ML20138M560

Insp Repts 50-269/85-30,50-270/85-30 & 50-287/85-30 on 850916-20.Violation Noted:Failure to Label Containers of Radioactive Matl

ML20138M560
Person / Time
Site:	Oconee
Issue date:	10/08/1985
From:	Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138M553	List: ML20138M551 ML20138M560
References
50-269-85-30, 50-270-85-30, 50-287-85-30, NUDOCS 8511040099
Download: ML20138M560 (6)

See also: IR 05000269/1985030

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UGelTED STATES

[an Riog%, sucLEAR REGULATORY COMMISSION

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OCT 16 1985

Report Nos.- 50-269/85-30, 50-270/85-30, and 50-287/85-30

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 Nuclear Station

Inspection Conducted: September 16 - 20, 1985

Inspector: _- 1 /d 89

B./ K. Riv si n' Date Signed

Accompanying Personnel: M. Poston-Brown

Approved by: , /d 8

C.M.Hosey,SectyonChief Date Signed

Division of Radiation safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 38 inspector-hours onsite

during regular hours in the area of radiation protection including external

exposure control; internal exposure control; training and qualifications of

personnel; radioactive materials contrcl, posting and labeling; and program for

maintaining exposures as low as reasonably achievable (ALARA).

Results: One violation - failure to label containers of radioactive material.

8511040099 851016

PDR ADOCK 05000269

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• M. S. Tuckman, Station Manager

• R. T. Bond, Compliance Engineer

• G. T. Powell, Health Physics, General Office

• S. A. Coy, Associate Health Physicist

• C. T. Yongue, Station Health Physicist

• T. S. Barr, Superintendent of Technical Services

C. L. Harlin, Health-Physics Coordinator

T. L. Cherry, ALARA Supervisor

D. Austin, Training and Safety Coordinator

T. E. Carroll, Health Physics Supervisor

M. L. Lynch, Health Physics Supervisor

D. R. White, Health Physics Supervisor

NRC Resident Inspectors

J . Bryant, Senior Resident Inspector

K. Sasser, Resident Inspector

L. King, Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on September 20, 1985,

with those persons indicated in paragraph 1 above. An apparent violation

for failure to label containers of radioactive material (paragraph Sa) was

discussed in detail. Licensee management took no exceptions. The licensee

did not identify as proprietary any of the materials provided to or reviewed

by the inspector during this investigation.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. Training and Qualifications (83723)

a. Radiation Protection Technician Training and Qualification

The licensee was required by Technical Specification (T.S.) 6.1.1.4 to

qualify health physics (HP) technicians in accordance with Section 4 of

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ANSI /ANS-3.1-1978. The inspector discussed the training and qualifica-

tion program with the HP Technical Associate in charge of implementa-

tion of the HP technician training program. The course outline for HP

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training was reviewed and selected records of HP technicians were

examined to verify that all mandatory classroom and on-the-job training

had been completed. A licensee representative stated that both the HP

and chemistry technician training programs would be submitted for

accreditation to the Institute for Nuclear Power Operations (INP0) by

December 31, 1985.

T.S. 6.1.1.5 specified that retraining and replacement of station

personnel shall be in accordance with Section 5.5 of ANSI /ANS-3.1-1978.

The inspector discussed the training / replacement program with the HP

Technical Associate and with the Training and Safety Coordinator.

b. Basic Radiation Protection Training

The licensee was required by 10 CFR 19.12 to provide basic radiation

safety training for workers with Regulatory Guides 8.27, 8.29 and 8.13

providing an outline of topics that should be included in such

training. The inspector discussed the initial general employee

radiation protection training (GET) with the Training and Safety

Coordinator and reviewed course outlines and lesson plans that

described the GET program. For annual GET retraining, the licensee

stated that workers may opt to take a by pass examination which

includes an update briefing covering changes that have occurred at the

facility as well as operating problems at other facilities. The

inspector discussed the training tracking system with the licensee and

found adequate controls in place to assure that radiation worker

training was up-to-date. Selected records of plant radiation workers

and outage radiation workers were examined to verify that their GET

training was current.

c. Respiratory Protection Training

The licensee was required by 10 CFR 20.103 to establish a qualification

program for workers who wear respiratory protection equipment.

Elements of the qualification program outlined in 10 CFR 20.103 were

delineated in NUREG-0041. The inspector discussed the respiratory

protection training with the Training and Safety Coordinator and by

review of records, verified that selected workers had completed the

training.

No violations or deviations were identified.

5. Centrol of Radioactive Materials and Contamination, Surveys and Monitoring

(83526)

The inspector observed the posting and labeling of Radioactive Materials

Areas, Radiation Areas and High Radiation Areas during tours of the

Auxiliary Building, Unit 3 Reactor Building, Turbine Building, Unit 3 Spent

Fuel Building, Warehouse No. 5 and other areas where radioactive materials

were stored within the protected area.

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a. 10 CFR 20.203(f) required that each container of licensed material bear

a durable, clearly visible label which bears the radiation caution

symbol and the words " Caution" or " Danger, Radioactive Materials" and

sufficient information to permit individuals to avoid or minimize

exposures.

The inspector noted that the area adjacent to the Unit 3 loading dock

was used for storage of radioactive materials. The area itself was

fenced and permitted entry through two access points, a locked door for

personnel entry and a gate for vehicle access. Most of the containers

were wrapped in yellow herculite secured by duct tape. A licensee

representative informed the inspector that the contair,ers were incore

casks used for storing used incore tubes. The inspector noted that

three of the containers had no labels, four containers had labels that

were suf ficiently weathered to erase all markings and that three other

containers had labels that were barely legible.

