IR 05000369/1987033

Insp Repts 50-369/87-33 & 50-370/87-33 on 870928-1002.No Violations or Deviations Noted.Major Areas Inspected: Radiation Protection,Including Organization & Mgt Controls, External Exposure Control & Previous Enforcement Items

ML20236B759
Person / Time
Site:	Mcguire, McGuire
Issue date:	10/14/1987
From:	Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236B717	List: IR 05000369/1987033 ML20236B714
References
50-369-87-33, 50-370-87-33, NUDOCS 8710260334
Download: ML20236B759 (10)

Text

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~ NUCLEAR REGULATORY. CON)MiSqlON f 41l!

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i Report Nos.: 50-369/87-33and57q70/87q3 , i

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. Licensee: Dde Power Company; ', ,

s j 422 South Church Strett '

Charlotte, NC 28242 'i s- k '

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Docket Nos.,'50-360 and 50-370 ' License Nos.: NPF-9 and t$.1,7 Facility Name: McGuire Nuclear Station +

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..- 3 InspectionConductdd: September 28 - October 2,1987 .

. , , . j Inspector: b /t & M M 7 h /0// h

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~ ., . Bassett , Date Signedt l Approved by: W C. M. Hosef, Section Chief e S

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Division of Radiat' ion Safety and SafegQros? .j [>',' .)

, ., I l SUMMARY -

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\ r t l Scope: This was a routine, unannounced inspectionJn the area of radiatio i protection including: organization and managementscontrol,s; external exposuit .f, $-

,y control; the program to maintain exposure as low as rs atonab9/ achievable - j-(ALARA); outage activities; previous'esiforcement item' fuWowup and allegation j followu ,,

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Results: No violations or deviations, were identifie ,

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. REPORT DETAILS a l

Persons Contacted

' . Licensee Employees

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• B. H. Hamilton, Superintendent of Technical Services

• D.- J.. Rains, Superintendent of Maintenance

• J.' W. Foster. Station Health Physicist-

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• M. McCraw, Compliance Engineer:

, -*N. - Atherton, Production Specialist, Compliance -

• G. Goodman, Quality Assurance J. S. Mooneyhan, Health Physics General Supervisor

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W. F. Byrum, Health Physics Sciences Supervisor

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C. H. Bailey, Health Physics Supervisor

.J. C. Correll,. Health Physics Supervisor T. L. McGee, ALARA Supervisor l

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'l Other licensee . employees- contacted included ' engineers, technician operators, mechanics, security office members and office personnel.

l- Nuclear Regulatory ' Commissio ,

• T. Orders, Senior Resident Inspector j d.- *F. S. Guenther, Resident Inspector l

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• D. J. Nelson, Resident Inspector I k * Attended exit interview Exit Interview 4 . The inspection scope and findings were suninarized.on October 2,'1987, with

,,~ those persons indicated in Paragraph 1'above. The inspector described the areas inspected and . discussed. the inspection findings. The licensee i i acknowledged the inspection findings and took no exceptions. The licensee !

l - did not identify as proprietary any of the material provided to or l t reviewed by the inspector during this. inspectio . Licensee Action on Previous Enforcement Matters (Closed) Violation (50-369/86-31-01) Failure to adhere to, Department of Transp'ortation- (DOT) requirements for shipment of radioactive material ,

The inspector reviewed the licensee's response dated December 26, 1987, ,

and verified that the specified corrective actions -had been implemented.

