ML16154A714
| ML16154A714 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/23/1994 |
| From: | Rankin W, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16154A713 | List: |
| References | |
| 50-269-94-34, 50-270-94-34, 50-287-94-34, NUDOCS 9411300011 | |
| Download: ML16154A714 (18) | |
See also: IR 05000269/1994034
Text
- tREG 1UNITED
STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
November 23,
1994
Report Nos.:
50-269/94-34, 50-270/94-34, and 50-287/94-34
Licensee: Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.:
50-269, 50-270,
License Nos.:
and 50-287
and DPR-55
Facility Name: Oconee Nuclear Station
Inspection Conducted: October 24-28, 1994
Inspector:
4 -7 X
C
o23
F. N. Wright
Date Sfgne
Approved by:
/,
V. H. RankTh, Chief
Date 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
program involved the review of occupational exposures. The review focused
primarily on the areas of:
audits and self-assessments; changes to the
program; outage planning and preparation; external and internal exposure
controls; control of radioactive materials, contamination surveys and
monitoring; and maintaining occupational exposure As Low As Reasonably
Achievable.
Results:
Based on interviews with licensee personnel, records review, and observation
of work activities in progress, the inspector found the Radiation Protection
program to be adequately managed. Internal and external exposure control
programs were effectively implemented with all exposures within 10 CFR Part 20
limits. One violation was identified concerning the licensee's failure to
follow quality assurance procedures concerning corrective actions and the
Oconee site's response to Quality Assurance audit findings (Paragraph 2).
9411300011 941123
PDR ADOCK 05000269
G
1.
Persons Contacted
REPORT DETAILS
Licensee Employees
- D. Berkshire, Senior Scientist, RP
- E. Brown, Scientist, RP
- E. Burchfield, Manager, Regulatory Compliance
T. Cherry, RP Supervisor, ALARA
- B. Dolan, Manager, Safety Assurance
H. Dummeyer, Coordinator, Quality Verification
- B. Foster, Maintenance
- B. Horton, Operations Support
- D. Hubbard, Maintenance
- D. Jenny, Quality Verification
E. Lampe, Scientist, RP
B. Pursley, Scientist, RP
H. Smith, RP Supervisor, ALARA
- J. Smith, Regulatory Compliance
S. Spear, General Supervisor, Station Sciences, RP
- D. Sweigart, Superintendent, Work Control
- J. Twiggs, Manager, RP
D. White, Supervisor, RP
Other licensee employees contacted during the inspection
included scientists, technicians, maintenance personnel, and
administrative personnel.
Nuclear Regulatory Commission
- P. Harmon, Senior Resident Inspector
G. Humphrey, Resident Inspector
- L. Keller, Resident Inspector
- Attended Exit Meeting
- Participated in November 2, 1994 Teleconference
Abbreviations used throughout this report are defined in the last
paragraph.
2.
Audits, Appraisals, and Effectiveness of Licensee Controls (83750)
Licensee activities, audits, and appraisals were reviewed to determine
the adequacy of the licensee's identification and corrective action
programs for deficiencies or weaknesses related to the control of
radiation or radioactive material.
10 CFR 20.1101(c) requires that the licensee periodically review the RP
program content and implementation at least annually.
2
DPC's QA Program for the safe and effective design, construction,
operation, and modification of it's nuclear stations was described in
the Topical Report, Amendment 16, dated December 16, 1993.
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."
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.
During the previous radiation protection program inspection, conducted
June 6-10 1994, the inspector identified concerns with the licensee's
corrective action program while reviewing the licensee's response to
audit findings identified in Audit Report NG-93-04(ON), "Chemistry and
Radiation Protection" issued March 18, 1993.
The NG-93-04(ON) audit identified five findings and the transmittal
letter for the QV audit report required the licensee respond to the
findings within thirty days after the receipt of the 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 have been taken and the results
achieved;
4)
Corrective steps which will be taken to avoid further
findings; and
5)
Date when full compliance will be achieved."
The inspector requested a review of the licensee's written response to
the audit findings documenting proposed corrective actions. Licensee
representatives initially reported that there was not a letter from the
ONS management to the QV Department, 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 tracking data base which was accessible to all DPC nuclear sites
and corporate offices. Licensee personnel reported that, with the use
of the PIP program for tracking corrective actions, it was not necessary
for the site to transmit a letter to the QV Department addressing
proposed corrective actions for findings issued during QV audits. The
3
inspector discussed the issue with licensee personnel and reported 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. Licensee personnel reported that the QV audit procedures were
being revised to reflect the new PIP corrective action process as an
acceptable method for documenting and tracking corrective actions to
audit findings.
