ML20034C208
| ML20034C208 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 04/19/1990 |
| From: | Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20034C204 | List: |
| References | |
| 50-369-90-01, 50-369-90-1, 50-370-90-01, 50-370-90-1, NUDOCS 9005020169 | |
| Download: ML20034C208 (23) | |
See also: IR 05000369/1990001
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UNITED STATES
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NUCLEA3 RE ULATCRY COMMISslON
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REGION ll
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101 MARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323 -
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Report Nos.:
50-369/90-01 and 50-370/90-01
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 I and 2
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Inspection Cond ted:
February 25 - March 2,1990 and March 12-16, 1990'
G.B.Ku[zo d~~~
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Inspectors:
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Dai'eligned
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Approved by:
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T' . Po~ tie ~r',~thi?f
D~te igned
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facilities Radiation Protection Section
Emergency Preparedness and Radiological
Protection Branch
Division of Radiaticn Safety and Safeguards
SUMMARY
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Scope:
This routine, unannounced inspection involved review of licensee radiation
protection programs including staffing and organization, training, radiological
controls, exposure evaluations, quality assurance program implementation, "As
Low as Reasonebly Achievable" (ALARA) initiatives, and review of previously
identified inspector followup items.
Results:
Identified strengths for the radiation protection program included specialized
training provided to workers involved in potential high dose expenditure tasks.
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Training provided to, or verified for. radiation protection- technicians involved
with outage activities was thorough and well organized.
Radiation protection
staffing provided adequate coverage for the extended outage activities in
progress.
Management was knowledgeable of the status of, and- aware of
identified ALARA concerns.
Dose expenditure was managed adequately, with the
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expanded scope of the steam generator maintenance tasks contributing to the
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high collective dose reported.
Program weaknesses for failure to follow
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procedures, identified as cited and non-cited violations, were identified
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during the inspection.
In addition, the lack of job sponsor knowlecge
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regarding Radiation Protection ALARA procedure requirements was. identified asia
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significant program weakness.
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The following cited and non-cited violations were identified:
- Failure to label properly, storage / shipping containers maintained in the
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Unit 1, Turbine Building.
Characterized as a non-cited violation with
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corrective actions completed prior to end of inspection (Paragraph 4.b).
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Failure to follow procedures for frisking personal items being removed
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from
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Auxiliary
Building- Radiologically
Controlled Area
(Paragraph 4.c).
Failure to follow procedures for maintainirg documentation regarding. ALARA.
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program job planning (Paragraph 6.d),
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Failure to follow procedures for providing deficiency report regarding
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incomplete extremity dosimetry monitoring package.
Characterized as a
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non-cited violation with corrective actions completed prior !c end of
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inspection (Paragraph 8).
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Failure to follow procedures for wearing radiation work' permit required
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protective clothing when performing maintenance activities. Characterized--
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as a non-cited violation with corrective actions completed prior-to end of
inspection (Paragraph 9.c).
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- N. Atherton, Engineer, Compliance
- W. Byrum, Supervising Scientist, Radiation Protection
- D. Ethington, Engineer, Compliance
- J. Foster, Manager, Radiation Protection
- D. Franks, Verification Manager, Quality Assurance
- G. Gilbert, Superintendent, Technical. Services
- S. Leroy, Regulatory Compliance, General Office
- T. McConnell, Station Manager
- S. Mooneyhan, General Supervisor, Radiation Protection
- W. Osburn, Associate Nuclear Instructor
- 8. Robinson, Engineering Supervisor, Maintenance Engineering Support
M. Sample, Maintenance Supervisor
- R. Sharpe, Manager, Compliance
Other licensee employees contacted included engineers, technicians,
operators, and office personnel,
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Other Organizations Contacted
J. Eaton, Manager, Field Service Training'and ALARA Engineering, Special
Projects and Special Services, Babcock and Wilcock, Company
Nuclear Regulatory Comission
- T. Cooper, Resident Inspector
- P. Van-Doorn, Senior Resident Inspector
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- Attended Exit Interview on March 2, 1990
- Attended Exit Interview on March 16, 1990
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2.
Organization and Staffing (83750)
The current status of the onsite Radiation . Protection (RP) and Steam
Generator (S/G) vendor ALARA' organizations, including staffing and
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responsibilities in effect during the Unit 1 outage, were reviewed and
discussed with cognizant licensee representatives.
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Organization
During the inspection, the RP organization was reviewed and discussed
with cognizant licensee representatives.
Currently three general
supervisors and one supervising scientist report directly to the
Radiation Protection Manager (RPM).
Six shift supervisors report to-
a general supervisor responsible for routine shift work activities,
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Supervisors responsible for ALARA. program activities, dosimetry, and
Unit 1 outage activities report to the Unit l' general: supervisor..
Supervisors responsible for the respiratory- protection / instrument
calibration, decon activities, projects and relief, and Unit- 2 outage
activities report to the Unit 2, general supervisor.
Approximately
eight individuals assigned tasks regarding selected technical issues
report to the supervising. scientist.
No concerns were noted by the
inspector regarding the current organizational-structure.
The integration of the. site ALARA program with the vendor-
organization responsible for Unit 1,. S/G - activities was reviewed ~.
The inspector noted that the vendor had developed a well-organized
program including ALARA planning, training, and evaluation regarding :
S/G issues utilizing lessons learned from previous 1 outages and-from
evaluations of day-to-day activities during the. current outage. The
vendor maintained onsite ALARA coordinators responsible for reviewing
and evaluating site vendor ALARA program activites which were
implemented through the vendor's S/G.0utage Manager;
Vendor job
sponsors who report to the S/G Manager were responsible for
coordinating and implementing the
day-to-day ALARA' activities.
The
job sponsors interacted directly with the licensee's RP ALARA program
specialist.
The inspector noted that established coordination
between the licensee and vendor ALARA organizations was considered a
program strength.
No violations or deviations were identified.
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Staff
RP section staffing levels were reviewed and discussed with cognizant
licensee representatives.
The' RPM stated that currently. 27
supervisor and scientist positions were staffed within the RP group.
The inspector was informed that the supervisory-position responsible
for respiratory protection function / instrument. calibration had been
vacant since February 1990, with a replacement expected to- be
announced in March 1990.
Functions assigned to the vacant position
were detailed to other staff members until a . replacement was
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selected.
