IR 05000280/1988025
| ML18152B034 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/28/1988 |
| From: | Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152B033 | List: |
| References | |
| 50-280-88-25, 50-281-88-25, NUDOCS 8807120310 | |
| Download: ML18152B034 (9) | |
Text
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Report Nos.:
50-280/88-25 and 50-281/88-2~
Licensee:
Virginia Electric and Power Company Richmond, VA 23261 Docket Nos.:
50-280 and 50-281 License Nos.: DPR-32 and DPR-37 Facility Name:
Surry 1 and 2 Inspection Conducted:
May 31, 1988 to June 3, 1988 Inspector: ~~-
Approved T. R. Co 11 ins
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I C. M. Hosey, Section 1Chief Division of Radiation Safety and Safeguards SUMMARY Date Signed Scope:
This was a special, announce~ inspection to review the circumstances surrounding an overexposure of greater than 3 rems per calendar quarter to a contract worker during Unit 1 refueling outag Results:
In the areas inspected, four violations were identified:
(1) failure to control an individual's occupational radiation exposure to less than 3 rems per calendar quarter (Paragraph 2.C.(3)); (2) failure to have an adequate procedure for purposes of admi ni steri ng a Radiation Work Permit program (Paragraph 2.C.(l)); (3) failure to evaluate the extent of the radiation hazards that were present (Paragraph 2.C.(2)), and; (4) failure to adequately instruct individuals working in or frequenting a restricted area (Paragraph 2.C.(4)).
REPORT DETAILS Persons Contacted Licensee Employees
- D. Benson, Station Manager D. Boone, Health Physics Shift Supervisor
- D. Cruden, Vice President, Nuclear Operations
- E. Grecheck, Assistant Station Manager
- N. Hardwick, Manager Nuclear Licensing
- G. Miller, Vice President, Licensing Coordinator
- J. Price, Quality Assurance Manager
- R. Saunders, Manager Nuclear Program
- S. Sarver, Superintendent, Health Physics
- W. Thornton, Director, Health Physics and Chemistry J. Tepley, Outage Manager, Westinghouse C. Wheeler, Refueling Coordinator Westinghouse M. Wilson, Health Physics Technician Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, security force members, technicians, and administrative personne Nuclear Regulatory Commission
- W. E. Holland, Senior Resident Inspector
- L. E. Nicholson, Resident Inspector
- Attended exit interview Onsite Followup Of A Personnel Overexposure (93702) Description of Events On May 27, 1988, a licensee contractor was preparing to enter Unit l containment to clean and inspect the reactor vessel flange (reactor head seating surface).
At approximately 9:00 a.m., the contractor and licensee representatives met to conduct a pre-job briefing to discuss the plans and preparation to perform the assigned task of cleaning and inspecting the reactor vessel flang It was determined during this pre-job briefing that the three contractor personnel assigned to perform this task would be provided with high and low range pocket ion chambers (0-200 millirem and 0-1500 millirem) and thermoluminescent dosimeters, to be worn on their torso and top of their hea Two of the individuals were given an authorized extension of their administrative radiation dose limit. from 1250 millirem to 1750 miliirem. The third individual had no exposure for the current calen~ar quarter and therefore, was authorized to
receive 750 millirem for this tas During this pr:e-job briefing neither the health physics technician that was to provide continuous coverage for this task nor the health physics shift foreman responsible for the health physics controls were presen However, the Superintendent of Health Physics responsible for the health physics program was present at this pre-job briefin Also, it was determined during this pre-job briefing that the Unit 1 reactor cavity was still flooded (reactor water above reactor vessel flange).
