IR 05000369/1986031

Insp Repts 50-369/86-31 & 50-370/86-31 on 861020-24. Violations Noted:Failure to Follow Radiation Protection Procedures for Calibr of Air Sampler & Failure to Adhere to DOT Requirements for Transportation of Radioactive Matls

ML20214U093
Person / Time
Site:	McGuire, Mcguire
Issue date:	11/21/1986
From:	Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214U042	List: IR 05000369/1986031 ML20214U039 ML20214U056
References
50-369-86-31, 50-370-86-31, NUDOCS 8612090131
Download: ML20214U093 (9)

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p NUCLEA] RE!ULAT!RY COMMISSION REGION 18 g j 101 MARIETTA STREET * e ATL ANTA, GEORGI A 30323

'+4 * * * * * $ NOV 2 61986 Report Nos.: 50-369/86-31 and 50-370/86-31

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Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-369 and 50-370 License Nos.: NPF-9 and NPF-17 Facility Name: McGuire 1 and 2 i Inspection Conducted: October 20-24, 1986 Inspector: [/ / f(f4 B. K. RevsinN Date Signed Approved by: / Wi ///4 /J/t C. F04e3, / Sect) on Chief .

Date Signed Division of Radistion Safety and Safeguards

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SUMMARY Scope: This routine, unannounced inspection involved onsite inspection in the area of radiation p~rotection'and included: , control of radioactive materials and contamination, surveys'and monitoring; solid ' radioactive waste; transportation of radioactive materials; training and qualifications; external exposure control; followup of previous enforcement activities; and allegation followu '

Results: Two violations - failure to follow radiation protection procedures for calibration of air sampler and failure to adhere to Department of Transportation requirements for transportation of radioactive material DR 861126 ADOCK 05000369 PDR

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REPORT DETAILS Persons Contacted ,

Licensee Employees

• T. L. McConnell, Station Manager

• B. H. Hamilton, Superintendent of Technical Services

• J. W. Foster, Station Health Physicist

• F. Byrum, Health Physics Coordinator

• McCraw, Compliance Engineer

• G. Atherton, Compliance

• B. Travis, Superintendent of Operations

• J. Rains, Superintendent of Maintenance

• L. Firebaugh, Assistant Operations Engineer

• M. Rains, Project Engineer P. G. Huntley, Health Physics Coordinator D. C. Britton, Health Physics Coordinator J. C. Correll, Health Physics Supervisor G. G. Murphy, Health Physics Supervisor J. A. Cox, Health Physics Technician F. S. Bulgin, Quality Assurance L. Helderman, Quality Assurance D. Mustian, Instrumentation and Electrical Nuclear Regulatory Commission

• T. Orders, Senior Resident Inspector

• F. S. Guenther, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on October 24, 1986, with those persons indicated in Paragraph 1 above. Two apparent violations, failure to follow radiation protection procedures (Paragraph 9) and failure to adhere to Department of Transportation (DOT) requirements for the transportation of radioactive materials (Paragraph 8), were discussed in detail. The licensee acknowledged the inspection findings and took no exception The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . LicenseeActiononPreviousEnforcementMatters(92702)

(Closed) Violation (50-369/85-45-02) Failure to Perform Routine Radiation Survey The inspector reviewed the licensee's response dated February 20, 1986, and verified that the specified corrective action had been implemente _- -

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-3 (Closed) Violation _(50-369/86-20-01) Failure to Follow Radiation Work Permit (RWP) Procedure The inspector reviewed the licensee's response dated August 20, 1986, and verified that the specified corrective action had been implemente . Followup On Inspector Identified Problems (92701)

