IR 05000348/1986022

Insp Repts 50-348/86-22 & 50-364/86-22 on 861021-24.No Violations or Deviations Noted.Major Areas Inspected:Mgt & Organization of Health Physics Program,External Exposure Control & Personal Dosimetry & Internal Exposure Control

ML20214P161
Person / Time
Site:	Farley
Issue date:	11/21/1986
From:	Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214P132	List: IR 05000348/1986022 ML20214P130
References
50-348-86-22, 50-364-86-22, NUDOCS 8612040096
Download: ML20214P161 (9)

Text

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UNITE) STATES

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NOV 21 1986 Report Nos.: 50-348/86-22and 250-364/86-22 Licensee: Alabama Power Company 600 North 18th Street

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Birmingham, AL 35291 Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility Name: Farley 1 and 2 Inspection Conducted: October 21-24, 1986 Inspector: [

T. R. Collins

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/Date///f/8 Signed Accompanying Personnel: .F. N. Wright Approved by: e il//1 /[4 C. M. Hbsey; Sectior Chief Date Signed Division of Radiatich Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection was in the areas of organization and management of the health physics, program, trainhig and qualifications of the facility staff, external exposure control and personal dosimetry, internal

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Exposure control , surveys,' monitoring and control of radioactive material, the-program to maintain, exposures as low as reasonably achievable (ALARA), solid

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radwaste systems,' transportation ,of radioactive materials and audits of the health phyiscs progra No violations or deviations were identifie ~

Results':

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8612040096 861119 PDR ADOCK 05000348 G PDR .

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REPORT DETAILS

- Persons Contacted Licensee Employees

• J. D. Woodard, General Manager

• D. N. Morey, Assistant General Manager - Operations

• C. D. Nesbitt, Technical Manager

• L. W. Enfinger, Administrative Manager

• M. W. Mitchell, Health Physics Group Supervisor

• J. M. Walden, Radwaste Supervisor

• B. P. Patton, Plant Health Physicist

• J. K. Osterholtz, Senior-Safety Audit and Engineering Review P. Harlos, Health Physics Foreman D. Griffen, Health Physics Foreman M. Maddox, Senior Plant Instructor Other licensee employees contacted included three construction craftsmen, four technicians, two operators, four mechanics, two security force members, and two office personne Other Organizations Nuclear Support Services, In Nuclear Regulatory Commission W. H. Bradford, Senior, Resident Inspector

• B. R. Bonser, Resident Inspector

• Attended exit interview

! Exit Interview

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! The inspection scope and findings were summarized on October 24, 1986, with those persons indicated in Paragraph I above. The inspector discussed with i licensee management the areas that were inspected during this inspection.

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The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

l Licensee Action on Previous Enforcement Matters l

This subject was not addressed in the inspectio .

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4. OrganizationandManagementControls(83722) Organization .

.The licensee was required by Technical Specification 6.2 to implement the plant organization specified in Table 6.2-2. The responsibilities, authorities, and other management controls were further outlined in Chapters 12 and 13 of the FSAR. Technical Specification 6.2 specified the members of the Plant Operations Review Consnittee (PORC) and -

outlined the functions and responsibilities to be assigned to the Health Physics Group Supervisor and radiation protection responsibilities to be assigned to line managemen The inspector reviewed recent changes to the plant organization, to determine their effect on plant radiological controls, by examining the resulting changes to administrativt procedures and position descriptions and discussing the changes with the Health Physics Group Superviso The inspector discussed with the radiation protection supervisor and the plant Health Physicist, the type, methods of, and degree of interaction between plant groups. The inspector discussed with the Health Physics Group Supervisor and selected Radiation Protection Supervisors and Foremen, how frequently they toured the plant and radiation control areas, Staffing Technical Specification 6.3 specified minimum plant staffing. FSAR Chapters 12 and 13 also outlined further details on staffing. The inspector discussed authorized staffing levels vs. actual on-board staffing with the Health Physics Group Supervisor. The inspector examined shift staffing for the day shift on October 22, 1986, to determine if it met minimum criteria for radiation protectio No violations or deviations were identifie '

l S. Training and Qualification (83723)

f Basic Radiation Protection Training l The licensee was required by 10 CFR 19.12 to provide basic radiation protection training to workers. Regulatory Guides 8.27, 8.29, and l 8.13, outline topics that should be included in such training.