From review of activities. in progress, the inspector did
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not note any negative impact on the performance of the RP. group
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functions resulting from the vacancy.
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The current McGuire Nuclear Station (MNS) onsite health physics (HP)
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staff included 48 specialists and 15 technician positions. .
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Specialist met the criteria for senior level HP technician status
outlined in ANSI 18.1, that is, a minimum of 4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br /> of
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experience. Approximately 22 HP positions from the MNS, HP staff were
available and utilized for the Unit 1 outage job coverage.
For the
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current outage approximately 160 onsite contractors supplemented the
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licensee's RP staff.
Contractors included approximately 120 and 20,
senior and junior level HP tecnicians, respectively, and
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approximately 10 dosimetry specialists.
Licensee representatives
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stated that from evaluations of contract HP staffing needs for
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outages conducted during the previous year, the number of- senior
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contract HP technicians was reduced by approximately 15 percent
relative to previous outages of similar scope.-
During the inspection the ability of the HP staff to support job
coverage was evaluated by the inspector through direct observation of
ongoing activities and through discussions with licensee management,-
general employees, and contract' workers.
Staffing for. all tasks.
reviewed appeared adequate for work in progress..
. Licensee-
representatives indicated that with the current outage extended to
140 days, relative to the normal 70 ' day period, and with one day off
per week the number of contract technicians could be reduced further
with no expected problems in providing adequate HP job coverage.
No violations or deviations were identified.
3.
TrainingandQualifications(83750)'
10 CFR 19.12 requires the licensee to instruct all ind_ividuals working or
frequenting any portions of the restricted areas in the= health protection
aspects associated with exposure to radioactive material or radiation,.in
precautions or procedures to minimize exposure, and in:the purpose and
function of protection devices employed, applicable provisions of-
Commission Regulations, individual's responsibilities and-the availability
of radiation exposure data.
Training provided to HP contract technicians; and Lgeneral employees.
assigned to high dose expenditure tasks associated with the Unit 1 outage
activities was reviewed and discussed with licensee representatives.
In
addition, the licensee's use of mockup training' for. potential high dose
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expenditure tasks was reviewed in detail,
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Contractor HP Technicians
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Radiation Protection Manual Section 7.6, Contractor Training and
Qualification System (CTQS), Revision- (Rev.) 12, dated January 4
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1990, and Section 7.15, CTQS Initial Training / Assessment, Rev.16,
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dated January 4,1990, review the implementation of programs to
assure that contractor HP personnel are trained appropriately to:
conduct radiation protection activities.
In addition, the procedures.
provide guidance for waiving routine training requirements during
unexpected situations.
The inspector reviewed and discussed the experience 'and the training'
provided for the current onsite contract HP staff.
Licensee:
representatives stateo that the - technician qualifications were
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established in the vendor contract and subsequently verified during
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initial screening of the potential candidates' resumes.
An attempt
is made to hire personnel having previous MNS contract HP experience.
Licensee representatives stated that as a result of the unexpected
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early initiation of the Unit 1 outage, the number of available'
contractors with previous HP experience at MNS was less than.
expected.
The need for-expedited training of the contract'HP staff
required changes to the routine CTQS program.; Changes'to the CTQS
training assessment program _and resultant contractor. HP technician
job coverage limitations were documented by the RPM and distributed
to _ cognizant station ~ personnel in, memoranda dated January 16, 1990,
and February 2, 1990. The changes included exemption of all contract
technicians from formal CTQS ' requirements, assessments' of ANSI
qualified technicians based on previous experience- and oral = board
qualifications- for each task, waiverfof ~ junior technician minimumi
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experience requirement on a case-by-case basis upon approval of the
general supervisor, and maintenance -of documentation to verify the
training and qualifications _for assigned tasks.
In addition,
contractor HP returnees were considered qualified if knowledgeablefof
the current . training and requalification guide and if their MNS-
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training / bypass occurred within the last 18 months..
The inspector reviewed selected contractor HP- training records for-
individuals assigned job coverage ' associated with S/G and lower
containment activities.
Review' of HP task data reports verified
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completion of training for all individuals. The inspector noted that
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the training was provided as required to qualify = the contractor
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technicians and was documented appropriately.
Training provided to,
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or verified for the ~ contractor HP technicians: involved with outage
activities was thorough and well-organi:ed.
No violations or deviations were identified.-
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General Employee Training
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The inspector reviewed selected records regarding annual' _ General
Employee Training (GET) for employess involved in-on-going and/or
completed outage activities.
For individuals , selected for review, -including contractor HP
technicians and Construction Maintenance Department (CMD) personnel,
licensee records indicated all training was conducted _ in accordance
with applicable procedures.
From direct observation and subsequent. discussion with selected.CMD
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individuals during the: audit, the inspector noted a - lack . of
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understanding concerning frisking requirements when exiting the Unit
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2 Auxiliary Building (Paragraph 4.c).
Licensee representatives-
stated that the CMD workers frequently. moved among the three Duke
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Power Company (DPC) nuclear sites where frisking requirements differ
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and which possibly contributed to misunderstandings noted regarding
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MNS survey requirements.
From discussion with selected workers and.
review of selected memoranda provided to individuals responsible for
training CMD personnel, the inspector verified that training
regardina proper MNS frisking requirements were reviewed during
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either GET or specialized refresher training.
Licensee management
stated that to eliminate confusion and to prevent improper frisking;
the need to- re-emphasize during training MNS frisking _ requirements
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relative to other DPC sites would be evaluated.
No violations or deviations were identified.
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Specialized / Mock-up Training
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Radiation Protection Manual, Section 3.10, Mock-up Training, Rev. _0,
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dated December 18. 1989, describes the requirements for conducting
mock-up training for high exposure jobs.
Mock-up training is
reconrnended for tasks where total exposure expended exceeds 1.0 rem
and is required for tasks whose total : exposure . exceeds 10_ rem.
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Responsibility for the
training is assigned to thel group / person
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responsible for the task.
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The inspector discussed specialized mock-up training -provided to
workers involved with high dose expenditure jobs at the facility. :In
particular, mockup training activities associated with ' Unit 1,
Reactor Head, Reactor Coolant Pump (RCP) and- S/G _ maintenance-
activities were discussed and reviewed.
