrective action was completed.
They shall also take appropriate action to assure that corrective
action is accomplished as scheduled."
Licensee activities, audits, and appraisals were reviewed to determined
the adequacy of licensee's identification and corrective action programs
for deficiencies or weaknesses related to the control of radiation or
radioactive material.
The QV Department, Audit Section was required to perform periodic audits
in the Nuclear Generation Department to provide assurance of the
continuing implementation of the Quality Assurance Program. The
inspector reviewed the most recent QV Department audit of the RP program
3
conducted March 1-17, 1993, and documented in Report NG-93-04(ON),
"Chemistry and Radiation Protection."
The audit report was issued to
the Vice President ONS on March 18, 1993, with a cover letter from the
QV Manager of Audits.
The audit included an evaluation of radiation worker practices, posting
and labeling, control of radioactive materials, laboratory analysis
practices, respiratory protection, surveillance and controls, dosimetry
records, training and qualifications, source control, and aspects of the
chemistry program. The audit identified five findings, seven
observations, three recommendations, and three audit follow-up items.
The audit findings were:
NG-93-04(ON)(01): All Gamma analysis geometries were not being
verified on an annual basis;
NG-93-04(ON)(02): Personnel contamination was not properly handled
in accordance with site implementation
procedures;
NG-93-04(ON)(03): A posted "High Radiation Area," was found in an
unlocked condition;
NG-93-04(ON)(04): Several examples were noted where RCZ's were
set-up, roped off, and/or posted improperly; and
NG-93-04(ON)(05) Personnel were observed violating the SRWP while
processing laundry.
The transmittal letter for the QV audit report required the licensee to
respond to the five findings identified in the report. The letter
stated, "The addressee must respond to Audit Items NG-93-04(ON) (01),
(02), (03), (04), and (05) within (30) days after the receipt of this
report, with a written statement addressing:
1)
Root cause for the findings;
2)
Scope and the results of any investigation performed to determine
the extent of the findings;
3)
Corrective steps which will be taken to avoid further findings
achieved;
4)
Corrective steps which will be taken to avoid further findings;
and
5)
Date when full compliance will be achieved."
The inspector attempted to review the adequacy of the licensee's
corrective actions for the audit findings and requested a review of the
site's response to the findings, as required by the licensee's Topical
Report and the QV Department's audit transmittal letter to the site Vice
4
President. Licensee representatives initially reported that there was
not a letter from the site to the QV Audit Section addressing corrective
action for the NG-93-04(ON) findings. Licensee personnel reported that
the corrective action program was in transition from a paper to an
electronic system when the audit findings were being addressed by the
ONS staff. The audit findings were documented in PIPs on a corrective
action data base accessible to all DPC nuclear sites and corporate
offices. Licensee personnel reported that it would not be necessary for
the site to transmit a letter to the QV Department addressing proposed
corrective actions for findings issued during QV audits. The inspector
discussed the issue with licensee personnel who agreed that there was a
discrepancy with requirements specified in the Topical Report for
documenting corrective actions in a letter to the QV Audit Section and
the current practice of reporting corrective actions through the PIP
system. The inspector reported to licensee management that failure of
the site to respond to the QV Department with a written statement
addressing root cause, results of investigations, corrective actions
taken, corrective actions to prevent recurrence, and date when full
compliance would be achieved; appeared to be a potential violation of
the licensee's requirements specified in Section 17.3.3.2.2, "Internal
Audits," and Section 17.3.2.13, "Corrective Action," of the Topical
Report. At the exit meeting the licensee provided the inspector with a
written response from the site's Safety Assurance Manager to the QV
Manager, Audits QV Department, dated May 5, 1993. Since the inspector
did not have sufficient information or time to evaluate the adequacy of
the site's response the inspector reported to licensee management that
the issue would be an unresolved item pending opportunity to evaluate
the adequacy of the response.
Following a review of the document provided at the exit meeting, the
inspector continued to have questions and concerns regarding the
licensee's response to the audit findings. The inspector noted the
following concerns with the site's response for the audit findings:
The site's response to the findings was not issued by the
addressee (ONS Site Vice President) as specified by the audit's
cover letter.
The response was not issued within 30 days as directed by the
audit's cover letter. The audit report was issued March 18, 1993,
and received by the site on March 22, 1993. The response was
issued 44 days after receipt of the audit findings.
The response did not address finding NG-93-04(ON)(05). The RP
group was responsible for addressing findings I though 4. The
Commodities and Facilities Group had responsibility for corrective
actions for finding number 5. The site's response of May 5, 1993,
referred to the RP Memorandum To File as an attachment which did
not address finding number 5.
The site's response for finding NG-93-04(ON)(01) did not include a
root cause determination.
5
The site's response for findings NG-93-04(ON)(01), (02), and (03)
did not include corrective steps which would be taken to avoid
further findings.
The site's documented corrective action for finding NG-93
04(ON)(02) was limited to reviewing the incident with the HP
technician involved.
The site's response for NG-93-04(ON)(03) indicated "NONE" for
corrective actions.
