ML20141N740

Insp Rept 50-395/86-04 on 860210-14.Violations Noted:Failure to Specify Quantities of C-14 & I-129 on Shipment Manifest & to Adhere to Procedures for Health Physics Computer Software Verification

ML20141N740
Person / Time
Site:	Summer
Issue date:	03/07/1986
From:	Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20141N737	List: ML20141N736 ML20141N738 ML20141N740
References
50-395-86-04, 50-395-86-4, NUDOCS 8603180036
Download: ML20141N740 (9)

See also: IR 05000395/1986004

Text

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Do NUCLEAR RESULATORY COMMISSION

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MAR 11 1986

Report No.: 50-395/86-04

Licensee: South Carolina Electric and Gas Company -

Columbia, SC 29218

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Docket No.: 50-395 License No.: NPF-12

Facility Name: Summer

Inspection Conducted: February 10-14, 1986

Inspector: . c'd o7 3(a

B./K.Revsb y Date Signed

Approved by: Xh 3 /7 /1/,

C. M. Hosey, Section\ Chief Date Signed

Division of Radiatiort Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 38 inspector-hours at the

site during normal duty hours, inspecting: radiation protection program,

including organization and management; training and qualifications of personnel;

external exposure and personal dosimetry; internal exposure control; control of

radioactive materials, posting and labeling; facilities and equipment; solid

radioactive waste; transportation of radioactive materials; and program for

maintaining exposures as low as reasonably achievable (ALARA).

Results: Two violations - (1) failure to specify quantities of carbon-14 and

iodine-129 on the shipment manifest and (2) failure to adhere to procedures for ,

health physics computer software verification.

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REPORT DETAILS

1. Persons Contacted

-Licensee Employees

• 0. S. Bradham, Director, Nuclear Plant Operations

M. N. Browne, Manager, Technical Support

• B. G. Crsley, Deputy Director, Operations and Maintenance

• L. A.' Blue, Manager, Support Services

. *W..H. Baehr, Manager, Corporate Health Physics and Environmental Programs

• J. Cox,' Associate Manager, Health Physics

"A. _ R. Koon, Jr. , Associate Manager, Regulatory Compliance

' *A. A. Morris, Jr. , Nuclear Computer Services Group

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• J. Barker, Corporate Health Physics

• L. C. New, Jr. , Quality Assurance

• R.' M. .Fowlkes, Regulatory Compliance

• J. Dinki,ns, Corporate Health Physics

.0ther licensee employees contacted included four technicians.

l NRC Resident Inspectors

• R. Prevatte, Senior Resident Inspector

• Attended exit interview

2. Exit Interview

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The inspection scope and findings were summarized on February 14, 1986, with

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those persons indicated in Paragraph 1 above. Two apparent violations,

failure to specify quantities of C-14 on the shipment manifest and failure

to adhere to procedures - for health physics (HP) computer software

verification, were discussed in detail . - Licensee management took no

exceptions.

il The licensee did not identify as proprietary any of the materials provided -

to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. Licensee Audits (83724, 83722, 83726, 83725, 86721, 84722, 83723)

The inspector discussed the audit and surveillance program with licensee

representatives in the area of radiation protection training and

qualification,- internal and external expc are control, ALARA, and

radioactive waste' management and transportation. There were two groups that

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audited radiation protection: the Corporate Health Physics group and the

onsite Quality Assurance (QA) group. The following audits were reviewed:

Surveillance II-29-85-T, Nonconformance Control and Cause and

Corrective Action, January 1986

Surveillance II-25-85-L, Station Radiation Control, November 1985

Surveillance 10-JRN-85-Y, Radioactive Waste Solidification,

November 1985

Surveillance 10-AEC-85-Y, Chem-Nuclear Systems, Inc., November 1985

Surveillance II-19-85-H, Station Training and Qualification,

September 1985

Audit GSSS-0282-HPE, Surveys, October 1985

Audit CGSS-0282-HPE, Man-Rem Evaluation and Prediction Program,

July 1985

Audit CGSS-0233-HPE, Training and Personnel Exposure Data, April 1985

The inspector discussed with licensee representatives the qualifications of

the audit teams in the areas being monitored, the responses to these audits

and the status of selective corrective actions resulting from the audits.

No violations or deviations were identified.

