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| {{Adams
| | #REDIRECT [[IR 05000269/1986005]] |
| | number = ML20199G445
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| | issue date = 03/25/1986
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| | 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
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| | author name = Collins T, Hosey C
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| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
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| | addressee name =
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| | addressee affiliation =
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| | docket = 05000269, 05000270, 05000287
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| | license number =
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| | contact person =
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| | 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
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| | package number = ML20199G398
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| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
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| | page count = 9
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| }}
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| See also: [[see also::IR 05000269/1986005]]
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| | |
| =Text=
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| {{#Wiki_filter:_ . _ . . .
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| ,
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| *
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| , $ narco URITED STATES
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| -
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| o NUCLEAR REGULATORY COMMISSION
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| , REGloN 11
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| g j 101 MARIETTA STRE ET.N.W.
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| * 'c ATLANTA, GEORGI A 30323
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| *****
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| fM 2 7 T.i36
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| Report Nos.: 50-269/86-05, 50-270/86-05 and 50-287/86-05
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| Licensee: Duke Power Company
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| 422 South Church Street
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| Charlotte,.NC 28242
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| Docket Nos.: 50-269, 50-270, and 50-287 License Nos.: DPR-38, DPR-47, and
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| DPR-55
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| Facility Name: Oconee
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| Inspection Conducted: February 24-28, 1986
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| Inspector :
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| T. R. Colli s
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| M8
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| _[ Tate S'igned
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| Approved by:
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| C. M. Hosdy, Sect ~ on Chief
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| J/27h//
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| Dats S;gn'ed
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| Emergency Prepardtess and Radiological
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| Protection Branch
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| Division of Radiation Safety and Safeguards
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| SUMMARY
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| Scope: This routine, unannounced inspection involved 36 inspector-hours on site
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| during normal hours, inspecting the radiation protection program including
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| training and qualification of personnel, internal and external exposure control,
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| radioactive material control, posting and labeling, and the program for
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| 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
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| respiratory protective equipment to maintain intakes of radioactive material as
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| low as reasonably achievable.
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| 2
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| . REPORT DETAILS
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| 1. 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
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| J. Owens, Health Pnysics Supervisor
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| T. Cherry, ALARA Coordinator
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| - S. Spears, Health Physics Coordinator
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| C. Harlin, Health Physics Coordinator
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| L. Garrett, ETQS Coordinator
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| B. Earnhart, Outage and Planning Coordinator
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| Other licensee employees contacted included four construction craftsmen,
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| five. technicians, two operators, three' mechanics, three security force
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| members, and.two office personnel.
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| Other Organizations
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| RAD Services, Inc.
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| 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
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| 2. Exit. Interview
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| The inspection scope and findings were summarized on February 28, 1986, with
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| those . persons indicated in paragraph 1 above. The inspector discussed the
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| apparent violation for not providing adequate respiratory protection to
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| individuals while working in Unit #3 Containment on March 29, 1985. See
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| report details paragraph 9.
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| The licensee did not identify as proprietary any of the materials provided
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| to or reviewed by the inspector during tnis inspection.
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| 3. Licensee Action on Previous Enforcement Matters
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| (Closed) Unresolved Item 50-269, 270, and 267/85-42-02. Provide air sample
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| 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
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| concluded that the licensee did evaluate and document air sample results to
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| evaluate the radiation hazards present to assure personnel did not exceed 40
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| MPC-hrs.
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| (Closed) Unresolved Item 50-269, 270 and 287/85-42-03. Provide air sample
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| data to evaluate airborne radioactivity in Unit #3 Containment. The
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| inspection reviewed air sample results of Unit #3 Containment as provided by
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| the licensee and concluded that the licensee had taken an adequate air
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| sample to evaluate the air concentrations in Unit #3 Containment.
