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| {{Adams | | {{Adams |
| | number = ML20199G445 | | | number = ML20212B352 |
| | issue date = 03/25/1986 | | | issue date = 07/17/1986 |
| | title = Insp Repts 50-269/86-05,50-270/86-05 & 50-287/86-05 on 860224-28.Violation Noted:Failure to Provide Adequate Respiratory Protective Equipment to Maintain Intakes of Radioactive Matl ALARA | | | title = Agrees w/860423 & 0506 Denial of Violation Noted in Insp Repts 50-269/86-05,50-270/86-05 & 50-287/86-05 Re Use of Respiratory Protective Equipment to Maintain Intake of Radioactive Matl by Any Individual ALARA |
| | author name = Collins T, Hosey C | | | author name = Reyes L |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| | addressee name = | | | addressee name = Tucker H |
| | addressee affiliation = | | | addressee affiliation = DUKE POWER CO. |
| | docket = 05000269, 05000270, 05000287 | | | docket = 05000269, 05000270, 05000287 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 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 | | | document report number = NUDOCS 8608060304 |
| | package number = ML20199G398
| | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | page count = 1 |
| | page count = 9 | |
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| {{#Wiki_filter:_ . _ . . . | | {{#Wiki_filter:6gt&d JR 171986 Duke Po r Company ATTN: r. H. B. Tucker, Vice President Nuclear Production Department 422 South Church Street Charlotte, NC 28242 Gentlemen: |
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| | SUBJECT: INSPECTION REPORT NOS. 50-269/86-05, 50-270/86-05 AND 50-287/86-05 Our letter dated May 27, 1986, in response to your letters of April 23 and May 6, |
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| | .1986, stated that we were eval uating your responses wh ich denied a violation regarding the use of respiratory protective equipment to maintain intake of radioactive material by any individual as low as is reasonably achievable, and that we would notify you of the acceptability of your responses in the near futur After careful review of the basis for your dental of the violation, we agree with your position and have deleted the violation from our record We appreciate your cooperation in this matte |
| , $ narco URITED STATES
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| o NUCLEAR REGULATORY COMMISSION
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| , REGloN 11
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| [' n g j 101 MARIETTA STRE ET. * 'c ATLANTA, GEORGI A 30323
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| fM 2 7 T.i36 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.: DPR-38, DPR-47, and DPR-55 Facility Name: Oconee Inspection Conducted: February 24-28, 1986 Inspector :
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| T. R. Colli s M8
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| _[ Tate S'igned Approved by:
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| C. M. Hosdy, Sect ~ on Chief J/27h//
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| 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).
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| 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.
| | Sincerely, |
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| . REPORT DETAILS Persons Contacted
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| ' Licensee Employees
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| *M. S. Tuckman, Station Manager
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| *T. S. Barr, Superintendant of Technical Services
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| *C. T. Yongue, Station Health Physicist
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| *E. Brown, Health Physics Supervisor
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| *M. Thorne, Health Physics Supervisor
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| *T. C. Matthews. Compliance Technical Specialist J. Owens, Health Pnysics Supervisor T. Cherry, ALARA Coordinator
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| - 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 personne Other Organizations RAD Services, In NRC Resident-Inspectors
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| *J. Bryant, Senior Resident Inspector
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| *K. Sasser, Resident Inspector
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| * Attended exit interview 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, 198 See report details paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during tnis inspectio . 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 w
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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-hr (Closed) Unresolved Item 50-269, 270 and 287/85-42-0 Provide air sample data to evaluate airborne radioactivity in Unit #3 Containmen 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 Containmen . Training and Qualifications (83723) Basic Radiation Protection Training The licensee was required by 10 CFR 19.12 to provide basic radiation protection training to worker Regulatory Guides 8.27, 8.29, and 8.13, outline topics that should be included in such trainin .
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| 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
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| effectiveness of the training. The inspector selectively reviewed the GET training records fcr workers to determine if records reflected adequate completion of GET initial and refresher trainin Radiation Protection and Chemistry Technician Qualification
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| '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 technician Respiratory Protection Training The licensee was required by 10 CFR 20.103 to establish a qualification program for workers who wear respiratory protective equipmen Elements of the qualification program outlined in 10 CFR 20.103 we are
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| delineated in NUREG-004 The inspector observed workers using respirators while they were performing maintenance in the auxiliary buildin The inspectors discussed this use with the radiation protection technician covering the job and with the worker The inspector reviewed the workers' respirator qualification reccrd The inspector reviewed recent changes in the respirator qualification program and discussed these changes with the training superviso .
