ML16154A817
| ML16154A817 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 07/24/1995 |
| From: | Bryan Parker, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16154A815 | List: |
| References | |
| 50-269-95-15, 50-270-95-15, 50-287-95-15, NUDOCS 9508020021 | |
| Download: ML16154A817 (14) | |
See also: IR 05000269/1995015
Text
pa~ REo
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
0
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
July 27,
1995
Report, Nos.: 50-269/95-15, 50-270/95-15, and 50-287/95-15
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.: 50-269, 50-270,
License Nos.:
and 50-289
Facility Name: Oconee 1, 2, and 3
Inspection Conducted: June 26-29, 1995
Inspector:
6720
,.72
B.
arker
Dte Signed
Approved by
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JcKL<
A
W. H. Rankin, Chief
Ddte
ligned
Facilities Radiation Protection Section
Radiological Protection and Emergency Preparedness Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection was conducted in the area of occupational
radiation safety and included an examination of:
organization and management
controls, audits and appraisals, training and qualification, external exposure
control, internal exposure control, control of radioactive material, surveys
and monitoring, and maintaining occupational exposures ALARA.
Results:
Based on interviews with licensee management, supervision, personnel from
station departments, and records review, the inspector found the radiation
protection (RP) program to be effective in protecting the health and safety of
plant employees. One violation was identified for multiple examples of
failure to properly frisk personnel and equipment/items (Paragraph 7.a.).
Also, one non-cited violation was identified for failure to perform work under
the appropriate radiation work permit (Paragraph 7.c.). A program strength
was noted for licensee efforts to anticipate and effectively deal with hot
particle concerns associated with an inordinate amount of failed fuel during
the ongoing Unit 3 refueling outage.
9508020021 950727
PDR ADOCK 05000269
G
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- M. Boyle, General Supervisor, Radiation Protection (RP)
E. Brown, Scientist, RP
- S. Bryant, Assessor, RP
- E. Burchfield, Manager, Regulatory Compliance
T. Cherry, ALARA Specialist, RP
- C. Curry, Work Control
- W. Foster, Manager, Safety Assurance
J. Hampton, Site Vice President
D. Kelly, Instructor, Training
M. Kline, Instructor, Training
W. Pursley, Supervisor, RP
- G. Rothenberger, Operations
- J. Smith, Regulatory Compliance
- S. Spear, General Supervisor, RP
M. Tuckman, Senior Vice President
- J. Twiggs, Manager, RP
- L. Wilkie, Safety Review Group
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
K. Poertner, Resident Inspector
- W. Rankin, Chief, Facilities Radiation Protection Section
- Denotes attendance at exit meeting held on June 29, 1995.
2.
Organization and Management Controls (83750)
The inspector reviewed the licensee's organization, staffing levels, and
lines of authority as they related to radiation protection (RP).
Since
the last inspection, the licensee had reorganized RP with two General
Supervisors and a Senior Scientist reporting to the Radiation Protection
Manager, who reported to the Station Manager. In discussions with
licensee management, the inspector learned that the licensees's total RP
staff had been recently downsized to a total of 64.
The licensee
continued to maintain a portion of the utility's long-term RP contractor
2
staff, and approximately 90 short-term contractors were hired for the
ongoing Unit 3 refueling outage. The reorganization and downsizing did
not appear to be significantly impacting the licensee's ability to
function effectively.
No violations or deviations were identified.
3.
Audits and Appraisals (83750)
Technical Specification (TS) 6.1.3.4 requires audits of facility
activities to be performed under the cognizance of the Nuclear Safety
Review Board (NSRB) encompassing conformance of facility operation to
all provisions contained in the TSs, applicable license conditions, and
implementing procedures.
The inspector noted that no audits had been performed since the previous
inspection of this area conducted October 24-28, 1994, and documented in
NRC Inspection Report No. (IR)
50-269, 270, 287/94-34. A violation was
cited at that time regarding inadequacies in correcting audit findings.