For the Reactor Head work, a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training course was presented-
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previously in June 1989~ and consisted of- a. review of._ approximately
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six mechanical maintenance procedures relating to Reactor Head work
.and subsequent completion of mock-up training _ activities.- Licensee
representatives stated that' during the current outage, changes to-
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procedures were presented and reviewed, and that mock-up training was
conducted.
The inspector reviewed and discussed with cognizant licensee-
representatives, the mechanical maintenance training for RCP--seal
replacement activities.
Mock-up training is conducted-_at1as DPC
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offsite facility utilizing a full-scale RCP _ mock-up.
Review of'the
licensee lesson plan for the task indicated that ALARA' considerations
were emphasized throughout the training.
Licensee' representatives
stated that actual mock-up training initially did not include use of.
protective clothing and equipment.
However, prior to completion.of-
the training all personnel involved are required to utilize.-the
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appropriate protective clothing and equipment while performing the
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task.
Additionally, licensee representatives stated that - the
train _ing involved both HP and quality: assurance (QA) personnel. The
inspector reviewed training completion records -and verified that
full-scale mock-up training for current maintenance workers had been
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conducted in April 1989 and November 1980.-
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For the S/G activities, the inspector was informed by cognizant
licensee representatives that mock-up training was provided both at:
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the S/G vendor facility and onsite.
During the audit, mock-up
training for planned tube sleeving activities conducted on a
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full-scale S/C mock-up was observed 'by the inspector at the vendor
facility.
Vendor representatives stated that_S/G crews were~ trained
yearly, or on an "as needed" basis, for specialized tasks.. The.
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training was established to meet both ANSI-and INPO guidelines and
consisted of written and oral examinations, and subsequent full-scale
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moci-up training.
The inspector noted extensive incorporation of
ALARA principles into the vendor program study guides and training.
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and the use of full protective clothing and< equipment during mock-up-
training. During the current MNS outage, vendor mock-up training had"
been provided for installation and use of S/G vendor robotic
instrumentation, and shot peening activities.
In; addition, the-
inspector noted that specialized mock-up training activites regarding
S/G tube removal' and tube- sleeving were in progress.
The_ extent.and
thoroughness of mock-up training for- personnel involved in S/G
activities was_ considered a RP program strength by the inspector.
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No violations or deviations were identified.
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4.
Respiratory Protection Program
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10 CFR 20.103(c)(2) permits the licensee ~ to maintain and to: implement a
respiratory protective program that includes, at a minimum: air sampling
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to identify the hazard; surveys and bioassays. to evaluate- the actual
exposures; written' procedures to select, fit and maintainLrespirators;1
written procedures regarding supervision and training of personne1'and .
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issuance of records; and determination by a physician _ prior' to;use: of
respirators, that the individual- user is physically .able' to ~ use
respiratory protective equipment.
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10 CFR 20, Appendix A, Footnote (d), requires -adequate- respirable air of
the quality and quantity in accordance with NIOSH/MSHA certification
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described in 30 CFR Part 11 to be provided for atmosphere-supplying
respirators.
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Training and Qualifications
The inspector reviewed and discussed respiratory _ protection: program
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training, fit testing, and medical qualification status for selected
personnel .using particulate and/or ~ air supplied respiratory
- protection equipment at the facility.
Review of selected training records indicated that'- selected
contractor and licensee HP technicians providing Reactor Head work,
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S/G, and RCP job coverage activities were trained, fit tested and
medically qualified in accordance with procedural requirements.
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No violations or deviations were identified.
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Breathing Air Quality
30 CFR 11.121 requires that compressed, gaseous breathing air meets
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the applicable minimum grade requirements for. Type 1 gaseous air set
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forth in the Compressed Gas Association (CGA) Commodity Specification'
for Air, G-7.1 (Grade D or higher quality).
Radiation- Protection Manual, Section- 17.11, Sampling the- VB System
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for Grade "D" Quality Air,
Rev. 7, dated May 10,' 1989, details the.
methods for verifying that the breathing air (VB) system meets the-
limits specified by CGA, G-7.1-1966.
The VB system is supplied by.
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two separate compressor systems alternately in use.
Although the
procedure -did not. specify a required frequency for ' sampling air
provided by the two independent compressors, licensee-representatives
stated VB system air was sampled monthly, but only for the compressor
in operation ~at the time of sample l collection.
Although.not az
licensee requirement,. the inspector noted that the National Fire-
Protection Association (NFPA) 1404, L Chapter : 7, Breathing : Air
-Programs, dated 1989, specifies quarterly Grade D air verification
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for supplied-air systems.
During review and discussion of the VB system, air' quality testing:
frequency, licensee representatives acknowledged that the current.
procedure did not-require verification that each compressor-provided:
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Grade D quality air.
Cognizant olicensee representatives? lndicated'
that the compressors supplying thelVB system were. switched each week
(Monday), and that during outages both compressors frequently were in'
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service, thus enhancing - the possiblity ~.that : each compressor was
sampled.
in addition, limited data regarding VB system maintenance
information in Operation logbooks, indicated. that from March 1989
through February 1990, both systems were sampled randomly.
For VB air samples collected-from August 1989 through lanJary 1990,
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the inspector vcrified that the licensee activities were conducted in
accordance with the approved procedure.
During . review of: the air:
uality data, the inspector noted that: results for' carbon monoxide
C0) frequently were reported as less than 10 parts per. million
ppm), and thus, met the recent reduction of Grade D air:C0' limits
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from 20 to 10 (ppm) as specified in the Compressed Gas Association,
Inc.
Standard, . ANSI /CGA G7.1-1989.
Cognizant " licensee
representatives, stated that the.10 ppm C0~ limiting value was-to be
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incorporated into the appropriate procedural guidance.
During the onsite inspection, a procedural change was completed to.
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identify the VB sample locations; to sample a different location each
month; if possible, and to sample each train (compressor) of the_VB
system each quarter.
In addition, Grade D specifications were-
updated in the procedure to_ meet the CGA G7.1-1989, specification of
10 ppm for C0.
No violations or deviations were identified.
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4.
Radiation Controls (83750)
a.
High Radiation Area Controls
Techncial Specification (TS) 6.12.1 requires that in lieu of the
" control device" or " alarm signal" required by paragraph 20.203(c)(2)
of 10 CFR 20, each high radiatior area, as defined in-10 CFR Part 20
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in which the intensity of ~ radiation is equal to:- or less than
1,000 millirem per hour (mrem /hr) at 45 cm -(18 inches) from the
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radiation source or from any surface which the radiation penentrates
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to be barricaded and conspicuously posted _as a high radiation area
and entrance thereto to be controlled by requiring' issuance of a:
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RadiationWorkPermit(RWP).
