ML20199G445
| ML20199G445 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 03/25/1986 |
| From: | Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20199G398 | List: |
| References | |
| 50-269-86-05, 50-269-86-5, 50-270-86-05, 50-270-86-5, 50-287-86-05, 50-287-86-5, NUDOCS 8604090139 | |
| Download: ML20199G445 (9) | |
See also: IR 05000269/1986005
Text
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Report Nos.: 50-269/86-05, 50-270/86-05 and 50-287/86-05
Licensee: Duke Power Company
422 South Church Street
Charlotte,.NC 28242
Docket Nos.: 50-269, 50-270, and 50-287
License Nos.:
Facility Name: Oconee
Inspection Conducted:
February 24-28, 1986
M8
Inspector :
_[ Tate S'igned
T. R. Colli s
Approved by:
J/27h//
C. M. Hosdy, Sect ~ on Chief
Dats S;gn'ed
Emergency Prepardtess and Radiological
Protection Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope: This routine, unannounced inspection involved 36 inspector-hours on site
during normal hours, inspecting the radiation protection program including
training and qualification of personnel, internal and external exposure control,
radioactive material control, posting and labeling, and the program for
maintaining exposure as low as reasonably achievable (ALARA).
Results: One violation was identified in the area of failure to provide adequate
respiratory protective equipment to maintain intakes of radioactive material as
low as reasonably achievable.
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. REPORT DETAILS
1.
Persons Contacted
' Licensee Employees
- M. S. Tuckman, Station Manager
- T. S. Barr, Superintendant of Technical Services
- C. T. Yongue, Station Health Physicist
- E. Brown, Health Physics Supervisor
- M. Thorne, Health Physics Supervisor
- T. C. Matthews. Compliance Technical Specialist
J. Owens, Health Pnysics Supervisor
T. Cherry, ALARA Coordinator
- S. Spears, Health Physics Coordinator
C. Harlin, Health Physics Coordinator
L. Garrett, ETQS Coordinator
B. Earnhart, Outage and Planning Coordinator
Other licensee employees contacted included four construction craftsmen,
five. technicians, two operators, three' mechanics, three security force
members, and.two office personnel.
Other Organizations
RAD Services, Inc.
NRC Resident-Inspectors
- J. Bryant, Senior Resident Inspector
- K. Sasser, Resident Inspector
- Attended exit interview
2.
Exit. Interview
The inspection scope and findings were summarized on February 28, 1986, with
those . persons indicated in paragraph 1 above.
The inspector discussed the
apparent violation for not providing adequate respiratory protection to
individuals while working in Unit #3 Containment on March 29, 1985.
See
report details paragraph 9.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspector during tnis inspection.
3.
Licensee Action on Previous Enforcement Matters
(Closed) Unresolved Item 50-269, 270, and 267/85-42-02. Provide air sample
results to assure adequate evaluation of airborne radioactive material. The
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inspector reviewed air sample results as provided by the licensee and
concluded that the licensee did evaluate and document air sample results to
evaluate the radiation hazards present to assure personnel did not exceed 40
MPC-hrs.
(Closed) Unresolved Item 50-269, 270 and 287/85-42-03.
Provide air sample
data to evaluate airborne radioactivity in Unit #3 Containment.
The
inspection reviewed air sample results of Unit #3 Containment as provided by
the licensee and concluded that the licensee had taken an adequate air
sample to evaluate the air concentrations in Unit #3 Containment.
4.
Training and Qualifications (83723)
a.
Basic Radiation Protection Training
The licensee was required by 10 CFR 19.12 to provide basic radiation
protection training to workers.
Regulatory Guides 8.27, 8.29, and
8.13, outline topics that should be included in such training.
.
Chapters 12 and 13 of the FSAR contain further commitments regarding
training. During tours of the plant, the inspector discussed topics
from the GET training with a maintenance mechanic to determine the
effectiveness of the training. The inspector selectively reviewed the
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GET training records fcr workers to determine if records reflected
adequate completion of GET initial and refresher training.
b.