The inspector reviewed the licensee's response and corrective actions to
the violation, as detailed in Paragraph 9. The licensee informed the
inspector that the next audit of the RP program was scheduled in
November 1995.
No violations or deviations were identified.
4.
Training and Qualification (83750)
10 CFR 19.12 requires, in part, that the licensee instruct all
individuals working in or frequenting any portions of a restricted area
in the health protection aspects associated with exposure to radioactive
material or radiation; in precautions or procedures to minimize
exposure; in the purpose and function of protection devices employed;
in the applicable provisions of the Commission regulations; in the
individual's responsibilities; and in the availability of radiation
exposure data.
The inspector reviewed the licensee's training of RP personnel,
including both in-house and contractor technicians. House and long-term
contractor personnel received essentially the same training, which
mainly focused on continuing training. Quarterly, the RPM and some of
the RP staff met with RP trainers to discuss training needs and
concerns, and plan out future training. The RP group was split into
five major groups and each group received an average of 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> of
training per year per technician. The actual amount per group varied
substantially based on recognized needs, but all technicians received
a minimum "core" of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of training per year. The inspector noted
that the training included task qualifications a's needed, as well as
operating experience at Oconee and other plants in the industry.
More specific/advanced training was given as the need arose. Task
qualifications were graded on a pass/fail basis, whereas other training
was tested with 70 percent as a passing grade.
3
Short-term contractors were given up to three days of site specific
training #nd were tested prior to working in the plant. Abbreviated
training was allowed for previously-trained returnees who had been at
Oconee within the past 15 months. This was significant in that the
licensee continued to experience a high rate of returnees. The licensee
informed the inspector that utility training procedures were being
revised to be more consistent, thereby allowing the Duke sites to do
more abbreviated training to expedite the in-processing of outage
workers. The inspector noted this to be consistent with current
industry practice and noted no problems.
The inspector also reviewed the licensee's General Employee Training as
it related to the utility's declared pregnant woman (DPW) policy.
This was done as followup to an inspector followup item (IFI) identified
during an inspection conducted June 6-10, 1994, and documented in
IR 50-269, 270, 287/94-18. Paragraph 9 contains the details of
this IFI.
No violations or deviations were identified.
5.
External Exposure Control (83750)
10 CFR 20.1201(a) requires each licensee to control the occupational
dose to individual adults, except for planned special exposures under
20.1206, to the following dose limits:
(1) An annual limit, which is the more limiting of:
(i) The total effective dose equivalent (TEDE) 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;
(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.
Collective and Individual Dose
The inspector reviewed and discussed collective and individual
dose with the licensee. The inspector noted that for 1994, the
total collective dose for the site was 536.8 person-rem, with the
highest individual TEDE being 2,623 millirem. The highest skin
dose was 3,119 millirem. At the time of inspection, the site dose
was approximately 170 person-rem for 1995, with the highest
is
individual TEDE being 1,647 millirem. The ongoing Unit 3
refueling outage had accrued approximately 115 person-rem to date,
and the inspector noted that the licensee was approximately
II
4
45 person-rem below projected estimates for the outage and the
year. The inspector concluded that the licensee was controlling
dose satisfactorily.
During tours of the radiation control area (RCA), the inspector
noted that personnel were properly wearing digital alarming
dosimeters (DADs) and thermoluminescent dosimeters (TLDs).
b.
Hot Particle Controls
The licensee discovered prior to shutdown for the ongoing Unit 3
refueling outage that iodine levels in the reactor coolant system
(RCS) were significantly higher than normal.
This indicated that
some order of fuel failure had occurred during the power run.
Based on analysis of the RCS iodine levels, the licensee's
RP group began preparing for "hot particle"/"fuel flea" problems
during the outage once systems were opened and worked upon.
Hot particles are small, often microscopic pieces of material that
break from or erode off of components and become irradiated and
activated in the reactor. Fuel fleas are actual pieces of nuclear
fuel that enter the RCS when failures in fuel cladding occur, and
are considered a special type of hot particle.
