IR 05000280/1990035
| ML18153C474 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/10/1990 |
| From: | Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153C473 | List: |
| References | |
| 50-280-90-35, 50-281-90-35, NUDOCS 9012210021 | |
| Download: ML18153C474 (9) | |
Text
UNiTED STATES NUCLEAR REGULATORY COMMISSION
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REGION 11 101 MARIETTA STREET, ATLANTA, GEORGIA 30323 DEC 111990 Report Nos.:
50-2.80/90-35 and 50-281/90-35
.Licensee: Virginia-Electric and Power Company Glen Allen, V Docket Nos.:.* 50-280 and 50-~81 Facility Name:
Surry 1 and 2 Inspec~: *
ff( Approved by:
Scope:.
-,,--..-~.
License Nos.:
DPR-32 and. DPR-3 Safeguards SUMMARY This routine, unannounced inspect~on was conducted in the area of occupational*
radiation safety during extended outages and included an examination of: audits *
and ~ppraisals, planning ~nd preparation, training and qualific~tion, external exp6sure control, internal exposute control, control of radioactive material and contamination~* surveys and monitoring, and maintaining occupational exposures ALAR In addition, Information Notices were reviewed. *
Resul t_s:
In the areas inspected, violation or deviations were not identified~ Based on i_ntervi ews with licensee management, supervision, personnel from station..
departments, and records review, the inspector found the radiation protectiori program to be well managed. The licensee's programs for external and internal radiation exposure controls were effective and functioning adequately to protect the health and safety of occupational radiation workers. The licensee's program to maintain occupational exposures as low as reasonably achievable (ALARA) wa*s considered to be a* program strength. The inspector _observed-improvements in all program ~reas that indicate the station has developed and supports high standards in radiation protection (RP). However, the inspector noted that the "Virginia Power Five Year Exposure Reduction Plan 11 had not been approved.
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REPORT DETAILS Persons Contacted Licensee Employees
- W. Benthall, Supervisor, Licensing
- R. Bilyeu, Engineer, Licensing
- W. Cook, Operations Supervisor, Radiation Protection
- D. Erickson, Superintendent, Radiation Protection
- E. Ferreira, Coordinator, Instrument and Controls
- D. Hart, Supervisor, Quality Assurance
- M. Kansler, Station Manager
- L. Morris, Radwaste Supervisor, Radiation Protection
- J. Peden, Engineer, Decontamination Services
- S. Poage, Engineer, Quality Assurance
- A. Price, Assistant Station Manager
- L. Ragland, Shift Supervisor, Radiation Protection
- H. Royal, Supervisor, Nuclear Training
- E. Smith, Superintendent, Quality Assurance
- T. Steed, ALARA Coordinator, Radiation Protection
- W. Thornton, Corporate Director, Health Physics and Chemistry
- V. Wyatt, Department ALARA Coordinator, Maintenance Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, and.administrative personne Nuclear Regulatory Commission
- W. Holland, Senior Resident Inspector
- Attended exit-interview Organization and Management Controls (83750)
The inspector reviewed changes made to the _licensee's organization, staffing levels and lines of authority as they related to RP, and verified that the changes had not adversely affected the licensee's ability to control radiation exposures or radioactivit The inspector discussed with the RP Superintendent, the type, methods of, and degree of interaction between plant groups. The inspector reviewed the
. licensee's program for self-identification of weaknesses related to the RP program and the appropriateness of corrective action taken. The inspector reviewed Radiological Problem Reports (RPRs), Personnel Contamination Events (PCEs), and Radiological Incident Reports (RIRs) and noted that for the more significant events in these categories the licensee had performed
.2 thorough investigations to determine root cause, and were trending the data for and taking corrective action The inspector discussed the audit and surveillance program related to RP with quality assurance (QA) management and staff. Licensee representatives stated that in addition to audits required by station technical specifications (TSs) an evaluation program had been developed similar to that of the Institute of Nuclear Power Operations (INPO).
