IR 05000280/1989002
| ML18153B637 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/22/1989 |
| From: | Bassett C, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153B636 | List: |
| References | |
| 50-280-89-02, 50-280-89-2, 50-281-89-02, 50-281-89-2, NUDOCS 8903140079 | |
| Download: ML18153B637 (20) | |
Text
Ut<llTED STATES NUCLEAR REGULATORY COMMISSION RcG!ON n 101 MARIETTA ST., N.W.
/'.TLANT A, GEORGIA 30323
~ '.
Report l~os.:
50-280/89-02 and 50-281/89-02 Licensee:
Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos.:
50-280 and 50-281 Facility Name:
Surry 1 and 2 Inspection Conducted:
January 23-27, 1989 I n spec tor :
(--1:s {v...-<:-l 1{-
C. H. 6assett Apprcved by: ~
License Nos.: DPR-32 and DPR-37 Ll, ~ter,Chief Fac1lities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection of the licensee's radiation protection program consisted of a review in the areas of:
organization and management controls; training and qualifications; external and internal exposure control; control of radioactive material and contamination, survey, and monitoring; the solid radioactive waste program; and transportatio The inspection also included a review of licensee actions concerning previous enforcement and inspector followup item Results:
The licensee has continued to make changes in the health physics organization in order to improve the radiation protection program and upgrade the newly formed radiological engineering sectio Management support of the radiation protection program is evident and appears to be adequate. The 1 icensee 1 s program for self-identification of problems has been changed to require more frequent use of Station Deviation Report During the inspection, weaknesses were again noted by the inspector, in the areas of procedural compliance, compliance with Technical Specification requirements, and inadequate evaluation of the radiological hazards presen Within the scope of the inspection, one violation, one unresolved item (URI)
and three licensee identified violations (LIVs) were identified as follows:
URI for failure to adequately evaluate the radiation hazards present prior and incident to welding work in the Unit 1 conoseal area which
then led to failure to adequately determine the need for extremity dosimetry and exceeding established administrative dose limit LIV concerning allowing an individual to exceed the established dose limit without obtaining the required management approva LIV for failure to maintain the entrance to a high radiation ar~a locked as require LIV for failure to ensure that an individual had been properly tr2ined to use a respirato Violation - Failure to perform the required calibration verifications and complete the verification forms following repair or replacement of contamination monitor detectors. Persons Contacted Licensee Employees REPORT DETAILS M. Beckham, Assistant Supervisor, Radwaste and Shipping, Health Physics
- R. Bilyeu, Licensing Engineer, Corporate w. Cook, Supervisor, Operations, Health Physics D. Densmore, Assistant Supervisor, Dose Control and Bioassay, Health Physics
- D. Erickson, Superintendent, Health Physics J. Fisher, Supervisor, Procedure Writing Group, Operations and Maintenance A. Friedman, Superintendent, Nuclear Training
- 8. Garber, Supervisor, Technical Services, Health Physics
- E. Grecheck, Assistant Station Manager, Nuclear Safety and Licensing
- B. Hall, Senior Quaiity Specialist, Quality Control M. Kansler, Station Manager
- G. Miller, Licensing Coordinator H. Miller, Assistant Station Manager, Operations and Maintenance L. Morris, Supervisor, Radwaste and Decontamination, Health Physics A. Royal, Supervisor, Nuclear Training
- W. Thornton, Director, Health Physics and Chemistry, Corporate
- F. Walking, Senior Staff Health Physicist, Corporate Other licensee employees contacted during this inspection included engineers, security force personnel, technicians, and administrative personne Nuclear Regulatory Commission W. Holland, Senior Resident Inspector
- L. Nicholson, Resident Inpsector
- J. York, Resident Inspector
- Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragrap.
Occupational Exposure, Shipping, and Transportation - Organization and Management Controls (83750) Organization The licensee is required by Technical Specification (TS) 6.1 to implement the plant organization specified in TS Figures 6.1-2. The responsibilities, authority and other management controls are further outlined in Chapters 12 and 13 of the Final Safety Analysis Report (FSAR).
