ML20199G445

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

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: ML20199G394 ML20199G445 ML20199H466
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.: DPR-38, DPR-47, and

DPR-55

Facility Name: Oconee

Inspection Conducted: February 24-28, 1986

Inspector :

T. R. Colli s

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_[ Tate S'igned

Approved by:

C. M. Hosdy, Sect ~ on Chief

J/27h//

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

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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 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. -

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. FSAR

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 .

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

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 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

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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 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

l 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 10 CFR 20.103(b)(2) (50-269,270, and

287/86-05-01).

10. Maintaining Occupational Doses ALARA (83726)

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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

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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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. b. ALARA Procedure Changes

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

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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d. 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-rems. Through

February 24, 1986, the total was 176 man-rem.

No violations or deviations were identi'~ed.

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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.

No violations or deviations were identified.

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'12. Preparation for Mardh 1986 Outage

-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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