ML20197J472
| ML20197J472 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/06/1986 |
| From: | Tucker H DUKE POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8605200048 | |
| Download: ML20197J472 (3) | |
Text
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bb DUKE Powen GOMPANY I,*.
(OX 33180 Opt'
., N.O. 28242
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IIAL H. TUCKER TE1JtPHONE s '.
(704) 373-4531
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May 6, 1986 (Dr.TJi$aloon_ Grace,[RegionalAdministrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW,~ Suite 2900 Atlanta, Georgia 30323
Subject:
Oconee Nuclear Station IE Inspection Report 50-269/86-05 50-270/86-05 50-287/86-05
Dear Sir:
In regard to my April 26, 1986 response to the cited item of non-compliance, please find attached a revision to my response. The revision corrects a typographical error.
Very truly yours, Hal B. Tucker PJN: sib Attachicent xc:
Mr. J. C. Bryant NRC Resident Inspector Oconee Nuclear Station 8605200048 860506 PDR ADOCK 05000269 G
PDR I
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,, Violation 10 CFR 20.103(b)(2) requires that when it is impracticable to apply process on other engineering controls to limit concentrations of radioactive material in air below those defined in 10 CFR 20.203(d)(.)(ii), other precautionary procedures, such as increased surveillance, limitation of working times, or provision of respiratory protective equipment, shall be used to maintain intake of radioactive material by any individual within any period of seven consecutive days as far below that intake of radioactive material which would result form inhalation of such material for 40 houru at the uniform concentrations specified in Appendix B, Table 1, Column 1 as is reas>nably achievable.
Contrary to the above, the requirement to use precautionary procedures to maintain intake of radioactive material by any individual as far below that intake of radioactive material which would result from inhalation of such material for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform concentra*;
-- ci fied in Appendix
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B, Table I, Column 1, as is reasonably achievabt.._
-'* in that on March 28 and 29, 1985, eleven individuals were allowed to,- torm work in Unit 3 containment without using proper respiratory protective equipment to reduce the intake of radioactive material. The individuals had intakes ranging from five to thirty times the quantity that would result from inhaling air containing uniform concentrations cpecified in Appendix B, Table I, Column i for one hour.
This is a Severity Level IV violation (Supplement IV).
Response
1)
Admission or denial of the alleged violation:
Duke Power Company denies the violation for the reason given below.
2)
Reasons for denial:
While complying with 10 CFR 20.103(b)(2) to maintain radioactive material intake ALARA, Duke Power Company also considers standard industrial safety concerns such as falling hazards, confined space hazards and heat hazards.
In the subject incident, the decision to not require respiratory protective equipment resulted form our concern for overall worker safety.
Prudent judgement indicated the increase in industrial safety hazard due to respirator usage exceeded the associated reduction in radiological hazard.
The reactor was in heat-up mode, purge ventilation had been secured, and both reactor building and reactor coolant system temperatures were high and rising. The primary job location, the RC pump cavities, would have become a significant personnel safety hazard if respirator usage had been mandated. This personnel safety hazard would have resulted from the increased cardiovascular / respiratory burden attributed to respirator usage, in combination with the heat, the restricted range of movement, and the physical exertion required to access the work. Therefore, respiratory protective equipment was not f
mandated, and did not serve as one of the precautionary procedures required by 10 CFR 20.103(b)(2).
e
.i5 e-10 CFR 20.103(b)(2) was met throut.: the precautionary procedure of limitation of working times througn MPC hour control.
Prior to building entry, the building was surveyed to ideatify the most conservative concentration, the recent MPC history of the proposed workers was reviewed, the allowable access time limits were determined to maintain intake below the administrative limit of 35 MPC-hrs, and a pre-job ALARA planning meeting was held. During entry, the access times were successfully limited. Pursuant to 10 CFR 20.103(a)(3), MPC hours were assigned to account for personnel radioactive material intake. No administrative limits were exceeded.
Post-job body burden analyses indicated all organ burdens below permissible quantities.
With iodine being the predominant isotope of concern in the reactor building atmosphere, breathing air and self contained breathing apparatuses (SCBA's) are the only NRC approved respiratory equipment alternatives for l
reducing the uptake of iodine. Recognizing ALARA concerns, breathing air was employed in areas where practical and accessible, and where it did not adversely inpact overall personnel safety. The use of SCBA equipment was explicitly precluded by the job location and duration. Air purifying respirators with iodine removal charcoal canisters have not been assigned an approved respiratory protection factor by 10 CFR 20 Appendix A, and therefore, credit cannot be taken for their use.
MPC hours were conservatively assigned for traverse time between locations where breathing air was employed.
In summary, Duke Power Company feels that both the letter and the intent of 10 CFR 20.103b)(2) were met, and that no violation is warranted.
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