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| No violations or deviations were identifie . ___ _. _. _ _ . _ _ _ _ _ _ _ _ _ _ - _ _ _
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| 4 Technical Specification 6.1 specified minimum plant staffin FSAR Chapters 12 and 13 also outlined further details on staffin The inspector discussed authorized staffing levels and actual on-board
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| - 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 protectio No violations or deviations were identifie . Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83726)
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| 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 survey Chapter 12 of the FSAR further outlines survey methods and instrumentatio Technical Specification 6.8 required the licensee to follow written procedures. Radiological control procedures further outlined survey methods and frequencie 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 assigne 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 result The inspector reviewed selected survey records for the month of February 1986 and discussed with licensee representatives methods used to disseminate st.rvey result The inspector noted that there were several locked high radiation areas outside containment, 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 materia _
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| 5 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 laborator 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 frisker 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 releas 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' identifie No violations or deviations were identift.e . Facilities and Equipment (83727)
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| 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 enclosure No violations or deviations were identifie . External Occupational Dose Control and Personal Dosimetry (83724)
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| 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), 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 area 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 pocket dosimeters by workers. The inspector discussed the assignment
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| 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 dosimeter 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 mishandle The inspector discussed, with an assigned radiation protection technician, the system for comparison of TLD and pocket dosimeter result The inspector reviewed the records of pocket dosimeter drift and calibration checks for the year of 193 Dosimetry Results The inspector reviewed the TLD results for 1985 and for the first quarter of 198 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 198 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
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| understanding of dosimetry results for their staff. The inspector reviewed records of administrative doso control extensions for the year 1985 and discussed the extensions with selected supervisors and staf The inspector reviewed records of cases where workers exceeded administrative controls without dose extension The inspector discussed these cases with selected involved individuals and reviewed corrective action No violations or deviations were identifie . Internal Exposure Control and Assessment (83725)
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| 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 assessmen ,-
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| 7 Control Measures During plant tours, the inspector observed the use of temporary ventilation systems, containment enclosures, and respirator The-inspector discussed the use of this equipment with workers and radia-
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| tion protection technician 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, 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, Uptake Assessment The inspector observed operation of whole body counter and discussed its operation and results with the counter operato 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 wee The inspector reviewed the MPC hour logs for 1985 and noted there were no personnel listed with greate. than 40 MPC-hours during a wee 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 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-13 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 l personnel because the shelf life on the canisters had expired and that
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| | l s l' \; ,1 cyjL Downle*3 Scr Luis A. Reyes, Acting Director Division of Reactor Projects cc: M. S. Tuckman, Station Manager bec: RC Resident Inspector |
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| material as low as is reasonably achievable was identified as an apparent violation of 10 CFR 20.103(b)(2) (50-269,270, and 287/86-05-01).
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| 10. Maintaining Occupational Doses ALARA (83726)
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| 10 CFR 20.1(c) specifies that licensees should implement programs to keep
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| ; workers' doses ALARA. FSAR Chapter 12 also contains licensee commitmentt regarding worker ALARA actions.
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| _ Worker and Supervisor Actions The inspector discussed with ALARA personnel their actions to reduce individual and collective doses, concentrating particularly on staff
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| members with highest doses. The inspector also discussed these actions to set dose goals for tasks, methods used to reduce dqses, and techniques used to monitor performance against goals.
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| . ALARA Procedure Changes
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| The inspector reviewed recent changes to administrative procedures that L implemented the elements of ALARA. The inspector discussed these enanges with the ALARA' Coordinator.
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| c ALARA Reviews
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| : The inspector reviewed the ALARA review documentation for selected
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| activities during 1985 and discussed resulting actions with the ALARA
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| Coordinator.
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| -- ALARA Reports 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-rem Through February 24, 1986, the total was 176 man-re No violations or deviations were identi'~ed.
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| 1 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 198 No violations or deviations were identified.
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| '1 Preparation for Mardh 1986 Outage
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| - 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 outag 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 startu The inspector. discussed methods to be. used to select and qualify the staff with contractor support, proposed metheds of supervision and limitations on task assignment Na violations or deviations were identifie .
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