TS 6.1 also specifies the members of the Station Nuclear
Safety and Operating Committee (SNSOC) and outlines its function and authorit Regulatory Guide 8.8 specifies certain functions and responsibilities to be assigned to the Radiation Protection Manager (RPM) and radiation protection responsibilities to be assigned to line managemen The inspector reviewed the licensee's station organization, as well as the responsibilities, authority, and control ~iven to management as they relate to the site radiation protection progra Recent changes in station organization were reviewed and the inspector verified that no organizational changes had been made which would adverse 1 y affect the abi 1 ity of the 1 i censee to implement the critical elements of the progra There appeared to be sufficient management support to implement improvements of the program as necessar The inspector also reviewed changes that had been made by the RPM in the recently reorganized health physics (HP) organizatio The previous HP organization had had two major work sections, technical services and operation As a result of the reorganization, two new sections v1ere created, a radiological engineering section and a radwaste/decon sectio The radiological engineering section had been supervised temporarily by a licensed operator from the operations staff. The 1 i censee subsequently had contracted with a vendor to bring in a person to fill the position of supervisor for the radiological engineering sectio The inspector reviewed the qualifications of the contractor who was hired to help build the radiological engineering group and give it depth of experience. The
.individual's experience and qualifications appeared to be adequate and appropriate fot the positio Prior to the Unit 2 refueling outage which began in September 1988, the 1 i censee had hi red an i ndi vi dua 1 to fi 11 the position of radiological assesso The individual was assigned to the site from the corporate office to assist in identifying problem areas in radiation protection and safet Two contractor assessors also had been hired to assist in this projec The contract assessors had performed that function for three months and finished their job during December 198 At the time of the inspection, the corporate radiological assessor was still on site and was providing daily support in assessing the HP progra The RPM had assigned the assessment function as part of the duties of the HP supervisors and shift foremen as wel Staffing TS 6.1 also specifies the minimum staffing for the plan FSAR Chapters 12 and 13 outline further details on staffing as wel The inspector reviewed the staffing level of the station HP sections and discussed the current level with licensee representative At
- the time of the inspection, of the 58 HP positions authorized for the site (including shift supervisors, specialists, and technicians), all but five were fille The shortages were in the specialist and shift supervisor positions. All the 38 authorized technician positions at the station were filled with personnel who were qualified to the requirements outlined by the American National Standards Institute (ANS1) Standard NlB.1-1971 and they were being assisted by 25 junior technician Due to the continuing outage in progress, the licensee also had retained the help of 66 contractor HP technicians and approximately 50 personnel who were assisting in decontamination efforts and,ons ite laundry facility opera ti o Root Cause Evaluation Program Follov1ing an evaluation by a company specializing in assessing management processes and organizational features, the licensee
,determined that improvement was needed in the program for self-identification of problems and the causes thereo The licensee had such a program in place prior to the assessment but took steps to revise it and implement needed change Increased emphasis was placed on identifying problems and determining the root cause by means of the Station Deviation Report (SOR).
A deviation report was not only written to outline the details of an incident but also contained a section which required a response to station management documenting the steps taken to correct the proble Prior to the assessment, there had been a few hundred deviation reports written annually to describe problems and develop corrective action Following the assessment, the licensee indicated that the number of deviation reports increased by a factor of approximately te The inspector reviewed selected deviation reports concerning problems noted in the area of radiation protectio The reports appeared to describe adequately the pro bl ems found and the corrective actions appeared to be appropriat These deviation reports are discussed in further detail in Paragraphs 4.a, 4.b, 4.c, 5.b, and No violations or deviations were identifie.
Occupational Exposure, Shipping, and Transportation -
Training and Qualifications (83750) General Employee Training (GET)
The licensee is required by 10 CFR 19.12 to provide radiation protection training to worker Regulatory Guides 8.13, 8.27, and 8.29 outline topics that should be included in such trainin The inspector verified, through selective review of training records of personnel allowed access to the radiation control area (RCA), that proper training had been given to those individuals prior to RCA entr Also, through discussions with training personnel, the inspector determined that a good line of communication existed
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- betv1een operational HP and GET training personne This allowed instructors tc quickly address poor work practices identified in the field through improvements in trainin Mock-up Training The inspector discussed, with licensee training personnel, the planned development of a mock-up training area, described as the integrated radiological/mechanical maintenance practical factors are The inspector toured the unfinished facility which currently contains various pumps, valves, and a recently purchased reactor coolant pump seal mock-u Licensee representatives indicated that they are in the process of assessing the merits of purchasing an elevated working platform for the facility to create realistic hoisting, climbing, and working condition The licensee also indicated that plans are being developed to create training situations which integrate certain maintenance, electrical engineering, operations, and HP training activitie No violations or deviations were identifie Occupational Exposure, Shipping and Transportation - External Exposure Control and Personnel Dosimetry (83750) Personnel Dosimetry 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 CFR 20.20l(a) defines a 11 survey 11 as an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of condition CFR 20.202 requires each licensee to supply appropriate personnel monitoring equipment to specific individuals and requires the use of such equipmen TS 6.4.D requires that radiation control procedures be f~llowe Health Physics Procedure HP-3.1.3, 11 Personnel Dosimetry - Dosimetry Issue and Dose Determination, 11 dated July 27, 1988, requires in step 4.7.3.2 that the licensee evaluate the need for extremity badges when the expected exposure to the hands and forearms or feet and ankles is equal to or greater than one rem per hour and the extremity to whole body dose (12 inches from the contact dose rate) ratio is 5:1 or greater.
