IR 05000338/1986027

Insp Repts 50-338/86-27 & 50-339/86-27 on 861111-21. Violation Noted:Failure to Establish,Implement & Maintain Procedures for Calibr of Alpha Survey Instrument

ML20212C122
Person / Time
Site:	North Anna
Issue date:	12/12/1986
From:	Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20212C084	List: IR 05000338/1986027 ML20212C081 ML20212C101
References
50-338-86-27, 50-339-86-27, NUDOCS 8612290396
Download: ML20212C122 (10)

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DEC 191986 Report'Nos.: 50-338/86-27and50-339/86-27 Licensee: Virginia Electric and Power Company Richmoqd, VA 23261 Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7 Facility Name: Ncrth Anna 1 and 2 Inspection Conductad: ovember 11-21, 1986 Inspector: t -

IM/L/ M4 B. K. Revsin N 1 Date Signed Accompanying Personnel: F. N. Wright , ,

Approved by: WVk_ lb//2/pf C. M. Hosey,NSectioq Chief _ Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection involved onsite inspection in the area of radiation protection and included: training and qualifications; external exposure control and dosimetry; control of radioactive materials and contamination, surveys and monitoring; solid wastes; internal exposure control

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and assessmer.c; and traqsportation of radioactive material Results: One violation - failure to establish, implement and maintain procedures for calibration of an alpha survey instrumen fpj2290396 a

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REPORT DETAILS Persons Contacted Licensee Employees

• E. R. Smith, Assistant Plant Manager

• A. H. Stafford, Superintendent, Health Physics

• 0. E. Hickman, Jr. , Supervisor, Health Physics

• R. F. Driscoll, Manager, Quality Assurance

• T. Bartlett, Senior Staff Health Physicist, Corporate Office

• J. Hellems, Director, Nuclear Security

• N. K. Martin, Supervisor, Security Operations

• T. Maddy, Supervisor, Security R. Newman, Training Instructor R. R. Irwin, Supervisor, Health Physics T.. Peters, Shift Supervisor, Health Physics C. Bradley, Assistant Supervisor, Health Physics E. Dreyer, Senior Staff Health Physicist H. F. Kahnhauser,- Assistant Supervisor, Health Physics F. T. Termine11a, Supervisor, Quality Assurance H. L. Hay, Quality Assurance Auditor R. T. Johnson, Supervisor, Surveillance Other licensee employees contacted included four technicians and two mechanic NRC Resident Inspector

• J. L. Caldwell, Senior Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on November 21, 1986, with those persons indicated in Paragraph 'I above. One violation, failure to

. establish, implement and maintain procedures to ensure calibration of an alpha survey meter (Paragraph 7), was discussed in detail. The licensee acknowledged the inspection findings and took no exceptions. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection. Licensee Action on Previous Enforcement Matters n

(Closed) Violation (50-338, 399/86-07-01) Failure to perform beta radiation surveys prior to steam generator entr The inspector reviewed the licensee's response dated September 5, 1986, and verified that the corrective action specified in the response had been implemente .

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(Closed) Violation (50-338, 399/87-07-03) Dose rates on the externa 1' surface of a package in excess of regulatory limit The inspector reviewed the licensee's response dated September 5, 1986, and verified that the corrective action specified in the response had been implemented. TrainingandQualifications(83723,83523)

During a previous inspection (Report No. 50-338/86-07), it had been noted that the licensee was in the process of developing an Advanced Radiation Worker (ARW) Training Progra At the time of the current inspection, approximately 50 individuals at the station had received ARW training. The company-wide Radiation Protection Plan, Chapter IV, Section 11.0, states that ARW training is to provide the level of awareness required for an individual to perfonn work in high radiation areas without continuous Health Physics (HP) Technician coverage or perform work on equipment or components containing radioactive material which could cause radiation levels in excess of 100 mR per hour. High radiation areas at the plant range from 100 mR per hour to 15 R per hou The inspector reviewed the ARW training program. The training consisted of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of classroom and laboratory study, eight hours of which were relegated to General Employee Training. Of the remaining 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />, eight were devoted to instrumentation, eight to radiation and contamination surveying, eight to air sampling and eight to general topics including incidents at other power plant An exam was administered for which 70 percent was considered passing. The training instructor estimated a 50 percent passage of the exam on the first attemp After completion of the course work the student is required to pass several Job Performance Measures (JPM) during which the student demonstrates competency in the skills learned during training by covering a simulated jo The JPMs require four to five hours for completion. Upon successful completion of the JPMs, the individual is considered a qualified AR Retraining is required annually. The licensee stated the ARW was not to be utilized to provide HP coverage for jobs but that the intent of the program was for the ARW to provide his own HP coverag The inspector interviewed an ARW who functioned as a member of a Quality Maintenance Team (QMT) during the last Unit 1 outage. The work was covered by Radiation Work Permit (RWP) No. 86-SP-883. August 30,1986-September 6, 1986, Replace 0-Ring on 1-RC-P-1B. The worker stated that he and two other QMT members decided prior to starting work that he would provide HP coverage for the job. A single survey meter was taken to the job site and the ARW carried out HP functions for the group which included performing radiation surveys and taking air samples. When this was discussed with the licensee, the licensee stated that each QMT member on a job was encouraged to cover himself, however, assigning one team member to provide HP coverage was not prohibite *