TS 6.12.2 requires that in addition to_ the requ'irements of TS' 6.12.1,
areas accessible to personnel with' radiation levels greater than
1,000 mrem /hr at 45 cm from the. radiation ' source from any. surface;
which the radiation penetrates to be provided with locked' doors -to
prevent unauthorized entry, and'the keys to be maintained under the
administrative control of the Shif t- Foreman on duty and/or health-
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physics supervision.
Doors are to remain locked except during-
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periods of access by personnel under an approved RWP which shall
specify the dose rate levels in the-immediate work; area and the
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maximum allowable stay time for individuals in that area.
In-lieu of
the stay time, continuous surveillance may be made by personnel
qualified in radiation protection procedures to provide. positive
exposure control over the activities being performed .in- the area.
For individual areas accessible to : personnel with radiation levels -
greater than 1,000 mrem /hr that are located within large areas, such
as PWR containment, where no enclosure exists for: purposes . of
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locking, and no enclosure can be . reasonably constructed:around the -
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individual. areas, that area will be barricaded, conspicuously posted,
and a flashing light will be activated as a warning device.
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During the audit, the inspector conducted daily tours of the. Unit 1-
and Unit 2 Auxiliary Building areas and observed selected activities
within the Unit 1 Containment. The inspector verified implementation
of controls for high radiation and locked high radiation areas were
appropriate.
In particular, radiological controls associated with -
S/G shot peening equipment were reviewed in detail.
All . areas
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potentially having dose rates greater than 1,000 mrem /hr associated
with the ' equipment located within the Unit I containment were
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btrricadded, posted, and identified by use of flashing lights in
accordance with TS requirements.
No violations or deviation were identified.
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b.
Labeling and Posting
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10 CFR 20.203(e) requires each area in which licensed material is
used or stored and which contains any radioactive material in an
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amount exceeding ten (10) times the quantity .of- such: material
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specified in Appendix C of this part to be posted with la sign or-
signs bearing the radiation caution symbol-and the words: " Caution,
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Radioactive Material (s)."
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10 CFR 20.203(f) requires each container of licensed material to bear
a durable, clearly visible label identifying.the radioactive contents-
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and providing sufficient information to permit individuals handling
or using the containers, or working'in.the vicinity thereof, to'take-
precautions to avoid or minimize exposures. -
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During tours of the' Unit 1- Turbine Building, the inspector noted .
waste and storage boxes containing licensed material which lacked the:
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appropriate ~ " Caution Radioactive Material"~ 1abels identifying 'the.
contents and providing- appropriate radiological information.' From:
discussions with licensee representatives, the inspector noted that
the waste containers were continually receiving potentially. low level
contaminated waste material from the Turbine Building and radiation
levels were expected to-be less than Appendix C-quantities. H.owever,
the storage boxes most likely contained insulation or-equipment
removed from containment and radionuclide quantities most likely
exceeded Appendix C limits and based on licenseefestimates. .The
inspector noted that ' the failure to lapel properly.- containers
having quantities' of licensed
radioactive material exceeding ten
(10) times the quantity specified in Appendix ^ C was : considered a
violation of l10 CFR 20.203(f) requirements.
The: licensee took
immediate corrective action and labeled the container appropriately,
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and reviewed other waste and storage containers for adequacy of:
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labels.
Review of other storage and- waste- containers within-' the '
facility did not indicate any additional , label violations. 'The
inspector informed licensee representatives that the- violation -was
not being cited because the criteria specified in Section V.A of, the-
NRC Enforcement Policy were satisfied.
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One non-cited violation _(NCV) was identified for failure to. label-
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containers properly as required by 10 CFR 20.203' (50-369,
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370/90-01-01).
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Surveys
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10 CFR 20.201(b) requires each licensee to make or cause to be made
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such surveys as may be necessary for the licensee to comply with the
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regulations in 10 CFR Part 20 and are reasonable under the
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circumstances to evaluate the extent of radiation hazards that may be
present.
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TS 6.11 requires procedures for personnel radiation protection to bei
prepared consistent with the requirments of 10 CFR 20. and to bei
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approved
maintained and adhered to for all operations involving
personnel radiation exposure.
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Radiation' Protection Nanual. Section 2.3, Contamination Control,
Rev. 23, dated November 11, 1989, requires that all personnel exiting;
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from radiologically : controlled ~ areas (RCAs) must frisk personal-
items, such as hardhats. notebooks, and flashlights.
The ; inspector reviewed and; discussed radiation surveys and personnel-
monitoring conducted for personnel exiting; the Unit 2 Auxiliary
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Building RCA.
During the week of March 12, 1990, the inspector
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observed approximately 20 workers exiting the RCA at the 774 foot -
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elevation of the Unit 2 Auxiliary Building and-performing whole body.
frisks using the PCM-1B monitors.
However, after ~ completion of. the
PCM-1B whole body frisk, epproximately 50 percent of the-individuals-
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failed to perform an individual" radiation survey of personal; items.
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for example hard hats, notebooks, and tools, until requested _to do so-
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either by the inspector or cognizant licensee' representatives.
From.
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discussion with selected individuals' recently-transferred from other
.
DPC nuclear facilities.- the -inspector was informed 'of confusion
regarding differences for_ frisking requirements. - Initial corrective
actions completed by the licensee included the posting of anoHP
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technician at the_ Unit 2, Auxiliary Building _774' RCA' exit point to
verify completion of all frisking requirements.
Licensee .
representatives stated that additional review of training provided-to
workers also would be conducted. - The inspector' informed licensee
representatives that the' failure to follow procedures for frisking-
personal items by individuals exiting. the RCA: was - considered an
apparent violation of TS 6.11 requirements.
One violation for failure to follow procedures for frisking personal-
items removed from the RCA was identified (50-369, 370/90-01-02).
,
5.
External Exposure (83750)
10 CFR 20.101 requires that no licensee shall possess, use, or transfer
licensed material in such a manner as to cause any individual in- a
restricted area to receive in any period of.one calendar quarter'a total _
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occupational dose in excess of 1.25 rems to the whole body, head and
'
trunk, active blood forming' organs, lens of- the eyes - or gonads;
'
18.75 rems to the hands, forearms, feet and ankles; and 7.5- rems to the
skin of the whole body.