An evaluation was in progress for the RP program during the inspection. QA personnel stated that the average duration for an evaluation of RP methodologies was90-120 days. Upon completion, the RP Program would be rated on a 1-4 scale and responsible personnel would be required to take corrective actions for all concerns identifie The inspector determined that no audits had been performed since the last inspection and revie The inspector noted over the pa~t *12-18 months that a change of attitude and improvement in morale of station employees had taken place concerning the RP program. At the beginning of the RP performance improvement program, licensee management identified to the NRC a number of RP program elements that needed strengthening. A radiological engineering staff was added to RP and began taking a more technical approach to resolving problem Management increased support for RP and the RP staff was reorganized at the shift supervisor level. During this period, the station experienced problems with personnel complying with RP ~rogram requirements and used the events to express management's expectations-to both station supervision and workers. Department ALARA coordinators were selected from major departments to interface with the Station ALARA Committee. As participation in the RP program increased, more responsibility and authority was transferred to station personnel at the working level, and it is this inspe.ctor's observation that these changes have resulted in a strong RP program with high standard *
No violations or deviations were identifie. Training and Qualifications (83750)
10 CFR 19.12 requires the licensee to instruct ~11 individuals working or frequenting any portions of the restricted areas in the health protection aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protection devices employed, applicable provisions of the Commission Regulations, individuals responsibilities and the availability of radiation exposure dat The inspector discussed training of licensee and contractor personnel in radiological controls with licensee representatives and reviewed contractor health physics technician job assignments relative to qualifications. No discrepancies were noted.
Licensee management support for training is evidenced by Advanced Radiation Worker (ARW) Training. Maintenance targeted approximately 210 workers for ARW training in 198 To date 70 percent of the targeted group has satisfactorily completed the required training. In spite of the heavy maintenance workload and outage in 1990, maintenance department per~onnel have a training attendance level of 100 percent. Licensee representatives stated that the mechanical, electrical, and instrumentation and control training programs had no findings and received renewal of INPO accreditation in May of this yea No violations or deviations where identifie.
External Exposure Control and Personnel Dosimetry (83750)
The inspector discussed the p 1 anni ng and preparation for the current outage with licensee representatives. Specific areas discussed included increases in staffing, special training, equipment and supplies, health physics (HP) involvement in outage planning, and licensee control over HP technician Licensee representatives stated that to provide additional personnel for the increased workload during the outag~, 80 contractor HP technicians were obtaine The contracted personnel were given general employee training, procedures training, and training in site specific HP requirements, and worked under licensee HP supervision to assure program consistenc RP assigned outage planning to two engineers to improve work coordination and minimize any delays during the outage. For past outages, previous dose, radiation work permits (RWPs), and past problems, were reviewed and analyzed. A list of action items were developed and assigned to superintendents for dispositioning prior to the Unit 1 refueling/steam generator maintenance outag *
RP developed task packages were reviewed internally, and by the Planning and Scheduling Department. Outage planners then made commitments for identified outage times, and completed identified work prior to the outag Licensee representatives stated that the prior planning by the RP staff resulted in no radtological delays and assisted in attaining the outage goal of 60 day CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas, and radioactive material. Additional requirements for control of high radiation areas are contained in TS 6.12. During tours of the plant, the inspector reviewed the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contamination areas, radioactive material areas, and the labeling of radioactive material. The inspector also performed radiation and contamination surveys to verify the adequacy of licensee surveys. No significant differences were noted.
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10 CFR 20.202 requires each licensee to supply appropriate personnel monitoring equipment to specific individuals and.require the use of such equipment. During tours of the plant, the inspector observed workers wearing appropriate ~ersonnel monitoring devices. The licensee has incorporated the use of digital alarming dosimetry (DAD) into the exposure controls program. The inspector noted that RP reviews the work areas and establishes DAD alarm set points in a manner that result in dose reductibn for the worke No violations or deviations were identifie.
Internal Exposure Control (83750) CFR 20.103(b)(l) requires that the licensee use process or other engineering controls to the extent practicable to limit concentrations of radioactive materials in the air to levels below those which delimit an airborne radioactivity area as defined in 20.203(d)(l)(ii).
10 CFR 20.103(b) also requires that when it is impracticable to apply process or other engineering contra 1 s to 1 imit concentrations of radioactive material, other precautionary procedures shall be used. The precautionary procedures include respiratory protective equipment.
