IR 05000338/1988003

Insp Repts 50-338/88-03 & 50-339/88-03 on 880314-18.No Violations or Deviations Noted.Major Areas Inspected:Util Program to Maintain Occupational Radiation Exposures ALARA

ML18152B093
Person / Time
Site:	Surry, North Anna, 05000000
Issue date:	08/11/1988
From:	Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18152B092	List: IR 05000338/1988003 ML18152B091 ML18152B094 ML18152B095
References
50-338-88-03, 50-338-88-3, 50-339-88-03, 50-339-88-3, NUDOCS 8808240271
Download: ML18152B093 (19)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, ATLANTA, GEORGIA 30323

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AUS 1. "" 1988 ENCLOSURE 2 Report Nos.:

50-338/88-03, 50-339/88-03 Licensee:

Virginia Electric and Power Company Richmond, VA 23261 Docket Nos.:

50-338, 50-339 Facility Name:

North Anna License Nos.:

NPF-4, NPF-7 Inspection Conducted:

Marc~l4-18, 1988 Team Leader: ~,-.., 6:J:,-c'=, *

R. E. Weddiri{it n

\\

Team Members:

T. Collins Accompanying Approved by:

R. Shortridge F. Wright Personnel:

D. Collins C.) Hosey r)

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C,-1/l /)/ t V

C. M. Hos y, Section Chief Division of Radiatio Safety and Safeguards SUMMARY Date Signed Date Signed Scope:

This was a special, announced assessment in the area of licensee 1s program to maintain occupational radiation exposures as low as reasonably achievable (ALARA).

Results:

The licensee now has in place the elements of a successful ALARA progra Continued support and involvement of management is required if the program is to be successfu However, several weaknesses were identified in the ALARA program that should be addressed to ensure that collective annual personnel radiation dose is reduced to the maximum extent possibl These weaknesses were in the areas of:

Exposure goal formulation, Paragraph Contractor craft proficiency and dose projection, Paragraph Radiation work permit hold program Paragraph Number of containment power entries, Paragraph ALARA Action Plan implementation schedule, Paragraph ~

Within the areas inspected, no violations or deviations were identifie ~I

• Persons Contacted Licensee Employees REPORT DETAILS T. Banks, Health Physics (Corporate)

L. Boggs, Chemistry Supervisor P. Bradley, Shift Technical Advisor R. Clark, Plant Engineer

• R. Driscoll, Quality Assurance Manager

• M. Gettler, Engineering and Construction Manager

• W. Harrell, Station Manager

• L. Hart, Instrument Supervisor E. Hendrixson, Surveillance and Test Engineering Supervisor T. Johnson, ALARA Coordinator T. Johnson, Quality Assurance Supervisor

• M. Kansler, Superintendent Maintenance

• G. Kane, Assistant Station Manager

• J. Leberstien, Licensing Engineer

• C. Michadick, Training Supervisor

• G. Milla, Licensing Coordinator (Surry)

• D. Roth, Nuclear Specialist

• A. Stafford, Superintendent Health Physics A. Stall, Superintendent Operations

• V. West, Planning and Scheduling Supervisor Other licensee employees contacted included engineers, technicians, maintenance and office personne Nuclear Regulatory Commission J. L. Caldwell, Senior Resident Inspector

• L. King, Resident Inspector

• Attended exit interview Exit Interview (30703)

The inspection scope and findings were summarized on March 18, 1988, with those persons indicated in Paragraph The inspector described the areas inspected and discussed in detail the inspection findings (see Paragraph 9).

The licensee acknowledged the inspection findings and took no exception The licensee did state it was their position that the number of containment power entries was appropriat The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection.

• 2 Background (83528/83728)

In 1987, the North Anna collective radiation dose was 760 person-rem per unit, which was 106 percent over the national average for pressurized water reactor Since 1981, the first full year with both Units 1 and 2 in commercial operation, North Anna significantly exceeded the national average for three separate year In 1982, the licensee began developing a Virginia Power Exposure Reduction Progra Formal implementation of the program began on January 1, 198 The exposure reduction was one element in an overall program for upgrading the radiation protection program at the licensee 1s nuclear station.

Program To Maintain Radiation Exposures ALARA (83528/83728)

Prior to April 1987, the station 1 s ALARA program was defined in the Station ALARA Manual (SAM).