The site's corrective action response for NG-93-04(ON)(04) did not
address the "big picture" cause for multiple RCZ deficiencies. The
response simply addressed the possible cause of failure for each
example the audit team identified and the immediate corrections
made for each example. The licensee's documented corrective
actions to prevent recurrence was "Items were reviewed with RP
Supervision during weekly staff meeting." No administrative
controls, procedure, surveillance or training changes were
documented.
URI 50-269, 270, and 287/94-18-01: Review corrective actions associated
with findings identified in QV Audit NG-93-04(ON) and licensee
procedures for correcting QV Audit findings.
At the exit meeting, the inspector noted that the PIP documents required
the identification and documentation of corrective actions; however, the
PIP documents did not specifically require that corrective actions to
prevent recurrence be identified and documented. The inspector stated
that corrective action to prevent recurrence was an important
consideration in taking effective corrective actions and generally
required in response to NRC enforcement issues. The inspector reported
that failure of the PIP document to require corrective actions to
prevent recurrence was a weakness in the licensee's corrective action
program and that failure to adequately address corrective actions to
prevent recurrence could be a potential violation of the licensee's QA
Program requirements.
No violations or deviations were identified.
3.
Changes (83750)
Changes in organization, personnel, facilities, equipment, programs, and
procedures, from the previous inspection, were reviewed to assess .their
impact on the effective implementation of the occupational RP program.
The inspector reviewed and discussed with licensee representatives
changes made to the HP organization and staffing levels since the
last inspection of this area. The last inspection was conducted
October 18-22, 1993, and documented in IR 50-269, 270, and 287/93-28.
The licensee had not made any additional changes in the plant HP
organization since the previous inspection. However, the licensee had
6
made significant changes in the number of contract HP technicians
utilized during the Unit 1 RFO715. In the previous Unit 1 RFO, the
licensee had utilized approximately 110 contract HP technicians and the
licensee utilized only 75 ,contract HP technicians in Unit 1 RFO-15. The
inspector determined through interviews with licensee personnel that the
reduction had caused some delays in HP response during periods of peak
outage activity. However, no problems with a lack of proper HP coverage
were identified by the inspector in the areas reviewed.
There were some changes in licensee's method of documenting responses to
QA audit findings and-communicating and documenting the corrective
actions (Paragraph 2).
No violations or deviations were identified.
4.
Planning and Preparation (83750)
Licensee activities and documents were reviewed to determined the
adequacy of management and staff efforts in planning and preparation of
radiation work.
At the time of the inspection, the licensee was in days 40 through 44 of
a RFO on Unit 1. The Unit 1, EOC 15 RFO began April 27, 1994, and was
scheduled to be completed by June 16, 1994. However, the outage had
been extended a few days to correct problems with control rods. The
licensee's radiological control planning for RFO-15 included the
following: -establishment of a RP Coordinator in the ROMO; involvement
of ALARA personnel in the early stages of the outage planning;
increasing the RP staff by approximately 75 contract persons; developing
ALARA work plans for all jobs having a collective dose greater than
1 rem; and utilization of remote monitoring equipment to reduce personal
exposures. The RP supervisory and management personnel maintained
24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> supervision of radiation protection activities to monitor
implementation of the outage plan. The inspector determined that there
was adequate management support for planning and implementing effective
radiological control measures for the refueling outage. The inspector
discussed the planning process with RP personnel and reviewed the Unit 1
EOC-15 RFO and Unit 3 EOC-14 RFO "Pre-Outage Plans."
No concerns with
the planning process were identified.
No violations or deviations were identified.
5.
Training and Qualifications (83750) and (TI 2515/123)
Training and qualifications were reviewed to determine whether
contractor RP technicians were qualified in accordance with the
licensee's standards and procedures, that radiation workers were
receiving appropriate instructions for their work assignments and that
the licensee had incorporated the changes of 10 CFR Part 20, Standards
for Protection Against Radiation, in the various training-programs.
7
10 CFR 19.12 requires that licensees instruct all individuals working in
or frequenting any portion of the restricted areas in the health
protection aspects associated with exposure to radioactive material or
radiation, in precautions or procedures to minimize exposure, and in the
purpose and function of protection devices employed, applicable
provisions of the Commission Regulations, individuals responsibilities
and the availability of radiation exposure data.
a.
General Employee Training
The inspector discussed with licensee representatives.and reviewed
the licensee's program for providing RP training to licensee
employees. Through those discussions and reviews the inspector
determined that GET was divided into two areas, Levels I and II.
Level I was for those licensee employees who were allowed
unescorted access to the Duke Power nuclear stations with the
exception of those areas that are radiologically controlled
lasting approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The inspector reviewed Lesson Plan
"General Employee Training, Nuclear", GET-LI, Revision 2, dated
February 24, 1994, and discussed this with licensee training
representatives. Through those discussions and reviews the
inspector noted that individuals were instructed in their
responsibilities for adhering to nuclear station security,
emergency, radiation control and safety procedures. This included
such topics as fitness for duty, quality assurance, security,
emergency plan, safety, fire protection, hazard communication,
environmental overview, management procedures and general
principles of radiation protection. In addition, individuals were
administered a 25 question written exam requiring a passing grade
of 80 percent.
