IR 05000369/1993014
| ML20057C157 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 09/09/1993 |
| From: | Forbes D, Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057C156 | List: |
| References | |
| 50-369-93-14, 50-370-93-14, NUDOCS 9309280015 | |
| Download: ML20057C157 (13) | |
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UNITED STATES r
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NUCLEAR REGULATORY COMMISSION
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f-l'a REGION 11
E 101 MARIETTA STREET, N.W., SUITE 2900
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y ATLANT A, GEORGIA 303234199
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Report Nos.:
50-369/93-14 and 50-370/93-14 r
Licensee: Duke Power Company P. O. Box 1007 Charlotte, NC 28201-1007 Docket Nos.:
50-369 and 50-370 License Nos.:
NPF-9 and NPF-17 Facility Name: McGuire 1 and 2 Inspection Conducted: August 16-20 1993
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Inspectors:
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B'. Shortri e
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Dat'e Signed
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D. B. Forbes
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Date Signed i
Approved by M
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9 f 9 )9 3 W. R. Rankin, Chief'
Date'S4gned
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Facilities Radiation Protection Section i
Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards
SU.iMARY l
r Scope:
This routine, unannounced inspection was conducted in the area of occupational
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radiation safety and included an examination of: organization and management
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controls, training and qualification, outage planning and preparation, audits
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and appraisals, external exposure control, internal exposure control, surveys, monitoring, control of radioactive materials and contamination, operational and administrative controls, maintaining occupational exposures as low as
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reasonably achievable (ALARA), and a review of inspector followup items
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(IFis).
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Results:
Based on interviews with licensee management, supervision, station personnel, t
and a records review, the radiation protection program appeared to continue to
be effective in protecting the health and safety of the workers and the public. An IFI was identified regarding the reduction of radiation levels
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around a valve (FW-9) and sump.
Licensee progress on resolving the high
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9309280015 930914 PDR ADDCK 05000369 G
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radiation levels'will be reviewed during subsequent inspections b(een effective. Paragraph 8.c).
The licensec's program to reduce out-of-core source. term has
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The inspector noted that key elements'of the program were
good shutdown chemistry, and flushing of hot spots. Operations, Radiation i
Protection, and Chemistry have exhibited good teamwork in this effort.
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REPORT DETAILS
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-1.
Persons Contacted Licensee Employees
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- J. Boyle, Superintendent, Work Control
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- D. Britton, Radiation Protection, General Supervisor
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R. Bufalo, ALARA Scientist l
- W. Byrum, Acting Radiation Protection Manager G. Cayton, ALARA Scientist
- T. Curtis, Manager, Engineering
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T. Eller, ALARA Specialist
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- G. Gilbert, Manager, Safety Assurance j
- T. McMeekin, Vice President
- K. Robinson, Chemistry Interface Coordinator l
- D. Scearce, Manager, Commodities and Facilities
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- R. Sharpe, Manager, Compliance t
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Other licensee employees contacted during the inspection included
technicians, maintenance personnel and administrative personnel.
i Nuclear Regulatory' Commission
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T. Cooper, Resident Inspector
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- G. Maxwell, Senior Resident Inspector j
- Denotes attendance at the exit meeting held on August 20, 1993 (
2.
Organization and Management Controls (83729)
l The inspector reviewed changes made to the licensee's organization, l
staffing levels and lines of authority as they relate to radiation i
protection. At the time of the inspection, the licensee was on the 46th day of a projected 95 day of Unit 2 End Of Cycle Outage 8 (U2E0C8).
The licensee continued to maintain a core radiological _ control
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organization with approximately 84 personnel. The Radiation Protection
Manager (RPM) position has been filled temporarily by a general
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Operations supervisor while the RPM is in reactor operators school. For
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U2E0C8, the inspector noted that approximately 75 contractor health l
physics (HP) technicians were employed to supplement the routine staff.
