ML18004B947
| ML18004B947 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/22/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8709290481 | |
| Download: ML18004B947 (7) | |
See also: IR 05000400/1987022
Text
(
ACCESSION
NBR
F*CIL 50-400
AUVH. NAME
GRACEI J. N.
'RECIP. NAME
UTLEYiE. E.
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
8709290481
DOC. DATE: 87/09/22
NOTARIZED:
NO
Sheav on Harv is Nucleav
Poujer Planti
Unit ii Carolina
AUTHOR AFFILIATION
Region
2I Offi ce of Director
RECIPIENT AFFILIATION
Carolina
Power
8c Light 'Co.
DOCKET
05000400
SUBJECT:
Ack
v eceipt of 870821 ltv denying violations noted
in Insp
Rept 50-400/87-22.
Cov v ective steps
ujhich eill be taken
requested
ujithin 30 days of ltv'ate.
DISTRIBUTION CODE:
IEOID
COPIES
RECEIVED: LTR l ENCL g
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violatio'n Response
NOTES: Application For permit
v eneeal filed.
05000400
REC IP IENT
ID CODE/NAME
PD2-1
INTERNAL: AEOD
MOR ISSEAUi D
NRR/DREP/EPB
NRR/DRIS DIR
EBERMANI J
EG FI
FILE
01
XTERNAL: LPDR
COPIES
LTTR ENCL
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
REC IP IENT
ID CODE/NAME
BUCKLEYiB
DEDRO
NRR/DOEA DIR
NRR/DREP/RPB
NRR/PMAS/ILRB
OGC/HDS1
DEPY GI
NRC
COP 1ES
LTTR ENCL
2
2
1
1
1
1
2
2
1
1
1
1
1
1
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
20
ENCL
20
Carolina
Power and Light Company
I-ATTN:
Mr. E.
E. Utley
Senior Executive Vice President
Power Supply and Engineering
and Construction
P. 0.
Box 1551
'aleigh,
NC
27602
Gentlemen:
SUBJECT:
NRC
INSPECTION
REPORT
NO. 50-400/87-22
rn
V)
I
CA
Thank you for your
response
of August 21,
1987,
to our Notice of Violation,
issued
on July 8,
1987,
concerning activities conducted at your Shearon
Harris
facility.
We
have
evaluated
your
response
and
found that it meets
the
requirements
of 10 CFR 2.201.
After careful
consideration
of the bases
of your denial of the Violation, we
have determined, for the reasons
presented
in the enclosure
to the letter, that
the violation occurred
as
stated
in the Notice of Violation.
Therefore,
in
accordance
with 10 CFR 2.201(a),
please
submit to this office within 30 days of
the date of this letter,
a written statement
describing
steps
which have
been
taken to correct the violation and the results
achieved,
corrective steps
which
will be utilized to avoid further violations,
and the date
when full compliance
will be achieved.
The
responses
directed
by this letter
are
not subject
to the
clearance
procedures
of the Office of Management
and Budget
as required
by the Paperwork
Reduction Act of 1980,
PL 96-511.
We appreciate
your cooperation
in this matter.
Sincerely,
Enclosure:
Staff Assessment
of Licensee
Response
cc w/encl:
~
A. Watson,
Vice President
Harris Nuclear Project
W L. Tibbitts, Director of Regulatory
Compliance
L. Willis, giant General
Manager
O-'"'
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J.
Nel son
Grace
Regi onal
Administrator
8709'290481
8709Z2
ADOCK 05000400
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Carol ina Power and Light Company
bcc w/encl:
Barth,
PIRC Resident
Inspector
A. Upchurch,
Chairman, Triangle J
Council of Governments
Document Control
Desk
State of North Carol ina
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ENCLOSURE
Staff Assessment
of Licensee
Response
Restatement
of Violation
requires
that
each
licensee
make or cause
to
be
made
such
surveys
as
may
be necessary
for the licensee
to comply with the regulations
in
10 CFR 20, and are reasonable
under the circumstances
to evaluate
the extent of
radiation hazards
that
may be present.
A survey is defined in 10 CFR 20.201(a)
as
an evaluation
of the radiation
hazards
incident to the production,
use,
release,
disposal,
or
presence
of radioactive materials
or other
sources
of
radiation under
a specific set of conditions.
specifies
the quarterly occupational
radiation
dose limits to
the lens of the eyes
and the skin of the whole body.
Contrary to the above,
the'licensee
failed to perform adequate
evaluations of
individual
exposures
to
noble
gas
in that
algorithms
used
to covert
thermoluminescent
dosimeter
(TLD) readings
to skin and lenses
of the eye dose
for personnel
who
made
containment entries
on June. 17,
1987,
and before
were
inappropriate for the noble gases
present
in containment.
The licensee
used
no
other dose
assessment
technique to assess
doses
due to noble gases.
L'icensee
Comment
The violation as
stated
was denied.
The licensee
stated that adequate
dose
evaluations
were
being
performed
in accordance
with
and that the
dose evaluations
were reasonable-under
the circumstances
to evaluate
the extent
of radiation hazards
that
may have
been present.
This position is based
on the
following:
(1) the
TLD dose algorithm was adequate
considering concentrations
of noble
gas
found in containment,
and
(2) it was
reasonable
for radiation
protection
personnel
to assume,
based
on the low concentrations
of noble gases
measured
during routine monitoring and the expected
MPC-hours of exposure,
that
personnel
dose
from the noble
gas would be insignificant and that further dose
evaluations
were not necessary.