Fuel fleas are
often a greater hazard than activated hot particles as the fleas
contain highly radioactive fission products. Hot particles in
general are very radioactive, but due to their small size, they
are difficult to detect, and are usually only hazardous if they
come into contact with an individual's skin or thin clothing for
a significant amount of time.
Due to this concern, the licensee developed a hot particle control
plan, establishing special controls to avoid potentially high skin
exposures due to hot particles. The inspector reviewed the
licensee's plan and noted that it was developed to be implemented
in two phases. Phase One consisted of RP controls and practices
put into place at the beginning of the outage, including double
stepoff pads at containment exit, increased surveillance in
"high-risk" areas, increased use of oil cloth and tacky mats, and
segregation of protective clothing (PCs) used in high
contamination jobs from normal laundry. Phase Two was additional
controls to be put into place if significant hot particle problems
existed, including frequent surveying of platform and steam
generator workers, establishment of "stay" times for PC usage, use
of glove bags/tents, and further increased surveillance and
decontamination. In addition, procedures were developed for
creating special control zones for hot particles as part of Phase
Two implementation.
The inspector reviewed and discussed the implementation of the
hot particle control plan with the licensee. No major problems
had been experienced to date during the outage regarding hot
particles. The inspector verified that Phase One of the plan
was implemented, and noted that very little of Phase Two had been
5
necessary thus far. The inspector considered the licensee's
efforts to proactively prepare for and control hot particles
during the ongoing Unit 3 refueling outage to be a strength in
the licensee's RP program.
No violations or deviations were identified.
c.
Personnel Contamination Events
The inspector reviewed the licensee's personnel contamination
events (PCEs) to date in 1995.
PCEs were tracked by the number of
skin and clothing events as well-as the-number of particle and
dispersed events. Some overlap in total numbers did occur in that
an individual with contaminated clothing and skin was normally
accounted for twice. The inspector noted that when contamination
involved licensee-supplied modesty garments only with no skin
contamination, a PCE report was not generated. This is an
acceptable industry practice.
As of June 27, 1995, a total of 242 PCEs were documented, 143 of
which were skin contaminations. The remainder were shoe, clothing
and hair contaminations. The inspector reviewed a number of the
PCE reports and noted no major problems. Most of the PCEs had
occurred in Unit 3 during the outage, 28 of them involving hot
particles. None of the hot particle exposures to date had
resulted in a significant skin exposure. Of the 131 dispersed
skin PCEs, 75 had occurred while increased levels of iodine were
present in containment during the first few days of the outage
(see Paragraph 6).
It was also noted that 52 of the 67 dispersed
shoe PCEs were found to be caused by cross contaminated nylon shoe
covers. In an attempt to reduce radwaste, the licensee had begun
using more reusable/launderable PCs at the beginning of the
outage; however, due to the cross contamination problems, the
licensee switched back to disposable shoe covers and the problem
went away. The inspector discussed the relatively high number of
PCEs with the licensee, recognizing the fact that many of them
were related to the failed fuel problem and higher than normal
iodine levels in containment.
No violations or deviations were identified.
6.
Internal Exposure Control (83750)
10 CFR 20.1502(b) requires each licensee to monitor the occupational
intake of radioactive material by and assess the committed effective
dose equivalent (CEDE) 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
S0
Table 1, Columns 1 and 2 of Appendix B to 10 CFR 20.1001-20.2401;
and
II
6
(2) Minors and declared pregnant women likely to receive, in one year,
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.
10 CFR 20.1701 requires the licensee to use, to the extent practicable,
process or other engineering controls to control the concentrations of
radioactive material in air.