This number included 55 senior technicians, 20 junior technicians, and HP clerks.
Based on discussions with licensee representatives and observations of activities in progress, no concerns were identified regarding the licensee's organization and staffing. The staffing levels appeared i
adequate to support ongoing and planned outage activities, j
'l No violations or deviations were identified.
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3.
Training and Qualifications (83729)
10 CFR 19.12 requires that licensees instruct all individuals working or l
frequenting any portion of the restricted areas in the health protection
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aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose
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and function of protection devices employed, applicable provisions of
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the Commission Regulations, individuals responsibilities and the
.l availability of radiation exposure data.
During tours of Unit 2 containment, the inspector inquired of personnel i
about work area dose rates and the operational aspects -of their i
monitoring equipment. The inspector observed personnel donning and j
removing protective clothing, reviewing Radiation Work Permits (RWPs),
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I and logging into areas using Digital Alarming Dosimeters (DADS).
i The inspector interviewed plant workers, HP personnel, and managers to
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determine the effectiveress of new 10 CFR Part 20 training.
Based on l
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observations and discussions with personnel, training in these areas appeared adequate to support ongoing work.
No violations or deviations were identified.
l 4.
Outage Planning and Preparation (83729)
I Technical Specification (TS) 6.11 requires that procedures for radiation protection shall be prepared consistent with the requirements of 10 CFR J
Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
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The inspector reviewed selected procedures prepared for U2E0C8 refueling / maintenance outage and observed briefings for workers prior to
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entering the Radiation Control Area (RCA). The planning and preparation e
for U2E0C8 was discussed with ALAPA personnel.
Specific areas discussed included staffing, special training, equipment and supplies, HP involvement in outage planning, dose reduction methods, and licensee
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control over HP technicians.
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The inspector reviewed the licensee's VIE 0C8 Collective Dose Summary Report and found the report to be excellent in the presentation of data
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and in comprehensiveness. The report included a concise narrative on each of the major operations in the outage relative to the exposure estimate, goal, and actual exposure received. The data from the last outage was compared to the previous four outages and quantified the licensee progress in all areas. The report covered the many ALARA initiatives and conveyed the support of management for the aggressive program to reduce collective dose and out-of-core source term.
No violations or deviations were identified
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Audits and Appraisals (83729)
j The licensee maintained a Problem Identification Report (PIR) system
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that was accessible to employees plant-wide and provided a means for identifying, tracking and trending all significant concerns, issues and
problems within the plant.
No adverse trends were r.ated since the last -
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the PIRs by the inspector indicated that corrective actions were being
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resolved in a timely manner in response to the identified findings.
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No violations or deviations were identified.
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6.
External Exposure Control (83729)
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a.
Whole Body Exposure
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10 CFR 20.1201 (a) requires each licensee to control the occupational dose to individual adults, except for planned special
exposures under 20.1206, to the following dose limits-l (1)
An annual limit, which is the more limiting of:
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The total effective dose equivalent being equal to
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5 rems; or (ii) The sum of the deep-dose equivalent and the committed i
dose equivalent to any individual organ or tissue other.than the lens of the eye being equal to 50 rems
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(2)
The annual limits to the lens of the eye, to the skin, and to the extremities, which are:
(i)
An eye dose equivalent of 15 rems, and (ii). shallow-dose equivalent of 50 rems to the skin or to
any extremity.
The inspector reviewed and discussed with licensee representatives external exposures for plant and contract personnel for the period January 1, 1993 through August 17, 1993. Through review of dose information, the inspector confirmed that all whole body exposures assigned during the period were within 10 CFR Part 20 limits. The licensee had pre-estimated a total outage dose of 178.4 person-rem as of outage day 49 and based on this estimate, established a lower goal of 161 person-rem for day 49 of tne outage. The licensee improved upon the established goal by outage day 49 with a total dose of 135.1 person rem. The licensee's total dose at outage day 49 was their lowest total dose for any refueling / maintenance outage performed to date. The licensee's total outage goal established was 222 person-rem. Major job dose evolutions included:
Steam Generator Work, In Service Inspections, Radiation Protection Surveillance, Reactor Head Work, Valve Repair, Shielding, Snubber Work, and ottar miscellaneous work performed in Unit 2 Containment.