Level II was for those licensee employees who were allowed
unescorted access to the Duke Power nuclear stations to include
those areas that are radiologically controlled lasting
approximately two and a half days. The inspector reviewed
selected lesson plans and discussed those plans with licensee
training representatives. Through those discussions and reviews
the inspector noted that individuals were instructed in those same
areas for Level I training with regards to nuclear station
security, emergency, radiation control and safety procedures. In
addition, individuals were given more detail and specific
instructions with regards to the principles of radiation
protection. This included topics such as contamination control,
internal contamination, radiation work permits, postings,
radioactive waste, and protective clothing. Individuals were
administered a 100 question written exam requiring a passing grade
of 80 percent. In addition to the written exam, the individuals
would have to take a practical or "hands on" exam demonstrating
that they were knowledgeable in radiation protection principles
and practices.
8
Annual retraining for Levels I and II did not require individuals
to retake the initial classroom instructions. A Bypass
examination could be utilized by the staff to demonstrate
knowledge of radiation protection program requirements and
radiation worker responsibilities. The Bypass examination for
Level I retraining consisted of approximately 25 questions and
required a passing grade of 80 percent. Level II Bypass training
consisted of approximately 100 questions and also required a
passing grade of 80 percent.
No violations or deviations were identified.
b.
Radiation Protection Technician Training
The inspector reviewed the RPT Initial/Basic Training program and
discussed the program with licensee representatives. Based on
those discussions and reviews, the inspector noted that the IBT
program consisted of approximately eleven weeks of classroom and
laboratory training in power plant fundamentals, station
familiarization and RP fundamentals. In addition, licensee
representatives stated that they had not conducted this program
with any individual within the last five years and did not plan to
do so in the future due to the.licensee's administrative
restrictions in not hiring new employees. Licensee
representatives reported that in the event a new employee would be
hired then the lesson plansfor that program would be updated to
incorporate changes in licensee procedures, policies and
regulations.
The inspector reviewed the RPT On-Job-Training program and
discussed the program with licensee representatives. Based on
those reviews and discussions with licensee representatives, the
inspector noted that RPTs were placed under one of three job.
classifications: Specialist, Technician, or Assistant Technician;
and conducted activities in one of five areas: Radioactive
Material Control, Surveillance and Control, Instrument Support,
Shift Coverage, and Count Room. Each RPT, dependent on their job
classification, would be required to complete certain tasks for
the area in which they conducted activities. Completion of
certain tasks would be mandatory to demonstrate an RPTs
- proficiency in conducting those work activities in their area.
The inspector reviewed the RPT Continuing Training program and
discussed the program with licensee representatives. Through
those discussions and a review of records, the inspector noted the
RP manager, supervisors and training representatives would meet
quarterly to discuss the training needs for RPTs. Upon
determination of those training needs the training department
would conduct on the average two classroom sessions per year
lasting approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> for each session. These training
sessions would be performance based and informational to include
reviews of changes in RP procedures and policies and outage
0
.9
reviews and critiques. In addition, the inspector noted that the
RPTs were required to participate in-a computer-based Basic
Fundamentals Retraining program. The computer program consisted
of 26 modules and RPTs were required to complete eight modules
annually to include the administration of an exam with a passing
grade of 80 percent.
No violations or deviations were identified.
c.
Vendor Radiation Protection Technician Training and Qualifications
The inspector reviewed RP training records and qualifications for
selected VRPT involved in current Unit 1 outage activities and
discussed those records with licensee representatives. Based on
those discussions and reviews the inspector noted that VRPTs who
had not been at a Duke Power nuclear station would be required to
take the licensee's RP Vendor Site Specific Training as outlined
in Lesson Plan No. RP-ONS-PT-VT-08, Revision 09, dated April 5,
1994, prior to employment. This included a review of RP related
duties with regards to the licensee's procedures as outlined in
the Site Directives, RP procedures, System RP Manual, RP Section
Manual and other applicable references. This training lasted
approximately two and a half days and those individuals meeting
the licensee's criteria for a Senior RPT would be administered a
100 question written exam entitled "Radiation Protection Vendor
Theory Exam" requiring a passing grade of 70 percent. Those
individuals meeting the licensee's criteria for a Junior RPT would
be administered the 100 question written exam requiring only a
passing grade of 50 percent. Upon completion of that exam, those
VRPTs who met the passing requirements would continue with a
review of the licensee's site specifics training and be
administered another 100 written exam entitled "Health Physics
Site Specific Test" requiring the same passing grades as discussed
above. If a VRPT had completed the licensee's RP Vendor Site
Specific training and been employed a Duke Power nuclear station
within the last 15 months, those individuals would be required to
only take a refresher or update course regarding any recent
changes in licensee RP procedures or policies. Those individuals
would then be administered the HP written exam requiring the same
passing grades as discussed above. If an VRPT did not meet the
passing grades requirement the VRPT would not be allowed to work
at the licensee's facility. Furthermore, for those selected
records reviewed, the inspector determined that those VRPTs met or
exceeded ANSI/ANS 3.1-1978 and N18.1-1971 qualifications in
accordance with licensee procedural requirements.
No violations or deviations were identified.
0
.10
d.