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5. Control of Radioa-tive Materials and Contamination, Surveys and Monitoring

(83726)

The licensee was required by 10 CFR 20.201(b), and 20.401 to perform surveys

and to maintain records of such surveys as necessary to show compliance with

regulatory limits. Survey methods and instrumentation were outlined in the

Final Safety Analysis Report ( FSAR), Chapter 12, while Technical

Specification (T.S.) 6.11 required adherence to written procedures for all

operations involv4.1g personnel radiation exposures,

a. Surveys

Survey frequencies and techniques were specified in:

Procedure HPP-410, Health Physics Routine Surveys, Revision 2,

May 17, 1984

Procedure HPP-302, Radiation and Contamination Survey Techniques,

Revision 4, March 24, 1985

The inspector stated that there seemed to be conflicting guidance in

the two prottdures in that HPP-410, Section 5.1.2.1 stated that high

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occupancy areas within the Radiation Control Area (RCA) should be

surveyed weekly for beta and gamma radiation while HPP-302,

Section 4.1.2.1 stated that general area surveys are normally conducted

to measure only gamma radiation levels. The inspector reviewed general

area survey maps and verified that only gamma radiation levels had been

measured.

The inspector also reviewed surveys performed in conjunction with steam

generator work performed during an outage in the fall of 1985. The

following Radiation Work Permits (RWPs) and associated surveys were

reviewed.

RWP No. R82-165, "A" Steam Generator-Rotopeen Steam Generator Hot

Leg Tubes

RWP No. R82-031, Renove and Replace Steam Generator (S/G) Manways

and Diaphragms - S/G "A"

RWP No.82-032, Remove and Replace S/G Manways and Diaphragms -

S/G "B"

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RWP No.82-033, Remove and Replace S/G Manways and Diaphragms -

S/G "C"

The inspector observed that no direct beta radiation surveys had been

documented after removal of the manway on S/G "A", and that only a

single direct beta radiation survey had been obtained for S/G "B" and

for S/G "C". Removable beta contamination surveys had been performed

for all three steam generators. The licensee stated that beta surveys

on S/G "B" and "C" obviated the need for such surveys on S/G "A" since

gamma radiation levels were similar in all three S/Gs. They further

stated that gamma radiation levels could be obtained at the distance

with the extendable probe of the teletector and since there was no

reason to assume that beta levels were significantly different in the

steam generators, they felt that their surveys were ALARA. Licensee

evaluation of the beta spectrum for the plant showed an average beta

energy of 109 kev. Protection of the worker was provided by the

protective clothing / respirator requirements of the RWPs.

During discussions with the inspector, the licensee representatives

stated that Procedures HPP-410 and HPP-302 would be reviewed and

revised as appropriate so that all survey requirements and their

documentation would be clearly specified. The inspector stated that

this will be a followup item and will be reviewed during future

l inspections (50-395/86-04-01).

During plant tours, the inspector performed independent radiation level

! surveys of selected areas using NRC equipment and compared these levels

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with those obtained by the licensee. The inspector noted that all

locked high radiation areas outside of containment were maintained as

required by 1.S. 6.12. The inspector noted that from January 1985, to

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January 1986, the amount of contaminated area in the plant had

decreased from 7979 square feet to 2837 square feet which represented

approximately two percent of .the total area of the plant.

Additionally, the general housekeeping of the plant was excellent.

b. Instrumentation

During plant tours, the inspector observed the use of survey

instruments by plant staff and examined calibration stickers on

radiation protection instruments in use by licensee staff.

No violations or deviations were identified.

6. Facilities and Equipment (83727)

FSAR Chapter 1 and 2 specified plant layout and radiation protection

facilities and equipment. During plant tours, the inspector observed the

cnntaminated clothing laundry, the use of temporary shielding, and

ventilated containment enclosures. The inspector discussed the use of these

items with licensee representatives.

No violations or deviations were identified.

7. External Occupational Dose Control and Personal Dosimetry (83724)

The licensee was required by 10 CFR 20.202, 20.201(b), 20.201, 20.102,

20.104, 20.402, 20.403, 20.405, 19.13, 20.407, and 20.408 to maintain

workers' doses below specified levels and keep records of and make reports

of doses. During observation of work in the plant the inspector observed

the wearing of thermoluminescent dosimeters (TLDs) and pocket dosimeters by

workers.