.
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Radiation Protection Manual, Section 11.8, Rev.16, dated January.16,
1990, outlines requirements associated. with multiple badging, extremity
monitoring and placement of dosimetry for special situations.
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The inspector reviewed and discussed with cognizant licensee ~
represent 9?ives, whole body and extremity dose reported for.all personnel
during-J:rm ary - December 1989 and personnel involved in selected highi
dose expenditure tasks during the current Unit 1 outage,
a.
1989 External Exposure
For 1989, all external exposures as measured by thermoluminescent
dosimetry (TLD) were within regulatory and administrative guidelines.
For 1989, approximately 10 individuals ' whole body dose exceeded
1,900 mrom with a maximum individual exposure of 2,710 mrem -reported.
for a contractor maintenance worker.
The maximum-skin and extremity-
~
exposures reported were approximately . 3,500 mremiand 3,900~ mrem,
,
respectively, for CMD personnel.
No violations or deviations were identified,
b.
U2-E0C6 External Exposure Evaluations
.
During the onsite inspection, the inspector reviewed the current
individual whole body dose as measured by; direct reading dosimetry
'
for personnel working in accordance with specific RWPs associated-
with Reactor Head and RCP activities.
For Reactor Head work, the-
current highest exposure was 135' mrem associated with: removal of-
ventilation duct, conoseals, insulation. and head seals. .For RCP
~
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activities, the highest current , individual dose, 315 mrem, was-
reported for a worker conducting seal repair'and replacement. :During
review of the exposure data, licensee representatives stated that, in
general, a decrease in the dose per person and for completion:of each
task was expected relative to previous outages as' a' result.of the
increased experience of the CMD crews.
In addition, the inspector reviewed and discussed implementation of
the current extremity monitoring program.
For tasks involving
extremity monitoring, both wrist and finger-ring mounted TLDs are
issued.
Although the-licensee has studied the ratio of wrist to
finger ring exposure results for selected tasks, no plans to.use only
wrist TLDs were expected as a result of. the ~ wide variability of the
results.
The- inspector verified from discussions with cognizant
licensee representatives and review of extremity monitoring results
that both wrist and finger ring mounted TLDs were utilized during the
current outage.
Also, the inspector reviewed in detail extremity-
~
monitoring during. completion 'of shot peening; equipment. dust cup .
change-outs.
The inspector noted the dust cups which had. contact
dose rates of nearly 100 rem per hour were removed manually from the-
shot peening equipment.
For the task, the maximum extremity dose
reported,1,085 mrem, was within regulatory limits.
No violations or deviations were identified.
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6.
ALARA(83728,837S0)
10 CFR 20.1(c) states that persons engaged in' activities under licenses
issued by the NRC should make every reasonable- effort to maintain
radiation exposures ALARA.
4
.
Radiation Protection Manual,- Section. 3.4, ALARA' Pre-job and~ Post-job
'
'
Evaluation, Rev.1, dated September 15, 1989,' details _ requirements for
conducting ALARA job evaluations including pre-job planning on-going task.
.;
evaluations, providing - job. supervision, compilation of post-job- history,
and timely resolution of ALARA recommendations.
For high dose expenditure
tasks. the procedure requires documentation of work- hour or dose rate
reducation methods for each activity; the adjusted-work hours dose rates,
and exposure estimates; and pre-job meeting. minutes.
During the inspection, the licensee's implementation of selected ALARA
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program activities regarding Reactor Head; S/G, and'RCP tasks.was reviewed
by the inspector.
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a.
Steam Generator Maintenance
The inspector reviewed the ALARA - planning, lessons learned and
collective dose due' to S/G - maintenance activities at. MNS.
S/G
maintenance has accounted for a significant fraction of the total
station collective dose since 1986.
Because of the inexperience of
some of the vendors and the licensee in using the equipment and/or in
performing the activities, higher than expected doses'resulted.
From
1986 to 1989, the collective dose duelto steam generator maintenance
activities represented approximately-.30" percent, 20 percent,
--
25 percent, and 38 percent, respectively, of the total station annual
collective dose. This percentage of total collective dose due to S/G
1
work was significantly higher than that observed at other facilities.
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Licensee representatives indicated that the design: of: the S/Gs.
!
installed at MNS was one which had a high potential for. corrosion
i
leading to early replacement.
- For that reason, several . unique
1
activities were, and continued to be performed on. the -S/Gs to
'
evaluate system integrity and to extend their' lifespan.
Licensee
activities included extensive eddy- current testing- (ECT), shot
peening of both the hot leg and cold leg side of each S/G, and:U-bend
stress relief.
In addition, the licensee. has installed S/G tube
i
plugs in tubes where there was greater than 40 percent through-wall _
j
indications revealed by ECT and has= removed / replaced tube plugs with-
'
cracking indications.
For the Unit 1, End of Cycle Six (U1-E006)
!
outage, additional unplanned maintenance activities, including the
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sleeving of 400 S/G tubes was proposed. . Licensee representatives.
i
also indicated that due to their concern with maintaining S/Gs
i
integrity while promoting ALARA practices, some prototype equipment
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and activities were developed for the primary side tube operations by_
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the S/G vendors.
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With regard- to the S/G- maintenance work activities associated with
U1-E006 refueling outage, the inspector observed that the licensee's
'
ALARA planning efforts were ' not complete nor well documented. -
Furthermore, the S/G vendor job sponsors were not aware of Radiation,
,
- Protection Manual Section 3.4 (Rev. 6,: dated September 15, 1989),
which provided guidance ~ for conducting _ proper pre-job planning.'. The
.
'
inspector attempted to review job; action plans fce the U1-E006',. S/G
maintenance activities. For the initial S/G. shot peening activities.
completed -documentation of pre-job ALARA . activities was not
maintained on site.
The inspector noted that several ALARA' planning
worksheets were initiated in December 1989; however,- Unit.liinitiated-
outage activities on January 8.1990,' three. months earlier;than:
planned so most of the job action plans were never completed.
The
dose estimates for a particular job evolution were based on pasti
,
performance and not on proposed' adjustments to both the time required
i
to perform the task and the representative dose rate in the worktarea
af ter incorpating' ALARA proposals.