Health Physics Procedure HP-5.1.20, 11 Administrative Dose Control,
dated December 16, 1988, requires in step 4.5 that a worker receive
an exposure extension approved by station management prior to exceeding the administ1*ative dose limits established for the quarte The inspector reviewed SOR, Number Sl-88-1626, which dealt with the radiological conditions for seal welding of the Unit 2 reactor head conosea During a review of the possible applications of engineering controls for the welding job, the licensee determined that the criteria for use of multiple dosimetry was me The radiation work permit (RWP) (88-3045) did not require special or multiple dosimetry initially, but following the review, the RWP was modified to specify extremity and upper body dosimetry for the jo The two contract we 1 ders, who subsequently performed the work, indicated that they had performed the Unit 1 conoseal welding but that special dosimetry had not been required for the job at that tim A concern was then raised about exposure received during the weldino on the Unit 1 conosea The licensee initiated a review of the Unlt 1 work package and the RWP (88-1516) used to control the jo Survey data indicated that contact and 12 inch radiation level readings were similar to those found in the Unit 2 conoseal work are Licensee representatives determined that special dosimetry was apparently warranted and should have been worn during the Unit 1 conoseal work as well.
Through a compilation of RWP 88-1516 survey data and an estimate of the dose rate inside the reactor head shield, a calculated or estimated 11 survey 11 was developed indicating the 11 typical 11 dose rates of a Unit 1 thermocouple column conosea The licensee used the highest radiation level readings for the 11 typical" dose rates, to be conservativ Then, through interviews with the welders, the licensee determined that, during the actual time spent in the conoseal area, the whole body dosimetry (worn in the upper chest area) was located approximately 16 to 20 inches from the conoseal weld are The workers' heads were thus 1 ocated approximately 12 inches from the weld area and were determined to be the part of the whole body in the highest radiation fiel The wrists and hands were located approximately 3 to 6 inches from the conosea Based on the calculated 11 survey 11 results, the workers* whole body dosimetry was located in an estimated 400 mR/hr dose rate area while the workers 1 heads were in an estimated 800 mR/hr dose rate are The hands and wrists were* located in up to a 1.2 R/hr dose rate are Since the head was in a radiation field of twice that of the whole body dosimetry location, the welders' whole body exposures recorded during the entire Unit 1 conoseal job were increased by a factor of two:
from 685 mrem to 1370 mrem for one worker for a quarterly total of 1412 mrern and from 884 mrem to 1768 mrem for the other for a quarterly total of 2710 mre The workers' administrative limits for the second quarter were 1000 mrem and 1750 mrem, respectivel *
The issue described above is similar to an event detailed in Inspectior: Report (IR) No. 50-280, 281/88-4 That was an event which dealt with the inadequate evaluation of the radiation hazards present prior to and during decon operations in the Unit 1 reactor cavit The event described in this report occurred prior to the Unit l reactor cavity decon event but was not discovered until after the cavity decon event occurre The licensee has not yet responded to the Notice of Violation (NOV) issued concerning the cavity decon even Because no response has been issued, the adequacy of the corrective actions taken to ensure the proper evaluation of future radiation hazards have not been review~d nor evaluate Consequently, the issue outlined above will be considered as a~ URI* pending receipt, review, and evaluation of the licensee's response to the NOV concerning the Unit 1 reactor*cavity decon event (50-280, 281/89-02-01). Administrative Exposure Limits TS 6.4.D requires that radiation control procedures be followe Health Physics Procedure HP-5.1.20, "Administrative Dose Control,"
dated December 16, 1988, requires in step 4.5 that a worker receive an exposure extension approved by station management prior to exceeding the administrative dose limit of 1250 mrem per quarte The inspector reviewed an SOR, Number Sl-88-1602, which dealt with exceeding an administrative exposure limit without proper authorizatio On December 18, 1988, a contract electrician prepared to enter the 11 C'
1 reactor coolant pump (RCP) cubicle of Unit 1 under the radiological constraints of RWP 88-2948 to work on the reactor coolant system (RCS) thermocouple He was wearing special dosimetry, as required by the RWP, as well as a whole body thermoluminescent dosimeter (TLD).