-(Closed) Inspector Followup Item (50-369/85-15-01): Testing Following Respiratory Protection Training. The inspector reviewed the testing' program established by the licensee to assess the effectiveness of the worker respiratory protection trainin . Training and Qualifications (83723) Health Physics (HP) and Chemistry Technicians Training The licensee was required by Technical Specification (TS) 6.3 to qualify personnel in accordance with ANSI N18.1-197 The inspector discussed the HP and chemistry training programs with licensee representatives who stated that both training programs were in the process of being reviewed by the Institute for Nuclear Power Operations (INPO) for accreditation. INP0 had begun the accreditation process at the Training and Technology Center where all the formal classroom training is conducted for all of the Duke Power Nuclear Station During the first two weeks of November 1986 INPO representatives were to review the on-the-job portion of the technician trainin It was anticipated that INP0 accreditation would be achieved within the next several month IndependentRadiationWorker(IRW) Training In 1985, the licensee had instituted an IRW program designed to increase the worker's responsibility for his own radiation protection and to provide the HP Section with assistance by providing HP coverage for routine job At the end of 1985, approximately 75 radiation workers had been trained as IRWs. The licensee stated that the number of IRWS at the plant had increased somewhat but that the actual implementation of the program through use of the IRW for HP coverage had not occurred. The licensee stated that due to the large amount of time that has lapsed between the training and the use of the skills learned in the training, that an evaluation will be conducted to determine the need for requalification of each IRW. The licensee stated that they were committed to implementation of the IRW program, but the timetable of implementation remained ambiguou Staffing HP staffing levels were discussed with the Station Health Physicis At the time of the inspection,112 positions were authorized,106 of which were filled. Seventeen of the 106 had come from the construction group, which was undergoing reduction, and were being rotated through

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the HP technician training program at the training cente The licensee had made a comitment to reduce their dependence on contractor HP technicians, and it was anticipated that by November 14, 1986, all contractor HP personnel would be gone from the site except for six who were involved in station decontamination wor No violations or deviations were identifie .6 Control Of Radioactive Materials And Contamination, Surveys And Monitoring

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The licensee was required by 10 CFR 20.201(b) and 20.401 to perform surveys and to maintain records of such surveys necessary to show compliance with regulatory-limit Survey methods and instrumentation were outlined in the Final Safety Analysis Report (FSAR), Chapter 12, while TS 6.11 provided the requirement for adherence to written procedure Radiological control procedures further delineated survey methods and frequencie During plant tours, the inspector examined radiation level and contamination survey results outside selected rooms and cubicles. The inspector performed j independent radiation level surveys of selected areas and compared them with

licensee survey results. The inspector noted that locked high radiation i

areas outside containment were maintained as required by TS 6.12. The inspector examined calibration stickers on radiation protection instrumentation in use throughout the plan During tours of the plant, it was noted that there were numerous catch containments which drained to plastic bottles or floor drain Licensee

! representatives stated that an aggressive contamination control program had been instituted at the facility at the beginning of 1986, and as a result,

the contaminated area of the Auxiliary Building decreased from approximately

! 40 percent (28,000 square feet) in January 1986, to approximately 13 percent l (9,000squarefeet)inOctober,1986. Budgetary allowances had been made to i permit acquisition of additional hydrolasing and steam cleaning equipment to

! facilitate the decontamination work. Work was continuing to decrease the amount of contaminated area in the plant through the catch containment / glove

! bag program and efforts were underway to remove the source of the j contamination through repair and maintenance of leaking equipment.

! No violations or deviations were identified.

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, SolidRadicactiveWaste(84722)

Onsite Disposal of Low Level Radioactive Material I On April 15, 1986, the Unit 1 makeup water storage tank (RMWST) was overpressurized and ruptured during a transfer of makeup water from Unit 2 in preparation for restart. Licensee investigation of the event concluded that overpressurization had occurred due to low air pressure of the level transmitter air supply which resulted in incorrect control