Although.the licensee. informally-
a
had identified some. methods to reduce work hours and/or dose rates
for S/G activities resulting in a reduction of dose expenditure,-
'
documentation of these methods was incomplete and not well organized.
For example, the evaluation and final resolution regarding the .
-
placement of shot peening equipment in the containmentifan rooms,-.a
low dose rate area, were not understood ~by job sponors and licensee-
r
ALARA specialists'nor documented.
Such issues;should,'at a minimum,
be documented informally for reference _ during . and following the
U1-EOC6 outage.
Typical ALARA work plans presented to the inspector
consisted of handwritten, undated, and ' unreviewed documents. iIn.
addition, during the review of_ job action plans, the inspector was-
not provided with documentation of. pre-job meetings.
Based on'
interviews with various job sponsors, the inspector.was. informed that
relief from' documentation requirements had been granted verbally by:
plant management to expedite outage activities.
'
The inspector observed that the licensee had conducted self-critiques
on S/G job performance for the ' U2-EOC5_ refueling outege.
The
inspector reviewed - the following 'two records documenting these
critiques:
2E005 Steam Generator Critique Meeting ' Minutes, dated
November 13, 1989
1989 Unit 2 E0C5 Refueling Outa
and Recommendations, (undated) ge Steam Generator ALARA Concerns-
The inspector noted that these documents provided detailed
recommendations for dose reduction opportunities.
According to HP,
ALARA representatives,
the Steam Generator _ Concerns- and-
.
Reconmendations document was submitted to the appropriate job
,
sponsors for possible incorporation into their ALARA planning
'
.
efforts.
However, the inspector observed.that no formal mechanism
existed onsite for feedback on= the feasibility of- the
e
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recomendations, or for their_ incorporation into the planning, as
applicable.
During a review of the ALARA. program activities conducted at the S/G
vendor facility, the inspector noted that' documentation regarding.
ALARA planning activities was completed and;available 'for review.
The documentation included dose reduction methodology. minutes: of-
.
pre-job meetings, and adjusted dose expenditure.-~The' inspector noted
that similar organized documentation should be maintained at the site
for reference.
'
Licensee ALARA group provided timely dissemination of current ' dose
status'. -During the review of U1-E006 S/G maintenance activities, the
--
inspector noted the job sponsors and Work crews were knowledgeable of
task dose and individual dose, respectively.
The inspector reviewed
,
the DPC/BW Daily ALARA Report, dated March 15,~1990, which provided-
collective dose information (total dose; dose . per S/G - tube;'
percentage of job completed _ and percentage estimated exposure) for
VI-E006 S/G maintenance activities.
As of March 15, 1990,-the
licensee had accumulated .100 person-rem for- primary S/G work, which-
represented approximately 40: percent of the goal (248 person-rein).
As of March 15, 1990, the licensee had not sleeved any steam
,
generator tubes.-
The _ licensee had estimated -approximately
52 person-rem to perform the - sleeving ' operation'(400 ~ sleeves: -
approximately-100 sleeves per S/G).
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Reactor Head ALARA Activities
Pre-job ALARA planning for Reactor Head removal /replacment activities
associated with the U1-E006. outage were discussed and; reviewed with :
cognizant licensee sponsers.
Station sponsors for the Reactor, Head
_
work activities were unware of details specified ~ in the- Radiation
Protection Manual ALARA- pre-job procedure, including required
documentation.
However, documents detailing.. November 14, 1989 and
January 11, 1990 Reactor Head Work ALARA planning meetings were
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provided to the inspector.
Licensee representatives stated that
,
eight post U2-E0C5 outage ALARA recommendations were presented for
incorporation into the current job planning..
No ' decumentation
regarding evaluations of the recommendations -were : available for'-
inspector review.
From the proposed _ recommendations,- licensee.
representatives stated that use of remote monitoring equipment for
entries into the reactor cavity during head removal and replacement,.
and use of experienced crews were implemented.
As of March 12,
1990, the person-rem exposure to remove the- Reactor Head was
5.385 person-rem with an expenditure of expected 16.38 person-rem for
completion of the task.
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c.
ALARA pre-planning activities regarding RCP maintenance tasks were
discussed with the current job sponsors.
No' documentation regardingi
,
the ALARA pre-job plans - were available for review. Further
discussions indicated that the current sponsors recently had assumed
1
their present position and were not provided with any ALARA data from-
the previous sponsor.
Furthermore,' the current sponsors were not
provided with training regarding the applicable ALARA: procedure.
The job. sponsors believed that the durrent. dose. expenditure estimates
,
-were from the previous outages and'did not involve-any time or dose
. rate adjustments.
The inspector noted that by the end- of the onsite' inspection. no
required pre-planning _ ALARA documentation, formal- or1 informal, as
specified in Radiation Protection Manual, Section~ 3.4, was available
.
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for RCP tasks.
The documentation should have included hour- or.-dose :
rate reduction methods for each activity; the adjusted work-hours,
-
dose rates, and exposure estimates; and pre-job, meeting minutes fo-
RCP tasks.
The inspector informed licensee: representatives that the
failure to follow procedures for maintaining ALARA ' pre-job '
documentation was a violation of TS 6.11.
'
During a previous NRC audit' of the MNS ALARA program documented 'in
Inspection Report No. 50-369, 370/89-28,. the lack of la plant-wide'
procedure for development and - submittal of ALARA' job action plans,
and for _ selection of ALARA. job sponsors was identified;as an ALARA=
program weakness.
However, in the licensee's . response -- dated
January 15, 1990, to the ' identified issue, licensee: representatives
stated that they believed the program. to be adequate and nc
,
additiont.1 actions were planned.
However,. from discussion with .
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selective job sponsors during the current audit, the inspector noted.
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that the majority of job sponsors were not aware of, nor provided
i
,
training regarding the Radiation' Protection ' Manual = ALARA . pre-job-
i
procedure, including required' documentation.
Subsequently,: the.
inspector informed licensee representatives that the niack of
,
!
documentation regarding ALARA activities negatively impacted the
radiation protection program.
The lack of training 'and/or
'
understanding by job sponsors regarding ALARA procedure requirements
was identified as a significant RP program weakness.
i
One violation for the- failure to follow procedures for maintaining
l
ALARA pre-job documentation for RCP activities was identified
'
(50-369,370/90-01-03).
