IR 05000348/1987006

Insp Repts 50-348/87-06 & 50-364/87-06 on 870223-27.No Violations or Deviations Noted.Major Areas Inspected: Organization & Mgt of Health Physics Program,Training & Qualifications of Facility Staff

ML20207T499
Person / Time
Site:	Farley
Issue date:	03/09/1987
From:	Collins T, Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207T487	List: IR 05000348/1987006 ML20207T486
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-3.D.3.3, TASK-TM 50-348-87-06, 50-348-87-6, 50-364-87-06, 50-364-87-6, IEB-78-08, IEB-78-8, IEIN-86-103, IEIN-86-107, IEIN-87-003, IEIN-87-007, IEIN-87-3, IEIN-87-7, NUDOCS 8703240075
Download: ML20207T499 (12)

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NUCLEAR REGULATORY COMMISSION

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.o REGION 11 101 MARIETTA STREET, ,j

• * ATLANTA, GEORGI A 30323

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fiAR 141987

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IReportNo.: 50-348/87-06.and'50-364/87-06 Licensee: Alabama Power Company 600 North 18th Street ~

Birmingham, AL 35291 Docket No.: 50-348 and 50-364 License No.: NPF-2 and NPF-8 Facility Name:- Farley 1 and 2 Inspection' Conducted: February 23-27, 1987 Inspector: M 3!T[27 Date Signed

T. R. Collin,s_

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9D Date Signed F. N. Wright ' 6

. Approved by: '8Ltv 3 / 7 /r 7 C. M. Hosey', Section Chief Date-Signed Division of Radiat1on Safety and Safeguards SUMMARY Scope: This special announced inspection was in the areas of. organization and-management of the health physics program, training and qualifications of the facility staff, external exposure control . and personal. dosimetry.. internal exposure controls, surveys, monitoring and control of radioactive material,'the program to maintain exposures as low as reasonably r.chievable (ALARA), solid radwaste systems, transportation of radioactive mai.erials, IE-Bulletin 78-08, TMI Action Items II.F.1(3) and III.D.3.3 of NUREG-0737, Inspector Followup Items and IE -Information Notice .

Results: No violations or deviations-were identified.-

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8703240075 870311 PDR G

ADOCK 05000348 PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• J. D. Woodard, General Manager

• D. N. Morey, Assistant General Manager-0perations

• C. D. Nesbitt, Technical Manager

• L. S. Williams, Training Manager

• L. A. Ward, Maintenance Manager

• M. W. Mitchell, Health Physics and Radwaste Supervisor

• R. , Bayne, Chemistry and Environmental Supervisor

• P. Farnsworth, Radwaste Supervisor

• 0. M. Graves, Health Physics Sector Supervisor

• B. P. Patton, Plant Health Physicist

• J. K. Osterholtz, Supervisor-Safety Audit and Engineering Review

• G. P. Crone, Training Supervisor

• R. D. Henley, Plant Instructor Other licensee employees contacted included four technicians, two operators, three mechanics, three security force members, and two office personne Nuclear Regulatory Commission

• H. Bradford, Senior Resident Inspector B. R. Bonser, . Resident Inspector

• Attended exit interview g Exit Interview l

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The inspection scope and findings were summarized on February 27, 1987, with those persons indicated in Paragraph 1 abov The inspector discussed with licensee management the areas that were inspected during this inspection. The licensee did r.ot identify as proprietary any of the -

materials provided to or reviewed by the inspectors during this inspection.

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' Licensee Action on Previous Enforcement Matters

[ This subject was not addressed in the inspection.

l Organization and Management Controls (83722)

i l Organization i

The licensee was required by Technical Specification 6.2 to implement the plant organization specified in Table 6.2- The l

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4 responsibilities, authorities, and other management controls were furtherL outlined in Chapters 12 and 13 of the : FSAR. Technical: '

Specification 6.2 specified the ' members of the Plant Operations

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Review ~ Committee (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 administrative 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 area Staffing Technical Specification 6.3 specified minimum plant staffing. FSAR Chapters 12 and 13 also outlined further details on staffing. The

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inspector discussed authorized staffing levels vs. actual on-board staffing with the Health Physics Group Supervisor. The inspecto examined shift staffing for the day and evening shift on February 25, 1987, to determine if it met minimum criteria for radiation protection.