The licensee conducted an evaluation based on operating experience and
historical data and concluded that it was unlikely that plant workers
would exceed 10 percent of any ALIs. Although not required to monitor,
the licensee chose to monitor in order to track any internal doses for
future reference. The licensee calculated Derived Investigational
Levels as administrative triggers, and made the decision to assign an
internal dose to an individual if the dose exceeded 50 millirem CEDE
from a special body burden analysis (BBA), or exceeded 100 millirem CEDE
from a routine BBA.
Licensee procedure Radiation Protection Directive No. VI-1, "Internal
Dose Assessment," Revision 3, dated June 1, 1995, was the main governing
document for the licensee's internal exposure program. The inspector
reviewed the procedure and noted that initial, annual, and termination
bioassay measurements were routinely required for workers who were
assigned dosimetry. The inspector reviewed records of selected contract
and plant personnel and determined that routine and special BBAs were
performed as required. In addition, special BBAs were performed as
necessary including when individuals underwent nuclear medicine
procedures and when certain incidents, such as facial contaminations,
occurred. Internal exposure was primarily monitored by Derived Air
Concentration-hours (DAC-hours), which were tracked predominately
through general area air sampling; however, doses were only calculated
from measured intakes, and not routinely assigned based solely on
DAC-hours. The inspector noted that a number of minor intakes had
occurred as a result of increased levels of iodine in containment at the
beginning of the outage. As previously mentioned, this was due to the
inordinate amount of failed fuel in the reactor. The inspector
discussed this problem with the licensee and identified no concerns with
the methods employed to handle the problem. During the first days of
the Unit 3 outage, some respiratory protection was used; however,
conservatively, no credit was taken for the protection factor offered by
the iodine canisters when DAC-hours were allocated. Initial followup by
RP was appropriate and was continuing during the inspection. At the
time of inspection, the maximum number of DAC-hours being tracked for a
- II7
single individual was 120 DAC-hours. No internal dose assignments had
been made thus far in 1995. In 1994, the licensee assigned a total of
0.533 person-rem in CEDE. Forty-five millirem was the maximum
individual CEDE assigned.
The inspector discussed respiratory protection with the licensee and
learned that the amount of respirator usage continued to decrease while
airborne hazards continued to be addressed mainly through engineering
controls. Since 1991, respirator usage has decreased roughly fivefold.
Use of full face respirators has decreased more rapidly than
bubblehoods. During the most recent outages of Units 1 and 2,
approximately 1,000 respirators were used in each, whereas
approximately 2,300 respirators were used in the last Unit 3 outage.
This was mainly due to the historically higher contamination levels
found in Unit 3. The number of respirators used during the ongoing
Unit 3 refueling outage was expected to be higher than the other units,
but still continuing on the downward trend. Although respirator usage
has reduced drastically over time and overall work scope has remained
relatively unchanged, no significant increase in internal exposures has
occurred, as noted above.
No violations or deviations were identified.
7.
Surveys, Monitoring, and Control of Radioactive Material and
Contamination (83750)
a.
Monitoring
As part of their self-assessment capability, the RP group informed
the inspector of a project undertaken to assess the plant workers'
frisking practices and knowledge of other radiation work-related
information during the outage. The frisking aspect of the project
was prompted in part due to past problems with controlling
radioactive material. The NRC identified violations and repeat
violations in the 1992-1993 timeframe regarding improper control
of radioactive/contaminated materials (NRC IRs 50-269, 270,
287/92-17 and 93-07).
More recently, the licensee had identified
similar problems and had documented them in the Problem
Identification Process (PIP) system. Part of this recurring issue
appeared to stem from the fact that the licensee maintains at
least 10 RCA entry/exit points.
Maintaining greater than one or
two RCA entry/exits is rare within the industry, and a large
number of RCA entry/exits makes it difficult to control traffic
into and out of the RCA. At Oconee, the inordinate amount of
RCA entry/exits are convenient for the worker, but the worker is
heavily relied upon to always "do the right thing" when entering
and exiting the RCA.