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-4 The ARW program was still in the preliminary stages in that extensive use had not yet been P= 7 of these individuals. The licensee anticipated that during the spring 1. 1 refueling outages, usage of'the ARW would expand in scop The inspector informed licensee management that several other utilities were implementing similar programs and that in all cases, more extensive training and experience were being required for qualification as an AR Additionally, in these programs, a lower ceiling was placed on radiological conditions under which these individuals could cover or perform wor The licensee stated that these factors would be considered in further implementation of their progra No violations or deviations were identified. External Exposure Control and Dosimetry (83724) Dosimetry 10 CFR 20.101(b)(3) requires licensees to determine an individual's accumulated occupational exposure to the whole body on an NRC Form-4 or equivalent prior to permitting the individual to exceed the limits of 10 CFR 20.101(a). The inspector reviewed selected cccupational exposure histories of individuals who exceeded the values in 10 CFR 20.101(a) and determined that exposure histories were' being ,

completed and maintained as require CFR 20.202 requires each licensee to supply appropriate personnel monitoring equipment and to require the use of such equipment. During tours of the plant, the inspector observed workers wearing thermoluminescent dosimeters (TLDs) and pocket dosimeters as require CFR 20.401(a) requires each licensee to maintain records showir.g the radiation exposures for all individuals for who personnel monitoring was required by 10 CFR 20.202 and that such records shall be kept on NRC Form-5 or equivalent in accordance with the instructions contained in that for Item 5, Instructions for Preparation of NRC Form-5, states that unless the lenses of the eyes are protected with eye shields having a tissue equiva}ent thickness of at least 700 milligrams per square centimeter (mg/cm ), dose recorded as whole body dose should include dose delivered2 through a tissue equivalent absorber having a thickness of 300 mg/cm or les The licensee had initiated studies to characterize the radiation field capable of producing measurable whole body dose between the density thicknesses of 300 and 1,000 mg/cm2 Theoretical considerations of a pure Sr/Y-90 beta field extrapolated to actual steam generator levels of Sr/Y-90 showed that only one to two percent of the beta field could be expected to contribute to whole body doses as measured between density thicknesses of 300 and 1,000 mg/cm2 Empirical verification of the theoretical treatment revealed some inconsistencies in that actual

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I measurements of count rates from a Sr/Y-90 source showed that 20 percent of the beta field was capable of producing measurable dose between density thicknesses of 300 and 1,000 mg/cm2, i.e., an amount considerably greater than that predicted theoreticall To resolve this discrepancy, the licensee stated that smears taken in various areas of the plant had been sent to a vendor laboratory for complete isotopic analyses. Upon receipt of these data, the licensee intended to perform calculations to verify their beta spectru In addition, .at the next refueling outage, beta attenuation studies on steam generator components were planned, RWP Program The licenseo had implemented at the beginning of November 1986, a new series of procedures for the RWP program. The inspector reviewed the following procedures:

HP-5.3.10, Radiation Work Permit Program HP-5.3.11, Radiation Work Permit Program Evaluation HP-5.3.12, Radiation Work Permit Records HP-5.3.20, Initiating, Using, Extending and Terminating a RWP HP-5.3.30, Preparing and Maintaining a RWP During tours of the facility the inspector noted several Standing RWPs in the Waste Solids area had expired. They were:

86-ST-5, Chem-Nuclear System Operations in Waste Solids 26-ST-23, Entry to Decon Building - Decon Equipment and Tools 86-ST-31, Surveys, Marking and Loading Rad Waste Shipments The licensee stated that Standing RWPs were written at the beginning of each year and were effective for a quarte In most cases, the Standing RWP (SRUP) was extended at the end of each quarter, the extension not to exceed one year in duration. Examination of the RWP Log Book showed that the above SRWPs had been extended and so documented in the HP office, the access control point and the log book so that only the copy at the jobsite had not been update The licensee stated that the last extension of the RWP had become effective prior to implementing the new procedures which required extension or termination of the jobsite copy and that at the beginning of the next quarter, this requirement would be incorporated into the RWP proces No violations or deviations were identifie .

