IR 05000369/1985015

Insp Repts 50-369/85-15 & 50-370/85-16 on 850506-09.No Violation or Deviation Noted.Major Areas Inspected: Instrument & Equipment Used for Radiation Protection of Personnel & Posting & Labeling

ML20128L063
Person / Time
Site:	Mcguire, McGuire
Issue date:	05/31/1985
From:	Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128L041	List: IR 05000369/1985015 ML20128L037
References
50-369-85-15, 50-370-85-16, NUDOCS 8507110222
Download: ML20128L063 (11)

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UNITED STATES I

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o NUCLEAR REGULATORY COMMISSION

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JUN 0 51985 l

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Report Nos.: 50-369/85-15 and 50-370/85-16 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-369 and 50-370 License Nos.: NPF-9 and NPF-17 Facility Name: McGuire Inspection Conducted: May 6 - 9, 1985 Inspector: M S-3I-d'5 T. R. Coll nY \ Date Signed Accompanying Personne : B. K. Revsin Approved by: 5-3/- W C. M. Hohe9, Sectido Chief Date Signed Division of Radiatibn Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection entailed 33 inspector-hours on site during regular hours inspecting: radiation protection program including instru-ments and equipment used for radiation protection of personnel; posting, labeling, and control of radiological control areas; radiation work permit controls; shipment of radioactive materials; internal and external exposure controls; training and qualifications of personnel; as low as reasonably achievable (ALARA) program; previously identified inspector followup items, and IE Information Notice Results: No violations or deviations were identifie %Uk G

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REPORT DETAILS Persons Contacted Licensee Employees

• T. L. McConnell, McGuire Station Manager

• D. Mendezoff, Engineering Specialist, Compliance

• B. Hamilton, Superintendent, Technical Services

• G. Terrell, Coordinator, Health Physics J. W. Foster, Station Health Physicist

- C. H. Bailey, Supervisor, Dosimetry Records D. F. Adams, Supervisor, Health Physics J. S. Mooneyhan, Supervisor, Health Physics D. C. Britton, Supervisor, Health Physics L. E. Haynes, Health Physics Staff L. J. McKenzie, ETQS D. Franks, Supervisor, QA Surveillance Other licensee employees contacted included three construction craftsmen, six technicians, one operator, two mechanics, three security force members, and three office personne Other Organizations NUMANCO, In NRC Resident Inspectors

• Orders, Senior Resident Inspector

• R. Pierson, Resident Inspecter

• Attended exit interview Exit Interview The inspection scope and findings were summarized on May 9, 1985, with those persons indicated in paragraph I abov The inspector discussed with licensee representatives the worker respirator usage qualifications through test and evaluation after trainin The licensee acknowledged the inspector's comment The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

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3. Licensee Action on Previous Enforcement Matters (Closed) Violation 50-269/84-07-01, 02, and 03; 50/270/84-07-01, 02, and 03:

failure to comply with 10 CFR 20.201, violation of Technical Specifications 6.11 for inadequate dosimetry procedure, and violation of Technical Specifications 6.12.2 for failure to post steam generator manway with flashing light The inspector reviewed and verified the corrective actions as stated in Duke Power-Company's letter of August 2, 198 . Training and Qualifications (83723) Basic Radiation Protection Training The licensee was required by 10 CFR 19.12 to provide basic radiation protection training to workers. Regulatory Guides 8.27, 8.29, and 8.13 outline topics that should be included in such training. Chapters 12

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and 13 of the FSAP contain further commitments regarding training. The inspector discussed 'the initial and refresher general employee i radiation protection training (GET) with the Training Supervisor and

reviewed lesson plans to determine what changes had been made-in GET

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training and the scope of these changes. During tours of the plant, the inspector discussed topics from the GET training with an auxiliary operator and a maintenance mechanic to determine the effectiveness of the training. The inspector reviewed the GET training records for selected individuals to determine if records reflected adequate

completion of GET initial and refresher training.

, Radiation Protection and Chemistry Technician Qualification The licensee was required by Technical Specification 6.3 to qualify

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radiation protection and chemistry technicians in accordance with 4 ANSI 1 The inspector discussed with selected technicians controls established for certain radiation work permits (RWP). The inspector

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discussed with the technicians their training and qualification program.' The inspector discussed the qualification program with one recently qualified radiation protection technicia The inspector reviewed the training records for these technicians to assure all

, topics were completed. The inspector discussed, with one radiation

, protection technician-in-training, the qualification program and-

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assignments to assure that they had not been assigned to work independently and had been qualified for assigned tasks.