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The following Licensee Procedures were reviewed during the f
inspection concerning personal monitoring and external exposure:
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II-1, Radiation Area Access and Monitoring Devices, Revision
(Rev.) 3, dated June 7, 1993 I-4, Control of Exposure From External Sources, Rev.1,
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dated June 7, 1993
III-4, Use of Alarming Dosimeters, Rev. O, dated January:1,
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1993 111-13, Steam Generator Work, Rev. 1, dated June 7, 1993
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Based on discussions with licensee representatives and review of the above procedures and selected records, the licensee was found to be in compliance with the aforementioned requirements. The inspector noted that Radiation Protection Directive II-1, Step 5.3.5, did not require the worker to read his or her self-j reading pocket dosimeter or DAD except at the beginning and end of
a job while in the RCA of the plant.
Since this was identified in the previous inspection in May 1993, the licensee has made procedure changes requiring the frequent reading of dosimetry when
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individuals are in radiation and high radiation areas. This same
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point was previously discussed by the licensee in radiological occurrence reports and the licensee had agreed to incorporate the-
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guidance into General Employee Training.
b.
Personnel Dosimetry 10 CFR 20.1502 (a) requires each licensee to monitor occupational exposure to radiation and shall supply-and require the use of individual monitoring devices by:
(1)
Adults likely to receive, in one year from sources external to the body, a dose in excess of 10 percent of the limits in 20.1201(a)
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Minors and declared pregnant women likely to receive, in one year for sources external to the body, a dose in excess of 10 percent of any of the applicable limits in 20.1207 or 20.1208.
10 CFR 20.1501(c)(1) and (2) requires that dosimeters used to i
comply with 10 CFR 20.1201 shall be processed and evaluated by a processor accredited by the national Voluntary Laboratory Accreditation Program (NVLAP) for the types of radiation being monitored.
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The inspector reviewed and discussed the licensee's dosimetry program with site personnel and determined licensee dosimetry was being processed by corporate personnel. The inspector reviewed i
licensee NVLAP certification records and determined the licensee to be. certified in eight categories which included all types of radiation being monitored by the licensee.
No violations are deviations were identified.
7.
Internal Exposure Control (83729)
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a.
Whole Body Counting 10 CFR 20.1204(a)(3) requires, in part, that the licensee, as appropriate, use measurements of radioactivity in the body, measurements.of radioactivity 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.
The inspector reviewed the licensee's bioassay program as implemented under Radiation Protection Manual Procedure No.17.14, Internal Exposure Control Program. No problems were found during a review of the procedure or of selected bioassay records.
Routine bioassays were performed at initial employment, annually, and at termination.
Special bioassays were performed as needed.
b.
Respiratory Protection i
10 CFR 20.1703(a)(3) permits the licensee to maintain and implement a respiratory protective program that includes, at a minimum: air sampling to identify the hazard; surveys and bioassays to evaluate the actual exposures; written procedu_res to select, fit, and maintain respirators; written procedures regarding supervision and training of personnel and issuance of records; and determination by a physician prior to the use of respirators, that the individual user is physically able to use respiratory protective equipment.
10 CFR 20, Appendix A, Footnote (d), requires adequate respirable air of the quality and quantity in accordance with NIOSH/MSHA certification described in 30 CFR Part 11 to be provided for atmosphere-supplying respirators.
30 CFR 11.121 requires that compressed, gaseous breathing air meets the applicable minimum grade requirements for Type 1 gaseous air set forth in the Compressed Gas Association (CGA) Commodity Specification for Air, G-7.1 (Grade D or higher quality).