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(Closed): Violation.(50-369/86-31-02) Failure to Efollow. radiation protection procedures .for calibration of an air sample The inspector-reviewed the 111censee response dated December 26, 1986, and verifieditha the corrective actions specified therein had been. implemented. ;

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2 Organization and Management Controls (83722)- Organizatio '

The 11cem:ee . is required _~ by Technical Specification -(TS) ' 6.2.2 to implement the station organization: as shown in' the Final Safety:

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Analysis Report (FSAR), Chapter-1 Chapte_rs 12 and 13 of the.FSARi

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also outline the = responsibilities, authority and other management'

controls to be implemented at the? statio The inspector reviewed the licensee's plant organization and lines-o authority as they' relate to the radiation. protection program with-the ,

Station Health Physicist. The. inspector verified that the licensee

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.had not made organization changes which would adversely affect' the ability of the licensee to implement the critical elements of that-progra ,

' Staffing Technical Specification 6.2.2' specifies the minimum staffing for the station. FSAR Chapters 12 and .13 further outline' details on .

staffin The inspector reviewed .the statio'n health physics. (HP)

organization staffingL levels and.recent promotions within the group.-

The subjects of use _ of contractor HP" technicians':and' actual versus -

authorized manning levels were also discussed with the>1icensee.-

At the time of the inspection, there were 112 HP positions authorized- y for the station including supervisors,- specialists and technician An additional 110 HP ' contractor positions were authorized for'the outage. Of the 112 permanent positions',.only 3 were not filled; all of the contractor positions were filled. ~-The inspector discussed the

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type, methods and degree of interaction and~ control of contract pennnnel with the ~ Station Health Physicist. The licensee indicated that, while many jobs are covered' by contractor personnel, overall supervision and control is exercised by. the station HP groups, Controls ,

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The inspector reviewed selected licensee reports used to identify and

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correct radiological problems. These reports included: .(1)'ALARA

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Problem Reports which can ' be used by anyone to note a' minor radiological' deficiency, (2) Employee Training and' Qualification System (ETQS) Evaluations which are -used-'by HP. personnel to improve the training program and upgrade HP-related: procedures, and (3) - HP Problem Reports - which are typically used by HP technicians to-document problems noted. . The HP Problem Reports can, be escalated into Incident Investigation Reports if. circumstances- warrant, such as personnel contamination events above specified limit No violations or deviations wereL identified.

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5. External Exposure Control and Dosimetry (83724) Personnel. Monitoring l 10 CFR 20.202 requires .each licensee to supply appropriate personne monitoring equipment to specific individuals and require the use of:

such equipment. During plant tours the inspector observed workers 1 wearing appropriate personnel monitoring device j Control of Radiation Areas- )

i 10 CFR 20.203 specifies posting, labeling and control requirements- .

J for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material and area During tours of the plant, the inspector observed the licensee's posting and control of radiation, high radiation, airborne radioactivity and radioactive material areas. ' The inspector verified that various locked high radiation areas in- the . Auxiliary Building were being maintained locked as required.- High radiation areas located inside' Unit 1 Containment that could not be enclosed or- !

locked were barricaded, posted and marked with a flashing. light as -

required by TS 6.1 Personnel Exposure Control The licensee is required by 10 CFR 20.101 and 102 to maintain worker's doses below specified levels. The inspector reviewed i selected occupational exposure histories and verified that the -l licensee was requiring a Form NRC-4 or its equivalent. to be i maintained on file prior to permitting an individual to exceed the limits specified in 10 CFR 20.101(a). The. inspector also reviewed the Form NRC-5 equivalent printout for the station and determined ;

that the radiation doses recorded were within the quarterly limits i specified abov l r Multi-Badging  !

l The inspector reviewed the licensee's program for assessing the need j for and the requirements for using multiple badging, extremity ;

monitoring and placement of dosimetry in abnormal situations. The j inspector reviewed the procedure governing the program, Health j Physics Manual (HPM) Section 11.8, Multiple Badging and Dosimetry l Placement, Revision 8 dated September 4,1987. The inspe.ctor also !

reviewed selected multiple badge forms used to track exposure by pocket dosimeters (PD) readings and thermoluminescent dosimeter (TLD)

results and verified the forms were completed correctly. Dose 1 histories for selected individuals were also reviewed to .ve'rify that i the dose reported on the multiple badge forms had been properly l poste l l