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| 4. Training and Qualifications (83723)
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| a. Basic Radiation Protection Training
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| The licensee was required by 10 CFR 19.12 to provide basic radiation
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| protection training to workers. Regulatory Guides 8.27, 8.29, and
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| 8.13, outline topics that should be included in such training. .
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| Chapters 12 and 13 of the FSAR contain further commitments regarding
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| training. During tours of the plant, the inspector discussed topics
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| from the GET training with a maintenance mechanic to determine the
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| "
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| effectiveness of the training. The inspector selectively reviewed the
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| GET training records fcr workers to determine if records reflected
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| adequate completion of GET initial and refresher training.
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| b. Radiation Protection and Chemistry Technician Qualification
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| 'The inspector reviewed the program for qualifiction of contract
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| radiation protection technicians. The inspector discussed separately
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| with three contract technicians their previous experience and training
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| to determine if it was comprehensive or if it had been limited to
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| selected tasks. The inspector also discussed the training and
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| qualification program the licensee had provided, what limits had been
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| placed on their activities, and controls that should be established for
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| one task they were qualified to perform. The inspector reviewed the
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| resumes, training records, and tests for these technicians. -
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| c. Respiratory Protection Training
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| The licensee was required by 10 CFR 20.103 to establish a qualification
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| program for workers who wear respiratory protective equipment.
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| 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
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| respirators while they were performing maintenance in the auxiliary
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| building. The inspectors discussed this use with the radiation
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| protection technician covering the job and with the workers. The
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| inspector reviewed the workers' respirator qualification reccrds. The
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| inspector reviewed recent changes in the respirator qualification
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| program and discussed these changes with the training supervisor.
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| No violations or deviations were identified.
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| 4
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| d. Technical Specification 6.1 specified minimum plant staffing. FSAR
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| Chapters 12 and 13 also outlined further details on staffing. The
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| inspector discussed authorized staffing levels and actual on-board
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| - staffing separately with the Station Health Physicist- and Station
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| Manager. The inspector exarr.ined shift staffing for the midnight shift
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| on February 25, 1986, to determine if it met minimum criteria fc
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| radiation protection.
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| No violations or deviations were identified.
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| 5. Control of Radioactive Materials and Contamination, Surveys, and Monitoring
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| (83726)
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| The licensee was required by 10 CCR 20.201(b) and 20.401 to perform surveys
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| to show compliance with regulatory limits and to maintain records of such
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| surveys. Chapter 12 of the FSAR further outlines survey methods and
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| instrumentation. Technical Specification 6.8 required the licensee to
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| follow written procedures. Radiological control procedures further outlined
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| survey methods and frequencies.
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| a. The inspector observed, during plant tours, surveyt being performed by
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| radiation protection staff. The inspector reviewed selected radiation
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| work permits, to determine if adequate controls were specified. The
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| inspector discussed the controls and monitoring with the radiation
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| protection technician assigned.
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| During plant tours, the inspector observed radiation level and
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| contamination survey results outside selected cubicles. The inspector
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| performed independent radiation surveys of selected areas and compared
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| them to licensee survey results. The inspector reviewed selected
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| survey records for the month of February 1986 and discussed with
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| licensee representatives methods used to disseminate st.rvey results.
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| The inspector noted that there were several locked high radiation areas
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| outside containment,
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| b. Frisking
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| During tours of the plant, the inspector observed the exit of workers
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| 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
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| proper direct and removable contamination surveys were performed on
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| materials. The inspector reviewed records of skin contamination
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| occurrences and resulting evaluations and corrective actions. Records
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| and discussions with licensee representatives showed contamination had
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| been promptly removed from the workers using routine washing
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| techniques. Subsequent whole body counts showed less than detectable
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| internal deposition of radioactive material.
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| 5
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| c. Instrumentation
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| During plant tours, the inspector observed the use of survey instru-
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| ments by plant staff and compared plant survey meter results with
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| results .of surveys made by the inspector using NRC equipment. The
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| inspector examined calibration stickers on radiation protection
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| instruments in use by licensee staff and stored in the radiation
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| protection laboratory. The inspector discussed with radiation
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| protection technicians the methods for doing instrument source checks
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| prior to each use and calibration methods. The inspector reviewed the
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| procedures and methods for calibration of survey instruments and
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| friskers.