After attending a pre-job briefing and receiving a stay time of 5 minutes, the contractor entered the area which had a general area dose rate of 2 R/h After working for the designated 5 minutes, the individual was brought out of the area by a licensee HP technician covering the jo The worker 1s self-reading pocket dosimeters (SRPDs) were read and they all indicated an exposure of approximately 150 mre The individual was again given a 5 minute stay time and allowed back into the area to continue workin After about 6 minutes the worker was again brought out and his SRPDs rea The SRPD that had been located on the right knee read 800 mrem while all the other SRPDs read between 180 and 390 mre At this point, the HP technician stopped the job and had the worker 1s TLDs rea *An unresolved item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviatio * *
The TLD results varied from 170 mrem to 470 mrem with the exception of the right knee TL The results of the right knee TLD indicated an exposure of 1093 mrem which was then assumed to be the highest whole body dose receive Through a review of the results of the periodic testing performed on the dosimetry, the licensee determined that both the TLD and the SRPD used to monitor exposure to the right knee had passed the normal response check required and prescribed by procedur The SRPD and TLD from the worker 1s right knee were then tested to determine if they sti 11 met the 1 i censee I s acceptance criteria of plus or minus 10% of a calculated exposure of 800 mrem received from a Cs-137 sourc The test results indicated that the TLD failed high and tbe SRPD failed lo The dosimeters were then exposed to a ca 1 cul ated exposure of 1000 mrem to test their performance agai Following this test, the results indicated that the TLD passed on the upper end of the acceptance criteria while the SRPD again failed lo The licensee investigated the work site and found that the insulation on a pipe where the individual had been working had been shifted out of it~- normal locatio It was assumed that the individual had inadvertently moved the insulation during the job and had then placed his right knee against the pip The licensee indicated that this had probably caused the added exposure accumulatio The pipe was surveyed and had a radiation level reading of 3 R/hr on contac The licensee assumed the 1093 mrem initial reading of the right knee TLD to be correct and assigned this dose to the individual as whole body dos This dose, when added to the previous quarter dose total, resulted in an exposure of 1268 mrem for the quarter, 18 mrem above the established quarterly administrative limit of 125 The incident was assumed to have been caused by the in-service failure of the SRPD even though both the TLD and the SRPD had passed the response check during normal periodic testin Allov1ing an individual to exceed the established administrative dose 1 imit without obtaining the required management approva 1 was identified as an apparent violation of TS 6. However, pursuant to 10 CFR 2, Appendix C.V.G., this issue was considered a licensee identified violation (LIV) and a Notice of Violation (NOV) was not issued due to the violation being (1) licensee identified, (2) of severity level IV or V, (3) not reportable, (4) corrected, and (5)
not expected to have been preventable by corrective action for a previous violation (50-280, 281/89-02-02).
Radiologically Controlled Areas 10 CFR 20.203 specifies posting and control requirements for radiation areas, high radiation areas, airborne radioactivity areas, radioactive material areas, and radioactive materia *
TS 6.4.B.1.b requires that the entrance to each radiation area in v1hich the intensity of radiation is equal to or greater than lOOC mrem/hr sha 11 be provided with 1 ocked barricades to prevent unauthorized entry into these area During plant tours, the inspector observed the licensee 1s posting and control of radiation, high radiation, airborne radioactivity, radioactive material areas, and the labeling of radioactive materia The inspector determined that the posting and controls for the various radiological control areas were adequat The inspector also verified that various locked high radiation areas in the Unit 1 and Unit 2 containment buildings and in the auxiliary building were being maintained locked as require The inspector reviewed an SOR, Number S2-89-031, concerning a high radiation area that was not controlled as require On January 8, 1989, during a walkdown of the Unit 2 Containment, an HP technician noted that the chain and padlock used to 1 ock the gate to 11 8 11 RCP cubicle were found wrapped around the gate to give the appearance of securing the entranc However, the chain was not secured by the padlock in such a manner as to prevent the gate from openin A second HP technician was summoned to control entrance to the cubicle and the area was searched to ensure that no one was insid Radiation level surveys in the cubicle indicated radiation dose rates in excess of 1000 mrem/h The gate was then locked properly with the cha.in and padloc The licensee 1s investigation of the event determined that the individual who initially 11 locked 11 the gate thought the padlock was locked on the chain so as to secure the gate from opening but had not checked it adequatel The initial corrective actions taken by the licensee in response to this incident were to shorten all chains at gates to high radiation areas to allow for easier lockin This was also done to allow the person securing the area to more easily determine that the gate was, in fact, locked as require HP personnel were also instructed to verify that all gates to high radiation areas that were required to be locked were secured as required or properly control led during walkdowns of the containmen As a long-term corrective action, work requests have been submitted to replace all the old gates with new gates having built-in locking mechanism The gates are to be designed to close and lock automatically and yet allow for opening from the inside to permit unrestricted exit from the high radiation are Failure to maintain the entrance to an area in which the intensity of radiation was greater than 1000 mrem/hr locked was identified as an apparent violation of TS 6.4.B. However, pursuant to 10 CFR 2, Appendix C.V.G., this issue was considered an LIV and an NOV was not issued (50-280, 281/89-02-03).