The inspector reviewed the program for qualification of contract

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radiation protection technicians and contract chemistry technicians.

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The inspector discussed separately with two contract technicians their

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previous experience and training to determine if it was comprehensive or if it had - been limited to selected task The inspector also discussed the training and qualification program the licensee had L

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provided, what limits had been placed on their activities, and controls that should be established for one task they were qualified to perfor The inspector reviewed the resumes, training records, and tests for-these technician Radiation Protection and Chemistry Foreman Qualifications Technical Specification 6.3 required that radiation protection and chemistry supervisory staff have four years experience in their specialty. The inspector discussed, with one recently appointed foreman from the radiation protection department, training and

. experience and selected duties and responsibilities of the respective positio The inspector reviewed the records of this individuals'

experienc Radiation Protection Manager Qualifications Technical Specification 6.3 required that the individual filling the position of Station Health Physicist meet the qualifications for a Radiation Protection Manager specified in Regulatory Guide The inspector discussed with the recently appointed Radiation Protection Supervisor his training and experience and reviewed the records of his qualification Respiratory Protection Training The licensee was required by 10 CFR 20.103 to establish a qualification program for workers who wear respiratory protection equipmen Elements of the qualification program outlined in 10 CFR 20.103 are delineated in NUREG-004 The inspector discussed the respiratory protection program with the cognizant Radiation Protection Supervisor and the Station Health Physicis The inspector was informed by licensee representatives that upon completion of the respiratory protection training, no testing or evaluation of the training was performed. The inspector stated that adequate evaluation should be conducted to assure that personnel completing the training are qualified to wear respiratory protection equipmen The licensee committed to a review of this issue with the view of incorporating respiratory protection training test ing for all workers who use respiratory devices, both for health physics purposes as well as industrial hygiene purposes. The inspector informed licensee representatives that this area would be reviewed in subsequent inspec-tions (Inspector Followup Item 50-369/85-15-01,50-370/85-16-01).

No vioistions or deviations were identified.

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4 Organization and Management Controls (83722) Organization The licensee was required by Technical Specification 6.2 to implement the plant organization specified in Figure 6.2- The responsibili-ties, authorities, and other management controls were further outlined-in Chapters 12 and 13 of the FSAR. Technical Specification 6. specified the members of the Nuclear Safety - Review Board (NSRB). and outlined its functions and authorities. Regulatory Guide 8.8 specified certain functions and responsibilities to be assigned to the Radiation Protection Manager and radiation protection responsibilities to be assigned to line managemen The inspector reviewed recent changes to the plant organization, to determine their effect on plant radiological controls, by examining the resulting changes to administrative procedures and position descrip-tions and discussing the changes with the Radiation Protection Manage The_ inspector discussed with a radiation protection foreman, and shift foremen, the type, methods of, and degree of interaction between plant groups. .The inspector discussed with the Radiation Protection Manager and selected Radiation Protection Supervisors and Foremen, how frequently they toured the plant and radiation control area Staffing Technical Specification 6.2.2 specified minimum plant staffin FSAR Chapters 12 and 13 also outlined further details on staffing. The inspector discussed authorized- staffing levels vs. actual on-board staffing separately with the Radiation Protection Superviso The inspector examined shift staffing for the midnight shift on May 8, 1985, to determine if it met minimum criteria for radiation protectio No violations or deviations were identifie .- Control .of Radioactive Materials and Contamination, Surveys, and Monitoring (83726).

~_The licensee was required by 10 CFR 20.201(b), 20.403, and 20.401 to perform surveys to show compliance with regulatory limits and to maintain records of such surveys. Chapter 12 of the FSAR further outlines survey methods and-instrumentation. Technical Specification 6.11 required the licensee to adhere to written procedures in radiation protection. Radiological control procedures further outlined survey methods and frequencies, Surveys During plant tours the- inspector observed surveys being performed by the radiation protection staf The inspector reviewed selected Radiation Work Permits (RWP) and the ' control specified thereon. The

