ML20132B079
| ML20132B079 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 01/09/1985 |
| From: | Albright R, Cooper W, Jenkins G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20132B058 | List: |
| References | |
| 50-269-84-33, 50-270-84-30, 50-287-84-34, NUDOCS 8507230416 | |
| Download: ML20132B079 (10) | |
See also: IR 05000269/1984033
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 88
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101 MARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323
JAM 2 3 25
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Report Nos.:
50-269/84-33, 50-270/84-30, and 50-287/84-34
Licensee:
Duke Power Company
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-422 South Church Street.
Charlotte, NC: 28242
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Docket Nos.: 50-269, 50-270, and 50-287
License Nos.:
-Facility Name:
Oconee 1, 2, and 3
Inspection Conducted:
November 26-30, 1984
Inspectors:
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R.
Albright
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Date Signed
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W. T. Coo e q //
Date Signed
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-Approved by:
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G. R. J 12 ns, S6ction Chief
Date Signed
Divisi
f Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection involved 78 inspector-hours on site
in the- areas of external exposure control and personal dosimetry, internal
exposure control and assessment, and control of radioactive materials and
contamination, surveys and monitoring.
Results:
Two violations were identified.
Unauthorized disposal of radioactive
material (paragraph 6), and failure to post an airborne radioactivity area
(paragraph 4).
8507230416 850123
ADOCK 05000269
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REPORT DETAILS
1.
Licensee Employees Contacted
- M. S. Tuckman, Oconee Nuclear Station Manager
- T. Barr, Superintendent of Technical Services
- R. T. Bond, Compliance Engineer
- D. Davidson, Compliance Engineer
- C. L. Harlin, Health Physics Staff
- B. P. Cripe, Health' Physics Staff
- B. Jones, Chemistry Staff
'0. L. Whit, Quality Assurance
Other licensee employees contacted included technicians and office
personnel.
NRC Resident Inspector
J. Bryant, Senior Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on November 30, 1984, with
those persons indicated in paragraph 1 above.
The violations for
unauthorized disposal of radioactive material (paragraph 6) and failure to
post an airborne radioactivity area (paragraph 5) were discussed with
licensee management.
Licensee management stated their position that the
airborne radioactivity area was not required to be posted because exposure
to noble gases is treated as external exposure in accordance with 10 CFR 20,
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3.
Licensee Action on Previous Enforcement Matters
(Closed) UNR (270/84-25-01) - This item was determined to be a violation and
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is discussed further in paragraph 5.
4.
External Exposure Control and Personal Dosimetry (83724)
10 CFR 20.101(b)(3) requires the licensee to determine an individual's
accumulated occupational dose to the whole body on an NRC Form 4 or
equivalent record prior to permitting the individual to exceed the limits of
20.101(a).
The inspector reviewed selected occupational exposure histories
of individuals who exceeded the values in 10 CFR 20.101(a).
The exposure
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histories were being completed and maintained as required by 10 CFR 20.102.
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10 CFR 20.202 requires each licensee to supply appropriate personnel
monitoring equipment to specific individuals and requires the use of such
equipment.
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During tours of the plant, the inspector observed workers wearing appro-
priate personnel monitoring devices.
The inspector reviewed selected active RWPs for appro,
teness of the
radiation protection requirements based on work scope, location, and
conditions.
20.401(a) requires each licensee to maintain records showing the radiation
exposure of all individuals for whom personnel monitoring is required under
20.202 of the regulations.
Such records shall be kept on Form NRC-5 or
equivalent.
The inspector reviewed selected individual exposure recrrds maintained by
the licensee for personnel employed at the plant.
10 CFR 20.201 requires licensees to make surveys as may be necessary to
comply with the regulations in 10 CFR 20 and which are reasonable under the
circumstances to evaluate the extent of radiation hazards that may be
present.
A survey is defined as an evaluation of the radiation hazards.
The inspector reviewed a licensee report of possible overexposure for
personnel working in the secondary side of the steam generator when their
extremity pocket dosimeters were found offscale.
The work being performed
involved adjusting an orifice plate in the secondary side of the 1A steam
generator.