h *
Occupational Exposure, Shipping, and Transportation - Internal Exposure Control and Assessment (83750) Engineering Controls CFR 20.103 ( b) requires the 1 i censee to use process or other engineering controls to the extent practical to limit concentrations of radioactive material in air to levels below those specified in 10 CFR Part 20, Appendix B, Table 1, Column During tours of the Auxiliary Building and Units 1 and 2 Containments, the inspector observed the use of process controls and engineering controls to limit airborne radioactivity in the plan The licensee used tent enclosures and vendor supplied sealed chambers to decontaminate various tools and items of equipment and to perform maintenance on contaminated i tern These tents and chambers were kept under negative pressure by means of high efficiency particulate air (HEPA) filtration system No violations or deviations were identifie Respiratory Protection 10 CFR 20.103(c) requires that, when respiratory protection equipment is used to limit the inhalation of airborne radioactive material, the licensee train, medically qualify, and fit test the individual user of such equipmen TS 6.4.D requires that radiation control procedures be followe Health Physics Procedure HP-5.2A.13, "Responsibilities, Requirements, and Restrictions of Respirator Use, 11 dated July 20, 1988, requires in step 4.1.2 individuals using respiratory protection must attend and satisfactorily complete respirator protection training prior to respirator use and retraining once per 12 months to maintain their respirator use qualificatio The use of respiratory protection was observed and discussed with licensee representative The inspector noted that, on occasion, respiratory protection is issued to individuals as a precaution against facial contamination and not necessarily due to airborne radioactivity or high levels of surface contaminatio This practice was not as widespread as noted during previous inspections, due in part to the efforts expended during the outage in progress to decontaminate the containment The inspector also reviewed an SOR, Number Sl-88-1650, which detailed a problem noted with issuing respirator On November 23, 1988, an individual reported to the main protective clothing (PC) issue point in the service building to obtain PCs and a respirato The laundry personnel stationed at the clothing issue point had a Personnel
Radiation Exposure Management System (PREMS) computer terminal to enable them to check and verify the training, medical and fit test qualifications of persons requesting a respirator for use in the RC On November 23, the PREMS computer system was not operating properly and the personnel issuing PCs then checked the computer printout issued every shift as a backup to the PREMS syste The computer printout was misinterpreted by the laundry personnel and a respirator was issued to an individual whose training qualifications had lapse When the individual again tried to obtain the use of a respirator on December 28, 1988, the error was discovered and the licensee initiated several corrective action The individual, whose training had expired February 11, 1988, was given a whole body coun No internal deposition of radioactive material was detecte Through interviews with the laundry personnel, it was determined that they did not have sufficient training to review the computer printout and manually issue a respirato Their training had covered issuance of respirators using the PREMS computer terminal but not using a printout to determine a person's qualification statu The laundry personnel were subsequently allowed to issue respiratory protective devices to individuals based on confirmation by the PREMS computer syste If the computer was not functioning or if problems were flagged by the computer when it was functioning, the laundry personnel were required to refer the individual requesting a respirator to Dose Control personnel for appropriate actio (When the computer system is functioning and training, medical or fit test qualifications do not meet the requirements, respirator issue vi a the computer is automatically denied.)