No violations or deviations were identifie . Training and Qualification (83723)

' Radiation Protection and Chemistry Technician Qualification

[ The licensee was required by Technical Specification 6.3 to qualify l' radiation protection and chemistry technicians in accordance with ANSI N18.1-1971. The inspector observed the. radiological controls established by a radiation protection technician covering L surveillance of Instrument and Control (I&C) personnel performing calibrations in controlled areas of the Auxiliary Building. - The inspector discussed with the technician these observed controls and 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 j' assure that they had not been assigned to work independently and had been qualified for assigned task . - - . - . . ._--. - - _ - - - - _ - -

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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 perfor The inspector reviewed the resumes training' records, and tests -for-selected contract technician 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 supervisors from the -

radiation -protection section, the training and experience -and selected : duties and responsibilities of their respective position The inspector reviewed the records of these individuals' experience and concluded that these personnel met the requirements of TS 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-0041. The inspector reviewed selected workers' respiratory qualification records.. The inspector reviewed recent changes in the respirator qualification program and discussed these changes with the Health Physics' Group superviso Technician Retraining Technical- Specification 6.4.1 states that a retraining and replacement training program for the facility staff shall be i 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 on several locked high radiation areas and observed the posting of survey results and the use of controls specified on three radiation work permits (RWPs).

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- .Use of Dosimeters and Controls

' lThe; licensee was required by .10 CFR 20.202, - 20.201(b), 20.101, 20.102, 20.104, .20.401, 20.403, 20.403, 20.405,19.13, 20.407, and 20.408 to maintain worker's' doses below specified levels - and keep

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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 areas. ; FSAR Chapter 12 also contained comitments

.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 postin The inspector . reviewed recent changes to plant procedures regarding the use of TLDs and dosimeter Dosimetry Results The inspector reviewed the TLD results for the year 1986. .These results showed that no individuals received greater than 5 rems in

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1986. . For.two individual 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 completed, 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 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)

The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403, and

.20.405 to control uptakes of radioactive material, assess such uptakes and keep records of and make reports of such uptakes. FSAR Chapter 12 also includes commitments regarding internal exposure control and assessmen 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. The inspector reviewed records for several workers who were issued respirators to determine if they were qualified for the respirators

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. 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 0- an interval of at .least every twelve months. as required by:

10CFR_20.103(c)(2)..

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- Uptake Assessment The inspector observed operation of the' whole body counter. The inspector also reviewed the results 'of. the analyses performed fo selected positive counts during 1986. ' The inspector reviewed the maximum -permissible concentration (MPC)-hour. log.for the second and third quarters 198 No violations or.deviat' ions were identifie .. . Transport'ation.(86721)

The ' licensee was required . by 10 CFR 71.5 to prepare shipments . of

. radioactive material in accordance with Department of Transportation

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regulations. The inspector reviewed recent changes to shipping procedures-and records of shipments of radwaste for the months of December 1986 and January. to March 198 The inspector verified that the licensee registered with the NRC for- packages used in 1986 and 198 No violations or deviations were identifie . Solid Waste (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

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specific ' requirements for conducting a quality control program for maintaining a manifest tracking system for all shipments.

! The inspector reviewed the following plant procedures for the packaging, L classifying, and tracking of radioactive waste shipped to low-level waste l burial - facilities: RCP-801, RCP-805, RCP-808, RCP-809, RCP-810, RCP-812, RCP-815 RCP-819, and RCP-820.

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i The inspector reviewed the methods used by the licensee to assure that waste was properly classified, met the waste forms and characteristics g required by use of these methods.

l The inspector reviewed selected manifests prepared for waste shipments

. made during the period of December 1986 and January to March 1987 to i verify that a tracking system was being used to insure that shipments l arrived at the intended destination without undue delay, i.

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The inspector reviewed training records of the personnel assigned the task for processing, packaging, and shipment of radioactive materials. The training received by these personnel was in accordance with appropriate procedures and 10 CFR 71.5 and the Department of Transportation regulation 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 day The inspector reviewed the licensee's-verification that the radwaste solidification system was operable for the fourth quarter of 198 The inspector discussed with a licensee representative the total solid radwaste shipped for burial during the year 1986, which was 8,645 ft3 containing 1,789.6 curies of activit No violations or deviations were identifie . Control of Radioactive Material (83726)

10 CFR 20.201 requires each licensee to make or cause to be made such surveys as (1) nay 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 equipmen 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 January 1987 and discussed with licensee representatives documentation of routine surveys and the review process to ensure routines were performed as require _ _ _ _ . _ _ _ _ _ _ .