Radiation Protection and Chemistry Technician Qualification
'The inspector reviewed the program for qualifiction of contract
radiation protection technicians.
The inspector discussed separately
with three contract technicians their previous experience and training
to determine if it was comprehensive or if it had been limited to
selected tasks.
The inspector also discussed the training and
qualification program the licensee had provided, what limits had been
placed on their activities, and controls that should be established for
one task they were qualified to perform. The inspector reviewed the
resumes, training records, and tests for these technicians.
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c.
Respiratory Protection Training
The licensee was required by 10 CFR 20.103 to establish a qualification
program for workers who wear respiratory protective equipment.
Elements of the qualification program outlined in 10 CFR 20.103 we are
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delineated in NUREG-0041.
The inspector observed workers using
respirators while they were performing maintenance in the auxiliary
building.
The inspectors discussed this use with the radiation
protection technician covering the job and with the workers.
The
inspector reviewed the workers' respirator qualification reccrds.
The
inspector reviewed recent changes in the respirator qualification
program and discussed these changes with the training supervisor.
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No violations or deviations were identified.
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d.
Technical Specification 6.1 specified minimum plant staffing.
Chapters 12 and 13 also outlined further details on staffing.
The
inspector discussed authorized staffing levels and actual on-board
- staffing separately with the Station Health Physicist- and Station
Manager. The inspector exarr.ined shift staffing for the midnight shift
on February 25, 1986, to determine if it met minimum criteria fc
radiation protection.
No violations or deviations were identified.
5.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring
(83726)
The licensee was required by 10 CCR 20.201(b) and 20.401 to perform surveys
to show compliance with regulatory limits and to maintain records of such
surveys.
Chapter 12 of the FSAR further outlines survey methods and
instrumentation.
Technical Specification 6.8 required the licensee to
follow written procedures. Radiological control procedures further outlined
survey methods and frequencies.
a.
The inspector observed, during plant tours, surveyt being performed by
radiation protection staff. The inspector reviewed selected radiation
work permits, to determine if adequate controls were specified. The
inspector discussed the controls and monitoring with the radiation
protection technician assigned.
During plant tours, the inspector observed radiation level and
contamination survey results outside selected cubicles.
The inspector
performed independent radiation surveys of selected areas and compared
them to licensee survey results.
The inspector reviewed selected
survey records for the month of February 1986 and discussed with
licensee representatives methods used to disseminate st.rvey results.
The inspector noted that there were several locked high radiation areas
outside containment,
b.
Frisking
During tours of the plant, the inspector observed the exit of workers
and movement of material from contamination control areas to clean
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areas to determine if proper frisking was performed by workers and that
proper direct and removable contamination surveys were performed on
materials.
The inspector reviewed records of skin contamination
occurrences and resulting evaluations and corrective actions. Records
and discussions with licensee representatives showed contamination had
been promptly removed from the workers using routine washing
techniques. Subsequent whole body counts showed less than detectable
internal deposition of radioactive material.
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c.
Instrumentation
During plant tours, the inspector observed the use of survey instru-
ments by plant staff and compared plant survey meter results with
results .of surveys made by the inspector using NRC equipment. The
inspector examined calibration stickers on radiation protection
instruments in use by licensee staff and stored in the radiation
protection laboratory.
The inspector discussed with radiation
protection technicians the methods for doing instrument source checks
prior to each use and calibration methods. The inspector reviewed the
procedures and methods for calibration of survey instruments and
friskers.
d.
Release of Materials for Unrertricted Use
The inspector discussed, with a radiation protection technician, the
program _ for survey-out of items from contaminated areas and reviewed
the procedures for such release.
The inspector observed release
surveys performed by radiation protection technicians, and documen-
tation of results. The inspector performed confirmatory direct and
removable contamination surveys on items released. During tours of
plant areas, the inspector observed posting of containers and performed
indepencent surveys to determine if containers of radioactive material
were properly' identified.