- II8
The inspector reviewed the findings of the frisking observations
made by RP personnel and became concerned. The inspector
discussed the issue with RP personnel and RP management and
concluded that a significant potential existed that
radioactive/contaminated material could exit or has exited the
RCA and the site unbeknownst to the licensee.
Licensee procedure Oconee Nuclear Site Directive 1.1.2,
"Radioactive Material Control," dated August 29, 1994,
delineated the following requirements:
Step 3.1.1 - Personnel Frisking Requirements
Frisk yourself as required below or as otherwise
directed by Radiation Protection (RP).
a)
Perform a minimum of a hand and foot frisk upon
exit of a clean (not contaminated) radiation
control zone (RCZ) located outside the RCA.
b)
Perform a whole body frisk upon exit of a
contaminated area.
c)
Perform a whole body frisk upon exit of the
RCA/RCA Buffer Zone(s) to clean areas.
d)
Perform a minimum of a hand and foot frisk when
entering the RCA Buffer Zone from the RCA prior
to changing elevations. If you are exiting the
RCA and passing through the RCA Buffer Zone to
the Turbine Building (all on same elevation),
you may go directly to the whole body monitor
at the RCA Buffer Zone/Turbine Building boundary
and perform a whole body frisk prior to exiting
the Turbine Building.
Step 3.1.2 - Equipment/Item Frisking Requirements
Frisk/Monitor equipment items for radioactivity as
follows:
a)
Frisk your dosimetry, hard hats and safety
glasses upon exiting a contaminated area or
RCA by wearing them while performing a whole
body frisk in the PCM-1B whole body monitor or
by frisking them with a hand held frisker as
any other hand held item(s).
RP is required to
monitor and release all other items that have
been in contaminated area(s).
9
b)
Frisk hand held items, clean carts and
equipment, food and tobacco products that have
been in an RCZ or the RCA but have not been in
a contaminated area by using the same techniques
and limits required for personnel frisking.
c)
Hand held items carried through the RCA Buffer
Zone(s) do not require frisking if positive
control is maintained of the items to ensure
that they do not have the potential to be
contaminated.
d)
Clean carts, etc., that are rolled through the
RCA Buffer Zone(s) shall have their wheels and
handles frisked prior to exiting the RCA Buffer
Zone to clean areas.
e)
Food, drinks, tobacco products, chewing gum,
etc., may be hand carried through the RCA Buffer
Zone and RCA provided they are in a closed
container and frisked as required for any other
hand held item.
Contrary to the above requirements, during the period of
June 13-26, 1995, the licensee identified: (1) approximately six
instances in which an individual failed to employ proper personnel
frisking requirements as noted in Step 3.1.1 above, and (2)
approximately 158 instances in which personnel failed to employ
proper frisking requirements as noted above in Step 3.1.2 for
hand held items such as hard hats, lunch boxes, coolers,
notebooks/papers, etc. In all instances, after each occurrence
was noted by RP personnel, RP personnel directed the individuals
or items to be properly frisked. Interviews with RP personnel
verified their understanding of the requirements and the
appropriate application of the requirements. The inspector
informed the licensee that the multiple failures to comply with
frisking procedures constituted a violation of NRC requirements.
Although the violation was licensee-identified, its potential for
safety significant consequences, and the extensive nature of the
frisking non compliances identified, is indicative of a
significant weakness in personnel procedural adherence, which
prevented an exercise of NRC discretion for a non-cited violation.
One violation was identified.
b.
Posting and Labeling
10 CFR 20.1601, 10 CFR 20.1602 and 10 CFR 20.1902 specify the
control and posting requirements for high radiation areas (HRAs)
and very high radiation areas (VHRAs).
I
10
10 CFR 20.1902 specifies the requirements for posting certain
areas with a conspicuous sign or signs bearing the radiation
symbol and a precautionary statement describing the area.
10 CFR 20.1904(a) requires the licensee to ensure 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 the radionuclide(s)
present, an estimate of the quantity of radioactivity, the date
for which the activity is estimated, radiation levels, kinds of
materials, and mass enrichment) to permit individuals handling or
using the containers, or working in the vicinity of the containers
to take precautions to avoid or minimize exposures.