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RWP system and controls were discussed with the Station Health Physici st. _ Several workers in Unit #1 containment were questioned as to the RWP they were working on and the requirements specified by the RW In all cases, workers were knowledgeable of their RWP and its requirement The inspector performed independent radiation level survey During plant tours, the inspector observed radiation level and contamination survey results outside selected cubicles. The inspector performed independent radiation level surveys of selected areas and compared them to licensee survey results. The inspector noted that all locked high radiation areas observed in the auxiliary building were locked as required by Technical Specification 6.12. The licensee was exercising the option specified in Technical Specification 6.1 whereby in lieu of stay time specification on the RWP, direct or remote continuous surveillance for individuals accessing a high radiation area greater than IRem/hr may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities within the are Frisking During tours of the plant, the inspector observed the exit of workers from the Reactor Building and from the Auxiliary Building to clean areas to determine if proper frisking was performed by worker In general, personnel frisking appeared adequate to detect station action levels should contamination be present. Discussions with licensee representatives showed that incidents of skin contamination had been promptly removed from the workers using routine washing technique Subsequent whole body counts showed less than detectable internal deposition of radioactive materia Instrumentation During plant tours, the inspector observed the use of survey instru-ments by plant staff and compared plant survey meter results with results of surveys made by the inspector using NRC equipment. The inspector examined calibration stickers on radiation protection instruments in use by licensee staff and at frisker stations located throughout the plant. The inspector discussed with radiation protec-tion technicians the methods for performing instrument source checks prior to each issuance from the health physics instrument issuance roc No violations or deviations were identifie . .

6 Facilities and Equipment (83727)

FSAR Chapters 1 and 12 specified plant layout and radiation protection facilities and equipment. During plant tours, the inspector observed the operation of the contaminated clothing laundry, the flow of traffic through change rooms, the use of temporary shielding and the use of glove bags, and ventilated containment enclosure No violations or deviations were identifie . Audits The licensee was required by Technical Specification 6.5.2.9 to perform audits of radiological controls and chemistry operation The inspector reviewed audits of the radiation protection operations during 1984 and 198 The inspector discussed the results of these audits with the Supervisor, Quality Assurance (QA) Surveillance. These discussions revealed that the audits were conducted by plant staff lacking technical backgrounds in tSe area of radiation protection and controls. The QA Surveillance Supervis;r indica'nd that a 46 week training program had been initiated in January 1985, coJ that two members of the QA Surveillance staff were in attendanc It was further stated that the remainder of the staff would be rotated through the training program on a staggered basi No violations or deviations were identifie . Transportation (86721)

The licensee was required by 10 CFR 71.5 to prepare shipments of radioactive material in accordance with Department of Transportation regulation The inspector observed the preparation of a shipment of Reactor Coolant System filters and discussed the shipment with the shipping supervisor and radiation protection technicians. The inspector reviewed the procedure under which the shipment was made and the resulting documentation. The inspector made confir-matory radiation level measurements of the shipment. The inspector reviewed recent changes to shipping procedures and records of shipments of radwaste for the month of January to April 1985. The inspector verified that the licensee was registered with the NRC for packages used. Also the inspector reviewed with the licensee the total cubic feet of radwaste shipped for the calendar year 1984, which was 14,304 ft3 with a total activity of 1.89 x 10' mci. The inspector determined that the volume shipped for burial for the year of 1984 was comparable with other facilities of the same siz No violations or deviations were identifie . External Occupational Dose Control and Personal Dosimetry (83724)

During plant tours, the inspector checked the security of the locks at selected locked high radiation areas and observed posting of survey results and the use of controls specified on three radiation work permits (RWPs).

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7 Use of Dosimeters and Controls The licensee was required by 10 CFR 20.202, 20.201(b), 20.101, 20.102, 20.104, 20.402, 20.403, 20.405,19.13, 20.407, and 20.408 to maintain worker's doses below specified levels and keep records of and make reports of dose The licensee was required by 10 CFR 20.203 and Technical Specification 6.12 to post and control access to plant area FSAR Chapter 12 also contained commitments regarding dosimetry and dose control During observation of work in the plant, the inspector observed the wearing of TLDs and pocket dosimeters by worker The inspector discussed the assignment and use of dosimeters with the Dosimetry and Records Supervisor and two dosimetry clerks and the pocket dosimeter vs thermoluminescent dosimeter (TLD) correlation program and how such discrepancies were resolved. Evaluations of dose assignments for lost or damaged TLDs or off scale pocket dosimeters was also discussed with the licensee. During plant tours, the inspector observed the posting of areas and made independent measurements of dose to assure proper postin The inspector reviewed recent changes to plant procedures regarding the use of TLDs and dosimeter Dosimetry Results The inspector examined the files of 35 contract workers presently o'n site to ensure that NRC Form 4s had been complete The inspector examined records of two cases of damaged dosimeters to evaluate the methods and conclusions regarding the assignment of dos The inspector examined three cases where doses were adjusted for other reason Management Review of Dosimetry Results The inspector discussed the method used for dissemination of dose data to the worker and their supervisors with the Dosimetry and Records Supervisor. No cases were reported whereby workers exceeded adminis-trative limits without appropriate dose extensions. When dose had to be assigned a worker due to problems with the PD/TLD correlation, the assignment was made each month by the Station Health Physicist after review of available dat No violations or deviations were identifie . Internal Exposure Control and Assessment (83725)

The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403, and 20.405 to control uptakes of radioactive material, assess such uptakes, and keep records of and make reports of such uptake FSAR Chapter 12 also includes commitments regarding internal exposure control and assessmen . .