Extremity and whole body doses were monitored by TLD and pocket
dosimeters located on the hands, upper arm and chest.
The highest extremity exposure for the four workers involved was 10.829 rem.
The quarterly extremity exposure limit is 18.75 rems.
The highest whole
body dose received was 1.080 rems.
The quarterly whole body exposure limit
is 3.0 rems.
The preplanning work package for this job indicated that the
highest dose rate would be from the steam generator tubes and gave the
highest previous dose rate as 17 R/hr.
The vendor health physics technician
who did the survey for the job read the preplanning work package; however,
when he made the initial survey, he surveyed only the handhole area and
found up to 3.3 R/hr.
About halfway through the job, this technician read the pocket dosimeters
located at the extremity and chest for the workers and found approximately
150 mrem at the chest and 1 rem for the right hand.
Near the end of the
work, a second vendor health physics technician took over the surveillance
and discovered the steam generator tubes were reading 21 R/hr.
He checked
the wrist and upper arm dosimetry for the individual doing most of the work.
At the end of the work, the right hand dosimetry for three personnel was
offscale.
No actual overexposures occurred.
The licensee investigation
determined the apparent cause of the incident as 1) inadequate radiation
surveys, 2) inadequate determination of which portion of the body was
receiving the highest exposure, and 3) inadequate monitoring of pocket
dosimeters at the extremities, upper arm, and chest during the work.
The
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licensee restricted the workers from the restricted area until their
exposures were determined.
The health physics technicians involved received
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disciplinary action and the incident was reviewed with the HP staff.
The
investigation report was also being routed to the HP staff for review and
this incident will be included in the preplanning work package for future
work on the secondary side of the steam generator.
The licensee had preplanned the work and had established adequate measures
for exposure control.
Personnel errors resulted in an inadequate evaluation
for the work.
The inspector stated that this is a violation of
However, since the violation meets the criteria of 10 CFR 2,
Appendix C for a licensee identified violation, no enforcement action will
be taken.
10 CFR 20.203 specifies the posting, labeling and c.ontrol requirements for
radiation areas, high radiation areas, airborne radioactivity areas and
radioactive material.
10 CFR 20.203(d) requires that each airborne radio-
activity area shall be conspicuously posted with a sign or signs bearing the
radiation caution symbol and the words:
" Caution - Airborne Radioactivity
Area".
Airborne radioactivity area is defined as any room, enclosure, or
operating area in which airborne radioactive materials composed wholly or
partly of licensed material exists in concentrations in excess of the
amounts specified in Appendix B, Table I, Column I of 10 CFR 20, or when, in
any of the areas listed above, airborne radioactive material when averaged
over the number of hours in any week during which the individuals are in the
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area, exceeds 25 percent of the amounts specified in Appendix B, Table I,
Column I of 10 CFR 20.
During tours of the plant, the inspector reviewed the licensee's posting and
control of radiation areas, high radiation areas, airborne radioactivity
areas, contamination areas, radioactive material areas and the labeling of
radioactive material.
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10 CFR 19.11 requires that each licensee post current copies of 10 CFR 19
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and 10 CFR 20 or if posting of the documents is not practicable, the
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licensee may post a notice which describes the document and states where it
may be examined.
10 CFR 19.11 further requires that copies of any Notice of
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Violation involving radiological working conditions be conspicuously posted
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within two working days after receipt of the documents from the Commission.
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The inspector observed the posting of notices required by 10 CFR 19.11
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during tours of the plant.
The inspector reviewed the licensee's program for handling and leak testing
sealed sources containing byproduct, source and special nuclear materials as
required by Technical Specification (TS) 4.16.1.
The inspector examined
survey records for 11 sealed sources for 1982, 1983 and 1984.
The inspector
also reviewed the licensee's " Health Physics Source Handling Procedure"
which implements TS 4.16.1 requirements.
Two separate records are currently
maintained to demonstrate compliance with the TS requirements.
Record
number 1 is a log book which indicates the sealed source number, the date of
the surveillance and the smear survey activity for all sources requiring
surveillance.
Record number 2 is Enclosure 5.1 to procedure number
HP/0/8/1C05/01 Health Physics Source Handling procedure which documents the
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source location, the leak test date, inventory date and the initials of the
employee performing the surveillance.