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 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 a June 9, 1994, 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 identified and tracked as an URI (94-18-01) pending
further review of the licensee's QA procedures, records and the adequacy
of the response.
Following a review of the document provided at the exit meeting, the
inspector identified additional concerns regarding the licensee's
response to the audit findings. The inspector noted the following
inadequacies with the site's response for the audit findings:
The ONS 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 issued by the ONS Safety Assurance
Manager.
0
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 ONS 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 1 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 a 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.
o
The site's response for findings NG-93-04(ON)(01) and (02) did not
include corrective steps which would be taken to avoid further
findings.
The site's response for NG-93-04(ON)(03) indicated "NONE" for
corrective actions.
4
Following the issuance of the Oconee IR 94-18, the inspector obtained a
copy of the QV procedure 3.1, "Internal Audits," Rev 0, dated June 1,
1992, which provided administrative guidance for the preparation,
conduct, and follow-up of audits performed by the Quality Verification
Audits Section. The inspector found that the procedure agreed with and
reflected the audit finding response requirements specified in
Section 17.3.3.2.2, "Internal Audits," of the Topical Report. QV 3.1
required the audited organization respond to the audit findings in
writing addressing corrective actions as prescribed in the March 18,
1993 cover letter transmitting the NG-93-04 (ON) audit report. The
inspector also noted that the procedure did not describe an alternative
corrective action process using the PIP system. The inspector stated
that failure to document and report corrective actions for QV findings
in accordance with licensee QA procedures appeared to be a violation of
the licensee's QA program.
VIO 50-269, 270, and 287/94-34-01:
Failure to follow QA procedures for
documenting and reporting corrective actions to audit findings.
The inspector reviewed Section 5.1, "Regulatory Audits, Rev 0, dated
August 30, 1994, of the Nuclear Assessment Functional Area Manual which
replaced QV-3.1, "Internal Audits". The inspector noted that the new
procedure provided for the use of the PIP system for processing
corrective actions for QA audit findings.
The licensee's actual corrective actions for the NG-93-04 (ON) audit
findings were adequate considering the significance of the findings,
even though the licensee's written response concerning corrective
actions for the findings was inadequate. The licensee did a better job
of taking corrective action than documenting it. Corrective actions
could have been better with specific consideration and actions to
prevent recurrence. The inspector reported that the URI 50-269, 270,
and 287/94-18-01 written to review the licensee's corrective actions for
the NG-93-04(ON) audit findings and corrective action procedures would
be closed.
During the previous inspection and at the June 9, 1994 exit meeting, the
inspector noted that 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 specifically require
corrective actions to prevent recurrence was a weakness in the
licensee's corrective action program. Licensee personnel reported that
corrective action, when properly taken, included corrective action to
prevent recurrence.
The inspector reviewed the licensee's requirements for taking corrective
actions to prevent recurrence. Section 17.3.2.13, "Corrective Action,"
of the Topical Report stated: "Procedures require that conditions
5
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, also 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, "Conformance of Duke Power
Program to Quality Assurance Standards, Requirements, and Guides,"
addressed the QA program conformance to the referenced standards and
stated that Duke QA Program conforms to ANSI N45.2.12 -1977 for internal
external audits. Section 4.5 of the ANSI standard addresses follow-up
and stated, in part:
"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".
In the October 27, 1994 exit meeting the inspector again emphasized the
need to specifically require personnel responsible for developing and
taking corrective action to clearly document corrective action to
prevent recurrence. The inspector stated that failure of the PIP
process to clearly require personnel developing corrective action to
specifically identify corrective action to preclude recurrence could
result in inadequate corrective actions and violations of existing QA
program requirements.
One violation was 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 previous inspection was conducted June 6-10, 1994, and documented in
IR 50-269, 270, and 287/94-18.
The ONS RPM for many years retired on August 31, 1994. An Acting RPM
was selected to direct the RP program activities until a permanent RPM
selection could be made. The inspector determined that the Acting RPM
was qualified to perform the assigned duties. The licensee had
identified the new RPM effective October 1, 1994. During the
inspection, the new RPM was completing assignments at Catawba and was
6
splitting time between his new and previous assignments. The RPM
expected to assume full responsibilities for the Oconee RP program
November 1, 1994.