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room indication for the Unit 1 RMWST. It was estimated that approximately 14,000 gallons of water escaped the ruptured tan The water was confined to a small area around the tank by erection of sand dikes. The remainder of the water was also soaked up by dry san The major contaminants of the released water were tritium and low levels of fission products (I-131; Cs-134, Cs-137; Co-58, 60; Mn-54; and Rb-88). At the time of the inspection, the licensee had covered the residual piles of sand with heavy plastic and were anticipating disposal of the sand in the near futur The licensee had applied to the State of North Carolina for permission to bury sludge from their waste treatment system which contained low levels of fission product Application to the State was made to similarly bury the sand used to absorb the water from the RMWST since the radioactivity was of the same order and magnitude as the waste treatment sludg Approval was granted on September 24, 198 The burial site was located outside of the plant protected area but remained on Duke Power propert The inspector reviewed licensee Procedure HP/0/8/1003/21m Water Treatment Waste Disposal, November 27, 1984, and verified that it implemented the limits and conditions of disposal stipulated by the state applicatio b. Transfer of Radioactive Waste to a Land Disposal Facility 10 CFR 20.311 requires that the licensee maintain a tracking system for radioactive waste shipments to verify that shipments had been received without undue delay by the intended recipient. The inspector reviewed the tracking methodology used by the licensee and examined the documented receipt acknowledgements for Shipment Nos.86-106, 86-120, 86-36, 86-97 and 86-9 CFR 20.311 requires a licensee who transfers radioactive waste to a land disposal facility to prepare all wastes so that the waste is classified according to 10 CFR 61.5 CFR 61.55(a)(8) states that the concentration of a radionuclide may be determined by indirect methods such as the use of scaling factors which relate the inferred concentration of one radionuclide to another that is measured if there is reasonable assurance that the indirect methods can be correlated with actual measurement On June 29, 1986, while conducting a core inspectiun during refueling activities, material resembling fuel pellets was discovered in the upender area and on the core baffles. The licensee identified the material as irradiated fuel pellets which had escaped from three fuel rods situated in a single fuel bundl Pellet retrieval was accomplished using an underwater vacuum system which collected the pellets into a basket which was transferred to the spent fuel pool for

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storage. Review of reactor coolant activities revealed an increase in September 1985 which the licensee believed to coincide with the time of fuel bundle damage. If that were the case, then samples drawn in late 1985 for development of scaling factors for classification of radioactive waste would have been representative of the various waste streams after fuel damage had occurred. Since it was not possible to more accurately pinpoint the date of fuel damage, the licensee suspended all waste shipments until waste stream sampling could be performed and new scaling factors determined. By Ceptember 18, 1986, new scaling factors for all waste streams had been determined and waste shipment resume The inspector reviewed station Procedure HP/0/8/1004/03, Determination of the Waste Classification for Radioactive Waste Offered for Shallow Land Burial August 18, 1986, and verified that the inferred concentration of selected radionuclides could be correlated with actual measurement No violations or deviations were identifie . Transportation (86721)

10 CFR 71.5(a) requires licensees who transport licensed material outside the confines of its plant or other place of use, or who deliver licensed material to a carrier for transport, to comply with the applicable requirements of the regulations appropriate to the mode of transport of the D0T in 49 CFR Parts 170 through 18 The inspector reviewed selected records of radioactive waste shipments performed in 1986 and verified that the requirements of 49 CFR Parts 170 through 189 had been met for those shipment CFR 173.425(b)(1) requires that packaged shipments of low specific activity (LSA) material consigned as exclusive use must be packaged in a DOT Specification 7A Type A package, or a strong, tight package so that there will be no leakage of radioactive material under conditions normally incident to transportation.

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On August 11, 1986, Radioactive Waste Shipment No. 0886-184-A was sent to a land disposal facilit The shipment contained 14 B-25 metal boxes, 13 of which contained compacted dry active waste (DAW) and one of which contained uncompacted DAW. Upon arrival at the burial ground, the B-25 box containing uncompacted waste was noted to have a hole in the bottom. The box contained 8.4 millicuries of activit The burial metal box. ground officialsent The licensee notified threethe licensee of the representatives tohole in thesite the burial oneto inspect the defective box. Pictures were taken. The burial ground staff opened the box for the licensee and was found to contain heavy gauge wire in the bottom dith heavier waste on top. The licensee postulated that during transport the heavier material on top of the wire caused the wire to puncture the bottom of the box. This could not be confirmed however, since

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the hole was located under one of the skids on the box and had not been

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removed for inspection prior to loading and shipment to the burial groun In addition, several protuberances were observed near the hole suggesting that other breakthroughs might have been imminent. Smear surveys around the hole showed no detectable activity above background level As part of their corrective actions proposed to the State of South Carolina, the licensee committed to lining the B-25 metal boxes with 5/8 inch plywood or equivalent to minimize the potential for further punctures. Further, the licensee increased preshipment inspection requirements for the boxes which included inspection under the skids prior to loading on the truck. The inspector reviewed selected shipments of wasta and verified that the corrective actions had been implemente Failure to package a shipment of LSA radioactive material in a D0T Specification 7A Type A package or a strong, tight package was identified as an apparent violation of 10 CFR 71.5(a) (50-369, 370/86-31-01).