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i Reports The inspector reviewed selected PD/TLD Comparison- or discrepancy' i reports and Lost /0ffscale or Abnormal PD Investigation Reports. The reports and the resultant dose assignments _ made following the investigations, when applicable, appeared adequate. No overexposur investigations had been performed 'because. no exposures exceedin local administrative or regulatory limits had occurre Radiation Work Permits (RWPs)

Procedure HPM Section 16.1, Preparation and Control of RWPs and "

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Standing RWPs, Revision 15, dated May 18, 1987, specified  ;

requirements for issuing and controlling RWP The more significant !

requirements for issuance /use of an RWP or SRWP are: (1) all entries

'into the Radiation Control Area (RCA), (2) all' work involving exposure in excess of 0.5 millirem per hour (mr/hr) and-(3) all work ' t involving exposure to airborne contamination in excess of 25 percent of the Maximum Permissible Concentration (MPC).

The inspector reviewed the following RWPs:

- RWP 87-331, All Work Associated With (AWAW). Operation, Surveillance and Inspection in Unit 2 Lower Containment and Pipe Chase

- RWP 87-261, AWAW Unit 1 Spent Fuel Pool Transfer Canal Work, Transfer Cart and IKF 122

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RWP 87-269, Removal of Upper Head Injection Piping and Remove / Replace Support Strutts on Unit 1 Reactor Head

- RWP 87-289, Nozzle Dam Installation and Removal in Steam Generator A

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RWP 87-296, Eddy Current Work Including Plugging in ' Steam Generator D The RWPs were reviewed with respect - to radiation monitoring, radiation and contamination surveys, airborne monitoring and dosimetry. The surveys, monitoring and dosimetry appeared adequat No violations or deviations were identifie . Control of Radioactive Material and Contamination, Surveys and Monitoring (83526)

The licensee is required by 10 CFR 20.201(b), 20.401 and 20.403 to perform surveys and to maintain records of such surveys necessary to show compliance with regulatory limits. Survey methods and instrumentation are outlined in the FSAR, Chapter 12, while TS 6.8 requires adherence to

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wri tten ' procedures. Radiological control procedures further delineate survey methods and frequencie Contamination Surveys While touring the facility, the inspector observed workers exiting the RCA and the movement of material from the .RCA to clean areas.to determine if adequate surveys were being performed by workers and if adequate direct and smearable contamination surveys were performed on material All personnel and material surveys appeared to be adequate. The inspector also examined selected records of personnel contaminations that occurred during 1987 and, through records review and discussions with licensee representatives, determined that the

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contamination had been ' properly and promptly removed and the skin dose calculations were adequate. Selected individual's exposure

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histories were checked to verify that the calculated skin dose had been assigned as indicated, Survey Results

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During plant tours, the inspector examined radiation level and .

contamination survey results posted outside selected areas and room The inspector performed independent radiation level -surveys of selected areas using NRC equipment and compared them with licensee survey result The inspector also examined licensee radiation ,

protection instrumentation and verified that the calibration stickers '

were curren l 1 Caution Signs, Labels and Controls l l

10 CFR 20.203(f) requires that each container.of licensed radioactive material bear a durable, clearly visible label identifying the contents when quantities of radioactive material exceed those specified in Appendix C. During plant tours, the inspector verified that containers of radioactive material were labeled as required and that proper controls were establishe No violations or deviations were identifie . Maintaining Occupational Exposure As low As Reasonably Achievable (ALARA)

(83728)

l 10 CFR 20.1(c) specifies that licensee should implement programs to l- maintain workers' doses ALAR Other recommended elements of an ALARA l program are contained in Regulatory Guides 8.8 and 8.1 FSAR, Chapter 12, also contains licensee commitments regarding worker ALARA actions.

