ML20132B079

Insp Repts 50-269/84-33,50-270/84-30 & 50-287/84-34 on 841126-30.Violations Noted:Unauthorized Disposal of Radioactive Matl & Failure to Post Airborne Radioactivity Area

ML20132B079
Person / Time
Site:	Oconee
Issue date:	01/09/1985
From:	Albright R, Cooper W, Jenkins G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20132B058	List: ML20132B054 ML20132B065 ML20132B079
References
50-269-84-33, 50-270-84-30, 50-287-84-34, NUDOCS 8507230416
Download: ML20132B079 (10)

See also: IR 05000269/1984033

Text

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UNITED STATES

- [p M!p ~*'o NUCLEAR REGULATORY COMMISSION

-y"

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, REGION 88

g j 101 MARIETTA STREET,N.W.

• g ATLANTA, GEORGI A 30323

• • • • • JAM 2 3 25

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Report Nos.: 50-269/84-33, 50-270/84-30, and 50-287/84-34

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Licensee: Duke Power Company

-422 South Church Street.

Charlotte, NC: 28242

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Docket Nos.: 50-269, 50-270, and 50-287 License Nos.: DPR-38, DPR-47, and

DPR-55

-Facility Name: Oconee 1, 2, and 3

Inspection Conducted: November 26-30, 1984

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Inspectors:

R.

,

Albright

I /- 9-g5

Date Signed

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> - . /-9-9S~

W. T. Coo e q Date Signed

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-Approved by: .-

, / Ib

G. R. J 12 ns, S6ction Chief Date Signed

Divisi f Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection involved 78 inspector-hours on site

in the- areas of external exposure control and personal dosimetry, internal

exposure control and assessment, and control of radioactive materials and

contamination, surveys and monitoring.

Results: Two violations were identified. Unauthorized disposal of radioactive

material (paragraph 6), and failure to post an airborne radioactivity area

(paragraph 4).

8507230416 850123

PDR ADOCK 05000269

G PDR

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REPORT DETAILS

1. Licensee Employees Contacted

• M. S. Tuckman, Oconee Nuclear Station Manager

• T. Barr, Superintendent of Technical Services

• R. T. Bond, Compliance Engineer

• D. Davidson, Compliance Engineer

• C. L. Harlin, Health Physics Staff

• B. P. Cripe, Health' Physics Staff

• B. Jones, Chemistry Staff

'0. L. Whit, Quality Assurance

Other licensee employees contacted included technicians and office

personnel.

NRC Resident Inspector

J. Bryant, Senior Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on November 30, 1984, with

those persons indicated in paragraph 1 above. The violations for

unauthorized disposal of radioactive material (paragraph 6) and failure to

post an airborne radioactivity area (paragraph 5) were discussed with

licensee management. Licensee management stated their position that the

airborne radioactivity area was not required to be posted because exposure

to noble gases is treated as external exposure in accordance with 10 CFR 20,

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3. Licensee Action on Previous Enforcement Matters

(Closed) UNR (270/84-25-01) - This item was determined to be a violation and

is discussed further in paragraph 5.

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4. External Exposure Control and Personal Dosimetry (83724)

10 CFR 20.101(b)(3) requires the licensee to determine an individual's

accumulated occupational dose to the whole body on an NRC Form 4 or

equivalent record prior to permitting the individual to exceed the limits of

20.101(a). The inspector reviewed selected occupational exposure histories

, of individuals who exceeded the values in 10 CFR 20.101(a). The exposure

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histories were being completed and maintained as required by 10 CFR 20.102.

10 CFR 20.202 requires each licensee to supply appropriate personnel

monitoring equipment to specific individuals and requires the use of such

equipment.

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During tours of the plant, the inspector observed workers wearing appro-

priate personnel monitoring devices.

The inspector reviewed selected active RWPs for appro, teness of the

radiation protection requirements based on work scope, location, and

conditions.

20.401(a) requires each licensee to maintain records showing the radiation

exposure of all individuals for whom personnel monitoring is required under

20.202 of the regulations. Such records shall be kept on Form NRC-5 or

equivalent.

The inspector reviewed selected individual exposure recrrds maintained by

the licensee for personnel employed at the plant.