Implementation of Revised 10 CFR Part 20 Requirements in Training
Programs
The inspector reviewed various aspects of the licensee's training
program with respect to incorporation of information related to
implementation of the revised 10 CFR Part 20. The programs were
also evaluated for any changes implemented since the last
inspection of this area conducted October 18-22, 1993, and
documented in IR 50-269, 270/93-28. Through discussions with
licensee representatives and a review of selected lesson plans for
GET, RPT and VRPT training, the inspector noted that the licensee
began implementation of revised 10 CFR Part 20 requirements
January 1, 1993, and had initiated training prior to this date
during the years 1991 and 1992. The licensee incorporated into
their lesson plans for GET the revised 10 CFR Part 20 requirements
beginning with the fourth calendar quarter of 1992.
For RPTs the
licensee began incorporation of this training beginning with the
second calendar quarter of 1991.
The selected lesson plans
reviewed by the inspector included:
GET-L2-04, Revision 01
entitled "Workers Rights and Responsibilities," dated August 1,
1993; GET-L2-05, Revision 02 entitled "Biological Effects," dated
February 23, 1994; GET-L2-06, Revision 02 entitled "Limits and
Guidelines," dated February 23, 1994; GET-L2-09, Revision 01,
entitled "Internal Contamination," dated August 1, 1993; GET-L2-11
entitled "Postings;" RP-ONS-SRQ-HA-01 entitled "Revised 10 FR 20,"
dated April 12, 1991; RP-MC-RFT-127 entitled Regulatory Changes to
10 CFR 20," dated June 12, 1991; and RP-ONS-SP-HA-14 entitled
"Revised 10 CFR 20 Overview of Contents," dated October 14, 1991.
Based on those reviews and discussions, the inspector noted that
topics included licensee policy and procedural changes with the
implementation of revised 10 CFR Part 20, planned special
exposure, declared pregnant female, respiratory protection devices
requirements, revised 10 CFR Part 20 terminology, annual limits
for exposure, ALARA objectives, and posting requirements. The
inspector noted that no significant changes had been made to the
RP related training program since this area was last reviewed.
The inspector informed licensee representatives that their
training program for both general employees and licensee RP
technicians appeared to adequately address the facility's
procedural changes associated with the revised 10 CFR Part 20
requirements and no concerns were noted with the training
material.
No violations or deviations were identified.
6.
External Exposure Control (83750) and (TI 2515/123)
This area was reviewed to determined whether personnel dosimetry,
administrative controls, and records and reports of external radiation
exposure met regulatory requirements.
10 CFR 20.1201(a) requires each licensee to control the occupational
dose to individual adults, except for planned special exposures under
10 CFR 20.1206, to the following dose limits:
(1) An annual limit, which is the more limiting of:
(i) The total effective dose equivalent being equal to 5 rems;
or
(ii) The sum of the deep-dose equivalent and the committed dose
equivalent to any individual organ or tissue other than the
lens of the eye being equal to 50 rems; and
(2) The annual limits to the lens of the eye, to the skin, and to the
extremities, which are:
(i) An eye dose equivalent of 15 rems; and
(ii) A shallow-dose equivalent of 50 rems to the skin or to any
extremity.
10 CFR 20.1501(a) 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 radioactive hazards that may be present.
a.
Administrative Controls for External Exposures
The inspector reviewed and discussed with licensee representatives
external exposures for plant and contract personnel for the period
October 1993 through May 1994. Through review of dose records the
inspector confirmed that all whole body exposures assigned during
the period were within 10 CFR Part 20 limits.
The inspector reviewed selected RWPs for their work activity and
determined that they appeared to prescribe adequate radiation
protection requirements for the assigned task. The inspector
observed personnel reviewing RWPs and logging into the DADs EDC
system. From observations, the inspector noted personnel were
properly utilizing the EDC system. The inspector conducted random
interviews with radiation workers in the RCA. The radiation
workers were knowledgeable of their RWP requirements, personal
dose, and proper response to DAD alarms.
During the Unit 1 EOC-15 RFO, the licensee had used telemetric
dosimetry, communication equipment and video cameras to monitor
several jobs planned inside containment. The equipment permitted.
radiological protection staff personnel the ability to monitor
live time dose and dose rates in low dose areas. The inspector
observed RPTs in the plant monitor worker activities in their
assigned locations, make radiation and contamination surveys and
advise workers on appropriate radiological protection procedures.
.12
The maximum doses for an individual radiation workers in 1993
were:
TEDE, 1,031 mrem;
Skin, 2,427 mrem;
Eye, 953 mrem;
and
CEDE, 113 mrem. The maximum doses for an individual radiation
worker through June 7, 1994 were:
TEDE, 1,668 mrem;
Skin, 2,156
mrem;
Eye, 1,668 mrem;
and CEDE, 45 mrem.
From a review of records and discussions with licensee
representatives, the inspector noted that worker dose in general
appeared to be under control.
No violations or deviations were identified.
b.
Personnel Dosimetry
10 CFR 20.1502(a) requires each licensee to monitor occupational
exposure to radiation and supply and require the use of individual
monitoring devices by:
(1) Adults likely to receive, in one year from sources external
to the body, a dose in-excess of 10 percent of the limits in
(2) Minors and declared pregnant women likely to receive, in one
year for sources external to the body, a dose in excess of
10 percent of any of the applicable limits of 10 CFR 20.1207
or 10 CFR 20.1208; and
(3) Individuals entering a high or very high radiation area.