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a. Station ALARA Organization The inspector reviewed the functions and tasks of the ALARA group with licensee. representatives. The group had been composed of more q personnel and had been heavily involved in planning and setting up i the majority of the. jobs involving radiological wor A . recent ;

change', which is not yet fully implemented, reduced the size of the 1 ALARA group to one supervisor and two Lstaff member ~

The group is now becoming less involved.with planning work except for the major,-

first-time. jobs that are not repetitive in. nature but that require a great deal of health physics. experience and background.. The group is trying to assume more of an audit function and also continues: to i establish plans to help the station achieve' the man-rem goals established by the corporate office and perform routine ALARA

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review b. Action Plans and Job Review In order for the station to meet. the ' goal established for 'the facility, the ALARA group requires each department to develop an Action Plan. An Action Plan is used for any job that requires an exposure estimate and is designed to ' establish the criteria for the department to accomplish the work assigned while remaining within the estimated man-rem goal. Such factors as shielding and the minimum number of personnel needed to perform the job, are considerations which are included in developing an effective Action Pla The licensee indicated that, while the Action Plans are reviewed and recommendations are made on ways to ' improve, job review is not as -

formalized as it could b If a problem occurs with a particular job and the man-rem goal is to be exceeded, no one is . required to review the job to ensure that the work is proceeding properly and that exposures are being maintained ALARA. Also, a proposed procedure, which would detail . pre-job and post-job review requirements and ALARA job planning and exposure estimating, is still in the review process at the station and has not been agreed upon and adopte c. ALARA Committee The inspector reviewed the organization of the station ALARA Committee, which is composed of a representative from each of the sections at the station with the ALARA bJpervisor serving as the chairma The committee meets quarterly to consider problems with releases, exposures and major work evolutions as well 'as ALARA Problem Reports and Action Plans. The inspector reviewed selected ALARA Problem Reports and noted that, while eighteen reports had been submitted in '1986, only four reports had been received to date for 198 ,

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, ALARA Goals  !

-l The inspector reviewed the licensee's goals for 1986 and 198 j Through discussions with licensee representatives, it was'noted that the man-rem' goal. for 1986 was 780 but actual exposure was 1011 man-rem. The goal for'1987 had been set at 954 while the actual 1 exposure through September was 764 man-rem. The inspector also noted j

that the outage goal had been . set at 316 man-rem and that 288 man-rem had been expended. Major work-evolutions that.have been accomplished during this and the previous outage for 1987 include. nozzle dam installation in the steam generators (S/G), shot peening of selected j tubes in the Unit 2 S/Gs and replacing safety injection check valve I No violations or deviations were identifie ~

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! Allegation Followup (99014) j RII-87-A-0072 ,

The alleger stated that he was hired by a contractor' to do. steam generator (S/G) work at McGuire Nuclear Station (MNS).. He was given a quarterly exposure limit 'of 2,500 millirem (mr) on May 10, 1987, when he started the job at MNS. The alleger said that he performed a S/G jump on May 10,1987, and received 800 mr. On May 11, 1987, he 3 reportedly performed another S/G jump: in a ' general area radiation i field of 200 mr/ min and remained in that area for 6 minutes receiving l an exposure of 1,200 mr. The subsequent' day, May 12, 1987, he was q told by his supervisor that he had 1,100 mr of exposure remaining and he was to make another S/G jump. When.he refused because he felt'he would receive a total cumulative exposure in excess of the 2,500 mr limit, he was terminate The alleger also indicated that another contractor had reached the exposure limit of 2,500 mr but still was ordered to perform another S/G jump. .When this occurred, the second individual informed the MNS health physics technicians that he could not go in because he had reached his exposure limit and that.MNS apparently did not have an accurate record of his exposure. The alleger stated that this second individual did nct perform another S/G jump and, therefore, did not exceed the 2,500 mr limi Discussion The inspector discussed these allegations with licensee representatives. Because these problems occurred during a previous outage, the inspector was unable to discuss these matters with the contractor supervisor who reportedly terminated the allege However, through records review the inspector determined the following sequence of events:

The alleger was initially given a whole body count (WBC) at MNS on May 5, 1987. 'On May 8, 1987, he was given an exposure extension to the station quarterly limit of 2,500 mr based on the fact that he had