10 CFR 20.201 requires licensees to make surveys as may be necessary to

comply with the regulations in 10 CFR 20 and which are reasonable under the

circumstances to evaluate the extent of radiation hazards that may be

present. A survey is defined as an evaluation of the radiation hazards.

The inspector reviewed a licensee report of possible overexposure for

personnel working in the secondary side of the steam generator when their

extremity pocket dosimeters were found offscale. The work being performed

involved adjusting an orifice plate in the secondary side of the 1A steam

generator. Extremity and whole body doses were monitored by TLD and pocket

dosimeters located on the hands, upper arm and chest.

The highest extremity exposure for the four workers involved was 10.829 rem.

The quarterly extremity exposure limit is 18.75 rems. The highest whole

body dose received was 1.080 rems. The quarterly whole body exposure limit

is 3.0 rems. The preplanning work package for this job indicated that the

highest dose rate would be from the steam generator tubes and gave the

highest previous dose rate as 17 R/hr. The vendor health physics technician

who did the survey for the job read the preplanning work package; however,

when he made the initial survey, he surveyed only the handhole area and

found up to 3.3 R/hr.

About halfway through the job, this technician read the pocket dosimeters

located at the extremity and chest for the workers and found approximately

150 mrem at the chest and 1 rem for the right hand. Near the end of the

work, a second vendor health physics technician took over the surveillance

and discovered the steam generator tubes were reading 21 R/hr. He checked

the wrist and upper arm dosimetry for the individual doing most of the work.

At the end of the work, the right hand dosimetry for three personnel was

offscale. No actual overexposures occurred. The licensee investigation

determined the apparent cause of the incident as 1) inadequate radiation

surveys, 2) inadequate determination of which portion of the body was

receiving the highest exposure, and 3) inadequate monitoring of pocket

dosimeters at the extremities, upper arm, and chest during the work. The

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licensee restricted the workers from the restricted area until their

exposures were determined. The health physics technicians involved received

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disciplinary action and the incident was reviewed with the HP staff. The

investigation report was also being routed to the HP staff for review and

this incident will be included in the preplanning work package for future

work on the secondary side of the steam generator.

The licensee had preplanned the work and had established adequate measures

for exposure control. Personnel errors resulted in an inadequate evaluation

for the work. The inspector stated that this is a violation of 10 CFR

20.201. However, since the violation meets the criteria of 10 CFR 2,

Appendix C for a licensee identified violation, no enforcement action will

be taken.

10 CFR 20.203 specifies the posting, labeling and c.ontrol requirements for

radiation areas, high radiation areas, airborne radioactivity areas and

radioactive material. 10 CFR 20.203(d) requires that each airborne radio-

activity area shall be conspicuously posted with a sign or signs bearing the

radiation caution symbol and the words: " Caution - Airborne Radioactivity

Area". Airborne radioactivity area is defined as any room, enclosure, or

operating area in which airborne radioactive materials composed wholly or

partly of licensed material exists in concentrations in excess of the

amounts specified in Appendix B, Table I, Column I of 10 CFR 20, or when, in

any of the areas listed above, airborne radioactive material when averaged

i over the number of hours in any week during which the individuals are in the

area, exceeds 25 percent of the amounts specified in Appendix B, Table I,

Column I of 10 CFR 20.

During tours of the plant, the inspector reviewed the licensee's posting and

control of radiation areas, high radiation areas, airborne radioactivity

areas, contamination areas, radioactive material areas and the labeling of

radioactive material.

I 10 CFR 19.11 requires that each licensee post current copies of 10 CFR 19

l and 10 CFR 20 or if posting of the documents is not practicable, the

l licensee may post a notice which describes the document and states where it

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may be examined. 10 CFR 19.11 further requires that copies of any Notice of

l Violation involving radiological working conditions be conspicuously posted

l within two working days after receipt of the documents from the Commission.

l The inspector observed the posting of notices required by 10 CFR 19.11

l during tours of the plant.

