ML20141N740
| 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: |
| References | |
| 50-395-86-04, 50-395-86-4, NUDOCS 8603180036 | |
| Download: ML20141N740 (9) | |
See also: IR 05000395/1986004
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UNITED STATES
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NUCLEAR RESULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET, N.W.
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ATLANTA.CEORGI A 30323
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MAR 11 1986
Report No.: 50-395/86-04
Licensee:
South Carolina Electric and Gas Company
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Columbia, SC 29218
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Docket No.:
50-395
License No.:
Facility Name:
Summer
Inspection Conducted:
February 10-14, 1986
Inspector:
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Date Signed
B./K.Revsb y
Approved by:
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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
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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.
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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.
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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,
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.
5.
Control of Radioa-tive Materials and Contamination, Surveys and Monitoring
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(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
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inspections (50-395/86-04-01).
During plant tours, the inspector performed independent radiation level
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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
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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
the fall 1985 outage and a comparative study had been performed.
The
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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.
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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.
T. S. 6.11 required that procedures for personnel radiation protection be
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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
quantity of the radionuclides, H-3, C-14, Tc-99 and I-129, that are present
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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.
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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
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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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