In 1985, the licensee had purchased a Panasonic 802 TLD system and as of

January 1,1986, were using data provided by this system to assign worker

dose. Both Panasonic TLDs and vendor TLDs had been worn side-by-side during

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the fall 1985 outage and a comparative study had been performed. The

licensee had applied for NVLAP certification and to this end had

successfully completed the performance testing and had received the

accreditation visit from a NVLAP representative several weeks prior to this

inspection period. The inspector reviewed the written evaluation of the

NVLAP representative.

The inspector discussed ti.e quality control (QC) program for the Panasonic

reader with licensee representatives. The licensee stated that QC checks

were usually run using TLD chips that had been irradiated to 500 mrem and

that the reader itself possessed a carbon-14 light source that was read

prior to the start of each tray and before each badge in the tray. The

licensee representative also stated that since NVLAP reaccreditation was

required only once per two years, it was his intention to go through a

" pseudo" NVLAP type testing program utilizing a private laboratory during

the off years. The inspector discussed with the licensee performance of QC

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checks in the range where most station dose was accrued, i.e.,100 mrem or

less, which would substantiate the TLD reader response. The licensee stated

that a response check was not performed in that region.

The . licensee representative performed an industry survey by phone on

February 12, 1986, to determine industry practice in this area. As a

consequence, the licensee stated that they would proceduralize the

requirements of performance testing to meet the criteria of ANSI N13.11 on

the off years when NVLAP accreditation was not being sought using a private

laboratory, and to perform a linearity check of the reader every six months.

The inspector stated that this followup item would be reviewed in future

inspections (50-395/86-04-02).

As of the time of this inspection, the licensee was continuing to badge

radiation workers with Panasonic TLDs and vendor TLDs. The Associate

' Manager, Health Physics stated that this practice would continue until.NVLAP

certification had been achieved by the site. Meanwhile, comparisons between

the two TLD systems was to continue.

The inspector reviewed the administrative dose limits established by the

license and reviewed the evaluations of four cases where worker dose

, exceeded administrative controls without dose extensions.

No violations or deviations were identified.

8. Internal Exposure Control and Assessment (837265)

The Itcensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403, and

20.405 to control uptakes of radioactive material, assess such untakes, and

keep records of and make reports of such uptakes. FSAR, Chapter 12,

includes commitments regarding internal exposure control and assessment.

During plant tours, the inspector observed the use of temporary ventilation

systems and containment enclosures. The inspector discussed the use of this

equipment with HP technicians.

L T. S. 6.11 required that procedures for personnel radiation protection be

prepared consistent with the requirements of 10 CFR 20 and be approved,

maintained and adhered to for all operations involving personal radiation

protection.

Health Physics Procedure HPP-917, Computer Program Testing, specified that

computer outputs be compared with hand calculated results in order to verify

the reliability of Health Physics software used for safety related

functions.

On February 11, 1986, a containment entry was planned with the plant at 100

percent power to replace the pressure transmitter for the pressurizer. The

inspector reviewed the air sampling data that had been collected for the

entry. The inspector noted that for the noble gas grab sample, the printout

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from the computer associated with the GeLi detector showed that the total

Maximum Permissible Concentration (MPC) (i.e., CA/MPCB+ B/MPCB + )

fraction was zero even though noble gas had been identi'ied as being present

in the sample. Xe-133 activity in the sample had been determined to be 7.5

5x10 ' uC1/cc with an MPC value specified in 10 CFR 20, Appendix B.

Table 1, Column 1- of 1x10 ' uCi/cc. Consequently for this nuclide, the

ratio, at a minimum, would have equaled 7.5. The licensee stated that the

computer code was in error. The licensee stated that the computer code had

been changed on January 13, 1986, and while the peak search routine had been

verified, the final value, the total MPC Fraction calculation, had not been

verified. Failure to verify the computer p ogram with hand calculations

was identified as an apparent violation of T. S. 6.11 (50-395/86-04-03).

The . licensee promptly corrected the problem with the computer program and

reviewed all computer printouts that had been generated as a result of the

change that had been effected on January 13, 1986. It was determined that

no NRC limits had been exceeded as a result of the miscalculations. The

inspector reviewed the recalculations.

9. Radiation Protection Staffing

The inspector discussed the status of HP staffing with the Associate

Manager, HP, who stated that staff turnover was low. HP was authorized

38 positions, 35 of which were filled. In addition, the normal complement

of contract HP technicians for routine operation was 16. At the time of

this inspection, 26 HP contract technicians were onsite.