Licensee TS 6.1.1.4 stated; "The Radiation Protection Manager shall have
a bachelor's degree in a science or engineering subject or the
equivalent in experience, including some formal training in radiation
protection, and shall have at least five years of professional
experience in applied radiation protection of which three years shall be
in applied radiation protection work in one of Duke Power Company's
nuclear stations." The inspector determined that the RPM met the
training and qualification requirements for the position as specified in
the licensee's TS. The licensee had not made any additional changes in
the plant HP organization since the previous inspection.
No violations or deviations were identified.
4.
Planning and Preparation (83750)
Licensee activities and documents were reviewed to determine 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 19 through 23 of
a RFO on Unit 2. The Unit 2, EOC-14 RFO began October 6, 1994, and was
scheduled to be completed by November 16, 1994. The licensee's
radiological control planning for the RFO 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.
No violations or deviations were identified.
5.
External Exposure Control (83750)
This area was reviewed to determine 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
7
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.
a.
Administrative Controls for External Exposures
The inspector reviewed and discussed with licensee representatives
1994 external exposures for plant and contract personnel.
Through
review of dose records the inspector confirmed that personnel
radiation exposures assigned during the period were within
10 CFR Part 20 limits. The maximum doses for an individual
radiation worker through October 25, 1994 were:
TEDE, 2,301 mrem;
Skin, 2,696 mrem; Eye, 2,341 mrem; and CEDE, 45 mrem. The highest
hot particle dose assigned was 4,024 mrem.
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, interacting with RP personnel
to determine adequate radiation and contamination controls for
their assigned task and observed radiation workers logging into
the EDC system. From observations, the inspector noted personnel
were properly utilizing the DADs and the EDC system.
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.
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.
8
b.
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
controls for access to High, Extra High and Very High Radiation
Areas. ONS Site Directive, 1.1.4 (RP), Radiation Access
Controls", Rev. dated January 27, 1994 established a radiation
exposure monitoring and control program for personnel entering the
Radiation Control Area or Radiation Control Zone.
The licensee's procedures made the following distinctions for
HRAs.
HRA - Any area, accessible to individuals, in which
radiation levels could result in an individual receiving a
deep dose equivalent in excess of 100 mrem in one hour, but
less than or equal to 1,000 mrem in one hour at 30 cm from
the radiation source.
EHRA - Any accessible area to individuals, in which
radiation levels could result in an individual receiving a
deep dose equivalent in excess of 1,00 mrem in one hour, but
less than or equal to 1,000 mrem in one hour at 30 cm from
the radiation source, but less than or equal to 500 rads in
one hour at one meter, from the radiation source.
VHRA - Any accessible area to individuals, in which
radiation levels could result in an individual receiving an
absorbed dose (deep dose equivalent) in excess of 500 rads
in one hour, at one meter, from the radiation source.
Prior to implementation of the revised Part 20 requirements, the
licensee had not applied for alternative methods to control access
into high radiation areas and was required, by Paragraph 20.203(c)
to lock all high radiation areas having a radiation dose rate
equal to and greater than 100 mrem/hr. Licensee's staff reviewed
Regulatory Guide 8.38, "Control of Access to High and Very High
Radiation Areas in Nuclear Power Plants," and interpreted the
guidance as authorizing nuclear power plants to use the
alternative methods of access control listed in the guides,
thereby meeting the requirements of 10 CFR 20.1601. The
licensee's interpretation was incorrect and the statement in
Regulatory Guide 8.38 indicating methods described in the
regulatory guide, as an acceptable alternative method to control
access to HRAs, did not constitute a "blanket approval."
Therefore, specific NRC approval to use an alternative method was
still required pursuant to 20.1601(c).
The licensee requested NRC
approval to use alternative access control methods of Regulatory
Guide 8.38 to meet the requirements of 10 CFR 20.1601.
9
As documented in a NRC Letter dated February 14, 1994 DPC
requested NRC approval, under 10 CFR 20.1601(c) to control the
high radiation areas at ONS in accordance with alternate controls
described in Regulatory Position 2.4 of Regulatory Guide 8.38.
Since no exceptions or variations were requested to the guidance
in Regulatory Guide 8.38, the NRC found the alternative controls
acceptable and approved for the use at ONS, Units 1, 2 and 3. The
letter also reported that any high radiation controls not
consistent with Regulatory Guide 8.38 or 10 CFR 20.1601(a) and
(b), without additional NRC approval would constitute a violation
of 10 CFR 20.1601.