The inspector verified that the licensee fssued respirators for use after determining the user's training and qualificatio The inspector determined by review that no individual had been exposed to concentrations of radioactive material greater than 40 mpc-tiours. The inspector also observed the use of absolute filtered ventilation and containments as engineered contra 1 s to prevent the need for respiratory protective equipmen Surveys, Monitoring, and Control of Radioactive Material and Contamination (83750)
10 CFR 20.203(e) requires each area in which licensed material is used or stored and which contains any radioactive material in an amount exceeding ten (10) times the quantity of such material specified in Appendix C of this part to be posted with the sign or signs bearing the radiation caution symbol and the words: "Caution, Radioactive Material(s)."
During tours of the Unit 1 containment, Auxiliary Building, and outside radiologically controlled areas (RCA), the inspector noted that all area and radioactive material posting and labeling were as specified by RP procedur The inspector discussed the contamination control program with licensee representatives. Decontamination of the RCA has been slow; however, as contaminated areas have been recovered, permanent epoxy coatings have been
- applied. The licensee had reported 14,495 of the 89,500 square feet (ft 2 )
area of the RCA was contaminated at the end of 1989 and that 2,400 ft 2 had been reclaimed through October. However, contaminated area in the RCA *
increased in November to 25,300 ft 2 due to laydown and work areas requ1red to support the outage, and several large spills of radioactive water. At-the time of the inspection the radwaste group had not made any significant progress in recovering the area lost in November but stated that at the completion of the outage and before the end of the year they expected to meet the yearly goal of 11,500 ft 2 *
Licensee management stated that the station was concerned about the increase in contamination and that in the future personnel causing increases in contaminated area would be responsible for their decontaminatio The station established an aggressive goal in 1990 for PCE On November 26, 1990, with the outage near completion, the sta:tion had experienced 178 PCEs, which was over the goal of 155 PCEs. Licensee representatives stated that each PCE had received a fu.11 investigation by RP engineering and a trend indicated that first time, contract personnel to the station were responsible for the majority of PCE No violations or deviations were identifie Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA)
10 CFR 20. le states that persons engaged in activities under 1 i censes issued by the NRC should make every reasonable effort to maintain radiation exposures a low as reasonably achievable.. The recommended elements of an ALARA program are contained in Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures ALAR The licensee established a collective annual dose goal of 607 person-rem
- and an outage dose goal of 427 person-rem for Unit 1. On November 25, 1990, 52 days into a scheduled 60 day outage, collective dose was 484 person-rem*
for the year and 407 person-rem for the outag The inspector discussed the ALARA program with licensee representatives and reviewed exposure data for both outage and year. The inspector noted that collective dose is managed on a monthly basis with information distributed to station personnel on a daily and weekly basis. Reviews of ALARA meeting minutes indicated substantial improvements in management, supervisory, and worker participation in the dose reduction program. In 1989, the station *
assigned volunteers from the major departments as ALARA coordinators, to interface with the Station ALARA Committee. During the inspection, the inspector attended the ALARA Committee meeting for December. Each ALARA coordinator made presentations for their departments relative to status toward meeting their departments' monthly and yearly dose goal, discussed any dose reduction problems and successes within the department, and addressed department commitments for the ALARA action item list. The inspector noted that the coordinator presentations indicated the aggressive actions being taken to achieve their goals. Major jobs in progress were discussed in detail relative to the department's exposure reduction pla The inspector attended a job planning session for removal of a control rod drive mechanism to enable repair of the stationary coil. Personnel involved with planning uti 1 i zed the Videodisc Information Management System (VIMS) *
to review all aspects of the operation for estimating dose and performing the work. The inspector noted that the licensee had made enhancements to the VIMS to the extent of labeling in color major components, identifying valves, and displaying where the low dose areas were located at the job site. Licensee personnel stated that the system was used* during planning for the majority of work and the enhancements had been effective in reducing dose. The job was performed without incident and within the ALARA job estimate. RP videotaped the seldomly performed operation for use in future planning and incorporation into the VIM The inspector reviewed one of two ALARA goal variance reports issued in the third quarter of 1990. A variance report is required when a department exceeds a quarterly department dose goal by 15 percent. The report specifically identified the prob 1 ems encountered that caused the goal overrun and identified the parties responsible. The report also included lessons learned, and the measures necessary to recover and be under the goal. The inspector noted that this was indicative of good dose management and discussed other measures taken to effectively manage collective dos The use of trained advanced radworkers for major jobs, increased use of closed circuit television monitors, use of a valve packing extraction tool during valve repairs, increased use of mockups, were other methods being utilized to manage and reduce dos *
In early 1990, an RP ALARA engineer in conjunction with operations personnel conducted a process review to identify methods to reduce operating personnel dos The review encompassed all routine functions performed by operations personnel and identified better ways to perform system walkdowns, relocation of gauges on the boric.acid flats to low dose areas, system design deficiencies, and the increased need for remote television monitors, to reduce dose. Preliminary data shows a 50 percent reduction after implementing the recommendations identified in the process review. ALARA personnel also stated that by flushing radiation hot spots in piping a source term of 17.5 rem/hour was remove Additionally, the use of quick disconnect scaffolding in lieu of standard scaffolding save<;!