A survey data sheet posted next to the personnel door indicated dose

rate on the bottom of one of the containers was 250 mR/ hour. In

general, dose rates on the containers appeared to vary between

12-50 mR/hr. Dose rate on the containers indicated that they contained

greater than the quantity of radioactive material specified in

10 CFR,.20, Appendix C.

The inspector noted that housekeeping in the area was such that on

September 16, 1985, two security persons were observed exiting the area

using the containers of radioactive material to maintain their balance

as they exited through the debris.

Failure to label containers with a durable, clearly visible label

bearing the radiation caution symbol and the words " Caution" or

" Danger, Radioactive Material" and which provided sufficient

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information to perrait individuals to avoid or minimize exposures was ,

identified as an apparent violation of 10 CFR 20.203(f) (50-269, 270,

287/85-30-01).

b. 10 CFR 20.203 requires the posting and control of radiation areas and

high radiation areas.

During plant tours, the inspector examined radiation and contamination

survey results outside selected rooms and cubicles. The inspector

performed independent radiation surveys of selected areas using NRC

equipment and compared them to licensee survey results. The inspector

reviewed surveys performed in conjunction with Radiation Work Permit

(RWP) Nos. 740, reactor coolant pump work, and 764, control rod drive

mechanism gasket replacement. Alpha, beta and gamma survey results

were reviewed. The inspector noted that selected locked high radiation

areas inside the Auxiliary Building were maintained as required by

10 CFR 20.203.

No violations or deviations were identified.

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6. External Occupational Dose Control and Personal Dosimetry (83724)

The licensee was required by 10 CFR 20.202, 20.201(b), 20.101, 20.102,

20.104, 20.402, 20.403, 20.405, 19.13, 20.407 and 20.408 to maintain

worker's radiation exposure below specified levels and to keep records of

and make reports of such exposures. The inspector reviewed licensee

requirements for extremity monitoring and multibadging with licensee

representatives and reviewed the methodology used by the licensee to capture

this dose data by the computer system. The daily computer printout of

cumulative radiation worker exposure was examined and it was determined that

no worker had exceeded any regulatory limit. Selected records of personnel

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working on RWP Nos. 740 and 764 were examined to verify completion of a Form

NRC-4.

No violations or deviations were identified.

7. 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.

During plant tours, the inspector observed the use of temporary ventilation

systems and respirators. The inspector reviewed respiratory protection

training, respirator fit testing, and medical qualifications of selected

individuals involved in RWP Nos. 740 and 764. The inspector reviewed the

MPC-hour records for the month of September 1985 and verified that no

personnel had exceeded 40 MPC-hours in one week. Air sample results for RWP

Nos. 740 and 764 were examined.

No violations or deviations were identified.

8. Maintaining Occupational Doses ALARA (83728)

10 CFR 20.1(c) specified that licensees should implement programs to keep

worker's doses as low as reasonably achievable ( ALARA). The recommended

elements of an ALARA program are contained in Regulatory Guide 8.8,

"Information Relevant to Ensuring that Occupational Radiation Exposure at

Nuclear Power Plants Will Be ALARA," and Regulatory Guide 8.10, " Operating

Philosophy for Maintaining Occupational Radiation Exposures ALARA."

The inspector c*ncussed the ALARA goals and objectives for 1985 with the

ALARA HP Supervisor. As of September 18, 1985, the actual collective

exposure was 1155 man-rem as measured by self-reading dosimeter (SRD). The

estimated exposure for the year was projected to be 1098 man-rem as measured

by thermoluminescent dosimeter (TLD). The licensee stated that the TLD dose

usually approvimated 85 percent of the SRD dose, but nonetheless, expected

to exceed their 1985 projection. The reason specified for the overrun of

the 1985 goal was the unexpected maintenance and repair work performed on

one reactor coolant pump (RCP) and the control rod drive mechanism gasket

replacement during the Unit 3 refueling outage.

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The estimate of collective dose for the Unit 3 outage was 320 man-rem and as

of September 18, 1985, the actual man-rem were 313 as determined by SRD.

The estimate for the RCP work had been 40 man-rem, but as of September 18,

1985, the accumulated total had already reached 48 man-rem and the licensee

was still experiencing problems in the reassembly of the pump.

No violations or deviations were identified.

9. IE Information Notices (92717)

The following IE Information Notices were reviewed to ensure receipt and

review by appropriate licensee management.

85-46, Clarification of Several Aspects of Removable Radioactive Surface

Contamination Limits for Transport Packages

85-42, Loose Phosphor In Panasonic 800 Series Badge Thermoluminescent

Dosimeter (TLD) Elements

85-57, Lost Iridium-192 Source Resulting In the Death of Eight Persons in

Morocco

85-07, Cpntaminated Radiography Source Elements

85-43, Radiography Events at Power Reactors

85-06, Contamination of Breathing Air Systems

84-56, Respiration Users Notice for Certain 5-Minute Emergency Escape

Self-Contained Breathing Apparatus

85-48. Respirator users Notice: Defective Self-Contained Breathing

Apparatus Air Cylinders

85-60, Defective Negative-Pressure, Air-Purifying, Full Facepiece

l Respirators

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