The inspector reviewed the licensee's controls for securing
locking EHRAs and VHRAs. The HPSS had the responsibility for
securing and issuing keys to EHRAs and VHRAs. The keys were
maintained in separate key cabinets in the HPSS work area. The
key for the VHRA was in the EHRA key cabinet. A key to the EHRA
key locker was passed to the following HPSS and noted in the
licensee's HPSS logbook during shift turnover. The keys for the
EHRA and the VHRA were to specific locks, however, there was a
master key that could be used by HP personnel to access EHRAs.
The master key was attached to a detection device to prevent the
key from exiting the protected area. The EHRA and VHRA keys could
only be issued to HP personnel and each key assignment was logged
in a key issue logbook.
Inspection Report 50-269, 270, and 287/93-28 documented a
procedure discrepancy involving Security access to three HRA keys
that was identified as a URI 93-28-02. The inspector reviewed the
issue for resolution. Step 5.2.3.1 of SRPM, 111-15 stated that
the RP controlled the keys to EHRAs except for reactor building
keys. The procedure stated that the Operations Shift Supervisor
controlled the issue of reactor building keys. However, the
inspector determined that the Security staff was periodically
required to verify certain security controls that required a
security officer open a door to the containment buildings.
Licensee personnel initially reported that Security personnel were
required to check out a key from the appropriate OSS which would
agree with the procedure requirements specified in SRPM, 111-15.
The inspector attempted to verify that the key issuances to
security personnel had been properly controlled and logged. The
inspector determined that the control room had permanently issued
the containment building keys to the Security department and did
not possess keys to the containment buildings. The inspector also
determined that Security had the containment building keys and the
keys were turned over to each Security Shift Supervisor as a turn
over-item. The inspector observed the same conditions as
documented in the URI, the SRPM, 11-15 did not include the
Security Department as a group responsible for ONS containment
building access keys. The inspector learned that the ONS staff
had attempted to change the SRPM 111-15 procedure to reflect the
site's practices but had been refused by the Surveillance and
10
Control Working Group. The group was made up of representatives
from each of the DPC Nuclear Sites and the Corporate Office to
establish uniform radiation protection procedural guidance
applicable to all DPC Nuclear Sites. According to site personnel
the working group did not want to establish site specific guidance
in the SRPMs. The inspector determined that a Site Directive
described the observed controls for the containment building high
radiation area keys assigned to the Security Department. ONS
Directive 1.1.4 stated that operations had control of containment
building keys as did SRPM-III-15. However, the site directive
procedure stated "Operations may delegate key control of the
Reactor Building entrances to Security providing that Security
procedures require them to obtain Operations and RP approval prior
to opening any of the doors."
The inspector discussed the SRPM
111-15 procedure and SD 1.1.4 (RP) practice differences with
licensee personnel.
The inspector did not identify any problems
with the site's control or use of the reactor building keys other
than the corporate SRPM procedure did not agree with the Site
Directive. Since the observed practice agreed with the Site
Directive 1.1.4 and the keys appeared to be properly controlled
the inspector reported that the URI 93-28-02 would be closed.
Through further discussions with licensee representatives, the
inspector noted that the Operations staff had possession of keys
for the Locked Extra HRAs to provide access during emergency
conditions. Keys for those Locked Extra HRAs, specific for each
unit, were maintained in a locked and sealed box in the OSS desk
near the control room for each unit and were not for routine use.
The inspector verified that the keys were available for emergency
use and the storage box secured with a breakable seal.
During tours of the Auxiliary Building, the inspector observed and
independently verified that all Extra HRAs were locked and/or
posted as required.
No violations or deviations were identified.
c.
Posting and Labeling
10 CFR Part 20, Subpart J - Precautionary Procedures, describes
posting requirements for radiation, high radiation, very high
radiation, airborne radioactivity areas and radioactive material
use and storage areas.
During tours of the auxiliary, containment, and selected outside
radioactive material storage areas, the inspector noted that the
licensee's posting and control of radiation areas, high radiation
areas, airborne radioactivity areas, contamination areas,
radioactive material areas, was generally adequate. All signs
were conspicuous and legible and maps and labels were clearly
11
visible and informative. The inspector also conducted random
independent radiation surveys in those areas and noted no problems
with observed radiation levels and observed postings.
No violations or deviations were identified.
6.
Internal Exposure Control (83750)
This area was reviewed to determine 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:
(1) Concentrations of radioactive materials in air in work areas; or
(2) Quantities of radionuclides in the body; or
(3) Quantities of radionuclides excreted from the body; or
(4) 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.
b.