The use of multiple records for the
same surveillance resulted in one record not being completed for the leak
test of one source (#0NS-144).
However, the second record showed that the
source leak test had been performed within the required time frame.
A
licensee representative stated that the two separate records would be
combined to make one record.
5.
Internal Exposure Control (83725)
10 CFR 20.103(a) establishes the limits for exposure of individuals to
concentrations of radioactive materials in air in restricted areas.
This
section also requires that suitable measurements of concentrations of
radioactive materials in air be performed to detect and evaluate the
airborne radioactivity in restricted areas and that appropriate bioassays be
performed to detect and assess individual intakes of radioactivity.
The inspector reviewed selected results of general in-plant air samples
taken during the period June - August 1984 and the results of air samples
taken to support work authorized by specific radiation work permits.
The inspector reviewed selected results of bioassays (whole body counts) and
the licensee's assessment of indiviaual intakes of radioactive material
performed during the period June - November 1984.
10 CFR 20.103(b) requires that when it is impracticable to apply process or
engineering controls to limit concentrations of radioactive material in air
below 25% of the concentrations specified in Appendix B, Table 1, Column 1,
other precautionary measures should be used to maintain the intake of
radioactive material by an individual within seven consecutive days as far
below 40 MPC-hours as is reasonably achievable.
By review of records,
observations and discussions with licensee representatives, the inspector
evaluated the licensee's respiratory protection program, including medical
qualifications, MPC-hour controls and quality of breathing air.
The inspector reviewed the analysis data for brecthing air quality.
A cross
contamination analysis is performed on the system on a quarterly frequency
and the air meets grade D breathing air requirements.
Health Physics procedure HP/0/B/1000/81 requires that only instrument air be
used for diving operations as the breathing air system does not supply the
necessary air pressure.
The inspector reviewed analysis data for the
instrument air system and found that the air met grade D quality specifica-
tions.
However, the licensee did not perform a radionuclide contamination
check on the instrument air.
The inspector stated that the licensee should
implement a radionuclide test program for the instrument air system when
used for diving operations.
The licensee stated that a procedure change
will
specify sampling the instrument air for radionuclide cross
contamination.
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10 CFR 20.103(a)(3) requires that for the purposes of determining compliance
with the requirements the licensee sha!1 use suitable measurements of
concentrations of radioactive material i i air for detecting and evaluating
airborne radioactivity in restricted areas and in addition, as appropriate,
shall use measurements of radioactivity in the body, measurements of radio-
activity excreted from the body, or any combination of such measurements as
may be necessary for timely detection and assessment of individual intakes
of radioactivity by exposed individuals.
10 CFR 20.103(b)(2) requires that
whenever the intake of radioactive material by an individual exceeds 40
MPC-hours in a seven day period, the licensee shall make such evaluations
and take such actions as may be necessary to assure against recurrence.
The
licensee shall maintain records of such occurrences, evaluations, and
actions taken in a clear and readily identifiable form suitable for summary
review and evaluation.
A review and discussion with licensee representatives of the body burden
analysis program
indicated that the program was not established to ensure
that body burden analyses are reviewed to determine if personnel have
exceeded 40 MPC-hours in a seven day period.
The inspector determined that
there were investigation points which would cause internal dose evaluations;
however, these investigation points for certain radionuclides would be
reached after the individual had been exposed to significantly greater than
40 MPC-hours in a seven day period.
At the established investigation points
an MPC-hour calculation was not required by the licensee program.
The
inspector reviewed selected body burden analyses for the period June -
November 1984 and found no indications that personnel had been exposed to
greater than 40 MPC-hours in a seven day period.
The calculation of
MPC-hours for individuals who have body burdens which could be the result of
greater than 40 MPC-hours in a seven day period is required so that the
required investigation and corrective action can be identified and docu-
mented.
Licensee management acknowledged the need for the program to be
changed.
The inspector stated that this is an inspector followup item and
will be reviewed during the next inspection (269/84-31-01, 270/84-30-01,
287/84-34-01).