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received no previous exposure for- the quarter. He performed a S/G-jump to install nozzle dam inserts in S/G "A" on May 9,1987. He received a whole body exposure of 800 mr as determined by pocket dosimeter (PD).. He made no entries on May 10, 198 He made a second S/G jump on May 11, 1987, to install nozzle dams in S/G "B" and received 800 mr as determined by P However, a mistake was made by the MNS Surveillance and Control Technician entering the dose into the computer from the multibadging form. As a. result, 600 mr was entered on May 12, 1987,. instead of.the 800 mr that he actually received. (This mistake was not discovered until th licensee investigated this allegation.) His remaining quarterly dose j was 1,100 mr. (or 900 mr using the correct figure of 800 mr for the second jump). This amount of remaining available . exposure would apparently have been adequate to allow the alleger to perform a third-jum The alleger received a termination WBC.on May 12, 1987. When his TLD l was processed May 21, 1987, the' highest maximum dose received was ,

1,180 mr to the whole body for the entire job ~.

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The licensee indicated that some confusion on the part of the alleger may have resulted upon his second S/G jum He may have'been told he was entering a radiation field of 200 mr/ min- whereas that was the ,

radiation level at contact with the S/G tube sheet. The general area l radiation level where he was working was actually 135 mr/ min whic i would yield a dose of approximately 810 mr for a 6 minute jump. The j licensee also stated that no MNS employee was ever made aware of the i alleger's concerns about exceeding an exposure limi In the case of the second individual named by the alleger as reaching the quarterly limit, the inspector determined the following sequence of event This individual was given an initial WBC at MNS on May 6,1987.. He was given an exposure limit of 2,290 mr for the . quarter minus the 573 mr he had received during the quarter resulting in an . allowable dose of 1,717 m The individual performed a S/G jump on the morning of May 11, 1987,.

to install the nozzle dam in S/G "A" cold leg. He received 470 mr exposure by PD and had a remaining quarter dose of 1,247 mr.. .He made l a second S/G jump during the evening of the same day to install nozzle dam inserts in S/G "C." He received 600 mr exposure as measured by PD but this.value was mistakenly entered twice into the compute In addition, a dose of~250 mr was also assigned to this individual during this same data entr These errors were detected the next morning, May 12, 1987, when the l

person's. name appeared on the Alert List indicating. that h.e had l exceeded 90% of his allowable quarterly dose. An investigation at

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that time rovealed the -double entry of the 600 mr and the additional entry of 250 mr which was determined to belong to another contractor ,

who had performed a S/G jump during the same shift. Because the individual's name had appeared on the Alert List, his dosimetry was -

pulled to prevent further entry into the RCA. His TLDs were sent for special processing on May 13, 1987, due to the confusion about his actual exposure and a whole body dose of 880 mr was assigned. When the problem was resolved, the errors were explained to the individual and he was allowed to resume wor To preclude such data entry problems, the licensee changed the data entry procedure and instructed those entering exposure data to call ,

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up the exposure data immediately after entering it to ensure the correct figures were recorded. The licensee has also begun requiring supervisory review of the multibadge records prior to data entr Also as a result of this incident, the licensee performed an audit of the 990 multibadge jump sheets completed during May and Jun Of ,

those packages reviewed, 38 data entry errors were discovere I Fifteen of these errors were found. during normal audits of the !

multibadge records (found within one week of input). In the other 23 ;

cases, the licensee stated that there was no potential for 1 overexposure because of the precautions, such as- the Alert List, which were established to preclude such occurrence !

c. Finding i

i The allegation was substantiated in that the alleger was apparently j terminated because he refused to perform work in a high radiation j are However, there appears to have been a misunderstanding j concerning the exposure he actually received and also the exposure j the second individual received. According to the records reviewed, 1 neither individual received exposure in excess of the MNS  !

administrative limit. No regulatory requirements were violate ]

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