The following Radiation Protection Directive Procedures were reviewed during the inspection concerning respiratory protection:
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l I-6, Respiratory Protection Program, Rev. O, dated
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January 1, 1993
III-5, Airborne Radioactivity Control and Accountability,
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Rev. 2, dated June 7, 1993
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III-6, External Exposure to Airborne Radionuclides, Rev.1,
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i dated June 7, 1993 i
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III-17, Radiological Respiratory. Protection Program, Rev. O,
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dated June 7, 1993
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VI-1, Internal Dose Assessment, Rev. 1, dated March 22, 1993
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i Based on the procedure review as well as a retiew of selected records involving Grade D air checks and respirator issuance, no
concerns were noted. Also, during plant tours, a number of self-
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contained breathing apparatus strategically located throughout the plant were randomly checked by the inspector. All were found to be fully charged and ready for use.
A concern was raised by the inspector regarding a non approved breathing air hose that was attached to a breathing air manifold located in the Auxillary Building.
The hose was not in use at-the time it was observed by the inspector and the licensee took immediate corrective action to remove the hose from the manifold.
Further inspection determined the licensee was using compatible hoses required for use with specific bubble hoods and air-line respirators. The inspector also observed selected respirators staged for-issue and determined the physical integrity of the equipment to be satisfactory.
No violations or deviations were identified.
8.
Surveys, Monitoring, and Control of Radioactive Material and
Contamination (83729)
10 CFR 20.1501(a) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be present.
a.
Surveys The inspector reviewed selected records of radiation and contamination surveys performed during 1993, and discussed the
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survey results with licensee representatives. During tours of the plant, the inspector observed HP technicians performing radiation
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and contamination surveys.
No concerns were identified. The inspector independently verified radiation and/or contamination levels in selected areas of the Unit 2 Contair.nent Building, Auxiliary Building, and Radioactive Material Storage Areas.
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Posting and Labeling 10 CFR 20.1904(a) requires the licensee to ensure that each container of licensed material bears a durable, clearly visible label bearing the radiation symbol and the words " Caution,
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Radioactive Material," or " Danger, Radioactive Material." - The
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label must also provide sufficient information (such as
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radionuclides present, and the estimate of the quantity of
radioactivity, the kinds of materials and mass enrichment) to i
permit individuals handling or using the containers, to take
precautions to avoid or minimize exposures, j
During tours of the plant and selected outside radioactive
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material storage areas, the inspector noted that the licensee's
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posting and control of radiation areas, high radiation areas, J
airborne radioactivity breas, contamination areas, radioactive
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material areas, was adequate. The inspector also noted radioactive material was properly labeled.
c.
High Radiation Areas TS 6.12.1 requires, in part, that each High Radiation Area (HRA)
with radiation levels greater than or equal to 100 mrem /hr but-i less than 1000 mrem /hr be barricaded and conspicuously posted as a.
HRA.
In addition, any individual or group of individuals permitted to enter such areas are to be provided with or accompanied by a radiation monitoring device which continuously indicates the radiation dose rate in the area ar a radiation-monitoring device which continuously integrates the dose rate in the area, or an individual qualified in radiation protection procedures with a radiation dose rate monitoring device.
During tours of the Auxiliary Building, the inspector noted that all HRAs were locked and/or posted as required. The inspector performed independent radiation surveys at the boundaries of selected HRAs verifying licensee results. The licensee's posting of the affected areas appeared conservative and appropriate.
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TS 6.12.2, requires in part, that for individual areas accessible to personnel with radiation levels greater than 1000 millirem per
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hour that are located within large areas, such as PWR containment, where no enclosure exist for the purposes of locking, and no enclosure can be reasonably constructed around the individual areas, that area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device. During tours of the Unit 2 Containment, the inspector noted an area on the "A" floor where a refueling cavity drain line had a 90 degree bend.