The inspector determined that the licensee was NVLAP-certified in
all eight categories. All TLDs were processed by the corporate
staff. The inspector reviewed the licensee's most recent "On-Site
Assessment Report for Personnel Radiation Dosimetry Laboratory
Accreditation Program," dated November 24, 1992. The NVLAP
assessment did not identify any dosimetry program deficiencies.
The inspector reviewed the results of the licensee's TLD and ED
correlation report for the fourth quarter of 1993 and noted that
the dose for TLDs and ED generally had very good agreement and
there few dose discrepancies. Of the total of number of TLDs
utilized in the fourth quarter of 1993 (1769) only eight met the
criteria (dose greater than 100 mrem and a difference of
25 percent) for investigation. TLD results were used for dose of
record in all eight cases. When the inspection was made the
licensee had not generated the correlation report for the first
quarter of 1994.
-During tours of the RCA, the inspector noted that personnel were
wearing DADs and TLDs properly.
No violations or deviations were identified.
13
c.
Radiation Protection Directive No. 111-15, "Access Controls for
High, Extra High, and Very High Radiation Areas," Revision 4,
dated April 21, 1994, established and defined the licensee's
proper control for access to High, Extra High and Very High
Radiation Areas.
During tours of the Auxiliary Building the inspector observed and
independently verified that all Extra HRAs were locked and/or
posted as required. During discussions with licensee
representatives and a review of records, the inspector determined
that the RPSS maintained a shift turnover logbook. During each
shift turnover, the RPSS would conduct an inventory for each of
the Locked Extra HRA keys for accountability and control.
The
keys to each of the Locked Extra HRAs were maintained in a locked
box on a wall in the RPSS work area. In addition, the licensee
maintained records for each time a Locked Extra HRA key was issued
and returned to ensure adequate key control for the Locked Extra
HRAs. Through further discussions with licensee representatives,
the inspector noted that the Operations staff maintained keys for
the Locked Extra HRAs to provide them access during emergency
conditions. Keys for those Locked Extra HRAs, specific for each
unit, were maintained in a locked and sealed box on a wall near
the control room for each unit.
Furthermore, during each shift
security would check the integrity of the seal on the boxes to
ensure that no one had entered them without authorization. In the
event the Operations staff was required to access a Locked Extra
HRA, the operator would obtain an RP escort to enter the Locked
Extra HRA.
No violations or deviations were identified.
d.
Posting and Labeling
10 CFR 20.1902(e), requires that for posting of 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 such material
specified in Appendix C to 20.1001-20.2401 with a conspicuous sign
or signs bearing the words "Caution, Radioactive Material(s)" or
"Danger, Radioactive Material(s)."
During tours of the plant and selected outside radioactive
material storage areas, the inspector noted that the licensee's
posting and control of radiation areas, HRAs, airborne
radioactivity areas, contamination areas, and radioactive material
areas, was generally adequate. All signs were conspicuous and
14
legible and maps and labels were clearly visible and informative.
The inspector also conducted random independent radiation surveys
and noted no problems with observed radiation levels.
No violations or deviations were identified.
7.
Internal Exposure Control (83750) and (TI 2515/123)
This area was reviewed to determined the adequacy of licensee's use of
process and engineering controls to limit exposures to airborne
radioactivity, adequacy of respiratory protection program, licensee's
administrative controls for assessing the total effective dose
equivalent in radiation and airborne radioactive materials areas,
assessments of individual intakes of radioactive material and records of
internal exposure measurements and assessments.
10 CFR 20.1502(b) requires each licensee to monitor the occupational
intake of radioactive material by and assess the committed effective
dose equivalent to:
(1) Adults likely to receive, in one year, an intake in excess of
10 percent of the applicable Annual Limit of Intake (ALI) in
Table 1, Columns 1 and 2 of Appendix B to 10 CFR 20.1001-20.2401;
and
(2) Minors and declared pregnant women likely to receive, in one year,
a committed effective dose equivalent in excess of 0.05 rem.
10 CFR 20.1204(a) states that for the purposes of assessing dose used to
determine compliance with occupational dose equivalent limits, each
licensee shall, when required under 10 CFR 20.1502, take suitable and
timely measurements of:
Concentrations of radioactive materials in air in work areas; or
Quantities of radionuclides in the body; or
Quantities of radionuclides excreted from the body; or
Combinations of these measurements.
a.
Use of Process or Engineering Controls
The use of process and engineering controls to limit airborne
radioactivity concentrations in the plant were discussed with
licensee representatives and the use of such controls were
observed during tours of the plant.
No violations or deviations were identified.
15
b.
Respiratory Protection Program
The inspector reviewed licensee reports that indicated significant
reductions in the use of respirators during recent RFOs. For
example the numbers of full face respirators issued during
outages:
Unit 1 EOC-13 were 4,039 compared to 1,900 issued during
EOC-14 outage completed January 25, 1993;
Unit 2 EOC-12 were 4,931 compared to 1,259 issued during
EOC-13 outage completed June 24, 1993; and
Unit 3 EOC-13 were 7,794 compared to 2,161 issued during
EOC-14 outage.