The laundry personnel were also instructed not to issue a respirator 11manually, 11 i.e. by referring to the computer printou Failure to ensure that an individual had been properly trained to use a respirator was identified as an apparent violation of TS 6. However, pursuant to 10 CFR 2, Appendix C.V.G., this issue was considered an LIV and an NOV was not issued (50-280, 281/89-02-04). Occupational Exposure, Shipping, and Transportation -
Control of Radioactive Material and Contamination, Surveys, and Monitoring (83750) Plant Surveys The licensee is required by 10 CFR 20.401 and 20.403 to maintain records of such surveys necessary to show compliance with regulatory limit Survey methods and instrumentation are outlined in Chapter 12 of the FSA During plant tours, the inspector reviewed radiation level and contamination survey results posted outside various areas and cubicle The inspector verified these radiation levels using NRC instrumentatio The inspector also reviewed selected records of
radiation and contamination surveys performed during the inspection and discussed the survey results with licensee representative No violations or deviations were identifie Radiation Detection and Survey Instrumentation TS 6.4.D requires that radiation control procedures be followe Health Physics Procedure HP-9.0.701, 11Calibration and Operation of Eberline Model PM-6,
and Health Physics Procedure HP-9.0.720, 11 Caiibration and Operation of Eberline Model PCM-lA, 11 each dated August 29, 1988, both require in step 3.4 that an operational check and calibration verification, in accordance with step 4.10, be performed following repair or replacement of a detecto Step 4.10 requires the completion of forms HP 9.0.701-2 and HP 9.0.720-2 respectively to verify completion of the calibration verificatio The inspector reviewed the 1 i censee I s use of portable radiation detection instruments for routine radiation protection activitie During plant tours, the inspector verified that all instruments observed in use had been calibrated within the prescribed time period and al sc observed that the selection and use of instruments was appropriate for the radiation protection activity involve Following a tour of the Auxiliary Building and Unit 1 Containment and upon exiting the RCA, the inspector noted that the licensee was using plastic tape to repair damaged mylar windows in the whole body personnel friskers or personnel contamination monitors (PCM-lAs).
Discussions with licensee representatives indicated that repairing the damaged mylar windows with tape had not proven to change the instruments' sensitivit The licensee also informed the inspector that the vendor's technical manuals allowed the use of tape to repair rny1ar windows until such time as the detector could be removed and the mylar covering replaced. Through a review of the PCM-lA technical manual and the portal monitor (PM-6) technical manual and a review of the calibration verification forms completed following detector repair or replacement, it was determined that this was the cas However, a review of the PCM-lA and PM-6 opera ti ona 1 check and calibration verification forms, also indicated that all the forms had not been completed as required further indicating that all the calibration verifications had not been performe No calibration
- verification forms were on file for the following:
Monitor Date PCM-lA Serial #201 January 12 and 19, 1989 Serial #210 January 19, 1989 PM-6 Serial #189 January 10 and 12, 1989 Serial #190 January 10 and 16, 1989 Upon investigating this problem, the licensee found that the instrument technician responsible for performing the verifications following detector repair or replacement had been terminated due to attendance problem Another individual, who also worked the same shift as the person who had been terminated, had noted that some of the monitors needed to have detectors repaired or replace Even though the second individual had only been officially trained to perform daily source checks on portable friskers, he completed the needed repairs on the detectors and source checked them to ensure that they were responding 11 properly.
Following discovery of the problem, the licensee informed the untrained individual that he was to make no further repairs to the monitors but only to remove the monitors from service if a detector failed due to a leak or other proble Also, all operating detectors that were involved in the documentation problem were reverified and the proper documentation complete Al 1 detectors involved passed the efficiency verificatio The licensee determined that this was an isolated incident and involved only one individual who went beyond what he was trained or expected to d Failure to perform the appropriate calibration verifications and verification forms as required following repair or replacement of PCM-lA or PM-6 detectors was identified as an apparent violation of TS 6. However, this violation meets the criteria specified in Section V of the NRC Enforcement Policy for not issuing a Notice of Violation and is not cited (50-280, 281/89-02-05). Personnel and Material Release Surveys During tours of the facility, the inspector observed the exit of workers and the movement of material from contamination control to clean areas to determine if proper frisking was performed by the workers and if proper direct and removable contamination surveys were performed on material The inspector determined that frisking and material release surveys were adequat No violations or deviations were identified.
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L..> Occupational Exposure, Shipping, and Transportation - Solid Radioactive vJaste (83750) Waste Classification CFR 20.3ll(d)(l) requires that licensees prepare all waste such that the waste is classified in accordance with 10 CFR 61.5 With the exception of dry active waste (DAW), the licensee is currently sampling waste streams prior to making a shipment due to changes noted in the isotopic mixtur The waste streams being sampled are ion exchange resins and filter elements involved in processing reactor coolant or spent fuel pool water, ion exchange resin and filter elements involved in processing liquid radwaste, secondary side ion exchange resins and filter elements and DA Samples are sent to a vendor for analysis and the results reviewed and verified by on site and corporate staff member The vendor also develops the site-specific scaling factors from these results and these are likewise reviewed and verified by the corporate staf The licensee uses a vendor-supplied computer program (RADMAN) which processes input information obtained from a package of waste to determine the package's waste classification and transportation type.
