ML19332E139

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Forwards Insp Repts 50-369/89-28 & 50-370/89-28 on 890828-0901.Several Areas Where ALARA Program Could Be Improved Noted
ML19332E139
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 11/15/1989
From: Stohr J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Tucker H
DUKE POWER CO.
Shared Package
ML19332E140 List:
References
NUDOCS 8912060274
Download: ML19332E139 (4)


See also: IR 05000369/1989028

Text

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NOV 151989i

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D'ocket Nos. 50-369,'50-37'O

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License Nos. NPF-9, NPF-17-

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Duke ~ Power Company- ~

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ATTN:: Mr. H. B. Tucker, Vice President

Nuclear Production Department

422 South Church Street

Charlotte,' North Carolina 28242

- Gentlemen:

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-SUBJECT:

NRC INSPECTION REPORT NOS. 50-369/89-28 AND 50-370/89-28'

This ' refers to the Nuclear Regulatory Commission:(NRC) inspection conducted by ~

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W.. B. Gloersen ' and team on August 28.- September 1,

1989.

The inspection

included a-review of activities authorized for your McGuire facility.

At the-

conclusion of the' inspection, the findings were discussed with those members of-

your staff ~ identified in the enclosed Inspection Report.

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The inspection was conducted to evaluate the effectiveness of actions that have

~ been taken or are being- taken to keep radiation doses:as low as reasonably

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achievable _( ALARA).-

The : inspection team used selective examinations of

procedures and representative records, interviews with personnel, and

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observation. of activities _ in progress to perform the evaluation.

Particular

-attention was directed toward assessing management's awareness of, involvement

' n, and support of your facility's ALARA program.

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A number of notable strengths and improvement efforts identified in your

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programs are. described inL Enclosure 1 and are discussed in detail in the

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enclosed report.

Within-the scope of-the assessment, several areas where the ALARA program couldL

be improved - were identified.

These improvement items are outlined in

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Enclosure 1 to this letter and are discussed in detail in the enclosed report.

Since the results of your evaluation of these improvements are of interest to

the 'NRC,-you are requested to submit to this office within 60 days of the date

Lof' this letter, your written assessment of each of item including actions that

you'have taken or plan to take ore the item.

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Additionally, . the; enclosed inspection report identifies one activity that

appeared-to violate NRC requirements but was not cited; therefore, no response

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is required.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and its enclosures

will be placed in the NRC Public Document Room.

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ENCLOSURE I

EXECUTIVE SUMMARY

During the period August 28 - September 1, 1989, a special team inspection was

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conducted of. the. licensee's program for maintaining occupational radiation

doses ALARA. The assessment included a review of the causes for the relatively

high radiation doses of the past; an evaluation of the licensee's current

organization' and program for keeping radiation doses ALARA; a review of

initiatives the licensee has taken or is taking. to bring radiation doses to

within industry norms; and, an assessment of licensee management's awareness

of, involvement in, and support of the program for maintaining doses ALARA.

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Since 1983, the annual collective doses have generally increased with a maximum

collective dose of 700 person-rem per reactor occurring in 1988.

The

significant. increase in the annual collective dose since 1986 primarily was

attributed to increased steam generator maintenance, valve and pump repairs,

and various. nuclear station modifications.

In 1988, resistance thermocouple

detector (RTD) bypass manifold removal, valve repair, and steam generator

maintenance collectively contributed 55 percent of the total collective dose.

Overall, steam generator maintenance work including shot peening, eddy current

testing, and tube plug removal and installation was the largest contributor to

the station's total collective dose since 1986.

In 1989, the Unit I steam

generator tube rupture event contributed 23 percent to the station's total

collective dose while steam generator maintenance activities contributed

32 percent.

Although some of this upward trend could be attributed to

non-routine. exposure, management's continued support of the as low as

reasonably achievable (ALARA) program is necessary in order to control this

upward trend in the station's collective dose.

-In general, the assessment team found an adequate level of plant and corporate

management awareness and support for the dose reduction program. The licensee

has allocated a significant amount of resources to steam generator maintenance

activities due to design problems in the system which have contributed

significantly to increase the annual collective dose.

Increased innovative

dose management techniques for steam generator maintenance and repair, and

valve maintenance have been implemented by the licensee in an attempt to

reverse the recent increasing trend in collective dose. Although the licensee

has attributed the increasing trend to non-routine activities, it becomes

increasingly important for the licensee's management to focus on improved dose

management techniques for routine, low dose activities. Program strengths and

items to consider for improvement that were identified in the inspection are

summarized below.

Strengths

General worker and managenent knowledge of ALARA concepts and awareness of

their responsibility to keep doses ALARA.

ALARA concepts stressed throughout training.

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Good contamination control program.

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Completion and/or implementation of many dose reduction initiatives, such

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as:

RTD bypass removal; controlled crud burst program; reactor head

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Use of the newly revised dose status summary report for improved dose

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managenent.

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Items to Consider for Improvement

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Plant-wide procedure for development and submittal of ALARA job action

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plans and for selection of ALARA job sponsors (Paragraph 3.a.).

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Controls for evaluation of on-going work by upper management for jobs

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approaching or exceeding dose estimates (Paragraph 3.b).

Increased job site visits in the radiologically controlled area (RCA) by

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jobplanners(Paragraph 3.c).

Update and use job history files during job planning (Paragraph 3.c).

ALARA Committee objective to perform post-job reviews for high dose rate

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jobs in cases where the actual dose was significantly greater than the

estimated dose (Paragraph 5.b).

Improved use of the suggestion program for . making ALARA improvements

(Paragraph 5.c).

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Improved use of protective clothing and equipment in mock-up training

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conducted for high dose jobs (Paragraph 7.d).

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Documented guidance on acceptability of thermoluninscent dosimeter (TLD)

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vs pocket ~ dosimeter (PD) correlations to facilitate job planninq

activities for work groups receiving high accumulated dose (Paragraph 8).

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Knowledge and awareness by individuals and supervisors of departmental and

section dose goals (Paragraph 9.a(2)).

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Guidance for conducting and responding to General Office evaluations,

reviews, and audits (Paragraph 10.b).

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