Requirements for TEDE/ALARA reviews were addressed in Section 5 of
the System Directive 111-5, "Airborne Radioactivity Control and
Accountability, Revision 3, dated March 3, 1994. The procedure
required ALARA evaluations to be performed by RP prior to
performing work in airborne radioactivity areas to demonstrate
that respiratory protection provisions are consistent with the
goal of maintaining individual and collective TEDE/ALARA.
Based on those reviews and discussions with licensee
representatives, the inspector determined that the licensee had
made efforts to maintain TEDE exposures ALARA.
No violations or deviations were identified.
c.
Internal Exposure Assessments
10 CFR 20.1204 states that 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
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 CEDE.
The inspector reviewed and discussed the licensee's program for
monitoring internal dose. Licensee procedure SRPM 11-2,
"Requirements For Bioassay," Revision 4, dated March 3, 1994,
outlined the conditions and criteria for scheduling bioassays.
SRPM 11-2 states that routine operations at Duke Power nuclear
stations is not expected to result in internal dose exceeding
10 percent of the allowable occupational limits. The program is
designed to allow tracking internal dose below the levels at which
it is required by regulation.
16
The licensee's program required periodic monitoring for internal
radioactivity. The program included the following:
Routine Baseline Bioassays For:
(1) Initial, annual, and termination bioassay measurements were
routinely required for workers who were assigned dosimetry;
(2) Persons entering a DPC nuclear facility from a non-DPC
nuclear facility; and
(3) Radiation workers that have declared to be a Declared
Pregnant Women.
Special Bioassays For:
(1) A BBA was required for individual's suspected of exceeding
four DAC-hours in a seven day period;
(2) Persons suspected of accidental exposures from an incident
(facial contamination, portal monitor alarm, etc); and
(3) Bioassays were also required for individuals reporting
medical treatments for radiopharmaceuticals and after any
PSE.
The inspector concluded that the licensee's program for
monitoring, assessing, and controlling internal exposures was
conducted in accordance with regulatory and procedural
requirements with no exposures in excess of 10 CFR Part 20 limits
identified.
The inspector reviewed the following WBC system calibration and
quality control procedures:
HP/0/B/1000/63, "Body Burden Analysis
Evaluation of
Results," Revision 13, dated January 1, 1993
HP/0/B/1000/67/C, "Quality Control for the ND 9900 Body
Burden Analysis System", Revision 4, dated January 22, 1991
HP/0/B/1003/21, "Procedure for Calibration of the ND 9900
Whole Body Counting System," Revision 1, dated May 12, 1989
System Radiation Protection Manual procedure No. VI-1,
"Internal Dose Assessment," Revision 2, dated March 3, 1994
Licensee personnel reported that the chair detector system was not
in service and had not been calibrated recently due to an error in
purchase of sources used for system calibrations. The chair whole
body counter had been out of service for about one year.
17
Calibration and quality control checks for the stand-up whole body
counting system were adequate and indicated the equipment was
being properly maintained.
No violations or deviations were identified.
8.
Planned Special Exposures (83750) and (TI 2515/123)
This area was reviewed to determined whether the licensee's program for
planned special exposures met the regulatory requirements.
10 CFR 20.1206 permits the licensee to authorize an adult worker to
receive doses in addition to and accounted for separately from the doses
received under the limits specified.in 10 CFR 20.1201 provided that
certain conditions are satisfied. Such exposures cannot exceed the dose
limits in 10 CFR 20.1201(a) in any year or five times the annual dose
limits during an individual's lifetime.
Radiation Protection Directive No. 11-5, "Planned Special Exposures,"
Revision 0, dated March 3, 1994, provided the requirements for
requesting, working and documenting planned special exposures. Through
discussions with licensee representatives and a review of records, the
inspector determined that the licensee had appropriate procedural
guidance for allowing PSEs.
No violations or deviations were identified.
9.
Dose to the Embryo/Fetus and Exposures of Declared Pregnant Women
(83750) and (TI 2515/123)
This program area was reviewed to determine that the licensee's program
for Declared Pregnant Woman met the regulatory requirements and that the
dose to the embryo/fetus were within the regulatory limits.
10 CFR 20.1208(a) requires that the dose to the embryo/fetus not exceed
500 mrem during the entire pregnancy due to occupational exposure of a
declared pregnant woman.
10 CFR 20.2106(e) requires each licensee to maintain the records of dose
to an embryo/fetus with the records of the declared pregnant woman. The
declaration of pregnancy shall also be kept on file, but may be
maintained separately from the dose records.
The inspector learned from discussions with licensee representatives
that at the time of the onsite inspection, five workers had declared to
be pregnant. During the inspection the inspector interviewed three of
the DPWs concerning the licensee's program for DPWs. Through those
discussions with the DPWs, the DPWs appeared to be knowledgeable of the
licensee's requirements in this area. Furthermore, upon declaration the
DPWs dosimetry were exchanged on a monthly basis rather than on a
18
quarterly frequency. Upon review of dosimetry records the inspector
independently verified that no administrative or regulatory limits were
exceeded with regards to any of the five pregnancies.