The program identifies non-gamma emitters based on the scaling factors developed for the particular waste stream in questio Waste Stability 10 CFR 20.3ll(d)(l) requires that any generating licensee prepare all wastes so that the waste meets the waste characteristics requirements in 10 CFR 61.5 Through discussions with licensee representatives and review of selected 1988 shipping records, the inspector determined that shipment preparations had been in conformance with the licensee's Process Control Progra The licensee purchased a vendor-developed dewatering system which the licensee now operate No solidification has been performed at the site for approximately two years following problems encountered with a vendor-operated project which yielded unsolidified waste in the form of a paste-like substanc Manifests 10 CFR 20.3ll(b) requires that each shipment of radioactive waste to a licensed land di sposa 1 facility be accompanied by a shipment manifest and specifies required entries on the manifest The inspector reviewed selected records of radioactive waste shipments completed during 1988 and 1989, and verified that the manifests had been properly complete No violations or deviations were identifie.
Occupational Exposure, Shipping, and Transportation -
Transportation (83750) Approved Procedures The inspector reviewed selected licensee procedures and instructions pertaining to the transportation of radioactive material The documents reviewed had been approved as required and appeared to be adequate to assure compliance with the applicable regulation The primary procedure used for shipping radioactive material was Health Physics Procedure HP-7.1.40, 11 Packaging and Shipment of Radioactive Material,
11 dated August 29, 198 Shipping Records 10 CFR 71.5 requires that licensees who transport licensed material outside the confines of their plant or other place of use, or who deliver licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR 170 through 18 In addition to the shipments referenced in Paragraph 7, the inspector reviewed selected records-of radioactive material shipments performed during 1988 and 198 Records reviewed included shipping manifests, package and vehicle radiation and contamination surveys, waste classification, and records indicating what package marking and labeling and vehicle placarding was used; The manifests and shipping documents examined were prepared consistent with 49 CFR requirement The radiation and contamination survey results reviewed were found to be within the limits specified for the mode of transpor The inspector determined that shipping documentation was being completed and maintained as require No violation or deviations were identifie.
Faci 1 ity Sta ti sti cs Annual Personnel Dose In 1987, the station's cumulative personnel dose was 356 person-rem per reactor as compared to the Pressurized Water Reactor (PWR)
national average of 369 person-rem per reacto This dose was accumulated during 115 days of scheduled and unplanned outage day The 1988 dose goal was set at 734 person-rem per reactor due to two anticipated refueling outage The actual cumulative dose received in 1988 was 762 person-rem per reactor as measured by TL This dose was accumulated during 220 days of scheduled and unplanned outage days involving Units 1 and/or Personnel Contaminations During 198S, the licensee experienced a total of 226 skin and 275 clothing contaminations compared to a total of 174 skin and 319 clothing contaminations for 198 This is a downward trend in personnel contaminations when the number of outage days for the two years are considere The downward trend was attributed to wearing paper coveralls over the outer set of PCs thus reducing the amount of contamination reaching the cloth PC The trend was also thought to be a direct result of the major efforts expended in decontaminating the Unit 1 and Unit 2 containment Solid Radioactive Waste Licensee representatives indicated that approximately 25,000 cubic feet (ft3) of sol id radioactive waste containing 193 curies of activity had been shipped to waste collectors or burial sites during 198 During 1987, the licensee had shipped approximately 24,000 ft 3 of solid waste containing 29,000 curies of activity. The high curie total for 1987 was attributed to shipping process resins and activated material which came from cleaning up the spent fuel poo Area Contamination Control At the end of 1987, the licensee maintained approximately 22,400 square feet (ft 2 ) within the RCA, excluding the containment buildings, as contaminate This represented about 24% of the total 92,000 ft 2 within the RC As of December 31, 1988, approximately 20,630 ft 2 were being controlled as contaminated area or about 23% of the RC No violations or deviations were identifie.