6 Internal Exposure Control and Assessment (83725)

The licensee is required by 10 CFR 20.103, 20.201(b), 20.401, and 20.405 to control uptakes of radioactive material, assess such uptakes and keep records of and make reports of such uptakes. FSAR, Chapter 12, included coamitments regarding internal exposure control and assessmen CFR 20.103(b) requires that when it is impracticable to apply process or engineering controls to limit concentrations of radioactive material in air below 25% of the concentrations specified in Appendix B, Table-1, Column 1, other precautionary measures should be used to maintain the intake of radioactive material by any individual within seven consecutive days as far below 40 MPC-hours as is reasonably achievable. By reviewing records,

observations and discussions with licensee representatives, the inspector

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determined that the licensee maintained internal exposures well below regulatory limit No violations or deviations were toentifie . Control of Radioactive Material, Surveys, and Monitoring (83726, 83526)

Technical Specification (TS) 6.8.1 states that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A Regulatory Guide 1.33, Paragraph 8.a recommends that the licensee maintain procedures to ensure that tools, gauges, instruments, controls and other measuring and testing devices are properly controlled, calibrated, and adjusted at specific periods to maintain accurac During tours of the facility the inspector reviewed calibration stickers on '

various radiation survey instrument At the exit from the Radiation Control Area, an alpha scintillation counter (Eberline RM-20, Serial No. 737, and AC-3 probe) was present and an efficiency factor of 7.2 had been posted on its sid Through discussions with licensee representatives, the inspector determined that no calibration procedure (s)

or records were available for the instrument. A licensee representative stated that the alpha scintillation counter was not used as a quantitative measuring device but as a discriminator to assess whether alpha contamination was present on smears. If no activity was detected, the smear results were reported as nondetectable. If the alpha counting device indicated alpha activity on the smears, the smears were then quantified using a gas proportional counte Through a review of survey records, the inspector determined that Alpha Scintillation Detector No. 737, had been used to quantify alpha contamination lesel Survey records for the Auxiliary Building, Elevation 244, dated November 3,1986, showed that 150 counts per minute (cpm) had been registered by the above instrument, and that the cpm had been converted to disintegrations per minute (dpm) using the efficiency factor of 7.2 which was posted on the instrumen *

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Failure to establish, implement, and maintain procedures to ensure that Alpha Scintillation Counter No. 737 is properly controlled, calibrated and adjusted was identified as an apparent violation of TS 6.8.1 (50-338, 339/86-27-01).

The inspector performed independent radiation surveys in the auxiliary buildings, radwaste and decontamination areas of the licensee's facility and verified that the areas were properly posted and controlle . Solid Waste (84722, 84522)

10 CFR 20.311 requires a licensee who transfers radioactive waste to a land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.56. Technical Specification 3.11.3 requires a Process Control Program (PCP) for waste solidification. 10 CFR 20.311(d)(3) requires any generating licensee who transfers radioactive waste to a land disposal facility to conduct a quality control (QC) program which must include management evaluation of audit The inspector reviewed the licensee's procedures for classifying, packaging, and shipment of radioactive waste. The licensee had identified in station Audit Report No. N-86-14, PCP, the following deficiencies in the radioactive

, waste program:

Failure to follow procedures that required annual sampling and analysis of radioactive waste streams to ensure compliance with 10 CFR 61.55 requirement Failure to maintain procedures current. Mdintenance procedures had not been updated to reflect specific maintenance requirements and documentation as agreed upon by the licensee and NuPac Leasing, Inc. As a result, the licensee failed to perform a required leak test on a cask after a primary lid gasket had been replace Failure to follow procedure Documented evidence of the use of established procedures could not be found in station records for:

sampling and transferring the low level liquid waste tank transferring the contaminated drains tank placing the lab drain pump in or out of service Failure to implement procedural controls. The licensee had not established procedural controls to specify the frequency at which recirculation of the resin tank would be performed as was required by the PC Failure to maintain procedures current in that the method utilized by the licensee to package dry filter elements was not the method described in the PCP manua *