During the review of the licensee's radiological survey data, the inspector
noted the presence of low levels of alpha radiation on some equipment used
during refueling operations.
Licensee representatives stated that the
equipment was used in all three units during refueling and that the
contamination possibly occurred in Unit 3, which did have fuel leakage when
the equipment was used.
The inspector questioned licensee representatives
about the counting equipment used for alpha detection and the equipment's
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ability to detect the low levels of alpha radiation on air samples necessary
to insure that the alpha radiation did not pose an internal exposure hazard
to employees.
Alpha measurement problems are discussed.in Inspection Report
No. 50-269/84-30, 50-270/84-29 and 50-287/84-32.
Licensee representatives
stated that alpha contamination was low in comparison to beta gamma
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contamination and that personnel protection from the beta gamma contaminants
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has been adequate to protect from the alpha contaminants.
The inspector
stated that alpha contamination may increase due to the fuel leakage and
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changes to the air sampling program could be necessary to accommodate
sensitivity problems with laboratory counting equipment.
10 CFR 20.203 specifies the posting, labeling and control requirements for
radiation areas, high radiation areas, airborne radioactivity areas and
radioactive material.
10 CFR 20.203(d) requires that each airborne
radioactivity area shall be conspicuously posted with a sign or signs
bearing the radiation caution symbol and the words:
" Caution - Airborne
Radioactivity Area".
Airborne radioactivity area is defined as any room,
enclosure, or operating area in which airborne radioactive materials
composed wholly or partly of licensed material exists in concentrations in
excess of the amounts specified in Appendix B, Table I, Column I of 10 CFR 20, or when, in any of the areas listed above, airborne radioactive material
when averaged over the number of hours in any week during which the
individuals are in the area, exceeds 25 percent of the amounts specified, in
Appendix B, Table I, Column I of 10 CFR 20.
NRC Region II Report Nos. 50-269/84-26, 50-270/84-25, and 50-287/84-28
discussed an unresolved item, UNR 50-270/84-25-01, concerning the failure to
post an airborne radioactivity area.
On October 1,1984, the resident
inspector was cautioned that the area outside the Unit 2 waste gas decay
tank room contained airborne noble gas.
The area was not posted as an
airborne radioactivity area.
The licensee measured noble gas concentration
of Xe-133 at 2.7 times its concentration listed in 10 CFR 20 Appendix B and
Xe-135 at 4.6 times its concentration listed in 10 CFR 20 Appendix B.
The
inspector discussed the failure to properly post the area as an airborne
radioactivity area with licensee representatives.
The licansee did not
agree that the area had to be posted as an airborne radioactivity area since
the xenon is inert and the gas is not an internal hazard.
10 CFR 20 allows
the licensee to account for exposures to noble gases as part of the
quarterly external exposure limits of 10 CFR 20.101.
The inspector stated
that the method by which the licensee chooses to account for exposure to the
noble gas, as described in 10 CFR 20.103(a)(1), does not allow for exemption
from the requirement to post airborne radioactive areas as stated in 10 CFR 20.203(d).
The failure to post the areas containing the xenon gas in
concentrations above those which require posting as an airborne radio-
activity area is a violation of 10 CFR 20.203(d) (270/84-30-02).
6.
Surveys, Monitoring, and Control of Radioactive Material (83726)
10 CFR 20.201(b) requires each licensee to make or cause to be made such
surveys as (1) may be necessary for the licensee to comply with the regula-
tions and (2) are reasonable under the circumstances to evaluate the extent
af .adiation hazards that may be present.
The 11spector reviewed procedure HP/0/8/1000/54 which established the
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licensee's radiological survey and monitoring program and verified that the
procederes were consistent with regulations and good health physics
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Procedure HP/0/B/1000/54 outlines the base schedule and frequency for the
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radiological survey and monitoring program.
The inspector reviewed selected records of radiation and contamination
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surveys performed during September and October 1984 and discussed the survey
results with licensee representatives.
During tours of the plant the inspector observed the health physics
technicians performing radiation and contamination surveys.
The inspector performed independent radiation surveys in the auxiliary
building and in the restricted area outside the auxiliary building and
verified that the areas were properly posted.