Action on Previous Inspection Findings (92701) (Closed) Inspector Followup Item (IFI) 50-280, 281/88-FRP-05:
Complete Radiation Protection Plan Implementatio Through interviews with 1 i censee representatives and review of associated documents, the inspector determined that the corporate radiation protection program had been fully implemente This project was completed following revision of the company Radiation Protection Pl an ( RPP) document, Vi rgi ni a Power Nuclear Operations RPP, and training on the revised procedures implementing the RPP at each sit (Closed) IFI 50-280, 281/88-FRP-09:
Implement and Train Personnel on Group II Procedures by December 31, 198 Through interviews with 1 i censee representatives and review of various records, the inspector determined that the revision,
implementation and training of HP technicians on "Group II
procedures had been complete This group of procedures dealt with external dosimetry, solid radioactive waste control, effluent control, radioactive environmental monitoring, surveillance and evaluations, and radiological incident investigation and analysi Due to the specific nature of these procedures, the initial training was targeted for and given to only those involved in implementing and using the procedure It is anticipated that these procedures will be reviewed with all HP personnel during 198 The training consisted of classroom instruction, in-plant training, guided self-study and group discussion Evaluation of the effectiveness of the training consisted of completing performance checklists through discussions and demonstrations with an evaluator and completing eiaminations on the subjects covere The inspector reviewed training schedules, lesson plans, performance checklists, attendance records and exami nati an A 11 the records reviewed appeared to be adequate and covered the appropriate topic (Closed)
JFI 50-280, 281/88-FRP-16:
Consolidate Procedure Development to Ensure Consistency and Integration The licensee indicated that a centralized procedure development staff was needed to ensure consistency and proper integration of procedures at the station. * Procedures had not been written in a consistent manner in the past and the proper interface between groups did not exis Procedures had evolved from general guidelines to specific step-by-step guidanc As a result, people had erroneously developed the idea that procedures did not need to followe Due to this, it was determined that a procedure writing guide would be published and a group of writers assembled to revise the existing procedures and write future procedures in a consistent and standardized manne Through interviev/s with licensee representatives, including the Supervisor of the station Procedure Writing Group, the inspector verified that a procedure writer 1 s guide had been developed and approved for use and a procedure writing group had been forme It was noted that, following the outage, the group 1s main objective would be to review the station 1 s procedures and determine what procedures needed to be revised firs A priority 1 i st would be developed and the procedures would be revised in a consistent and standardized manne Although the licensee indicated that the procedures upgrade would take approximately three years to complete, this item is considered closed due to the fact that it is being followed by the resident inspectors through IFI 50-280, 281/88-18-0 (Ciosed)
IFI 50-280,281/88-FRP-17:
Ensure Proper Procedural Architectufe and Human Factors Implementatio The inspector reviewed the establishment of a procedure writing group at the station and the group's charte The group was to upgrade the existing operating procedures for the instrumentation and control, and electrical and mechanical maintenance departments and correct any problems note The licensee indicated that this upgrade would take three years to complet This item is considered closed but will be followed by a previously established IFI 50-280, 281/88-18-0.
Exit Interview The inspection scope and findings were summarized on January 27, 1988, v1ith those persons indicated in Paragraph 1 abov The inspector described the areas inspected and discussed in detail the inspection findings listed belo The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspectio Licensee management was informed that the items discussed in Paragraph 10 were considered close On February 21, 1989, a telephone conversation was held between the inspector and a licensee representative to inform the licensee that the issue surrounding an event which involved welding work in the Unit 1 conoseal area would be considered an URI pending further evaluatio Item Number 50-280, 281/89-02-01 50-280, 281/89-02-02 50-280, 281/89-02-03 50-280, 281/89-02-04 50-280, 281/89-02-05 Description and Reference URI - Failure to adequately evaluate the radiation hazards present prior and incident to welding work in the Unit 1 conoseal area which lead to failure to adequately determine the need to provide extremity dosimetry and exceeding specific administra-tive dose limits (Paragraph 4.a).
LIV~ Allowing an individual to exceed the established administrative dose limit without obtaining the required management approval (Paragraph 4.b).
LIV - Failure to maintain the entrance to a high radiation area locked (Paragraph 4.c).
LIV - Failure to ensure that an individual had been properly trained to use a respirator (Paragraph 5.b).
Violation - Failure to perform the required calibration verifications and verification forms fo 11 owing repair or rep 1 a cement of PCM-lA and PM-6 detectors (Paragraph 6.b)
- 1 Acronyms and Initialisms ANSI CFR DAv/
DOT FSAR ft2 ft 3 GET HEPA HP HR/\\
IF I IR LIV mR/hr mrem NOV PC PCM-lA PCP PM-6 PREMS PWR R/hr RC,l RCP RCS RPM RPP RWP SOR SNSOC SRPD TLD TS URI American National Standards Institute Code of Federal Regulations Dry Active Waste Department of Transportation Final Safety Analysis Report Square feet Cubic feet General Employee Training High Efficiency Particulate Air (filter)
Health Physics High Radiation Area Inspector Followup Item
Inspection Report
Licensee Identified Violation
Milliroentgen per hour
Mil 1 i rem
Protective Clothing
Personnel Contamination Monitor (Eberline)
Portal Monitor (Eberline)
Personnel Radiation Exposure Management System
Pressurized Water Reactor
Roentgen per hour
Radiation Control Area
Reactor Coolant Pump
Radiation Protection Manager
Radiation Protection Program
Radiation Work Permit
Station Deviation Report
Station Nuclear Safety and Operating Committee
Self-reading Pocket Dosimeter
Thermoluminescent Dosimeter
Technical Specification
Unresolved Item