During tours of the RCA, the inspector noted that all postings and
labeling observed were appropriate. All signs were conspicuous
and legible, and maps and labels were clearly visible and
informative. The inspector observed the performance of radiation
surveys by RP staff and noted no problems. HRAs and VHRAs were
appropriately controlled and locked.
No violations or deviations were identified.
c.
Radiation Work Permits
On two separate occasions during plant tours (June 26 and 28,
1995), the inspector inquired of radiographers working in the RCA
as to what radiation work permit (RWP) they were working under.
In both cases, upon verification with the RP group, the inspector
discovered that both radiography crews, a total of six workers,
were working under the wrong RWPs. In one case, the crew was
working in the Auxiliary Building while signed in on a Unit 3
Reactor Building RWP. In the other case, the radiography crew was
performing outage-related work under a standing RWP reserved
solely for non-outage work periods. Various licensee procedures
required that work in the RCA and radiation control zones (RCZs)
be performed in accordance with a standing RWP or RWP. Licensee
procedure SRPM III-I, "Use of the Radiation Work Permit,"
Revision 4, dated March 3, 1994, Section 4.0, stated:
RWPs represent one of the primary administrative
controls by which radiological work is planned and
radiation worker safety is addressed. In addition,
they provide a means to trend radiation exposure by
specific jobs. RWPs are a formal documented
mechanism for the RP group to communicate
radiological conditions and controls to radiation
workers. RWPs accomplish this goal in a manner that
postings by themselves cannot, since involvement and
accountability by all workers for proper job conduct
are built into the RWP process.
The inspector compared the RWPs and noted that, while different in
many respects, the controls and requirements of the RWPs that were
being utilized by the radiographers were analogous to the RWP that
should have been used in both instances. In addition, the
inspector observed that the radiographers' work was appropriately
conducted using sound radiation protection principles and
techniques. The inspector informed the licensee and the licensee
agreed that both instances constituted a violation of NRC and
licensee procedural requirements; however, the violation was of
minor significance and is being treated as a non-cited violation
(NCV), consistent with Section IV of the NRC Enforcement Policy.
The other portion of the project discussed in Paragraph 7.a.
involved a poll by RP of plant workers regarding such radiation
work-related information as their RWP, DAD setpoints, DAD alarms,
work area dose rates, TEDE, etc. RP personnel polled
approximately 50 workers, asking a series of nine questions.
The question "What RWP are you working under?" received no
incorrect answers, as did the question "Where is the nearest
Low Exposure Waiting Area?". The number of incorrect answers
ranged from one to seven for questions such as "What are the
DAD setpoints for the RWP?"; "What is the dose rate in your work
area?"; and "What is required when the Electronic Dose Capture
system is not working?". The most incorrect answers (12 each) were
received to questions "What is your TEDE?" and "What are the
alarms sounds of the DAD and what do they mean?". Overall, the
results were acceptable and the inspector considered the poll a
worthwhile exercise with meaningful results; however, at the time
of the inspection, the licensee was unsure as to how the data
would be utilized to effect program improvements.
One NCV was identified.
d.
Area Contamination
According to the licensee, 128,346 square feet (ft2 ) of the RCA
was maintained as controllable. This accounted for the vast
majority of the entire RCA. At the time of inspection, 1,755 ft2
of the controllable RCA was contaminated. The inspector noted
that the licensee was aggressively controlling contaminated square
footage through decontamination and other material condition
upgrades. In June 1995, the ALARA Committee approved a proposal
by RP to conduct a large-scale material condition/reclamation
upgrade of the Auxiliary Building. Work on the project was just
beginning at the time of inspection.
No violations or deviations were identified.
12
8.
Program for Maintaining Exposures As Low As Reasonably Achievable
(ALARA) (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).