Operations personnel were to be contacted and arrangements made to drain the reactor cavity down below the reactor vessel flang Licensee and contractor personnel agreed to reconvene their meeting again at approximately 5:30 p.m. to decide if the reactor cavity was accessible to perform this tas During the afternoon of May 27, 1988, health physics personnel were informed that the Unit 1 reactor cavity was accessible and, therefore, this task could be performed as planne Again at approximately 5:30 p.m. the licensee conducted another pre-job briefing with the same contractor personnel, Superintendent of Health Physics and the health physics shift foreman in charge of activities in Unit 1 containmen During this meeting, it was agreed that 500 millirem was sufficient radiation exposure to perform this assigned tas However, at this time a radiation survey had not been performed to adequately evaluate the radiation levels that were actually present in the work are The health physics technician assigned to perform continuous coverage for this task was not present during this second pre-job briefing and was not informed of the worker 1 s available dose to perform this tas In addition, the inspector determined by interviews with both the health physics shift foreman and health physics technician that at no time were they informed of the three contractors available dose to perform this tas This was confirmed through additional interviews with the three contractor personne The inspector also determined through interviews with the personnel involved in the pre-job briefings that only the mechanics of performing this task were discusse The health physics aspects, such as radiation levels in the work area, precautions or stay times to minimize radiation exposures to personnel were not discusse After the last pre-job briefing the health physics technician and the health physics shift foreman entered Unit 1 containment awaiting the three contractor personne The.three contractor personnel were authorized to enter Unit 1 containment on Radiation Work Permit (RWP)
No. 88-1472, issued on May 6, 198 The inspector reviewed the RWP and noted that the radiation levels indicated on the RWP were 1,500 millirem contact and 600 millirem general are This Radiation Work Permit had been terminated and re-issued three times over the period of May 6, 1988 to June 3, 1988, to perform associated reactor head and reactor vessel inspection On May 27, 1988, after the second pre-job briefing, the three contractor personnel were given authorization to enter Unit 1 containment by the health physics shift supervisor at the Unit 1 containment entry window by verification of available allowable dose and signing their containment passes for
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entr Once the three contractors were in Unit 1 containment the health physics shift foreman that was already in containment informed the inspector that he visually observed the contractor 1 s containment entry passes inside of their whirlpacks (plastic bag containing TLDs and pocket ion chambers).
However, he never read the containment passes or discussed available dose for these personne The three contractors and the health physics shift foreman proceeded to the operating deck, 47 foot elevatio Upon arrival the health physics technician had already entered the Unit 1 reactor cavity and was performing a radiation survey of the work area (reactor vessel flange area).
During this time, the health physics technician, wearing a full face respirator, communicated to the three contractors and his health physics shift foreman that the general area dose rates were 2 to 3 Roentgens per hour (R/hr) and a low dose rate area of 200 mR/hr was present against the reactor cavity wall under the reactor vessel i nterna 1 s storage stan No men ti on was made of the dose rates inside of the reactor vessel flange (inside diameter of the reactor vessel).
The radiation levels interior to the reactor vessel flange were measured by the health physics technician prior to informing the three contractors of the 2 to 3 R/hr general area dose rates found and to be approximately 7 to 15 R/h After a short period of time operations had drained the reactor vessel water level back down below the reactor vessel flange and the three contractors and the health physics technician entered the reactor cavit Prior to entering the reactor cavity the three contractors were not given any specific stay times or precautions for minimizing their radiation exposure They were especially not cautioned to not extend their heads beyond the interior of the reactor vessel flange where the highest radiation levels existe The inspector determined by interviews with the contractors and the health physics technician that they were inside the reactor cavity for approximately 25 to 30 minute During this time the inspector determined by interviews that the health physics shift foreman remained on the operating deck, 47 foot elevation, observing various other tasks being performed simultaneously. After completion of the cleaning and inspection of the reactor vessel fl ang-e, the three contract workers informed the hea 1th physics technician that they had completed the task and were ready to leave the reactor cavit Upon exiting the reactor cavity one contract worker asked another health physics technician assigned work associated with the reactor head to read their self-reading pocket ion chamber The health physics technician noted that all three contract workers low range and high range dosimeters were off-scale for both head and tors The health physics technician halted all operations in the Unit 1 reactor containment and all personnel, except for essential personnel, were escorted out of containmen The inspector determined by review of dosimetry records that the following exposures were received during this inciden (1). Contractor A had 752 millirem for the current calendar quarter and had been extended to 1,750 mi*llire The radiation exposure as measured by his thermoluminescent dosimeter worn on his head