Respiratory Protection Program
The inspector reviewed licensee reports that indicated significant
reductions in the use of respirators during recent RFOs.
For
12
example, the numbers of full face respirators issued during recent
RFOs were:
Unit 1 EOC-14 were 1,900 compared to 754 issued during EOC
15 outage completed June 29, 1994;
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 completed February 26, 1994. Unit 3 numbers
were higher than the other units due primarily to higher
contamination levels associated with the unit.
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 total effective dose
equivalent 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 stated 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 highest CEDE
recorded for 1994, at the time of the inspection, was 45 mrem.
The inspector reviewed and discussed the licensee's program for
monitoring internal dose. Licensee procedure SRPM 11-2,
"Requirements For Bioassay," Rev. 4, dated March 3, 1994, outlined
the conditions and criteria for scheduling bioassays. 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.
No violations or deviations were identified.
13
7.
Control of Radioactive Materials and Contamination, Surveys, and
Monitoring (83750)
This program area was reviewed to determine whether survey and
monitoring activities were performed as required and control of
radioactive materials and contamination met requirements.
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 levels in portions of the containment and auxiliary
building. No concerns with the adequacy or frequency of the
radiological survey activities were identified.
The inspector reviewed the licensee's PCEs to date since the last
inspection and discussed those records with licensee representatives.
For the year 1994 to October 27, 1994, the licensee had documented
approximately 246 personnel contaminations. This compares with 151
documented for 1993. Of the 246 PCEs, approximately 103 were from hot
particles. The inspector noted that approximately 90 occurred in areas
within the RCA that were considered clean areas. The licensee
attributed the contaminations to constant licensee efforts to reduce
total contaminated area square footage. 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 within limits, the highest hot particle dose assigned was 4,024
mrem.
No violations or deviations were identified.
8.
Program for Maintaining Exposures As Low As Reasonably Achievable
(83750)
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).
14
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 licensee had 3 RFOs scheduled within the 1994 calendar year. The
site's collective dose goal for 1994 was set at 592 person-rem. The
licensee had completed RFOs for Units 1 and 3 and was near completion of
the Unit 2 RFO when the inspection was made. The collective dose for
the year was approximately 471 person-rem on October 25, 1994 and the
licensee was below dose estimate projections for the work completed.
The inspector reviewed and discussed with licensee representatives the
ALARA program implementation and initiatives and the planning for the
RFOs. The licensee removed the Nitrogen 16 decay tanks from all three
units. The removal of the tank on Unit 3 lowered containment radiation
doses in the area from 2,000 mrem/hr to 200 mrem/hr. 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 person-rem which was significantly below the estimated
304 person-rem for the RF0. The Unit 1 RFO began on April 28, 1994, and
ended on June 26, 1994. The Unit 1 outage was scheduled to be 49 day
outage with estimated collective dose of approximately 142 person-rem.
The outage lasted approximately 60 days with a collective dose of
approximately 125 person-rem exposure. The estimated collective dose
for the Unit 2 RFO outage was 136 person-rem and at the time of the
inspection, the collective dose was approximately 62 person-rem. The
licensee has been successful in source term reductions and the licensee
continued to reduce personnel radiation exposures. The collective dose
average for 1992, 1993, and 1994 was expected to be approximately
155 person-rem per unit.
The inspector noted that the licensee was pursuing initiatives to reduce
personnel exposures during outages. Licensee representatives reported
telemetric monitoring, video and radio systems had been utilized in the
most recent outages to aid with remote monitoring capabilities. The
inspector also discussed initiatives, for both immediate and long term
dose savings, that recently had been completed or were planned for
implementation during each unit outage. These included replacement of
Component Drain Header piping and associated valves to delete many right
angles, and subsequent permanent shielding of the piping. The
installation of permanent playpens for steam generator work areas was
expected to aid in contamination control, reduced task time and dose,
and radioactive waste reductions. The removal of components which have
historically acted as crud traps and flushing of hot spots have received
priority during outages and according to licensee personnel has been an
effective tool in reducing source term and area dose rates.
No violations or deviations were identified.
15
9.
Action on Previous Inspection Findings (92701)
(Closed) VIO 50-269, 270 and 287/92-17-01:
Failure to post an airborne
radioactivity area as required by licensee procedures and failure to
identify contaminated work areas in the primary chemistry laboratory.
The inspector verified that the licensee's corrective actions reported
in the licensee's response to the violation dated December 15, 1992 had
been completed.