The inspector discussed with the licensee the method used to release
material from the restricted area and observed technicians performing
release surveys for material.
10 CFR 20.301 forbids a licensee to dispose of licensed material as waste
except 1) by transfer to an authorized recipient as provided in the regula-
tions in Parts 30, 40, 60, 61, 70, or 72 of this chapter, whichever may be
applicable, or 2) as authorized pursuant to 10 CFR 20.302 or 10 CFR 61, or
3) as provided in 10 CFR 20.303, applicable to the disposal of licensed
material by release into sewage systems, or in 10 CFR 20.306 for disposal of
specific wastes, or in 10 CFR 20.106 (radioactivity in effluents to
unrestricted areas).
The inspector reviewed a licensee investigation for the disposal of approxi-
mately 13.5 microcuries of Cs-137 and 1.18 microcuries of Cr-51 in 18,635
gallons of waste oil during the period September 1981 to June 1984.
The
waste oil was shipped to a fossil fueled plant to be burned.
Environmental
surveys around the fossil fueled power plant subsequent to the burning did
not indicate high radioactivity levels.
Duke Power Company internal
correspondence dated March 25, 1981, indicated that waste oil from oil
sources on the primary side could be handled differently than oil sources
from the secondary plant.
The correspondence indicates that it was under-
stood by Duke Power Company that there were no exempt concentrations of
licensed material when it originated from contaminated systems on the
primary side.
However, they determined that oil from the secondary system,
principally turbine oil, would not normally be considered contaminated and
after a survey if less than exempt quantities per 10 CFR 30.18 were measured
the oil could be disposed or by burning without additional regulatory agency
approval.
The inspector reviewed the licensee's response to IE Information Notice No. 83-05.
The IE Information Notice stated that a license application had
to be initiated for any method of disposing of radioactive material which
was not described in the regulations.
Their response to the general office
(GO) did not question the disposal of contaminated waste oil which was being
shipped to the fossil fuel steam plant for burning.
The problem was first
realized by GO personnel who read a letter from NRC Region II dated
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March 20, 1984, to the McGuire plant where the allowed use of the exempt
quantity as defined by 10 CFR 30.18 was explained.
Shortly after the last
shipment of contaminated oil was made, GO personnel realized that the NRC
interpretation of 10 CFR 30.18 would not allow it to be used for disposal
purposes.
The plant was notified by the GO not to ship contaminated oil on
July 25, 1984.
Near the end of September 1984, the NRC Region II was
notified that the licensee had disposed of radioactive material in the oil.
The inspector stated that the unauthorized disposal of licensed radioactive
material was a violation of 10 CFR 20.301 (269/84-31-02, 270/84-30-03, and
287/84-34-02).
7.
ALARA Program (83728)
10 CFR 20.lc states that persons engaged in activities under licenses issued
by the NRC should make every reasonable effort to maintain radiation
exposure as low as reasonably achievable (ALARA).
The recommended elements
of an ALARA program are contained in Regulatory Guide 8.8, Information
Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power
Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for
Maintaining Occupational Radiation Exposures ALARA.
The inspector determined the ALARA goals and objectives for the current year
from licensee representatives and reviewed the man-rem estimates and results
for the current year.
As of November 30, 1984, the actual collective exposure for calendar year
1984 was 1056 man-rem which represented approximately 90 percent of the
estimated exposure for the year.
No violations or deviations were identified.
8.
Information Notices (93717)
The inspector reviewed licensee responses to the following Information
Notices:
84-24
Physical Qualification of Individuals to Use Respiratory
Protective Devices
04-34
Respirator Users Warning:
Defective Self-Contained Breathing
Apparatus Air Cylinders
84-40
Emergency Worker Doses
84-61
Overexposures of Diver in Pressurized Water Reactor (PWR)
Refueling Cavity
84-59
Deliberate Circumventing of Station Health Physics Procedures
84-60
Failure of Air Purifying Respirator Filters to Meet Efficiency
Requirement
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84-75
Calibration Problems - Eberline Instrument Model 6112B Analog
Teletectors
From the' review and discussions with licensee personnel, the inspector
determined that appropriate evaluations of these IE Information Notices had
been made. -The inspector had no further questions.
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