8 Control Measures During plant tours, the inspector observed the use of temporary ventilation systems, containment enclosures, and respirator The inspector discussed the use of this equipment with workers and radia-tion protection technicians. The inspector reviewed recent changes to '

respiratory protection procedure Respiratory Maintenance and Issue The inspector observed the cleaning and maintenance of respirators with two staff members assigned the tas The inspector observed the issuance of respirators and reviewed records for selected workers who were' issued respirators to determine if they were qualified for the respirators issue The inspector reviewed recent changes to respirator maintenance and issue procedure ; Uptake Assessment The inspector observed operation of whole body counter and discussed its operation and results with the counter operato The inspector discussed the assessments and corrective actions with a radiation protection supervisor. For 1984, there were no positive counts exit or routine (not including initial) count No violations or deviations were identifie . Maintaining Occupational Doses ALARA (83728)

10 CFR 20.1(c) specifies that licensees should implement programs to keep workers' doses ALARA. FSAR Chapter 12 also contains licensee commitments regarding worker ALARA action Worker and Supervisor Actions The inspector discussed with a Station Health Physicist licensee actions to reduce individual and collective doses, concentrating particularly on staff members with highest doses. The inspector also discussed these actions to set dose goals for tasks, methods used to reduce doses, and techniques used to monitor performance against goal ALARA Procedure Changes The inspector reviewed the system-wide ALARA manual which contained the administrative procedures that delineated management commitment to ALARA principles and which implemented the elements of ALARA. Station specific procedures were reviewed as was a draft ALARA procedure which would effectively lower the collective person-rem requirement for initiating certain ALARA action . .

9 ALARA Reports The inspector reviewed the ALARA data for 1984 and for the recently completed Unit 2 outage. The dose projection for 1984 was 577 man-rem while the actual dose received by workers was 505 man-rem as measured by thermoluminescent dosimeters (TLD). During this timeframe, a refueling outage and a four week maintenance outage occurre For the recently completed Unit #2 outage of approximately 14 weeks duration, the projected man rem total was 270.8, while the actual exposure received was 330 man-re This outage encompassed both refueling and maintenance activitie For the Unit #1 outage which had just begun an expenditure of 258 man-rem was estimate For the entire station (Units #1 and #2),

the collective dose projected for 1985 was 720.9 man-re The inspector noted that for outages alone 588 man-rem would be utilized, leaving only 132 man-rem for the remainder of the year for routine operation. The licensee acknowledge the comment and indicated that major maintenance during the outages had been more extensive than originally planned, and as a consequence, thought that the original goal for 1985 might be exceede No violations or deviations were identifie . Problem Reports and Radiological Deficiency Reports The inspector examined the Problem Reports and Radiological Deficiency Reports and resulting corrective actions for the period January through June 1984 and discussed selected reports with involved worker The inspector reviewed maintenance work requests and plant modification requests to determine if deficiencies contributing to the reports had been correcte No violations or deviations were identifie . Preparation for March 1985 Outage The inspector discussed with the Radiation Protection Supervisor the plans for supplemental staffing, including decon, shielding, and laundry staff, during the outage and subsequent startup. The inspector discussed methods to be used to select and qualify the staff with contractor support, proposed methods of supervision and limitations on task assignment No violations or deviations were identifie . IE Information Notices (92717)

The following IE Information Notices were reviewed to ensure their receipt and review by appropriate licensee management:

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IN-84-24, Physical Requalification of Individuals to Use Respiratory Protective Devices IN-84-34, Respiratory User Warning: Defective Self-Contained Breathing Apparatus Air Cylinder IN-84-40, Emergency Worker Doses IN-84-59, Deliberate Circumventing of Station Health Physics Procedures IN-84-60, Failure of Air-Purifying Respiratory Filters to Meet Efficiency Requirements IN-84-61, Overexposure of Diver in Pressurized Water Reactor (PWR)

Refueling Cavity No violations or deviations were identifie r

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