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| d. Release of Materials for Unrertricted Use
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| The inspector discussed, with a radiation protection technician, the
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| program _ for survey-out of items from contaminated areas and reviewed
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| the procedures for such release. The inspector observed release
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| surveys performed by radiation protection technicians, and documen-
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| tation of results. The inspector performed confirmatory direct and
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| removable contamination surveys on items released. During tours of
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| plant areas, the inspector observed posting of containers and performed
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| indepencent surveys to determine if containers of radioactive material
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| were properly' identified.
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| No violations or deviations were identift.ed.
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| 6. Facilities and Equipment (83727)
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| FSAR Chapters 1 and 12 specified plant i yout and radiation protection
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| facilities and equipment. During plant tours, the inspector observed the
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| operation of the contaminated clothing laundry, the flow of traffic thru
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| change rooms, the use of temporary shielding and the use of glove bags, and
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| ventilated containment enclosures.
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| No violations or deviations were identified.
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| 7. External Occupational Dose Control and Personal Dosimetry (83724)
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| During plant tours, the inspector checked the security of the locks at
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| 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),
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| 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,
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| 20.104, 20.402, 20.403, 20.405, 19.13, 20.407, 20.408 to maintain
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| workers's doses below specified levels and keep records of and make
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| reports of doses. The licensee was required by 10 CFR 20.203 to post
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| and control access to plant areas. FSAR Chapter 12 also contained
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| commitments regarding dosimetry and dose controls. During observation
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| 6
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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
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| and use of- dosimeters with maintenance mechanics and radiation
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| protection technicians. During plant tours, the inspector observed the
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| -posting of areas and made independent measurements of dose to assure
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| proper posting. The inspector reviewed recent changes to plant pro-
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| cedures regarding the use of TLDs and dosimeters.
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| b. Processing of Dosimeters
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| The inspector discussed with the Dosimetry Supervisor the flow of the
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| TLD badge from its return by a worker thru the recording of information
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| (dose) from the readout on the worker's dose record, to determine areas
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| where information could r,ssibly be mishandled. The inspector
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| discussed, with an assigned radiation protection technician, the system
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| for comparison of TLD and pocket dosimeter results. The inspector
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| reviewed the records of pocket dosimeter drift and calibration checks
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| for the year of 1935.
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| c. Dosimetry Results
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| The inspector reviewed the TLD results for 1985 and for the first
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| 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
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| inspector selectively reviewed the results of the TLD vs. pocket
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| chamber comparisons for the year of 1985.
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| d. Management Review of Dosimetry Results
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| The inspector discussed the dosimetry results with a Health Physic's
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| Supervisor, concentratirg on their assigned staff to determine their
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| understanding of dosimetry results for their staff. The inspector
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| reviewed records of administrative doso control extensions for the year
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| 1985 and discussed the extensions with selected supervisors and staff.
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| The inspector reviewed records of cases where workers exceeded
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| administrative controls without dose extensions. The inspector
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| discussed these cases with selected involved individuals and reviewed
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| corrective actions.
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| No violations or deviations were identified.
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| 9. 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
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| 20.405 to control uptakes of radioactive material, assess such uptakes, and
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| keep records of and make reports of such uptakes. FSAR Chapter 12 also
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| includes commitments regarding internal exposure control and assessment.
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| p . A
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| 7
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| a. Control Measures
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| During plant tours, the inspector observed the use of temporary
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| ventilation systems, containment enclosures, and respirators. The
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| -inspector discussed the use of this equipment with workers and radia-
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| "
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| tion protection technicians.