20 person-rem over past performanc Configuration Management Walkdowns to perform validation of all plant components historically have been high dose tas Time estimates were submitted by vendor personnel and the task was estimated* at 22.5 person-re~. ALARA personnel sought the help of a communications vendor to develop state of the art communications equipment for use in the tas The VIMS system was utilized for all planned operations. Only advanced radworker trained personnel were used in the performance of the walkdowns and the operation was performed for 4.5 person-re Licensee personnel stated that source term reduction items recently implemented were still being evaluated for results. The licensee reduced filter pore sizes to filter and reduce the size of radioactive cobalt
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particles in the letdown and reactor coolant system (RCS).
The licensee also performed hydrogen peroxide injection in conJunction with early boration of the RCS during Unit 1 shutdown. Some data was available to the inspector regarding the operation but comparative dose savings had not yet been determined. Licensee representatives stated that the program of Modified Lithium utilization had shown a slight reduction (10-15 percent)
in steam generator dose rates, and was expected to show a larger reduction in the future. The licensee has completed the replacement of fuel with zircaloy grid spacers in two thirds of the core in Unit 1 and will complete Unit 2 during the 1991 scheduled outage. Licensee personnel stated that during Unit 1 fuel inspection, two leaking fuel assemblies were found and removed from the cor The inspector discussed the ALARA Action Plan and Source Term Reduction Study with ALARA personnel. The corporate ALARA group developed the ALARA plan and the study in 1987. Sometime later both reports were combined into one document titled the 11 Five Year Exposure Reduction Plan.
Currently a number of dose reduction items contained in the plan are being pursued and have been implemented but as stated in the second draft of the plan the utility still does not have an approved strategic plan to reduce collective dose. The inspector stated a concern that the plan had not been approved and the 1991 budget had been approved and questioned what effect, if any, would there be for the inclusion and implementation of out of core source term reduction items in 1991. Station ALARA personnel indicated that the action items in the plan were recommendations and could not be sure what will be done in 1991 until the priority of items was established and the -
plan approve The inspector reviewed corporate information concerning the historically high dose at the utility's plants and their ranking within the industry regarding collective dos The conclusion drawn was that the utility was not being as aggressive as it should be in source term reduction efforts or in dose reduction efforts. The inspector discussed the issue with the Superintendent of Radiation Protection and the Plant Manager, and noted that the 11 Five Year Exposure Reduction Plan 11 was not approved and that some indicated source term reduction items scheduled for 1991 may not be performe.
Information Notices (92701)
The inspector determined that the following Information Notices (INs) had been received by the licensee, reviewed for applicability, distributed to appropriate personne 1, and that action, as appropriate was taken or scheduled:
11Update on Waste Form and High Integrity Container Topical Report Review Status, Identification of Problems With Cement Solidification, and Reporting of Waste Mishaps
.8 IN 90-33:
11Sources of Unexpected Oc:cupational Radiation Exposures at Spent Fuel Storage Pools
11Transportation of Type A Quantities of Non-Fissile Radioactive Materials 11 Exit Meeting The inspector met with licensee representatives denoted in Paragraph I at the conclusion of the inspection on November 30, 1990. The inspector summarized the scope and findings of the inspection. The inspector also expressed the concern regarding the failure to have the 11 Five Year Exposure Reduction Plan" approved. The licensee did not identify any such documents or processes as proprietar Dissenting comments were not received fro the licensee.