IR 05000369/1985044
| ML20198J124 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 01/22/1986 |
| From: | Hosey C, Revsin K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20198H979 | List: |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 50-369-85-44, 50-370-85-45, NUDOCS 8601310207 | |
| Download: ML20198J124 (7) | |
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UNITED STATES
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'o NUCLEAR REGULATORY COMMISSION
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101 MARlETTA STREET,N.W.
' ATLANTA, GEORGIA 30323
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JM 2 21986
. Report Nos.:
50-369/85-44 and 50-370/85-45
' Licensee: Duke Power Company 422 South Church. Street Charlotte, NC 28242
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Docket Nos.:
50-369 and 50-370 License Nos.:
NpF-9 and NPF-17 Facility-Name: McGuire 1 and 2 Inspection Conducted:
December 16-20, 1985 dld/ h4 Inspector:
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B/K.RevsN, Date Signed
. Approved by:
N/D
/[11/.Pd C. M. Hosey, Section Chief Date Signdd
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Division of Radiation Safety and. Safeguards SUMMARY Scope: This -routine, unannounced inspection involved 37 inspector-hours onsite during regular hours inspecting:
radiation protection program including training
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. and qualifications of personnel, program for maintaining exposures as low as reasonably achievable (ALARA), and activities associated with the Unit 2 outage;
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~- Resul ts : 'One violation - failure to perform radiological surveys.
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8601310207 860122 PDR ADOCK 05000369 i._G PDR
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REPORT DETAILS 1.
Persons contacted Licensee Employees
- T.-L. McConnell, Station Manager
- B. Hamilton, Superintendent of Technical Services
- B. Travis, Superintendent of Operations
- J. W. Foster, Station Health Physicist
- N. McCraw, Compliance Engineer P. G. Huntley, Coordinator, Health Physics D. C. Britton, Coordinator, Health Physics W. F. Byrum, Coordinator, Health Physics L. M. McKenzie, Technical Specialist, Health Physics R. J. Garcia, Technician, Health Physics J. S. Mooneyhan, Supervisor, Health Physics B. A. Mcdonald, Assistant Health Physicist Other licensee employees contacted included four technicians, six mechanics, two security force members, and two office personnel.
NRC Res'ident Inspectors
- W. Orders, Senior Resident Inspector
- R. Pierson, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarizea on December 20, 1985, with those persons indicated in paragraph I above. An apparent violation for failure to perform radiological surveys was discussed in detail.
Licensee management took no exceptions. The licensee did not ider.tify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters i
This subject was not addressed in the inspection.
4.
Training and Qualifications (83723)
a.
Radiation Protection Technician Training The licensee was required by Technical Specification 6.3 to qualify radiation protection technicians in accordance with ANSI 18.1.
The inspector discussed ~the training and qualification program with the j
Health Physics (HP) Technical Specialist in charge of implementation of the HP training program. The program is defined by three stages and
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requires six years for successful completion and includes formal classroom training and on-the-job training. The course outline for the training was reviewed.
Each stage of the program is defined by both mandatory and el.ective tasks with successful completion of the mandatory tasks being required for independent work by the technician.
Before a technician can be promoted to the next stage, he must have qualified on all electives as well as all mandatory tasks.
Selected records of HP technicians were examined to verify that all mandatory tasks of the on-the-job training had been completed.
The licensee stated that the HP technician training program _had been submitted for accreditation to the Institute for Nuclear Power Operations (INPO) on December 20, 1985.
Technical Specification (TS) 6.4.1 specified that a retraining and replacement training program for the unit staff shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971.
The inspector discussed the training / replacement program with the HP Technical Specialist.
b.
Independent Radiation Worker Training The licensee is in the process of developing a training program for a category of radiation workers designated as Independent Radiation Worker (IRW). This program is designed to take station employees other than Health Physics and provide them with a more extensive education in health physics.
At present the training consists of one week of classroom instruction and three weeks of on-the-job training.
The licensee stated that approximately 75 individuals at the site had been trained as an IRW, and that most of these persons belonged to the Maintenance Section.
The licensee stated that the intent of the program was to increase the worker's responsibility for his own radiation protection and to provide the HP Section with assistance in performing routine jobs. The IRW was described to the inspector as being one who would perform tasks such as equipment decontamination, contamination and radiation surveys, escort of radioactive materials within the plant and cover routine jobs in high radiation areas. The participation of the IRW in HP coverage of the job appears to be minimal at this point; however, it is envisaged by the licensee that in the near future, IRW participation in the HP arena will increase. The inspector pointed out that the licensee had not formalized the IRW program by procedures to cover such areas as types of radiological tasks the IRW may perform, who will review the work, how training will be accomplished and documented, do these individuals meet the requirements specified in TS 6.12, and who will control their work activities. Since these workers belong to sections other than HP, to whom will they report when functioning as an IRW.
The licensee acknowledged the inspector's statements, agreeing that
' documentation of the program was lacking.
This item will be reviewed during future inspections (50-369/85-44-01, 50-370/85-45-01).
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c.
Training and Qualifications of Contract HP Technicians The ' inspector reviewed the program for qualification of contract HP technicians.
The inspector discussed separately with two contract technicians their previous experience and training to determine if it was comprehensive or if it had been limited to selected tasks.
The-inspector reviewed the resumes, training records, and tests for these technicians.
No violations or deviations were identified.
5.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83726)
The licensee was required by 10 CFR 20.201(b) 20.403, and 20.401 to perform surveys and to maintain records of such surveys necessary to show compliance
- with regulatory limits. Survey methods and instrumentation were outlined in the FSAR, Chapter 12, while TS 6.8.1 provided the requirement for adherence to written procedures.