The inspector observed the arrival and receipt of a shipment of irradiated fuel from Oconee Nuclear Station using the TN-8L cask which permitted shipment of three fuel bundles at a time. Direct radiation measurements and smears for possible loose contamination were performed on the cask and all were found to be within regulatory limits. The inspector verified that the licensee was authorized to receive the shipmen 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 and 20.405 to control intakes of radioactive material, assess such intakes and keep records of and make reports of such intakes. FSAR, Chapter 12, included conrnitments regarding internal exposure control and assessmen TS 6.11 states that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposur Health Physics Procedure HP/0/0/1005/15, Calibration of Fixed Flow Rate, Variable Flow, and Constant Flow Rate Samplers, March 31, 1985, Paragraph 3.1 states that all samplers in use shall be calibrated at least every three month During tours of the plant, on October 11, 1986, the inspector observed air samplers in use in various locations in the facility. In the Waste Shipping Area, an air filter head had been attached to the top face of the B-25 box compactor and connected to a pump by tygon tubing. Inspection of the calibration sticker on the pump showed the device to be out of calibration since recalibration was due on September 12, 1986. A review of licensee records confirmed that the calibration sticker was correct and that the air sampler was past due for calibration. The licensee stated that all portable

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HP equipment was tracked by computer and that when the last calibration cycle had ended, efforts to locate the air sampler had been unsuccessfu Therefore, the computer printout had listed the air sampler located in the Waste Shipping Area as not in service. During compacting operations the air sampler had been used to determine the concentrations of radioactive materials in air in that area for determining compliance with regulatory limits and assessing individual exposures. The licensee removed the air sampler from service and returned it to the calibration laborator The sampler was checked and found to perform within *10 percent of the specified valu Failure to ensure that all air samplers in use were calibrated at least every three months was identified as an apparent violation of TS 6.11 (50-369/86-31-02).

10. AllegationFollowup(99014)

RII-85-A-100-002 and 003 The alleger said that he had several concerns regarding safety and radiography at the site. He stated that on one occasion he had been asked to set a boundary around a radiography shot that was being made so that people could continue to work in the area being radiographed. He stated that to the best of his knowledge and experience when a radiography shot is being made the area is usually cleared of non-rad!ography personnel. He said that even though a boundary had been established, the area should have been cleared of personne Discussion The inspector discussed radiography practices at the station with the licensee representative named as Radiation Protection Officer (RFO) far the byproduct license issued to the plant by the State of North Carolina for radiography source On the date in question a 87 curie iridium-192 source was used to conduct shots in the Unit 1 containment. Over a 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> and 15 minute time span, the source was actually exposed 21 minutes and 40 seconds. The RPO stated that general practice for radiography at plant locations was to establish a boundary such that no individual, excepting the radiography crew, if continuously present in the area could receive a dose in excess of 2 mR per hour or 100 mR in any seven consecutive days, which confonas to the requirements of permissible levels of radiation in unrestricted areas as specified in 10 CFR 20.105(b)(2). The RPO stated that the boundary was established by both calculatinn and physical survey of the radiation field and that when shots were being conducted all non-radiography personnel were removed from the area. It was further stated that when shots were being made in the Reactor Building (RB), the general practice was to clear the entire RB of all non-radiography personnel. However, on some occasions when critical retn work needed to be performed, instead of evacuating the entire RB for the shet. a 2 mR per hour boundary would be established, and persons

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would be permitted to work in the RB beyond the exclusion area. At these times, one of the crew maintained the interface between radiographers and non-radiographer On other occasions when work needed to be performed by non-radiographers in the exclusion area, the source would be cranked back into the camera and the individual escorted into the area to work. In all of these instances of work in the RB, the individuals involved were radiation worker The inspector reviewed the Industrial Radiography Safety Manual Revision 2, March 8, 1983, and verified that the general practices described by the RPO were specified in the Manua Finding The allegation was substantiated in that on occasion, non-radiographers were permitted to work outside the exclusion area established for the shot without requiring the entire building to be evacuated. Also on these occasions, one of the radiography crew manned the boundary between the radiographer's area and the non-radiographers. Also on occasions, workers were permitted to work within the exclusion area when the source was not exposed if the worker were escorted by a member of the radiography crew. No regulatory requirements were violated.