No violations or deviations were identift.ed.
6.
Facilities and Equipment (83727)
FSAR Chapters 1 and 12 specified plant i yout and radiation protection
facilities and equipment. During plant tours, the inspector observed the
operation of the contaminated clothing laundry, the flow of traffic thru
change rooms, the use of temporary shielding and the use of glove bags, and
ventilated containment enclosures.
No violations or deviations were identified.
7.
External Occupational Dose Control and Personal Dosimetry (83724)
During plant tours, the inspector checked the security of the locks at
several locked high radiatior, areas and observed posting of survey results
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and the use of controls specified on six radiation work permits (RWPs),
a.
Use of Dosimeters and Controls
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The licensee was required by 10 CFR 20.202, 20.201(b), 20.102, 20.102,
20.104, 20.402, 20.403, 20.405, 19.13, 20.407, 20.408 to maintain
workers's doses below specified levels and keep records of and make
reports of doses.
The licensee was required by 10 CFR 20.203 to post
and control access to plant areas.
FSAR Chapter 12 also contained
commitments regarding dosimetry and dose controls. During observation
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of work in the plant, the inspector observed the wearing of TLDs and
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pocket dosimeters by workers. The inspector discussed the assignment
and use of- dosimeters with maintenance mechanics and radiation
protection technicians. During plant tours, the inspector observed the
-posting of areas and made independent measurements of dose to assure
proper posting. The inspector reviewed recent changes to plant pro-
cedures regarding the use of TLDs and dosimeters.
b.
Processing of Dosimeters
The inspector discussed with the Dosimetry Supervisor the flow of the
TLD badge from its return by a worker thru the recording of information
(dose) from the readout on the worker's dose record, to determine areas
where information could r,ssibly be mishandled.
The inspector
discussed, with an assigned radiation protection technician, the system
for comparison of TLD and pocket dosimeter results.
The inspector
reviewed the records of pocket dosimeter drift and calibration checks
for the year of 1935.
c.
Dosimetry Results
The inspector reviewed the TLD results for 1985 and for the first
quarter of 1986.
The inspector selectively examined individuals'
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dosimetry files to determine if NRC Form 4's had been completed. The
inspector selectively reviewed the results of the TLD vs. pocket
chamber comparisons for the year of 1985.
d.
Management Review of Dosimetry Results
The inspector discussed the dosimetry results with a Health Physic's
Supervisor, concentratirg on their assigned staff to determine their
understanding of dosimetry results for their staff.
The inspector
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reviewed records of administrative doso control extensions for the year
1985 and discussed the extensions with selected supervisors and staff.
The inspector reviewed records of cases where workers exceeded
administrative controls without dose extensions.
The inspector
discussed these cases with selected involved individuals and reviewed
corrective actions.
No violations or deviations were identified.
9.
Internal Exposure Control and Assessment (83725)
The licensee 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 uptakes, and
keep records of and make reports of such uptakes.
FSAR Chapter 12 also
includes commitments regarding internal exposure control and assessment.
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a.
Control Measures
During plant tours, the inspector observed the use of temporary
ventilation systems, containment enclosures, and respirators.
The
-inspector discussed the use of this equipment with workers and radia-
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tion protection technicians.
b.
Respiratory Maintenance and Issue
The inspector observed the issuance of respirators and reviewed records
for several workers who were issued respirators to determine if they
were qualified for the respirators issued.
The inspector reviewed
recent changes to respirator maintenance and issue procedures,
c.
Respirator Fit Testing and Training
The inspector discussed fit testing with Health Physics personnel. The
inspector reviewed recent changes to procedures regarding fit testing
and training. The inspector discussed respiratory protection training
with workers,
d.
Uptake Assessment
The inspector observed operation of whole body counter and discussed
its operation and results with the counter operator.