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7.
ShippingandTransportation(86721)
\\
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10 CFR 71.5 requires that licensees who transport.-licensee material
outside the confines of its plant or other place'of use, or who deliver
licensed material to a carrier for transport, comply with the applicable
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requirements of the regulation appropriate to the mode of transport of the
Department of Transportation (DOT) in 49 CFR Parts 170 through 189.
10 CFR 20.311(b) requires that each shipment of. radioactive waste to a
licensed land disposal facility be-accompanied by a shipment manifest and
also specifies the required entries.on the manifest.
10 CFR 20.311(d) requires, in part, that any generating licensee who
transfers waste to- a licensed waste processor who treats or repackages
waste comply with the requitements of 10 CFR 20.311(b) and (c).
The inspector revicwed selected records-of radioactive waste and materials
shipments made from January 1,- 1989 through February 28, 1990.: The-
shipping manifests examined, for shipments made directly to a licensed
land disposal facility (Barnwell),'were prepared consistent with'49 CFR
requirements.
The radiation and contamination survey'results were within.
the limits specified for the mode of. transport and shipment classification
and the shipping documents were _being completed? and maintained _as -
i
required.
The inspector also reviewed shipping paper _ documentation
i
associated with licensed material shipped directly to a licensed . waste
!
processor (Scientific Ecology Group) for processing and supercompaction of
non-compacted waste.
The inspectors observed that the shipment-manifests
'
werecompletedinaccordance.withtherequirementsof10CFR20.311(b)..
The inspector also reviewed the shipping papers and documents of shipments
.
using D0T Spec 7A Type A packages covering the'same time period ~noted',
-
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above.
The licensee was shipping pressure vessel surveillance specimens
i
steam generator tube samples and plugs for analytical purposes.. During-
the records review, the inspector otserved that the licensee maintained on,
file documentation of the testing, engineering evaluation and comparative-
data showing that the containers mat _ked as 00T Specification 7A Type.A met
!
the requirements of that package (119 CFR 178.350).
The inspector also
i
observed that the licensee used a 00T 6M Type B package to ship steam
generator tube plug samples to Babcock and Wilcox~ in Lynchburg, VA
j
(Shipment No. RSR 89-44, dated August 17,1989). The inspector noted that
.j
the licensee had on file a statement of the certificate of-compliance and
1
a copy of the quality assurance package from the package manufacturer.
During the records review process, the inspector determined through-
interviews with licensee personnel that the shipper (licensee) inspected-
l
the package to insure that the package met DOT specifications and: thet
)
Quality Assurance / Quality Control (QA/QC) requirements .of the package
-
manufacturer; however, the tecords of the inspections were not made.
The
inspector discussed the need to maintain these and other. documents
referenced in the approval relating to the use and maintenarce of the
packaging and to the actions to be taken prior to shipment. The inspector
discussed the need to audit the QA program if the package, or similar
packages, were to be used routinely.
l
The inspector also reviewed the various certificates of compliance (C0Cs)
the licensee maintained on file for the various high integrity containers
!
(HICs) and shipping casks used to ship filter media, ion exchange resins,
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and other solidified low level waste.
The inspector observed that the
f
internal volumes of the various liners used were properly utilized to
calculate total curies on the-shipment manifests.
c
The ins)ector- also discussed the amendments to the Hazardous Materials
Regulat ons (HMRs) on Emergency Reponse Communication Standards as-
J
specified in .49 CFR 171,172,173, and 176.
The HMR amemdments will-
impose new requirenents for emergency response information on shipping
papers and placment of energy response information on vehicles and -at
transportation facilities.
.The - licensee was aware of the new
requirenents.
No violations or deviations were identified.
8.
Quality Assurance Controls (83750)
(
'
10 CRF 50, Appendix B,
Criterion XVI, requires that measures be
established to assure that conditions adverse to quality, such as
deviations and nonconformances, are promptly identified and corrected..
Radiation Protection Manual, Section 2.6,
Radiological Protection -
!
Incidents and Deficiencies, Rev.
5,
dated May 5, 11989,- details-
requirements for nionitoring performance .of station personnel by-
identifying radiological deficiencies for . determining ' root causes and
correcting human errors that cause radiological performance problems.
i
Deficiencies are to be documented on a Radiological._ Deficiency Report.-
'
During discussion with licensee representatives regarding extremity ~
exposure monitoring, the inspector was informed. of the failure of RP
personnel to issue a complete set of multibadge dosimetry ,for Lan
individual conducting S/G activities.
RWP 90-1047, All Work' Associated
With Special' Interest Eddy Current, Tube Pulling S/G D. Rev. O, dated
February 13, 1990, requires extremity dosimetry, that is, both wrist and
finger-ring TLDs, to be issued.
Licensee representatives stated that'on
February 20, 1990, as a result of a misunderstanding by-the responsible HP
technician, finger ring TLDs were not provided to the worker as required.
The issue was identified by RP personnel and proper evalJations conducted.
Whole body and extremity exposures, approximately 200 millirem (mrem) and
i
10 mrem were assigned to the individual. Wrist dosimetry was utilized for
evaluating the extremity dose.
The inspector noted that no radiological
deficiency report was issued although this issue met the criteria for
report issuance.
The inspector noted that the failure to issue a
deficiency report as required by applicable procedures was identified as a
>
violation of TS 6.11. The inspector noted that the report should be used
to identify the root cause of the deficiency and prevent' further
recurrence.
Further review of the licensee's RWP~ extremity monitoring
requirements indicated approximately six other RWPs not specific for
issuance of finger-ring TLDs.
Licensee representatives initiated
corretive actions to change the RWPs prior to the end of the onsite-
inspection.
The inspector informed licensee representatives that this
&
NRC-identified violation for failure to follow procedures Lissuance of a
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radiological deficiency report is not being cited because the criteria
specified in Section V.A of the NRC Enforcement Policy were satisfied.
One non-cited NRC-identified violation for failure to follow procedures
for issuance of a radiological deficieny report was identified (NCV-
50-369,370/90-01-04).
-
9.
Tour of Facilities (83750)
>
During the onsite inspection radiological controls and/ work practices were
observed during- tours of the Unit I and Unit 2 Auxiliary- Building and
Unit I containment areas.
The following . issues were . noted by the
inspector and-discussed with licensee management.
a.