The inspector reviewed the licensee's program for handling and leak testing

sealed sources containing byproduct, source and special nuclear materials as

required by Technical Specification (TS) 4.16.1. The inspector examined

survey records for 11 sealed sources for 1982, 1983 and 1984. The inspector

also reviewed the licensee's " Health Physics Source Handling Procedure"

which implements TS 4.16.1 requirements. Two separate records are currently

maintained to demonstrate compliance with the TS requirements. Record

number 1 is a log book which indicates the sealed source number, the date of

the surveillance and the smear survey activity for all sources requiring

surveillance. Record number 2 is Enclosure 5.1 to procedure number

HP/0/8/1C05/01 Health Physics Source Handling procedure which documents the

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source location, the leak test date, inventory date and the initials of the

employee performing the surveillance. The use of multiple records for the

same surveillance resulted in one record not being completed for the leak

test of one source (#0NS-144). However, the second record showed that the

source leak test had been performed within the required time frame. A

licensee representative stated that the two separate records would be

combined to make one record.

5. Internal Exposure Control (83725)

10 CFR 20.103(a) establishes the limits for exposure of individuals to

concentrations of radioactive materials in air in restricted areas. This

section also requires that suitable measurements of concentrations of

radioactive materials in air be performed to detect and evaluate the

airborne radioactivity in restricted areas and that appropriate bioassays be

performed to detect and assess individual intakes of radioactivity.

The inspector reviewed selected results of general in-plant air samples

taken during the period June - August 1984 and the results of air samples

taken to support work authorized by specific radiation work permits.

The inspector reviewed selected results of bioassays (whole body counts) and

the licensee's assessment of indiviaual intakes of radioactive material

performed during the period June - November 1984.

10 CFR 20.103(b) requires that when it is impracticable to apply process or

engineering controls to limit concentrations of radioactive material in air

below 25% of the concentrations specified in Appendix B, Table 1, Column 1,

other precautionary measures should be used to maintain the intake of

radioactive material by an individual within seven consecutive days as far

below 40 MPC-hours as is reasonably achievable. By review of records,

observations and discussions with licensee representatives, the inspector

evaluated the licensee's respiratory protection program, including medical

qualifications, MPC-hour controls and quality of breathing air.

The inspector reviewed the analysis data for brecthing air quality. A cross

contamination analysis is performed on the system on a quarterly frequency

and the air meets grade D breathing air requirements.

Health Physics procedure HP/0/B/1000/81 requires that only instrument air be

used for diving operations as the breathing air system does not supply the

necessary air pressure. The inspector reviewed analysis data for the

instrument air system and found that the air met grade D quality specifica-

tions. However, the licensee did not perform a radionuclide contamination

check on the instrument air. The inspector stated that the licensee should

implement a radionuclide test program for the instrument air system when

used for diving operations. The licensee stated that a procedure change

will specify sampling the instrument air for radionuclide cross

contamination.

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10 CFR 20.103(a)(3) requires that for the purposes of determining compliance

with the requirements the licensee sha!1 use suitable measurements of

concentrations of radioactive material i i air for detecting and evaluating

airborne radioactivity in restricted areas and in addition, as appropriate,

shall use measurements of radioactivity in the body, measurements of radio-

activity excreted from the body, or any combination of such measurements as

may be necessary for timely detection and assessment of individual intakes

of radioactivity by exposed individuals. 10 CFR 20.103(b)(2) requires that

whenever the intake of radioactive material by an individual exceeds 40

MPC-hours in a seven day period, the licensee shall make such evaluations

and take such actions as may be necessary to assure against recurrence. The

licensee shall maintain records of such occurrences, evaluations, and

actions taken in a clear and readily identifiable form suitable for summary

review and evaluation.

A review and discussion with licensee representatives of the body burden

analysis program indicated that the program was not established to ensure

that body burden analyses are reviewed to determine if personnel have

exceeded 40 MPC-hours in a seven day period. The inspector determined that

there were investigation points which would cause internal dose evaluations;

however, these investigation points for certain radionuclides would be

reached after the individual had been exposed to significantly greater than

40 MPC-hours in a seven day period. At the established investigation points

an MPC-hour calculation was not required by the licensee program. The

inspector reviewed selected body burden analyses for the period June -

November 1984 and found no indications that personnel had been exposed to

greater than 40 MPC-hours in a seven day period. The calculation of

MPC-hours for individuals who have body burdens which could be the result of

greater than 40 MPC-hours in a seven day period is required so that the

required investigation and corrective action can be identified and docu-

mented. Licensee management acknowledged the need for the program to be

changed. The inspector stated that this is an inspector followup item and

will be reviewed during the next inspection (269/84-31-01, 270/84-30-01,

287/84-34-01).