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7 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 made,

. Contamination Control The inspector discussed with the Health Physics Group Supervisor the total contaminated area within the Radiation Controlled Area (RCA).

The inspector was informed that 20,243 ft2 out of 114,977 ft2 was considered contaminated, which is 17.6% of the RCA. The licensee' goal for 1987 was to reduce the contaminated area to approximately 7,500 fte by June 198 No violations or deviations were identifie . Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA (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 exposures as low as reasonably achievable. 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 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 i

The inspector reviewed selected ALARA evaluations for high exposure task and temporary shielding. Meeting minutes of the ALARA Review Committee were also reviewed. 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

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exceeding 1 man-rem. The licensee utilizes a manual tracking system

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to assign dose to a job. 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

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documented by the ALARA staf ALARA Man-Rem Goals The inspector reviewed the licensee's method for establishing i

facility annual ALARA man-rem goal The licensee's ALARA section l

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task for~ the upcoming year. The ALARA engineer and the individual section. representatives agree on exposure estimates based- upon

. previous ~ experience with the projected task. The annual ALARA man-ren goals for the facility were originally set -at 700 man-re However. expanded work during the Unit 2 refueling outage . held in the spring of 1986 exceeded the outage estimate 1of 235 by about In September 1986, the licensee revised the annual

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32 man-re man-rem goal upwards to 741 man-rem. During the inspection the inspector was informed that the facility's total man-rem for 1986 was 857.6 rem as measured by thermoluminescent dosimeter .(TLD). .The reasons given for exceeding the 741 man-rem goal was due to problems

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encountered during the fall 1986 outage on Unit 1. Even though the man-rem goal for 1986 was exceeded by 116 man-rem the facility compared well with the national average of 844 man-rem for a 2 unit PWR. The man-rem projection for 1987 has been set for 740 man-re .

No violations or deviations were identifie . TMI Action Plan Requirement Followup (2515/65)

In a letter to the licensee dated July 10, 1981, the Connission issued an Order for Confirming Licensee Commitments on Post-TMI Related Issues. The Order included licensee commitments made in letter to the Commission dated January '14, February 5, February 9, February 13, February 23, and February-23, 1981, and other references stated in the order to implement' the requirements set- forth in NUREG-073 Licensee letters dated January 14 February 9, and February 23,1981, addressed the licensee's connitments for TMI Item II.F.1(3), " Containment High Range Radiation Monitors."

Licensee letter dated January 14, 1981, also addressed the licensee's connitments for TMI Item III.D.3.3, " Improved Inplant Iodine-Instrumentation Under Accident Conditions."

TMIItemII.F.1(3),ContainmentHigh-RangeRadiationMonitor

' The licensee agreed to install two Victoreen Model 875 Radiation Detection Systems inside containment six feet above the operating deck, approximately 90' apart, and at locations to provide a reasonable assessment of area radiation conditions inside the containment during and following an accident. As described in the licensee commitment each radiation detection system consisted of an ion chamber detector, readout panel, and interconnecting cable Each detectoy was designed to measure ganna radiation with a range of 1 R/hr to 10 R/hr and have an energy response - 15% to 80 key and 8%

from 100 key to 3 me The inspector reviewed the vendor's literature and information provided by the licensee and determined that the monitor meets the l range and sensitivity criteria established in licensee commitments.

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The - monitors were to be calibrated at a maximum interval o month The licensee reported the capability for onsite calibration of the monitor to 10 R/h The licensee agreed to install -and have radiation monitors operational no later than January 1,1982.-

The inspector reviewed the licensee's calibration procedures for containment high radiation monitors. Licensee procedures require that the monitor be disconnected and calibrated onsite with a gama calibrator at 307 R/hr, 37 R/hr, and 1 R/hr i 30% of known radiation field. The licensee also response checks the detectors using a source with the detector in place in containmen However, th response check was not described in procedures. Calibration records documenting the results of the source calibration indicated that the response check was performed and satisfactory on all records reviewe Licensee representatives indicated that the response checks were made using a source which exposed the detector to 6-10 R/hr. The inspector discussed the lack of procedural guidance associated with the response check with licensee representatives and stated this will be reviewed in subsequent inspections (IFI 50-348, 50-364/87-06-01). The licensee's procedures also required that the monitors pre-amp receive an electronic signal 4 calibration corresponding to 0.01 R/hr,14.3 R/hr and 1.43 x 10 R/h The inspector reviewed the most recent electronic / radiation Calibration and response Checks of the instruments. The recorded data was within acceptance criteria for all calibration records reviewe The inspector observed the readout and strip chart recorders for the monitors in the Control Room. The monitors and strip chart recorders for the detectors were set as required in plant procedures and operational. The inspector discussed the use of the monitor in

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evaluating plant conditions.