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The inspector did not identify any additional deficiencies in the radioactive waste progra Failure to develop, maintain, and follow procedures for the solid waste program as described above would normally be considered a violation of the requirements of 10 CFR 20.311, and 10 CFR 61 and the licensee's Technical Specifications. However, the NRC Enforcement Policy,10 CFR 2, Appendix C, 1986, states that a Notice of Violation will generally not be issued for violations identified by the licensee, if (1) it was identified by the l licensee; (2) it fits in Severity Level IV or V; (3) it was reported, if I required; (4) it was or will be corrected, including measures to prevent recurrence, within a reasonable time; and (5) it was not a violation that could reasonably be expected to have been prevented by the licensee's corrective actions for a previous violation. The apparent violations listed above meet the criteria specified in 10 CFR 2 Appendix C and consequently, are considered licensee identified. The inspector stated that the implementation of the yet completed corrective actions would be reviewed during future inspections (IFI 50-338,339/86-27-02).

No violations or deviations were identified. Transportation (86721,86740)

10 CFR 71.5 requires that licensees who transport licensed material outside the confines of its 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 (D0T) in 49 CFR Parts 170 through 18 The inspector observed the preparation of a shipment involving 96 containers of dry active waste (DAW). The inspector reviewed the procedures under which the shipment was made and the resulting documentation. The inspector reviewed selected records of radioactive waste shipments performed during 198 The shipping manifests examined were prepared consistent with 49 CFR 170-189 requirements. The radiation and contamination survey results were within the limits 'specified for the mode of transport and shipment classificatio No violations or deviations were identified.

10. Audits (84722, 86721, 86726, 86725, 86728)

A Quality Assurance (QA) program is required for transportation of radioactive materials and for transport of packages in accordance with the provisions of 10 CFR 71, Subpart H. The licensee elected to apply their established 10 CFR 50, Appendix B QA program to the packaging and transportation of radioactive materials to fulfill the requirements of 10 CFR 71, Subpart In addition to the general QC provisions required by 10 CFR 50, Appendix B, specific QC requirements to assure compliance with 10 CFR 61.55 and 61.56 are required by 10 CFR 20.31 F"

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9 Quality Assurance The inspector reviewed the licensee's Topical Report and QA administrative procedures. The inspector determined that although the licensee conducted periodic audits of the PCP program as required by TS 6.5.3.1, which included various aspects of the transportation program, the licensee did not have routine audits scheduled for other health physics activitie The inspector reviewed three audits that had been performed in the radiological protection area within the last two years which included two Process Control Program (PCP) audits, N-85-17 conducted in August 1985 and N-86-14 conducted in October 1986. The third audit entitled, Health Physics Dose Control, N-85-06, was conducted in April and May 198 The PCP audits appeared adequate in scope and reported numerous program findings that were administrative in natur Details on PCP audit N-86-14 are included in the Solid Waste section of this report, Paragraph 8. The Dose Control audit addressed the following program '

areas: ALARA, radiation work permits, external exposure control, respiratory protection, internal dosimetry, and instrumentatio Checklists utilized by the licensee for the above audits were reviewed and were found to be primarily administrative in nature rather than technically orientate The corrective action program for identified findings appeared to be functioning in a timely manner with adequate documentation of corrective action taken. Records reviewed by the inspector indicated that audit findings were closed only after the QA staff verified completion of the corrective actio The inspector reviewed the qualifications of the auditors conducting radwaste and radiation protectior audits and surveillance All auditors reviewed had been certified in accordance with the requirements of ANSI N45.2.23. The licensee utilized a lead auditor to conduct the radiological protection and PCP audits who had formal health physics training and on-the-job-training as a health physics technician, Quality Control The inspector reviewed approximately 20 of the licensees QC surveillances in the areas of radiological protection and radwaste which included health physics portable friskers and portable monitors, postings, radiation surveys, the high range calibration facility, 10 CFR 19 posting requirements, and radioactive waste shipmen The inspector noted that the licensee had not established a schedule for surveillances and that surveillance reporte and checklists were brie At the time of inspection the licensee was developing checklists which

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were _of expanded scope and greator detail regarding what was to be reviewed on a specific surveillanc No violations or deviations were identifie .