During the review of the licensee's radiological survey data, the inspector

noted the presence of low levels of alpha radiation on some equipment used

during refueling operations. Licensee representatives stated that the

equipment was used in all three units during refueling and that the

contamination possibly occurred in Unit 3, which did have fuel leakage when

the equipment was used. The inspector questioned licensee representatives

about the counting equipment used for alpha detection and the equipment's

i ability to detect the low levels of alpha radiation on air samples necessary

to insure that the alpha radiation did not pose an internal exposure hazard

to employees. Alpha measurement problems are discussed.in Inspection Report

No. 50-269/84-30, 50-270/84-29 and 50-287/84-32. Licensee representatives

stated that alpha contamination was low in comparison to beta gamma

! contamination and that personnel protection from the beta gamma contaminants

l has been adequate to protect from the alpha contaminants. The inspector

stated that alpha contamination may increase due to the fuel leakage and

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changes to the air sampling program could be necessary to accommodate

sensitivity problems with laboratory counting equipment.

10 CFR 20.203 specifies the posting, labeling and control requirements for

radiation areas, high radiation areas, airborne radioactivity areas and

radioactive material. 10 CFR 20.203(d) requires that each airborne

radioactivity area shall be conspicuously posted with a sign or signs

bearing the radiation caution symbol and the words: " Caution - Airborne

Radioactivity Area". Airborne radioactivity area is defined as any room,

enclosure, or operating area in which airborne radioactive materials

composed wholly or partly of licensed material exists in concentrations in

excess of the amounts specified in Appendix B, Table I, Column I of 10 CFR

20, or when, in any of the areas listed above, airborne radioactive material

when averaged over the number of hours in any week during which the

individuals are in the area, exceeds 25 percent of the amounts specified, in

Appendix B, Table I, Column I of 10 CFR 20.

NRC Region II Report Nos. 50-269/84-26, 50-270/84-25, and 50-287/84-28

discussed an unresolved item, UNR 50-270/84-25-01, concerning the failure to

post an airborne radioactivity area. On October 1,1984, the resident

inspector was cautioned that the area outside the Unit 2 waste gas decay

tank room contained airborne noble gas. The area was not posted as an

airborne radioactivity area. The licensee measured noble gas concentration

of Xe-133 at 2.7 times its concentration listed in 10 CFR 20 Appendix B and

Xe-135 at 4.6 times its concentration listed in 10 CFR 20 Appendix B. The

inspector discussed the failure to properly post the area as an airborne

radioactivity area with licensee representatives. The licansee did not

agree that the area had to be posted as an airborne radioactivity area since

the xenon is inert and the gas is not an internal hazard. 10 CFR 20 allows

the licensee to account for exposures to noble gases as part of the

quarterly external exposure limits of 10 CFR 20.101. The inspector stated

that the method by which the licensee chooses to account for exposure to the

noble gas, as described in 10 CFR 20.103(a)(1), does not allow for exemption

from the requirement to post airborne radioactive areas as stated in 10 CFR

20.203(d). The failure to post the areas containing the xenon gas in

concentrations above those which require posting as an airborne radio-

activity area is a violation of 10 CFR 20.203(d) (270/84-30-02).

6. Surveys, Monitoring, and Control of Radioactive Material (83726)

10 CFR 20.201(b) requires each licensee to make or cause to be made such

surveys as (1) may be necessary for the licensee to comply with the regula-

tions and (2) are reasonable under the circumstances to evaluate the extent

af .adiation hazards that may be present.

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The 11spector reviewed procedure HP/0/8/1000/54 which established the

l licensee's radiological survey and monitoring program and verified that the

procederes were consistent with regulations and good health physics

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f Procedure HP/0/B/1000/54 outlines the base schedule and frequency for the

l radiological survey and monitoring program.

The inspector reviewed selected records of radiation and contamination

l surveys performed during September and October 1984 and discussed the survey

results with licensee representatives.

During tours of the plant the inspector observed the health physics

technicians performing radiation and contamination surveys.