The elbow was approximately 12 inches below valve FW-9 and read approximately 50 rem per hour at shutdown, 4.5 rem after
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flushing, and was currently at 200 millirem per hour after
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shielding. The licensee has barricaded the area and posted a yellow flashing light both at the top and bottom of the ladder
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accessing the area; however, the inspector. inquired if the' area
should have an enclosure constructed to support locking the area.
Licensee representatives stated that the area was very tightly packed with components and piping which precluded easily constructing an enclosure for locking. There were approximately i
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nine access points to the area around the pipe chase in addition to other ways over low walls to access the area. The-inspector reviewed licensee efforts to resolve the problem and noted that
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engineering authorization had been received to perform a modification on the pipe run to get rid of the crud trap; however, at the last ALARA committee meeting a problem was i
identified that the sump just below the FW-9 valve had increased j
in radiation levels and was contributing to the problem. The i
inspector requested licensee management review resources being
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applied to resolve the problem and informed the licensee that this would be tracked by the NRC as an Inspector Followup Item (IFI 50-
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369/93-14-01) and progress toward resolution would be evaluated during a subsequent inspection.
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d.
Personnel and Area Contamination
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During facility tours, the inspector noted that contamination control and general housekeeping practices were adequate.
i As of August 18, 1993 approximately 64 personnel contamination events (PCEs) had occurred during the year. The inspector
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reviewed PCEs and noted that licensee documentation and followup on the individual events was appropriate.
e.
Radiation Detection and Survey Instrumentation During tours of the plant, the inspector noted that friskers and contamination monitors had up-to-date calibration stickers and had i
been source-checked as required.
In addition, the licensee
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appeared to possess an adequate number of survey instruments and
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related equipment with only a small number out of service and in
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need of repair.
e No violations or deviations were identified.
9.
Operational and Administrative Controls (83729)
I a.
Radiation Work Permits (RWPs)
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The inspector reviewed selected routine and special RWPs for adequacy of the radiation protection requirements based on work scope, location and conditions.
For the RWPs reviewed, the inspector noted that appropriate protective clothing, respiratory protection, and dosimetry were required. During tours of the plant, the inspector observed the adherence of plant workers to I
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RWP requirements and discussed the RWP requirements with plant workers at the job site. The inspector also reviewed licensee i
procedure III-1, Use of the Radiation Work Permit, Rev. 2, dated July 1,1993.
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Notices to Workers
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10 CFR 19.ll(a) and (b) require, in part, thu. the licensee post current copies of-10 CFR Part 19, Part 20, the license, license
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conditions, documents incorporated into the license, license amendments and operating procedures, or that a licensee post a j
notice which describes the document and where it may be examined.
l 10 CFR 19.11(c) and (d) requires that a licensee post form NRC-3, Notice to Employees.
Sufficient copies of the required forms are i
to be posted to permit licensee workers to observe them on the way to or from licensee activity locations.
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During the inspection, the inspector verified that NRC Form-3 was
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posted properly at plant locations permitting adequate worker I
access.
In addition, notices were posted referencing the location where the license, procedures, and supporting documents could be.
reviewed.
No violations or deviations were identified l
10.
Program for Maintaining Exposures As Low As Reasonably Achievable
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(ALARA) (83729)
10 CFR 20.1101(b) requires that the licensee shall ue, to the extent practicable, procedures and engineering controls based upon sound
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radiation protection principles to achieve occupational doses and doses
to members of the public that are As low As Reasonably Achievable (ALARA).
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During tours of the lower level of Unit I containment in the inspection
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conducted in May 1993, the inspector noted that the entry to containment was posted a HRA. While many of the areas did not meet the 100 millirem per hour or greater at 12 inches, there were no radiation signs informing the workers of dose rates less than 100 millirem per hour.
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The licensee had posted hot spot areas and some heavily shielded components bore a sign that showed "Significant Dose Contributor."