Radiological control procedures further delineated survey methods and frequencies.
a.
Surveys The inspector observed, during plant tours, results of surveys performed by the HP staff.
The inspector reviewed two Radiation Work Permits (RWP), No. 85-1021, Work Associated with "D" Steam Generator Eddy Current Testing Including Manway Removal, and No. 85-1022, Work Associated with Eddy Current Testing on "D" Steam Generator Including Diaphragm Removal, to determine if adequate controls were specified.
The inspector discussed the controls and monitoring with the HP staff.
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TS 6.8.1 required the establishment, implementation and maintenance of written procedures as specified in Appendix A, Regulatory Guide 1.33 -
1978.
McGuire Station HP Manual, Section 8.3, " Radiological Status and Routine Surveys," provided instructions for survey documentation in the Routine Log Book and on the survey maps while Exhibit 8.3-2, " Routines
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and Their Frequencies," specified the areas of the plant to be surveyed, the type of survey to be performed, the frequency with which they are to be performed and the responsible section. During plant tours the inspector examined radiation level and contamination survey results posted on plan views outside certain cubicles. Comparison of plan ' view survey dates with those listed in the Routine Log Book revealed that numerous surveys required by HP Manual Section 8.3, Exhibit 8.3-2 had not been performed.
To iliustrate this fact missed surveys of step-off pads from November 1 to December 13, 1985, are cited as an example. The survey frequency for step-of f pads was daily.
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Step-off pad surveys were not performed on the following days:
(1) Elevation 760 - November 6 and 26, December 5, 12 and 13, 1985 (2) Elevation 767 - November 6 and 27, December 5, 12 and 13, 1985 (3) Elevation /50 - November 6, 7 and 27, December 5, 12 and 13, 1985 (4) Elevation 733 - November 6,12, and 27, December 5,12 and 13, 1985 (5) Elevation 716 - November 7 and 27, 1985 The inspector was informed by the licensee that HP Supervisors were supposed to review the Routine Log Book each day to ensure that all routines had been performed. At the end of each quarter all routine sheets ' vere collected and sent to the cognizant HP coordinator for reviev. It was not possible to verify this statemant since there was no procedural requirement for routine log sign off to indicate that the HP Supervisor had reviewed these documents. The inspector informed the licensee that failure to perform radiological surveys was an apparent violation of TS 6.8.1 (50-369/85-44-02, 50-370/85-45-02).
During plant tours, the inspector noted that all locked high radiation areas outside containment were maintained as required by TS 6.12. The inspector noted that during the past year, the square footage of the plant determined to be contaminated had increased from 25 to 35% of the plant area that had been designated as controllable. The inspector was informed that some of this increase was in reality only an increase on paper since the licensee had performed a reassessment of the amount of controlled area in the plant, i.e., the area underlying four to six feet thick walls had not been taken into consideration and when this area was taken out, the actual percent of contaminated area increased.
With 35% contaminated on October 1, 1985, this corresponds to approximately 24,600 square feet.
Licensee management stated that extensive work was now getting underway to deconteminate as much of the plant as possible but much depended upon the speed with which work requests could be processed and acted upon.
b.
Frisking During tours of the plant, the inspector observed the exit of workers from contamination control to clean areas to determine if proper frisking was performed by workers.
The inspector reviewed selected
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records of skin contamination occurrences and resulting evaluations and corrective actions.
Records and discussions with licensee representatives showed that contamination had been promptly removed from the workers using routine washing techniques.
Skin dose assessment was performed on all contamination events greater than 1000 corrected counts per minute. All calculated doses greater than 10 mrem
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were added to the individual's exposure history and tracked as part of his official dose.
c.
Instrumentation During plant tours, the inspector observed the use of survey instruments by plant staff and compared plant survey instrument readings with readings made by the inspector using NRC equipment. The inspector examined calibration stickers on radiation protection instruments in use by licensee staff and friskers throughout the plant.
The inspector discussed methods for performing instrument source checks prior to each use with radiation protection technicians.
No deviations were identified.
6.
External Occupational Dose Control and Personal Dosimetry (83724)
During plant tours, the inspector checked the security of the locks at locked high radiation area and observed posting of survey results and the use of controls specified on three RWPs.
a.
Use of Dosimeters and Controls 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 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 areas.
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 maintenance mechanics and radiation protection technicians.
During plant tours, the inspector observed the posting of areas and made independent measurements of dose to assure proper posting.
b.
Dosimetry Results The inspector reviewed the TLD results for 1985. These results showed that all individuals were within the limits specified by 10 CFR 20.101 and 20.102.
No violations or deviations were identified.
7.
Maintaining Occupational Doses ALARA (83728)
10 CFR 20.1(c) specified that licensees should implement program to keep worker's doses 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
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Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures ALARA.
The inspector discussed the ALARA goals and objectives for 1985 with the ALARA HP Supervisor.
As of November 30, 1985, the actual collective
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exposure for the station was 720 man-rem as measured by TLD. The estimated exposure for the year was projected to be 721 man-rem as measured by TLD.
Based on the short approximately 10 day outage in December 1985, a new 1985 projection uas made at 760 man-rem. As of December 19, 1985, 62 man-rem of the total dose had been accumulated due to unexpected maintenance and repair work and due to eddy current testing and tube plugging during the December 1985, Unit 2 outage.
Planning for the 1986 100-day outage has begun with various work packages under development. The man-rem projection for 1986 was estimated at 1030 as measured by TLD.
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