(Closed) VIO 50-269, 270 and 287/92-17-02: Failure to control and
label radioactive materials as required by licensee procedures. The
inspector verified that the licensee's corrective actions reported in
the licensee's response to the violation dated December 15, 1992 had
been completed.
(Closed) VIO 50-269, 270 and 287/93-28-01:
Failure to control access
into posted high radiation areas as required by 10 CFR 20.1601(a).
The licensee received approval for the alternative methods described
in Regulatory Guide 8.38 in a NRC Letter dated February 14, 1994
(Paragraph 5.b).
(Closed) URI 50-269, 270 and 287/93-28-02:
Failure to control keys to
personnel emergency escape hatches as required by licensee procedures.
The SRPM 111-15 procedure stated that Reactor Building keys were only
controlled by Operations Shift Supervisor and Radiation Protection
personnel.
However, Security personnel had keys to check the security
of the doors to the personnel emergency escape hatch which was a
procedural discrepancy. The inspector determined that the ONS RP staff
had attempted to include the Security Department as a controller of the
Containment Building keys in the SRPM 111-15 but had not been permitted
to include site specific procedure requirements in the document.
However, the inspector determined that Site Directive 1.1.4 adequately
described the use of keys to the Containment Buildings by ONS Security
personnel and reported the URI would be closed (Paragraph 5.b).
(Closed) URI 50-269, 270 and 287/94-18-01: Review corrective actions
associated with findings identified in QV Audit NG-93-04 (ON) and the
licensee's procedures for correcting QV Audit findings. This item was
closed and a violation issued (Paragraph 2).
(Open) 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. The licensee had not incorporated the policy
into written and controlled procedures.
10.
Exit Meeting
On October 27, 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
16
inspector summarized the scope and findings of the inspection. The
inspector reported that there appeared to be Quality Assurance Program
procedure violation concerning failure to follow procedures for
reporting corrective action for QA Audit findings. 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. Licensee
personnel requested a teleconference on November 2, 1994, with those
persons identified in Paragraph 1. The licensee wanted additional
clarification of the inspector's concerns with corrective actions for
audit findings. There were no new issues identified following the
October 27, 1994, exit meeting.
Type Item Number
Status
Description and Reference
50-269, 270, and
Open
Failure to follow Quality
287/94-34-01
Assurance requirements for
documenting and reporting
corrective actions for audit
findings (Paragraph 2).
50-269, 270, and
Closed
Review licensee's corrective
287/94-18-01
actions for licensee audit
report findings (Paragraph 2).
IFI
50-269, 270, and
Open
Review licensee's policy and
287/94-18-02
procedure documents for
embryo/fetus exposure and
declared pregnant worker
(Paragraph 9).
50-269, 270 and
Closed
Failure to control access into
287/93-28-01
posted high radiation areas as
required by 10 CFR 20.1601(a)
(Paragraph 5.b).
50-269, 270 and
Closed
Failure to control keys to
287/93-28-02
containment buildings hatches
as required by licensee
procedures
(Paragraph 5.b).
50-269, 270 and
Closed
Failure to post an Airborne
287/92-17-01
Radioactivity Area as required
by licensee procedures and
failure to identify
contaminated work areas in the
primary chemistry laboratory
(Paragraph 9).
- I
17
50-269, 270 and
Closed
Failure to control and label
287/92-17-02
radioactive materials as
required by licensee
procedures (Paragraph 9).
11.
Index of Abbreviations Used in this Report
As Low As Reasonably Achievable
ANSI
American National Standards Institute
CFR
Code of Federal Regulations
DAD
Digital Alarming Dosimeter
Duke Power Company
Declared Pregnant Women
EDC
Electronic Dose Capture
EHRA
Extra high Radiation Areas
End Of Core
Health Physics
HPSS
Health Physics Shift Supervisor
IFI
Inspector Follow-up Item
IR
Inspection Report
mrem
Milli-Roentgen Equivalent Man
NRC
Nuclear Regulatory Commission
Nuclear Safety Review Board
Oconee Nuclear Site
OSS
Operations Shift Supervisor
Personal Contamination Events
Problem Investigation Process
Quality Assurance
QV
Quality Verification
Radiation Absorbed Dose
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
Total Effective Dose Equivalent
TI
Temporary Instruction
Thermoluminescent Dosimeter
TS
Technical Specifications
Un-Resolved Item
Very High Radiation Areas
Violation
Whole Body Count