Both reactors were at power during the inspection perio The

licensee supplied the inspector drawings and Design Change Review indicating proper installation for Unit Unit 2 detectors were installed while the Unit was under construction and the licensee was

• unable to provide the inspectors sufficient documentation during the inspection that indicated that the detector had been properly installed, inspected, and approved for operation. Verification that the containment high-range monitors for Unit 2 have been properly installed will be reviewed in subsequent inspections (IFI 50-348,

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50-364/87-06-02).

TMI Item III.D.3.3, Improved Inplant Iodine Instrumentation Under i

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The licensee committed to have' portable monitoring systems available for both units which uses silver'xeolite filter and single channel analyzer for :inplant monitorin The licensee reported that '

' emergency procedures had been revised to address the equipment and training .on the equipment had been provided. The licensee also reported the capability to prepare and count the sample in several

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The inspector, reviewed the licensee's portable equipment for inplant radiciodine monitoring and determined that the licensee appeared to

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have .a sufficient quantity of monitoring equipment for all vital-areas .where continuous occupancy is require The inspector determined that the licensee had procedures for operation, maintenance, and calibration of the air sampling and analysis equipmen The. inspector determined that the plant's health physics staff- receives training and retraining which includes training on the use of the air sampling equipmen Section 6.8.3.b of the licensee's Technical Specifications requires the licensee to maintain a program which will ensure the capability to accurately determine the airborne iodine concentration in.certain plant areas where personnel may be present under accident condition The program shall include - training of personnel, procedures for monitoring, and provisions for maintenance of sampling and analysis equipment. Training for inplant radioiodine sampling during accident conditions is dispersed throughout the health physics and chemistry programs in numerous training course Section 6.10 of licensee Administrative Procedure FNP-0-AP-17 defines-the Inplant Radiation Monitoring Program (STS 6.8.3.b) for inplant post accident airborne iodine. Section 6.'10 states that training for this program is covered under Appendix H to FNP-0-AP-45.

FNP-0-AP-45, Appendix H however, does not address training activities

associated with inplant airborne radiciodine sampling and analysis l

systems.

I The licensee agreed to define and assemble the appropriate training l elements for inplant sampling of radiciodine during. accident conditions and revise procedures to describe the training activities, b The revision of plant administrative procedures to clearly define the h training program to meet technical specification requirements of L 6.8.3.b will be reviewed in subsequent inspections (IFI) 50-348 and j 50-364/87-06-03).

No violations or deviations were identifie . Followup on IE Bulletins (92703)

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The inspector reviewed and verified the licensee's response and actions

taken to IE Bulletin 78-08 Radiation Levels from Fuel Element Transfer

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Tubes. for both Units 1 and 2. The licensee has added adequate shielding and eliminated access to any unshielded portions of the transfer tubes to maintain exposures ALARA. The inspector reviewed radiation survey results both prior'to and after shielding during fuel transfer and concluded that the licensee met-the requirements as set forth in IE Bulletin 78-0 No violations or deviations were identified.

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14. Inspector Followup Items (IFI) (92701)

(Closed) IFI 50-348/86-22-01 and 50-364/85-22-01: Revise respiratory protection procedures to comply with the medical qualifications 'of at least every twelve months as required by 10 CFR 20.103(c)(2). The inspector reviewed and verified that. the licensee has revised all

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respiratory protection procedures as related to respiratory equipment, to insure all personnel are. medically qualified at least every twelve months

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prior to issuance of any respiratory equipmen '

15. IE Information Notices (IEN) (92717)

l The inspector determined that the following information notices had been i received by the licensee, reviewed for applicability, distributed to l appropriate personnel and that action, as appropriate, was taken or planned.

86-103' Respirator Coupling Nut Assembly Failure 86-107 Entry Into PWR Cavity with Retractable Incore Detector Thimbles Withdrawn 87-03 Segregation of Hazardous and Low-Level Radioactive Wastes i

87-07 Quality Control of Onsite Dewatering / Solidification Operations j by Outside Contractors

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