! Chapters 12 and 13 of the FSAR contain further commitments regarding

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trainin The inspector discusseu the initial and refresher general -

employee radiation protection training (GET) with the Training Supervisor and reviewed lesson plans to determine what changes had been made in GET training and the scope of these changes. The inspector reviewed the GET training records for several workers to determine if

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records reflected adequate completion of GET initial and refresher training, b. Radiation Protection and Chemistry Technician Qualification The licensee was required by Technical Specification 6.3 to qualify radiation protection and chemistry technicians in accordance with ANSI N18.1-197 The inspector observed the radiological controls established by a radiation protection technician covering the receipt of new fuel. . The inspector discussed with the technician these observed controls ari those specified on the RWP. The inspector reviewed training records for selected technicians to assure all topics were completed. The inspector discussed, with one radiation protection technician-in-training, the qualification program and assignments to assure that they had not been assigned to work independently and had been qualified for assigned task The inspector reviewed the program for qualification of contract radiation protection technicians. 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 selected contract technician c. Radiation Protection and Chemistry Foreman Qualifications Technical Specification (TS) 6.4 required radiation protection and chemistry supervisory staff to have four years experience in their specialty. The inspector discussed, with the Health Physics' Group Supervisor, the qualifications of selected foremen from the radiation protection section, the training and experience and selected duties and responsibilities of their respective positions. The inspector reviewed the records of these individuals' experience and concluded that these personnel met the requirements of TS d. Respiratory Protection Training The licensee was required by 10 CFR 20.103 to establish a qualification program for workers who wear respiratory protective equipmen Elements of the qualification program outlined in 10 CFR 20.103 were delineated in NUREG-004 The inspector observed workers using respirators while they were performing maintenance in the Auxiliary Building. The inspector discussed this use with the radiation protection technician covering the job. The inspector reviewed selected workers' respirator qualification records. The inspector -

reviewed rec'ent changes in the respirator qualification program and discussed these changes with the Health Physics' Group superviso . -

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5 Technician Retraining Technical Specification 6.4.1 states that a retraining and replacement .<

training program for the facility staff shall be in accordance with

. ANSI N18.1-197 Paragraph 5.5 of ANSI N18.1 states that a training program shall be established which maintains the proficiency of the operating organization through periodic training exercises, instruction periods and review .

The inspector discussed the replacement training and refresher training program for various personnel with licensee representatives and reviewed selected training record No violations or deviations were identifie . External Occupational Dose Control and Personnel Dosimetry (83724)

During plant tours, the inspector checked the security of the locks of several locked high radiation areas and observed the posting of survey results and the use of controls specified on six radiation work permits (RWPs). Use of Dosimeters and Controls The licensee was required by 10 CFR 20.202, 20.201(b), 20.101, 20.102, 20.104, 20.401, 20.403, 20.405, 19.13, 20.407, and 20.408 to maintain worker's doses below specified levels and keep records of and make reports of doses. The licensee was required by 10 CFR 20.203 and Technical Specification 6.12 to post and control access to plant area FSAR Chapter 12 also contained commitments regarding dosimetry and dose controls. During observation of work in the plant, the inspector observed the wearing of TLDs and pocket dosimeters by workers. The inspector discussed the assignment and use of dosimeters with the Health Physics Group Supervisor and several 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 procedures regarding the use of TLDs and dosimeters.

' Dosimetry Results The inspector reviewed the TLD results for the years 1985 and 198 These results showed that no individuals received greater than 5 rems in 1985. For four individuals who received greater than 1.25 rems in one quarter in 1986, the inspector examined each individual's dosimetry file to determine if NRC Form 4s had been complete . Management Review of Dosimetry Results The inspector discussed the dosimetry results with the Plant Health .

Physicist and the Health Physics' Group Supervisor. The inspector discussed administrative dose control extensions with selected . . - . . - - . . . . _ . .

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supervisors and staff. The inspector discussed these. cases with selected involved individuals and reviewed corrective action .;

No violations or deviations were identifie . Internal Exposure Control and Assessment (83725)

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The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403, and 20.405 to control uptakes of radioactive material, assess such uptakes and -

keep records of an make reports of such uptakes. FSAR Chapter 12 also includes commitments regarding internal exposure control and assessmer, 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 the Health Physics Group Supervisor and radiation protection technicians. . The inspector reviewed recent changes to respiratory protection procedures. During review of these procedures the inspector noted that two separate procedures RCP-106, Use and Operation of Full Face Filter Type Respirators and RCP-102 Selection of Respirators for Radiological Applications, stated that personnel qualified to wear respirators must receive a physical (medical qualification) at an interval of 456 days (One year +25%). The inspector reviewed records for several workers who were issued respirators to determine if they were qualified for the respirators issued and that an appropriate medical qualification was on file for eac The inspector determined that the licensee's program for medically qualifying personnel to wear respiratory equipment was at

an interval of at least every twelve months rather than at an interval of 456 days as stated in their Radiation Control Procedures. The inspector informed licensee management that 10 CFR 20.103(c)(2) states in part that prior to initial use of respirators individuals shall be

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determined physically able to wear a respirator and at least~ every twelve (12) months thereafter. The inspector concluded by his review that the licensee's program for assuring personnel were medically

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. qualified to wear respiratory equipment was adequate, however, their '

Radiation Control Procedures RCP-102 and RCP-106 should be revised to state the correct intervals for medical qualifications as required by 10 CFR 20.103(c)(2) (IFI/50-348/86-22-01). Uptake Assessment

.The inspector observed operation of the whole body counter. The inspector also reviewed the results of the analyses performed for

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selected positive counts during 1986. The inspector reviewed the maximum persmissible concentration (MPC)-hour log for the second and

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third quarters 198 No violations or deviations were identified.