The inspector performed independent radiation surveys in the auxiliary

building and in the restricted area outside the auxiliary building and

verified that the areas were properly posted.

The inspector discussed with the licensee the method used to release

material from the restricted area and observed technicians performing

release surveys for material.

10 CFR 20.301 forbids a licensee to dispose of licensed material as waste

except 1) by transfer to an authorized recipient as provided in the regula-

tions in Parts 30, 40, 60, 61, 70, or 72 of this chapter, whichever may be

applicable, or 2) as authorized pursuant to 10 CFR 20.302 or 10 CFR 61, or

3) as provided in 10 CFR 20.303, applicable to the disposal of licensed

material by release into sewage systems, or in 10 CFR 20.306 for disposal of

specific wastes, or in 10 CFR 20.106 (radioactivity in effluents to

unrestricted areas).

The inspector reviewed a licensee investigation for the disposal of approxi-

mately 13.5 microcuries of Cs-137 and 1.18 microcuries of Cr-51 in 18,635

gallons of waste oil during the period September 1981 to June 1984. The

waste oil was shipped to a fossil fueled plant to be burned. Environmental

surveys around the fossil fueled power plant subsequent to the burning did

not indicate high radioactivity levels. Duke Power Company internal

correspondence dated March 25, 1981, indicated that waste oil from oil

sources on the primary side could be handled differently than oil sources

from the secondary plant. The correspondence indicates that it was under-

stood by Duke Power Company that there were no exempt concentrations of

licensed material when it originated from contaminated systems on the

primary side. However, they determined that oil from the secondary system,

principally turbine oil, would not normally be considered contaminated and

after a survey if less than exempt quantities per 10 CFR 30.18 were measured

the oil could be disposed or by burning without additional regulatory agency

approval.

The inspector reviewed the licensee's response to IE Information Notice

No. 83-05. The IE Information Notice stated that a license application had

to be initiated for any method of disposing of radioactive material which

was not described in the regulations. Their response to the general office

(GO) did not question the disposal of contaminated waste oil which was being

shipped to the fossil fuel steam plant for burning. The problem was first

realized by GO personnel who read a letter from NRC Region II dated

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March 20, 1984, to the McGuire plant where the allowed use of the exempt

quantity as defined by 10 CFR 30.18 was explained. Shortly after the last

shipment of contaminated oil was made, GO personnel realized that the NRC

interpretation of 10 CFR 30.18 would not allow it to be used for disposal

purposes. The plant was notified by the GO not to ship contaminated oil on

July 25, 1984. Near the end of September 1984, the NRC Region II was

notified that the licensee had disposed of radioactive material in the oil.

The inspector stated that the unauthorized disposal of licensed radioactive

material was a violation of 10 CFR 20.301 (269/84-31-02, 270/84-30-03, and

287/84-34-02).

7. ALARA Program (83728)

10 CFR 20.lc states that persons engaged in activities under licenses issued

by the NRC should make every reasonable effort to maintain radiation

exposure 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

Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for

Maintaining Occupational Radiation Exposures ALARA.

The inspector determined the ALARA goals and objectives for the current year

from licensee representatives and reviewed the man-rem estimates and results

for the current year.

As of November 30, 1984, the actual collective exposure for calendar year

1984 was 1056 man-rem which represented approximately 90 percent of the

estimated exposure for the year.

No violations or deviations were identified.

8. Information Notices (93717)

The inspector reviewed licensee responses to the following Information

Notices:

84-24 Physical Qualification of Individuals to Use Respiratory

Protective Devices

04-34 Respirator Users Warning: Defective Self-Contained Breathing

Apparatus Air Cylinders

84-40 Emergency Worker Doses

84-61 Overexposures of Diver in Pressurized Water Reactor (PWR)

Refueling Cavity

84-59 Deliberate Circumventing of Station Health Physics Procedures

84-60 Failure of Air Purifying Respirator Filters to Meet Efficiency

Requirement ,

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84-75 Calibration Problems - Eberline Instrument Model 6112B Analog

Teletectors

From the' review and discussions with licensee personnel, the inspector

determined that appropriate evaluations of these IE Information Notices had

been made. -The inspector had no further questions.

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