The inspector reviewed ALARA Action Items implemented in 1995. Many of
the items involved coordination of RP and Operations to flush hotspots.
For example, hotspots on various piping that read 40,000, 20,000,
15,000, 5,000, 4,000, and 2,500 millirem per hour were flushed and
reduced to 4,000, 600, 70, 8, 1,000, and 5 millirem per hour,
respectively. Other items included cutout of hotspots, installation of
shielding, decontamination, and improved work planning. Other groups
were also involved such as Maintenance, Mechanical Services, and
Engineering. All of the items reviewed by the inspector saved
significant dose and/or significantly improved work conditions or
efficiency.
The inspector noted that many of the items were not "owned" by RP, but
the RP ALARA group was following the progress of the items since all
had potentially significant dose savings associated with them.
The inspector also noted that many of the items came about as a result
of non-RP personnel thinking "ALARA" and making suggestions/proposals.
This indicated that management was effectively supporting ALARA and that
plant workers were recognizing the advantage and benefit to maintaining
dose ALARA.
No violations or deviations were identified.
9.
Review of Previously Identified Inspection Findings (83750)
a.
(Closed) IFI 50-269, 270, 287/94-18-02: Review licensee's
documentation of Duke Power Company's DPW policy, procedures for
processing DPWs, and training of radiation workers on the policy
and procedures.
The inspector reviewed the areas specified in the IFI.
The
inspector found that the licensee's DPW policy was documented and
incorporated into GET/Radworker Training. The inspector reviewed
the GET material and noted no concerns. Radiation workers were
appropriately trained on the policy, which was clear, concise, and
met all of the requirements of 10 CFR Part 20. In addition, the
inspector reviewed licensee procedure SRPM 11-9, "Declared
Pregnant Worker," Revision 0, dated January 20, 1995, which
delineated the procedure for processing DPWs. The inspector noted
that the procedure referenced applicable Regulatory Guides,
discussed allowable exposure limits, and stressed the point that
declaring/undeclaring a pregnancy was strictly voluntary. Based
on the inspector's review, this item is considered closed.
13
b.
(Closed) VIO 50-269, 270, 287/94-34-01: Inadequate corrective
action to licensee audit findings.
The inspector reviewed the licensee's actions in response to the
violation. The inspector noted that the Quality Assurance Topical
Report was revised, effective March 30, 1995, requiring that
procedures must require that conditions adverse to quality be
corrected. It further required that for significant conditions
adverse to quality (i.e., More Significant Events (MSEs) in the
PIP system), procedures must assure that root cause is determined
and action taken to prevent recurrence. The inspector also
reviewed other related revisions-mad2 to Section RA 5.1,
"Regulatory Audits," of the Nuclear Assessment Functional Area
Manual, and NSD 208 of the Nuclear Policy Manual.
No concerns
were noted with those revisions. Based on the inspector's review,
this item is considered closed.
10.
Exit Meeting
At the conclusion of the inspection on June 29, 1995, an exit meeting
was held with those licensee representatives indicated in Paragraph 1
of this report. The inspector summarized the inspection scope and
findings, including the apparent violations. The licensee did not
indicate any of the information provided to the inspector during the
inspection as proprietary in nature. No dissenting comments were
received from the licensee during the exit.
Item Number
Status
Description and Reference
50-269, 270, 287/95-15-01
Open
VIO - Multiple examples of
failure to properly frisk
personnel and equipment/items
(Paragraphs 7.a)
50-269, 270, 287/95-15-02
Closed
NCV - Failure to perform work
under the appropriate RWP
(Paragraph 7.c).
50-269, 270, 287/94-18-02
Closed
IFI - Review licensee's
documentation of Duke Power
Company's DPW policy,
procedures for processing
DPWs, and training of
radiation workers on the
policy and procedures
(Paragraph 9.a).
50-269, 270, 287/94-34-01
Closed
VIO - Inadequate corrective
action to licensee audit
findings (Paragraph 9.b).