However, for many work areas and access pathways reading 40, 60, and j
80 millirem per hour signs were not evident. The inspector discussed with the licensee the potential benefits of providing additional dose information for the worker in a way of dose rate signs to better inform workers not only of the dose rates in their immediate work areas but of increaseddose rates in pathways to and from the job site.
During tours of Unit 2 containment, the inspector noted that the licenser ::ad taken extra measures to inform the worker by posting additional signs with j
dose rate information in many of the areas with higher anticipated radiation levels.
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The Hot Spot Program (HSP) began in 1992, and 59 hot spots have been identified since its inception. To date 23 hot spots have been successfully flushed to below the level that define a radiation hot spot
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(greater than 100 millirem per hour and four times the background
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radiationlevel). ALARA representatives stated that of the 36 remaining hot spots, 14 are in units 1 and 2 containments and work on these areas require considerable more planning since they are worked during outage periods.
The inspector observed that in the Unit I containment basement all four Crossover Leg Drain Valves had been successfully flushed.
Readings as high as 15 Rem per hour had been reduced to 200 millirem per hour. ALARA representatives stated that without 100 percent support and cooperation from operations and chemistry the program would not be successful. The inspector described the HPS as a program strength at the exit interview.
In addition to a number of dose reduction initiatives, the licensee has performed early boration during shutdown for the last several peroxide injections.
Chemistry representatives stated that approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to shutdown, they reduce hydrogen and within 2-8 hours delithated with cation demineralizers.
When all rods are in, operations initates boration which achieves a radical drop in pH.
The reactor coolant system (RCS) undergoes clean up or purification via mixed bed and cation bed demineralizers. Hydrogen is removed by degasing and in mode 5 hydrogen peroxide is injected to force oxidation.
Attempts are made to get to 0.01 micro curies per milliliter after cobalt 58 peak.
Chemistry personnel stated that for UlE0C8, approximately 700 curies had been removed from the RCS and for U2E0C8, approximately 1300 curies of cobalt 58 was removed.
Source term reduction is measured and quantified by Radiation Protection with new equipment that has the capability to monitor 88 general area points and 40 contact points on the RCS.
Chemistry representatives stated that they were developing methods to reduce the introduction of non-radioactive nickel to the RCS which becomes cobalt 58 the main source term problem.
No violations or deviations were identified.
11.
Followup on Inspector Followup Items (IFI) (92702)
a.
(Closed) VIO 50-369, 370/93-08-01:
Failure to Label Radioactive Material Containers.
The licensee surveyed and labeled all vacuum cleaners used in radiologically controlled areas.
A new procedure was generated to control the use of vacuums in controlled areas.
The inspector reviewed the procedure and found it to be satisfactory.
This item is closed.
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b.
(Closed) VIO 50-369, 370/93-08-02:
Failure to implement controls for vacuum cleaners used in RCAs.
The licensee developed Radiation Protection Manual Directive III-18, Use of Vacuum Cleaners in Radiologically Controlled Areas.
- The inspector did-not observe any procedural non-compliance with vacuums during this inspection. A review of the procedure showed the licensee addressed the pertinent safety questions identified
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by the inspector during the inspection in May 1993. This item is l
closed, t
12.
Exit Meeting (83729)
At the conclusien of the inspection on August 20, 1993 an exit meeting was held with those licensee representatives denoted in Paragraph 1 of this report. The inspector summarized the scope and findings of the
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inspection. The inspector discussed one IFI identified below and in Paragraph 8.c of this report. The inspector also discussed two
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violations which were closed and discussed in Paragraph 11.
The i
inspector described the HPS discussed in Paragraph 10 as a program strength. The inspector received no dissenting comments.
Item Number Description and Reference
50-369/93-14-01 IFI - Followup on licensee actions to reduce I
radiation levels in the area of valve FW-9, Reactor Cavity Drain Line (Paragraph 8).
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