The inspector
reviewed the results of the analyses performed for selected individuals
for 1985.
The inspector discussed the assessments and corrective
actions with Health Physics personnel.
The inspector reviewed the
Maximum Permissible Concentration-hour (MPC-hour) log for selected
periods of 1985 and discussed the actions taken by the licensee for
personnel that received greater than 2 MPC-hours in a day and 10
MPC-hours in a week.
The inspector reviewed the MPC hour logs for 1985 and noted there were
no personnel listed with greate. than 40 MPC-hours during a week.
However, the inspector noted an event which occurred on March 29, 1985,
where workers were allowed to enter Unit #3 Containment to perform
associated duties during reactor start-up.
During this period high
concentrations of Iodine-131 were present, up to approximately 20 times
the Maximum Permissible Concentrations (MPCs) set forth in 10 CFR 20
Appendix
B.
The licensee permitted these personnel
to enter
containment without adequate respiratory equipment which resulted in
the individuals receiving uptakes of radioactive material ranging from
1.5% maximum permissible organ burden (MPOB) to 6.5% MPB0 Iodine-131.
10 CFR 20.103(b)(2) requires in part that respiratory protective
equipment be used to limit the intake of radioactive material to as low
as is reasonably achievable. The licensee stated that they decided not
to provide respirators equipped with iodine removal canisters to these
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personnel because the shelf life on the canisters had expired and that
they felt the job could be performed faster and safer without
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respiratory equipment.
Failure to maintain intakes of radioactive
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material as low as is reasonably achievable was identified as an
apparent
violation
of
(50-269,270,
and
287/86-05-01).
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10. Maintaining Occupational Doses ALARA (83726)
10 CFR 20.1(c) specifies that licensees should implement programs to keep
workers' doses ALARA.
FSAR Chapter 12 also contains licensee commitmentt
regarding worker ALARA actions.
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a.
Worker and Supervisor Actions
The inspector discussed with ALARA personnel their actions to reduce
individual and collective doses, concentrating particularly on staff
members with highest doses. The inspector also discussed these actions
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to set dose goals for tasks, methods used to reduce dqses, and
techniques used to monitor performance against goals.
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b.
ALARA Procedure Changes
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The inspector reviewed recent changes to administrative procedures that
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implemented the elements of ALARA.
The inspector discussed these
enanges with the ALARA' Coordinator.
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c.
ALARA Reviews
The inspector reviewed the ALARA review documentation for selected
activities during 1985 and discussed resulting actions with the ALARA
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Coordinator.
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d.
ALARA Reports
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The inspector reviewed selected ALARA Reports for 1985 and the 1985
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ALARA summary report and discussed the results with the ALARA Coordi-
natory and Station Health Physicist. The summary of tasks estimate for
1985 was 1093 man-rems.
The total cumulative dose for 1985 was 1303
man-rems.
The outage estimate for 1986 was 395 man-rems.
Through
February 24, 1986, the total was 176 man-rem.
No violations or deviations were identi'~ed.
11.
Problem Reports and Radiological Deficier :y Reports.
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The inspector selectively examined the Problem Reports and Radiological
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Deficiency Reports and resulting corrective actions for the period January
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through June 1985.
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No violations or deviations were identified.
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'12.
Preparation for Mardh 1986 Outage
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-a.
Work Packages
The inspector discussed the preparations for the February 1985 outage
with the Outage Coordinator, ALARA Coordinator, and the Station Health
Physicist. The inspector reviewed the task list for the outage.
b.
Radiation Protection and Chemistry Staffing
-The inspector discussed with the Station Manager and the Statica Health
Physicist, the plans for supplemental staffing, including decon,
shielding, and laundry staff, during the outage and subsequent startup.
The inspector. discussed methods to be. used to select and qualify the
staff with contractor support, proposed metheds of supervision and
limitations on task assignments.
Na violations or deviations were identified.
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