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| b. Respiratory Maintenance and Issue
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| The inspector observed the issuance of respirators and reviewed records
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| for several workers who were issued respirators to determine if they
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| were qualified for the respirators issued. The inspector reviewed
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| recent changes to respirator maintenance and issue procedures,
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| c. Respirator Fit Testing and Training
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| The inspector discussed fit testing with Health Physics personnel. The
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| inspector reviewed recent changes to procedures regarding fit testing
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| and training. The inspector discussed respiratory protection training
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| with workers,
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| d. Uptake Assessment
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| The inspector observed operation of whole body counter and discussed
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| its operation and results with the counter operator. The inspector
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| reviewed the results of the analyses performed for selected individuals
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| for 1985. The inspector discussed the assessments and corrective
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| actions with Health Physics personnel. The inspector reviewed the
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| Maximum Permissible Concentration-hour (MPC-hour) log for selected
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| periods of 1985 and discussed the actions taken by the licensee for
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| personnel that received greater than 2 MPC-hours in a day and 10
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| MPC-hours in a week.
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| The inspector reviewed the MPC hour logs for 1985 and noted there were
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| no personnel listed with greate. than 40 MPC-hours during a week.
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| However, the inspector noted an event which occurred on March 29, 1985,
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| where workers were allowed to enter Unit #3 Containment to perform
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| associated duties during reactor start-up. During this period high
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| concentrations of Iodine-131 were present, up to approximately 20 times
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| the Maximum Permissible Concentrations (MPCs) set forth in 10 CFR 20
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| Appendix B. The licensee permitted these personnel to enter
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| containment without adequate respiratory equipment which resulted in
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| the individuals receiving uptakes of radioactive material ranging from
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| 1.5% maximum permissible organ burden (MPOB) to 6.5% MPB0 Iodine-131.
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| 10 CFR 20.103(b)(2) requires in part that respiratory protective
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| equipment be used to limit the intake of radioactive material to as low
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| as is reasonably achievable. The licensee stated that they decided not
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| to provide respirators equipped with iodine removal canisters to these
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| l personnel because the shelf life on the canisters had expired and that
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| ; 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
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| apparent violation of 10 CFR 20.103(b)(2) (50-269,270, and
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| 287/86-05-01).
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| 10. Maintaining Occupational Doses ALARA (83726)
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| {
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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
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| regarding worker ALARA actions.
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| _
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| a. Worker and Supervisor Actions
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| The inspector discussed with ALARA personnel their actions to reduce
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| individual and collective doses, concentrating particularly on staff
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| 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
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| techniques used to monitor performance against goals.
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| --
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| . b. ALARA Procedure Changes
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| :
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| The inspector reviewed recent changes to administrative procedures that
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| L implemented the elements of ALARA. The inspector discussed these
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| enanges with the ALARA' Coordinator.
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| c
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| c. ALARA Reviews
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| : The inspector reviewed the ALARA review documentation for selected
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| :
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| activities during 1985 and discussed resulting actions with the ALARA
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| _
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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-
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| natory and Station Health Physicist. The summary of tasks estimate for
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| 1985 was 1093 man-rems. The total cumulative dose for 1985 was 1303
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| man-rems. The outage estimate for 1986 was 395 man-rems. Through
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| February 24, 1986, the total was 176 man-rem.
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| No violations or deviations were identi'~ed.
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| _
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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.
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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
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| The inspector discussed the preparations for the February 1985 outage
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| with the Outage Coordinator, ALARA Coordinator, and the Station Health
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| Physicist. The inspector reviewed the task list for the outage.
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| b. Radiation Protection and Chemistry Staffing
| |
| -The inspector discussed with the Station Manager and the Statica Health
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| Physicist, the plans for supplemental staffing, including decon,
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| shielding, and laundry staff, during the outage and subsequent startup.
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| The inspector. discussed methods to be. used to select and qualify the
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| staff with contractor support, proposed metheds of supervision and
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| limitations on task assignments.
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| Na violations or deviations were identified.
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| }}
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