Random interviews were made with female radiation workers in the RCA to
determine their knowledge of licensee's policy and procedures for
Declared Pregnant Women. The inspector asked the following questions:
If they had been advised of the licensee's policy and procedures
for the Declared Pregnant Women;
Was the reporting of a pregnancy to their supervision a
requirement; and
What were the exposure limits for a Declared Pregnant Women?
In all cases the workers reported that they were aware of a Declared
Pregnant Woman policy, they knew the occupational exposure limit for a
Declared Pregnant Women and that it had been provided in GET. However,
all stated that reporting a pregnancy to management was a requirement.
The inspector explained to all of the interviewees that the intent of
the regulations was that the reporting or declaration of pregnancy be
voluntary. The inspector discussed the issue with representatives from
Plant Management, RP and Training departments. The inspector determined
that prior to April 1, 1994, DPC policy required female radiation
workers report pregnancy to their management. The policy was recently
changed to make the reporting of a pregnancy, and a workers intent to be
a Declared Pregnant Women, a voluntary option for female radiation
workers. The inspector interviewed radiation workers that had declared
their pregnancy and determined that all had voluntarily reported their
pregnancy. The inspector also determined that while the declared
pregnant worker policy was a voluntary process and was properly provided
to GET students after April 1, 1994; most of the workers had been
trained with the understanding that reporting a pregnancy was required.
The inspector also determined and reported to management that the
licensee's policy and procedures concerning the declaration of pregnant
workers were not documented. The inspector discussed the intent of the
regulations with licensee management at the exit meeting. Licensee
personnel acknowledged the need to clarify, document and instruct
radiation workers on DPC's revised policy for declared pregnant women.
The inspector stated that a review of the licensee's activities
including the documentation of the DPC declared pregnant worker policy
and the instruction of radiation workers on the policy would be made an
IFI.
IFI 50-269, 270, and 287/94-18-02:
Review licensee's documentation of
the DPC's declared pregnant women policy, procedures for processing a
DPW and the training of the radiation workers on the policy and
procedures.
No violations or deviations were identified.
)
19
10.
Control of Radioactive Materials and Contamination, Surveys, and
Monitoring (83750) and (TI 2515/123)
This program are was reviewed to determine whether survey and monitoring
activities were performed as required and control of radioactive
materials and contamination met requirements.
a.
Surveys, Personnel Monitoring, and Instrumentation
10 CFR 20.1501(a) 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 radioactive hazards that
may be present.
During tours of the plant, the inspector noted that portable
radiation detectors, air samplers, and friskers and contamination
monitors had up-to-date calibration stickers and had been source
checked as required.
The inspector reviewed selected records of routine and special
radiation and contamination surveys performed during the current
refueling outage and discussed the survey results with licensee
representatives. During tours of the plant, the inspector
observed HP technicians performing radiation and contamination
surveys.
The inspector independently verified radiation and
contamination levels in portions of the auxiliary building.
No
concerns with the adequacy or frequency of the radiological survey
activities were identified.
No violations or deviations were identified.
b.
Radiological Postings and Control of Contamination and Radioactive
Material
10 CFR 20.1904(a) requires the licensee to ensure that each
container of licensed material bears 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, and the estimate of the quantity of
radioactivity, the kinds of materials and mass enrichment) to
permit individuals handling or using the containers, to take
precautions to avoid or minimize exposures.
During facility tours, the inspector observed adequate
housekeeping and contamination control practices. The inspector
noted that the licensee's control and labeling of radioactive
material was adequate. In addition, the inspector reviewed survey
records and verified that the licensee was performing routine
surveys of radioactive materials areas and checks of labels on
radioactive material containers stored in outside storage areas.
20
The inspector noted that the licensee's posting and control of
radiation areas, HRAs, Extra HRAs, Very HRAs, airborne
radioactivity areas, contamination areas, and radioactive material
areas were appropriate. The inspector noted that all containers
and-materials were properly labeled in accordance with radiation
hazards present.
No violations or deviations were identified.
c.
Control of Contaminated Areas
The licensee maintained approximately 119,380 ft2 of floor space
as radiologically controlled. At the time of the onsite
inspection, the contaminated area tracked by the licensee was
approximately 6,620 ft2.
During facility tours, the inspector
noted that contamination control and general housekeeping
practices were adequate. Based on those direct observations made
by the inspector, the inspector concluded that the licensee was
adequately controlling the spread of contamination.
No violations or deviations were identified.
d.
Personnel Contaminations
The inspector reviewed the licensee's PCEs to date since the last
inspection and discussed those records with licensee
representatives.
For 1993,
the licensee had a total of 161 PCEs
with 61 skin contaminations and 100 clothing contaminations. Of
the contaminations there were 14 involving particles to the skin
and 41 involved particles to clothing.
For the year 1994 to
June, 172 PCEs had occurred. Of the 172 PCEs, 80 involved hot
particles. Review of selected contamination events noted that
licensee documentation and follow-up on the individual events were
appropriate, and skin dose assessments were performed, when
required. For reports reviewed, resultant exposures were minor.