NRC Res
onse
The licensee's
response
implies that
an informed judgement
.had
been
made
by
onsite
radiation protection
personnel
that the
TLD was
adequate
to monitor
exposures
from inconsequential
noble
gas concentrations.
The onsite personnel
actually were unaware of the capabilities of the
TLD in this regard.
The noble
gas concentrations
in the vicinity of the work were riot known since noble gas
air
samples
in the
work area
were
not taken.
The installed
Radiation
Monitoring System
(RMS) indicated
noble
gas concentrations
in containment
were
approximately at
Maximum Permissible
Concentration
(MPC) levels,
although
the
licensee
had not yet concluded tests to demonstrate
how representative
the
readings
were for various
areas
in containment.
Offsite personnel
were aware
of the TLD's capabilities,
but had not communicated this to onsite
personnel
Encl osure
and
were
not involved routinely in the daily personnel
protection decision
process
at the plant.
Thus the onsite
health
physics staff who controlled
exposures
to workers,
did not
have in 'place
a system to provide sufficient
information on total dose.
Lacking information on the dose to workers from the
noble gas,
the
dose
evaluations
were not reasonable
or adequate.
They were
based
on the erroneous
assumption that the
TLD measured
the noble
gas exposure.
In order for an evaluation
to
be
considered
acceptable,
the licensee
must
include
an assessment
of the potential
source
and the capability of the
TLD to
measure
exposures
from that source.
In this case,
the licensee
did neither,
but rather
assumed
there
was
no problem in the absence
of data.
Licensee
Comment
The
TLD dose algorithm utilizes beta correction factors which are based
on the
range of beta
energies
most responsible for personnel
exposure.
Although some
noble
gases
emit beta particles
with energies
outside of this
range,
the
resultant
dose
which
may
go
unassigned
is
very
small.
Conservative
calculations
based
on air sampling
results
at
SHNPP
show that the
maximum
potential
unassigned
dose to any individual during the first two quarters of
1987 were less
than
7 mrem to the skin and I mrem to the lens of the eye.
Such
low doses
are considered
insignificant.
Therefore the assumption
by radiation
protection
personnel
that
the
TLD would adequately
monitor the exposure
of
personnel
entering containment
was correct.
NRC Res
onse
Prior to the
NRC calling the situation to the attention of station personnel,
they were not aware that the dose
from certain noble gases
were not measured
by
the
TLD.
Although the station personnel's
subsequent
evaluation
has
shown the
dose
from unmeasured
exposure
to noble
gas
was
low, there
was
a failure to
perform an adequate
evaluation prior to exposing workers to the noble gas.
The
onsite radiation
personnel
stated
to the. inspector that they thought that the
TLD was measuring
the noble
gas exposure,
which it wasn'.
They did not assume
that
the
noble
gas
hazard
was insignificant
and therefore
did not warrant
monitoring.
Had
there
been
a significant
noble
gas
concentration
in
containment,
the control
systems
in place would not have called for changes
as
workers accumulated
dose from noble gas since station staff believed that their
TLD was monitoring the noble gas exposure.
Licensee
Comment
The maximum unassigned
doses
to the skin and lens of the eye correspond
to less
than
0. 1% of the
applicable
quarterly
dose
limits in
NRC
regulations
do not require monitoring when exposure
is not expected
to exceed
25K of the quarterly limit.
NRC Res
onse
The licensee's
position would be relevant if workers only received
exposures
during the 'quarter
from a small
number of noble gas exposures.
But many plant
. workers
receive
exposures
from other sources
during the quarter which are in
~ Encl osure
excess
of the
record
keeping criteria.
Measurable
noble
gas
exposure
then
becomes
part of the worker's cumulative quarterly exposure.
It should also
be
noted
that
the
licensee
would not
have
known whether or not minor or
significant exposures
were being received
because
their TLDs were not capable
of monitoring this dose,
and they did not assess
the potential
exposure
by any
other means.
Licensee
Comment
In conclusion,
the
dose
assessment
techniques
used for
SHNPP were adequate
to
evaluate
the
exposure
to noble
gases.
However,
CP8L recognizes
that with
continued .plant operation,
the potential for higher noble
gas levels exists.
If this occurs, it will be
noted during routine monitoring
and appropriate
actions will be
taken
to ensure
that
dose
evaluations
are
reasonable
to
evaluate
the extent of any radiation hazard present.
NRC Res
onse
i
The staff does not agree with the licensee's
conclusion.
The station personnel
charged with controlling dose to workers did not assess
the dose from noble
gas
exposure,
therefore
the dose
assessment
technique
could not have been adequate.
The
TLD algorithms
were not capable of measuring
the dose
from noble gas,
and
no other
dose
assessment
technique
was used.
The onsite personnel
incorrectly
assumed
the
TLD could
measure
dose
from noble
gas
exposure.
The licensee's
evaluation
showed that resultant
errors in total
dose
were low, however,
the
adequacy
of the dosimetry to measure
noble gas,
the concentration of noble gas
and
the likely doses
to
be
encountered
had
not
been
evaluated
prior to
assigning
dosimetry
and establishing
work controls.
The licensee
had
not
established
a system to establish
controls to ensure that, if noble gas levels
become higher, they will be appropriately identified and evaluated.
NRC Conclusion
For
the
above
reasons,
the
NRC staff concludes
that the violation occurred
as
stated.