was 2,527 millire When a9ded to his previous quarterly dose, the total for the quarter was 3,279 millirem, which was in excess of the NRC quarterly allowable limit o.f 3,000 millirem to the whole bod (2)
Contractor B had no previous exposure for the current calendar quarter and had a dose limit of 750 millire The radiation exposure as measured by his thermoluminescent dosimeter worn on his head was 1,990 millire This was in excess of the licensee 1 s administrative limit of 750 millire (3)
Contractor Chad 739 millirem for the current calendar quarter prior to the entry and had been extended to 1,750 millire The worker's radiation exposure as measured by his thermoluminescent dosimeter worn on his head was 1,650 millire When added to his previous quarterly dose the total for the quarter, his cummulative exposure was 2,389 millire This was in excess of the licensee 1 s administrative limit of 1,750 millire (4)
The health physics technician providing continuous coverage for this task, as measured by his thermolumniscent dosimeter worn on his head received a total dose of 390 millirem during this inciden When added to his previous quarterly dose, his total dose for the quarter was 532 millire Inspection Results The inspector discussed this event with licensee representatives and interviewed personnel who had been associated with the even The inspector also reviewed records assembled by the licensee as part of this investigatio The inspector reviewed the Radiation Work Permit (RWP) No. 88-1472, dated May 6, 1988, which authorized the three contract workers to enter Unit 1 containment to perform the cleaning and inspection of the reactor vessel flange area on May 27, 198 The radiation levels i ndi ca ted on the RWP were 1,500 mi 11 i rem contact and 600 mi 11 i rem general are The inspector determined by the review of radiation survey records that the radiation levels of the actual work area were measured to be 2 to 3 R/hr general area around the reactor vessel flange and 7 to 15 R/hr inside the reactor vessel near the reactor internal The inspector also determined that the RWP did not specify any specific stay times or precautions for personnel to minimize their individual exposure The inspector interviewed two of the three contract personnel involved in this incident and determined that they had been given extensions of their current quarterly exposures up to 1,750 millirem for two of the contractors and up to 750 mi 11 i rem for the third contracto The contract workers that were interviewed informed the inspector that neither the health physics technician or the health
- physics shift foreman involved in this incident were.informed of their available exposures to perform the inspection and cleaning of the Unit 1 reactor vessel flang The contractors interviewed ~lso stated that stay times, precautions, or available exposures were not discussed during either pre-job briefin The inspector interviewed the health physics shift foreman involved in this incident and was informed that he had only attended the second pre-job briefing just prior to entry into Unit 1 containmen The shift foreman indicated that only the mechanics of the job were discusse However, the expected dose rates were thought to be approximately 2 Rem per hour and the time to perform this task was stated to take approximately 2 to 5 minute The inspector interviewed the health physics technician involved in this incident and determined that* he had not attended either pre-job briefing and was not aware of the three contractors' available doses to perform this tas The inspector also determined by discussion that a radiation survey of the actual work area was not performed until just prior to entry into the Unit 1 reactor cavit The inspector determined by discussions and interviews that normally the reactor head is pl aced just over the reactor vessel, approximately three feet above the reactor vessel flange, when performing this tas The reactor head is placed in this position to provide shielding from the reactor internal However, during this event due to additional inspection and cleaning of the reactor head seating surface, the reactor head was left in its normal storage locatio Therefore, no shielding was provided to reduce radiation levels while the contractors were performing work inside the reactor cavit In addition, the lack of shielding was not discussed during either pre-job briefin The inspector al so determined by discussions and interviews that the three contract workers were not made aware that their heads would be in a higher radiation field than their torsos due to the position they would be tn to perform their wor Additionally, the inspector determined by interviews and discussions that the health physics technician providing continuous coverage on this job did not inform the three contract workers to keep their heads out of the area where the higher radiation levels existe During further interviews with the health physics technician and the health physics shift foreman providing health physics controls for this assigned task, the inspector*was informed that they never discussed precautions or stay times with the workers after the radiation levels were actually measured in the reactor cavity and near the reactor internals.
The inspector reviewed the training records of the health physics technician that was involved in this event and concluded that the technician had approximately three years of experience in health
physics which met the qualifications of ANSI-Nl8.1.197 In discussion with the health physics technician and his shift foreman, the inspector was informed that the technician had previously provided coverage for work in high radiation areas (containment entry at power).