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8. Transportation (86721)

The licensee was required by 10 CFR 71.5 to prepare shipments of radioactive ,

material .in accordance with Department of Transportation (DOT) regulation The inspector observed the preparation of a shipment of irradiated tools and equipment and discussed the shipment with the radwaste supervisor, and radiation protection technician The inspector reviewed the procedures under which the shipment was made and the resulting documentation. The inspector made confirmatory radiation level measurements of the shipment. -

The inspector reviewed recent changes to shipping procedures and records of shipments of radwaste for the months of January to October 1986. The inspector verified that the licensee registered with the NRC for packages used in 198 No violations.or deviations were identifie . SolidWaste(84722)

10 CFR 20.311 requires a licensee who transfers radioactive waste to a land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.5 It further establishes specific requirements for conducting a quality control program for maintaining a manifest tracking system for all shipment The inspector reviewed the following plant procedures for the packaging, classifying, and tracking of radioactive waste shipped to low-level waste burial facilities: RCP-801, RCP-805, RCP-808, RCP-809, RCP-810, RCP-812, RCP-815. RCP-819, and RCP-82 The inspector reviewed the methods used by the licensee to assure that waste

was properly classified, met the waste forms and characteristics required by l use of these methods with licensee representatives.

l The inspector reviewed selected manifests prepared for waste shipments made during the period January to October 1986 to verify that a tracking system

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i was being used to insure that shipments arrived at the intended destination without undue delay.

l The inspector reviewed training records of the personnel assigned the task i for processing, packaging, and shipment of radioactive materials. The l training received by these personnel was in accordance with appropriate procedures and 10 CFR 71.5 and 49 CFR regulations.

l Technical Specification 6.9.1.9 requires the licensee to submit a l Semi-Annual Effluent Report to the NRC in accordance with Regulatory Guide 1.21. The inspector reviewed the Semi-Annual Report for 1986 and concluded that the licensee met Technical Specification requirements as they relate to solid radwaste.

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Technical Specification 4.11.3.1(a)(b) requires the licensee to demonstrate that their radwaste solidification system shall be operable at least once per 92 days. The inspector reviewed the licensee's verification that the ..

radwaste solidification system was operable for the first three quarters of 198 No violations or deviations identifie i

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10. Control of Radioactive Material (83726)

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10 CFR 20.201 requires each licensee to make or cause to be made such l surveys as (1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under circumstances to evaluate the extent of radiation hazards that may be presen Procedures The inspector reviewed the licensee's procedures for the control of radioactive materials and determined that there had been no change which adversely affected the program, Frisking During tours of the plant, the inspector observed the exit of workers and movement of material from contamination control to clean areas to determine if proper frisking was performed by workers and that proper direct and removable contamination surveys were performed on material Surveys During plant tours, the inspector observed the use of survey instruments 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 staf The inspector reviewed selected routine survey results for the month of October 1986 and discussed with licensee representatives documentation of routine surveys and the review process to ensure routines were performed as require Radiation Work Permits The inspector reviewed selected radiation work permits in effect in Units 1 and 2 to determine if adequate controls were specified and ALARA considerations had been mad ,

No violations or deviations were identified.

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11. ALARA Program (83728)

10 CFR 20.lc states that persons engaged in activities under licenses issued s by the NRC should make every reasonable effort to maintain radiation exposures as low as reasonably achievable (ALARA). The recomended 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 ALAR ALARA Procedures ,

The inspector reviewed the recent changes to administrative procedures that implement the licensee's ALARA activities. The inspector discussed these changes with the ALARA coordinato ALARA Documentation The inspector reviewed selected ALARA evaluations for high exposure task and temporary shielding. Meeting minutes of the ALARA Review Committee were also reviewe The licensee stated that pre-job evaluations were required when the estimated collective dose for a job exceeded 5 man-rem or an individuals estimated dose for a job exceeding 1 man-rem. The licensee utilizes a manual tracking system to assign dose to a jo The inspector determined from the licensee that all of the refueling outage jobs resulting in exposures greater than the pre-job evaluation criteria had been evaluated and documented by the ALARA staf ALARA Man Rem Goals The inspector reviewed the licensees method for establishing facility annual ALARA man-rem goal The licensee's ALARA section receives input from the individual sections annually on projected task for the upcoming yea The ALARA engineer and the individual section representatives agree on exposure estimates based upon previous experience with the projected task. The annual ALARA man-rem goals for l

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the facility were originally set at 700 man-rem. However, expanded

! work during the unit two refueling outage held in the spring of 1986 exceeded the outage estimate of 235 by about 32 man-re In l

l September 1986, the licensee revised the annual man-rem goal upwards to 741 man-re During the inspection the licensee had obtained

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249 man-rem of the 375 man-rem projected for the Unit I refueling l outag The licensee expected to achieve the revised annual man-rem

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No violations or o",lations were identified.

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