For the recent ' efueling outage, during which extensive S/G work had been

performed,140 contract HP technicians had been utilized, approximately 30

of whom wera used for plant decontamination.

No violations or deviations were identified.

10. Solid Waste (84722)

10 CFR 20.311 required that the licensee maintain a tracking system for

radioactive waste shipments to verify that shipments had been received

without undue delay by the intended recipient. The inspector reviewed the

tracking methodology used by the licensee and examined the documented

receipt acknowledgements in the shipping files for selected shipments made

in 1985 and 1986.

10 CFR 20.311 required a licensee who transfers radioactive waste to a land

disposal facility to prepare all waste so that the waste is classified

according to 10 CFR 61.55.

10 CFR 61.55(a)(8) stated that the concentration of a radionuclide may be

determined by indirect methods such as the use of scaling factors which

relate the inferred concentration of one radionuclide to another that is

measured if there is reasonable assurance that the indirect methods can be

correlated with actual measurements.

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The inspector discussed waste classification with licensee representatives.

The licensee stated that four waste streams were sampled and analyzed

annually. They were dry active waste (DAW), evaporator concentrates, resin

and filters. The scaling factors developed were based on correlating

activation products to Co-60, fission products to Cs-137 and transuranic

radionuclides to Ce-144. The licensee purchased the computer code, RADMAN,

for generating these scaling factors, performing the actual classification

and generating the shipment manifests. The licensee stated that all waste

shipments had been Class A except for one which had been Class C based on

the concentration of Pu-241 in the shipment.

10 CFR 20.311(b) addressed the requirements for the shipment manifest that

must accompany each shipment of radioactive waste to a licensed land

disposal facility. The manifest required by this part must show the total

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quantity of the radionuclides, H-3, C-14, Tc-99 and I-129, that are present

in the shipment.

The inspector reviewed selected waste shipments transported in 1985 and

1986. It was noted that Shipment No. 5087 which consisted of process

filters and was shipped on December 3, 1985, specified zero amounts of C-14

and I-129 on the shipment manifest. Examination of results of annual sample

analysis performed by the offsite vendor showed measurable concentrations of

C-14 for process filters. The licensee stated that C-14 was scaled to

co-60. The inspector stated that since both C-14 and Co-60 were present in

measureable quantities in the annual sample, then necessarily the same

relationship must hold true for shipments. The licensee re-examined the

data on the shipment manifest and the isotopic content as specified from the

gamma analysis. The licensee stated that a mistake had been aade and

performed a manual calculation for total quantity of C-14 in tne shipment.

The actual activity of C-14 present was 2340 mil 11 Curies.

The inspector stated that reporting the quantity of C-14 as zero on the

shipment manifest when the shipment actually contained 2340 mil 11 Curies was

an apparent violation of 10 CFR 20.311(b) (50-395/86-04-04).

The licensee stated that the error das due to an omission in the RADMAN

computer code and promptly notifleo the vendor of this deficiency. The ,

error described above would not have changed the classification of the

waste.

11. Transportation (86721)

10 CFR 71.5 required that licensees who transport licensed material outside

the confines of their plants or other places of use, or who deliver licensed

material to a carrier for transport, shall comply with the applicable

requirements of the regulations appropriate to the mode of transport of the

Department of Trinsportation in 49 CFR Parts 170 through 189.

The inspector reviewed selected records of radioactive waste shipments

performed in FY 1986 and verified that the requirements of 49 CFR Parts 170

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through 189 had been met for those shipments. The inspector verified that

the licensee was registered with the NRC for packages used in January 1986.

No violations or deviations were identified.

12. Statistics

a. Solid Waste

During 1985, the licensee had made 40 shipments of radioactive waste

consisting of 15,750 cubic feet of waste containing 138 curies of

activity. As of January 1., 1986, the waste inventory onsite was 112

cubic feet containing 16 curies of activity,

b. Contaminated Areas

On January 1,1986, the amount of contaminated area in the plant was

2837 square feet which represented approximately two percent of the

total plant area.

c. Collective Man-Rem

For 1985, an outage year for the licensee, the collective dose for the

facility as measured by TLD was 358 man-rem. For 1986, a projected

estimate of the collective dose was 24 man-rem.

13. IE Information Notices (92717)

The following IE Notices were reviewed to ensure their receipt and review by

appropriate licensee management.

IN-85-43, Radiography Events at Power Reactors

IN-85-85, Hazards of Inverting Atmospheres

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