However, they stated that the technician had never provided health physics controls using stay times to minimize personne 1 exposure The inspector was informed by the hea 1th physics shift foreman that even though the health physics technician had not performed this assignment previously, the training and
experience received by the technician was determined to be sufficient to provide adequate health physics coverage for this tas Discussions with the foreman and the technician indicated that there was an apparent misunderstanding concerning who was to provide controls to minimize the workers I exposure Consequently neither the health physics technician nor the health physics shift foreman assumed responsibility for providing any precautions or stay times for the reactor cavity entr Regulatory Implications (1) Technical Specification (TS) 6.4.B requires that radiation control procedures be provided and that the station radiation protection program be organized to meet the requirements of 10 CFR 2 Health Physics Radiation Protection Manual, Section 2, Part 1, Radiation Work Permits, dated January 21, 1988, requires in Step C.w.a that a specific Special Radiation Work Permit (RWP)
be used for the performance of a specific work activity in a specific location or are On May 27, 1988, the licensee used a Special Radiation Work Permit No. 88-1472, issued on May 6, 1988, to control the work in the Unit 1 reactor cavity and other related activities associated with the reactor vesse The RWP did not contain specific precautions, stay times or actual radiation levels of the work location to minimize personnel radiation exposures to three contract worker On May 27, 1988, three contract workers exceeded their authorized administrative dose limit Failure of the procedure for issuance of Radiation Work Permits to contain instructions which ensured that the Special RWP described the actual radiological conditions in the area of the reactor vessel flange and prescribed adequate controls and precautions to minimize the workers' exposures was identified as an apparent violation of Technical Specification 6.4.B (50-280, 281/88-25-01).
(2)
10 CFR 20.20l(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in this part, and (2) are reasonable
under the circumstances to evaluate the extent of radiation hazards that may be presen On May 27, 1988, the three contract workers entered Unit 1 reactor cavity to perform cleaning and inspection of the reactor vessel flange are The licensee failed to adequately evaluate the scope of the work and the extent of the radiation hazards that were presen Consequently, no precautions or stay times were determined to adequately control radiation exposures within administrative dose limits and 10 CFR 20 regulation Failure to adequately evaluate the extent of the radiation hazards that were present in the Unit 1 reactor cavity and inside the reactor vessel was identified as an apparent violation of 10 CFR 20.201 (b)(50-280, 281/88-25-02).
(3)
10 CFR 20.lOl(b)(l) requires that during any calendar quarter the total occupational dose to the whole body shall not exceed 3 rem On May 27, 1988, a contract worker entered the Unit 1 reactor cavity to perform cleaning and inspection of the reac-tor vessel flang Upon exiting the reactor cavity the individuals thermoluminescent dosimeter placed on his head (part of whole body) indicated he had received 2.527 rem When added to the previous whole body dose for the quarter, the individual 1 s quarterly dose was 3.279 rem Failure to control an individual 1 s quarterly occupational radiation exposure dose to within 3.000 rems was identified as an apparent violation of lO CFR 20.lOl(b)(l) (50-280, 281/88-25-03).
(4)
10 CFR 19.12 requires that all individuals working in a restricted area be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portions of the restricted area and be instructed in the health protection problems associated with exposure to such radioactive materials or radiation, and in precautions or procedures to minimize exposur On May 27, 1988, the three contract workers entered the Unit 1 reactor cavity to perform inspection and cleaning of the reactor vessel flange are The contractors were informed that the general area dose rates in and around the reactor vessel flange area was approximately 2 to 3 R/hr and a low dose area under the reactor i nterna 1 s storage stand was 200 mR/h However, the health physics personnel providing coverage for this task did not inform the contract workers that the radiation levels of the reactor internals inside the reactor vessel were measured to be 7 to 15 R/h The three contract workers had to position themselves on their hands and knees with their heads extended inside the reactor vessel from time to time to adequately perform the inspection and cleaning activities of the reactor
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- vessel flange seating surface... Thi~_job took approximately 25 to 30 minutes to complete the cleaning and inspection effor During the inspection.and cleaning process, the contract workers were not cautioned or informed to keep their head away from the reactor vessel internals nor were they asked to read their self-reading pocket dosimeters to monitor their exposur Failure to adequately inform the three co_ntract workers of the radiation levels, precautions or procedures to minimize their radiation exposures was identified as an apparent violation of 10 CFR 19.12 (50-280, 281/88-25-04). Exit Interview The inspection scope and results were summarized on June 2, 1988, with those persons indicated in Paragraph The inspector described the areas inspected and discussed in detail the inspection result Four violations were discussed in detail:
(1) failure to control an individual 1 s occupational radiation dose to less than 3 rems per calendar quarter, (2) failure to have an adequate procedure to administer an effective Radiation Work Permit program to control radiation doses to within administrative limits and 10 CFR 20 regulations, (3) failure to adequately evaluate the extent of the radiation hazards that were present in the Unit 1 reactor cavity to control radiation doses to within allowable limits, and (4) failure to adequately instruct individuals entering the Unit 1 reactor cavity of the radiation levels that were present to minimize radiation dose Proprietary information is not contained in this repor Dissenting comments were not received from the licensee.