Radiation Monitoring and Survey Equipment.
For selected radiation survey / monitoring equipment in use at MNS. the
'
inspector noted that the equipment was calibrated and performance-
checked in accordance with licensee procedures.
No violations or deviations were identified.
!
b.
Radiation Control Zones
,
3
Radiation Protection Manual, Section 16.2 Rev. 25, da'ted October 29,
1989, ' defines the criteria for establishment of, and posting
associated with radiation control zones (RCZs).
For areas within thr1
RCA, RCZs are required to be established - for areas - where -
'
contamination levels exceed 1,000 disintegration per minute per. hour
(dpm/hr) for beta-gairma radiation - or where exposure rates exceed
2 mrem /hr.
From discussion with selected RP individuals. during tours of- the
Unit 1 and Unit 2 Auxiliary Building, the inspector verified
'
appropriate establishment of RCZs in accordance with the. established
procedure.
No violations or deviations were identified.
'l
c.
Protective Clothing
1
Radiation Protection Manual, Section 2.3, Rev. 23, dated November 17,
.
1989, states that instructions for protective clothing are found on
RWPs for specific jobs or posted at entry to frequency and . routinely.
.l
entered rooms or areas.
SRWP
90-05,
Entry
for
Routine
Corrective
Maintenance / Housekeeping, dated Janu?ry 1,1990, details protective
.
clothing requirements when performing trash collection within the
RCA.
For trash collection the procedure requires the use of a lab
coat and surgical gloves when performing trash collection.
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On February 27, 1990, the inspector observed contractor maintenance
workers performing trash collection activities on the 733 foot
elevation within the Unit 2 Auxiliary Building. The inspector noted -
t
an individual not wearing gloves while collecting .by hand,
potentially contaminated waste materials.
The-inspector noted that
t
the failure to follow procedures for use of proper . protective
,
clothing was a violation of TS 6.11 requirements.
Licensee immediate.
-
corrective actions included personnel surveys . of the- individual-
involved and-issuance of a Memorandum, dated February 27.-1990, to-
all primary side personnel regarding the requirements to follow RWP
instructions. No additional examples of RWP violations were
identified during the onsite inspection.
The inspector noted that
this NRC identified item was not being cited because -the criteria.
'
specified in Section V.A. of the NRC Enforcement Policy were
satisfied.
One NCV for failure to follow procedures-for RWP protective clothing
requirements was identified (NCV: 50-369,370/90-010-05).
L
10. Followup Items (92701)
The following inspector followup items (IFIs) were reviewed and discussed
+
with cognizant licensee representatives.
a.
(Closed) IFI 50-369, 370/89-28-06: . Limitation of L the suggestion ~-
<
program for making ALARA improvements.
This item documented the. lack ofca mechanism for personnel to present
exposure reduction ideas for review and potential incorporation into
site operations.
i
The inspector reviewed and verified implementation of licensee
actions regarding the improvement items as stated in DPC's response
,
!
dated January 15, 1990.
Licensee actions included l the use of'
L
Suggestion Boxes to allow for_ prompt- or spontaneous 7 exposure
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reduction ideas to be submitted by the workers. . During tours' of '
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licensee fe
6 'ies, the inspector noted the placement of ALAR 4
suggestion'noxe for receipt of:esposure reduction ideas.
,
Based on licensie actions this item is considered closed.
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b.
(Closed) IFI 50-369, 370/89-28-07:
Limited use of protective:
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clothing in mock-up training conducted for high dose rate jobs.
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This item identified the lack of guidance 'regarding the .use of
!
protective clothing and equipment during mock-up training regarding
high dose expenditure or dose rate tasks.
The inspector reviewed and verified implementation of licensee-
l_
actions regarding the item as stated in DPC's _ response dated
,
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January 15, 1990.
Evaluation regarding the need for protective:
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clothing and equipment during mock-up training was to. be~ identified
and scheduled as work requests are planned; and ALARA pre-planning
occurs. . The inspector noted during), review of- Radiation Protection
Manual Section 3.10, (Paragraph 3.c
that the use of appropriate
'
protective clothing and tools. during the ' actual training : was
recommended.
During the audit of the onsite and' vendor' mock-up
,
training facilities, the inspector verified use of protective
clothing and equipment during mock-up training for S/G, RCP, and
Reactor Head activities.
The inspector informed licensee representatives that based on review
of activities currently in progress, this item would be considered
closed.
12.
Exit Interview (30703)
The inspection scope and results were summarized on March 2,1990,~ and
March 16, 1990, with those individuals indicated in Paragraph ~ 1.
The
inspector d2 tailed the radiation program areas ' reviewed and noted the
findings consisting of cited and NCVs listed below.
In addition, program
strengths associated with RP contract staff training and mockup. training
were discussed.
A significant weakness regarding a lack of knowledge by.
,
job sponsors regarding the RP ALARA' procedure and.the failure tu. document ~
adequate ALARA pre-planning activities were: identified as significant
,
weaknesses and were discussed in detail.
Two'previously identified NRC
followup items detailed in Paragraph 11 were closed.
Licensee representatives acknowledged the inspector's ' comments.
-The
licensee did not identify as proprietary any of the material provided to
or reviewed by the inspector during this inspection.
Item Number
Descripti_on and Reference
it
50-369,370/90-01-01
NCV: . Failure to label properly,
storage / shipping containers maintained in
'
the Unit 1, Turbine Building. ~ Characterized
as a NCY with corrective actions completed.
prior to end of inspection (Paragraph 4.b)-
.
.
50-369,370/90-01-02
VIO: Failure to follow
.
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procedures for frisking personal. items being
removed from the Auxiliary Building .RCA
(Paragraph 4.c).
50-369, 370/90-01-03
VIO:
Failure to follow procedures for
y
maintaining documentation regarding ALARA
program job planning (Paragraph 6.d).
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50-369,370/90-01-04
VIO:
Failure to follow procedures for .
providing deficiency
report regarding
incomplete extremity dosimetry package.
Characterized as a NCV with corrective
actions completed prior to end of inspection
(Faragraph 8).
'
'
50-369,370/90-01-05
NCV:
Failure to follow p~rocedures for-
wearing RKP required ' protective clothing
when performing maintenance activities.
Characterized as a NCV with corrective
actions completed prior to end of inspection
-
(Paragraph 9),
-
.
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