No violations or deviations were identified.
Program for Maintaining Exposures As Low As Reasonably Achievable
(83750) (TI 2515/123)
10 CFR 20.1101(b) requires that each licensee use, to the extent
practicable, procedures and engineering controls based upon sound
radiation protection principles to achieve occupational doses and doses
to members of the public that are as low as reasonably achievable
(ALARA).
21
This program area was reviewed to determine the adequacy of ALARA
program. Areas reviewed included organization support, training, goals
and objectives, radiation-source reduction, worker awareness and
involvement, ALARA plans and reviews, and ALARA results in the
implementation of .the licensee's ALARA program.
The site's collective dose goal for 1994 was set at 592 person-rem. The
licensee had completed a Unit 3 RFO and was near completion of the Unit
1 RFO when the inspection was made. The collective dose was
approximately 336 person-rem on June 10, 1994, and the licensee was
below dose estimate projections for the work completed.
The licensee had three RFOs scheduled within the 1994 calendar year.
The inspector reviewed and discussed with licensee representatives the
ALARA program implementation and initiatives and the planning for the
RFOs.
The inspector noted that for the 61 day Unit 3 outage which began on
December 28, 1993, and ended on February 26, 1994. The licensee
accumulated approximately 194.332 person-rem which was significantly
below the estimated 289.033 person-rem for the RFO. The Unit 1 RFO
began on April 28, 1994, and was scheduled to be 49 day outage with
estimated collective dose of approximately 142 person-rem. The
collective dose for the outage, at the time of the inspection, was
approximately 118 person-rem. The lowest Oconee RFO dose had been 120
person-rem several years ago and the licensee had aspired to match it
during the 1994 Unit 1 RF0. However, problems with control rods had
extended the outage and resulted in the head removal and additional
outage dose. The licensee was reviewing plans for the Unit 2 RFO
scheduled to begin in the fall of 1994.
The inspector also reviewed ALARA Problems Reports submitted and minutes
from ALARA Committee meetings conducted since the last inspection. The
inspector noted that during this period six APRs had been submitted to
the ALARA Committee for review. The inspector noted that although the
number of APRs submitted to the Committee for review was limited
considering the number of RFOs conducted by the licensee during this
period, the issues were substantive and resolution of appeared to result
in dose savings for the licensee. The inspector also noted that the
ALARA Committee had met on two occasions since the last inspection. The
inspector noted that the Committee reviewed and discussed ALARA items to
include a "Top Ten ALARA List Update" and "Potential Top Ten Issues".
The inspector noted that the licensee implemented an adequatemethod for
review and implementation of efforts to reduce personnel exposures.
The licensee appeared to be aggressively controlling routine and outage
doses.
No violations or deviations were identified.
22
12.
Exit Meeting
On June 9, 1994, an exit meeting was held with those licensee
representatives denoted in Paragraph 1 of this report. The exit meeting
was held on that date at the request of licensee management. The
inspector summarized the scope and findings of the inspection and
indicated that no apparent violations or deviations were identified.
The licensee did not indicate any of the information provided to the
inspectors during the inspection as proprietary in nature and no
dissenting comments were received from the licensee. The inspector
reported that the inspection would continue through the following day
and if any new issues developed during that inspection period another
exit may be required. There were no new issues identified following the
June 9, 1994, exit meeting.
Type Item Number
Status
Description and Reference
50-269, 270, and
Open
Review licensee's corrective
289/94-18-01
actions for licensee audit
report findings (Paragraph 3).
IFI
50-269, 270, and
Open
Review licensee's corrective
289/94-18-02
policy and procedure documents
for embryo/fetus exposure and
declared pregnant worker
(Paragraph 9).
13.
Index of Abbreviations Used in this Report
As Low As Reasonably Achievable
ANSI
American National Standards Institute
American National Standard
APR
ALARA Problem Report
BBA
Body Burden Analysis
CFR
Code of Federal Regulations
Derived Air Concentration
DAD
Digital Alarming Dosimeter
Duke Power Company
Declared Pregnant Women
EDC
Electronic Dose Capture
End Of Core
General Employee Training
Health Physics
IBT
Initial Basic Training
IFI
Inspector Follow-up Item
IR
Inspection Report
mrem
Milli-Roentgen Equivalent Man
NRC
Nuclear Regulatory Commission
Nuclear Safety Review Board
National Voluntary laboratory Accreditation Program
On-Job-Training
23
Oconee Nuclear Site
Personal Contamination Events
Problem Investigation Process
Planned Special Exposure
Quality Assurance
QV
Quality Verification
Radiologically Controlled Area
RCZ
Radiologically Controlled Zone
Re-Fueling Outage
ROMO
Refueling Outage Management Organization
Radiation Protection
RPSS
Radiation Protection Shift Supervisor
Radiation Protection Technician
Radiation Work Permit
SR
Safety Review
SRPM
System Radiation Protection Manual
SRWP
Standing Radiation Work Permit
Total Effective Dose Equivalent
TI
Temporary Instruction
Thermoluminescent Dosimeter
TS
Technical Specifications
Un-Resolved Item
VRPT
Vendor Radiation Protection Technician
Whole Body Count