In April 1987, the SAM was replaced with a series of procedures which will be essentially the same at the licensee 1s two nuclear station The following procedures which implement the station ALARA program were reviewed by the inspector:

HP-5.4.10 HP-5.4.11 HP-5.4.12 HP-5.4.20 HP-5.4.30 HP-5.4.40 HP-5.4.60 HP-5.4.70 Organization (1)

Staff Station ALARA Program ALARA Program Evaluation and Reports ALARA Program Records Station ALARA Committee ALARA Pre-job Planning and Post-job Reviews ALARA Suggestion Program Design Change ALARA Review Determining and Tracking ALARA Goals The licensee 1s ALARA organization consisted of a permanent staff of an ALARA coordinator (supervisory level), reporting to the Station 1s Superintendent of Health Physics, a licensee health physics technician and two contractor technician The inspector reviewed the staff members experience and qualifications and determined that they met the technician qualification requirements of ANSI 3.1 and had extensive applied health physics experienc (2)

Review Committee The licensee established a Station ALARA Committee in 198 The following year, the committee was reorganized to place emphasis on management participatio The Assistant Station Manager -

Operations was assigned to chair the ALARA Committe Maintenance Superintendent, HP Superintendent and department representatives from Operations, Engineering, Instrumentation,

• Maintenance, Engineering and Construction, Planning and Quality Assurance/Quality Control are members of the ALARA Committe The Committee routinely meets on a monthly basis to review the station's success in keeping dose within the dose goals, ALARA suggestions, preplanned jobs with estimated doses greater than 10 person-rem and post-job reviews of jobs with doses greater than 25 person-re The inspector reviewed the minutes of the Station ALARA Committee meet1ngs held during the period January 1986 through February 198 The minutes indicated that each suggestion had received a thorough review and the reasons for acceptance or rejection of the suggestion were state The inspector discussed with licensee representatives the omission from the minutes of the Committee documentation of discussions regarding exceeding dose goals or job dose estimates in terms of lessons learned and remedial actions.. Licensee representatives stated that such topics were discussed in their meetings and acknowledged that the minutes could be ~nhanced by including documentation, in the meeting minutes, of root causes for exceeding dose estimates and recommended preventive actions take Work Reviews Licensee procedure HP 5.4.30, ALARA Pre-job and Post-job Reviews, April 9, 1987, required pre-job reviews by the ALARA staff for work in which the collective dose estimate exceeded one person-re A Station ALARA Committee review was required for work estimated to exceed 10 man-rem, and a review for Corporate ALARA Coordinating Committee for work estimated to exceed 50 person-re In determining if a job met the guidelines for each level of review, radiation work permits (RWPs) authorizing work contributing to a specific task, such as steam generator sludge lancing, were considered collectively rather than individually to ensure that appropriate reviews were not overlooke The inspector selectively reviewed pre-job reviews performed during 1987, and ve~ified that appropriate dose control techniques and lesson learned from prior similar work were considered during the review During 1987, 86 percent of the station's dose was received from work that had been preplanne The licensee's procedure required post-job ALARA reviews by the ALARA Coordinator for work with actual collective dose greater than one person-rem and which exceeded the estimated dose by 25 percent, that required two or more revisions to the dose estimate during the course of the work, that had a total actual collective dose greater than ten person-rem, or as deemed necessar However, as a good practice, the ALARA Coordinator stated that post-job reviews were performed for all preplanned work, if possibl The Station ALARA Committee also performed post-job reviews for work requiring greater than 25 person-re The inspector selectively reviewed documentation of

• post-job reviews performed during 198 The inspector verified that reasons for exceeding dose estimates or lessons learned, as appropriate, were specified on the review Radiation Dose Goals Station procedure HP 5.4.70, Determining and Tracking ALARA Goals, April 9, 1987, described the process used by the 1 i censee to establish department collective dose goal The goals were based on the average dose received during the current and two preceding years in terms of average dose for an outage and _ nonoutage da The station annual collective dose goal was formulated in a similar manne For 1988, the station's dose goal was 8.830 person-rem for an outage day and 0.355 person-rem for a nonoutage da The licensee projected there would be 48 outage and 318 nonoutage days in 1988, for a total goal of 537 person-re As of March 14, 1988, the station's actual dose was 57.775 person-rem, which was 220 percent of the licensee's projection to that date of 26.270 person-re The reasons for the excesses were attributed to unanticipated forced outages such as repairs to the Unit 1 Reactor Coolant Pump sea On February 26, 1988, the station manager established an interim reduced nonoutage dose goal of 0.200 person-rem per day until the collective dose was reduced to within the projectio The inspector discussed the management of daily dose goals with licensee representative Generally, department mangers ensured conformance with the daily dose goal by deferring work until they had enough exposure saved to allow performance of the work or, if the work could not be deferred, as in the case of forced outages, the excess over the projection was attempted to be made up for on succeeding day The inspector observed that meeting the daily exposure goal does not necessarily ensure that the exposure received is ALARA since it does not take into account the tasks that are performed each day, which may be highly variabl Supporting this observation was information gathered from interviews with first-line supervisors and workers which indicated they were generally unfamiliar with their department's dose goal or dose goals for their routine activitie Formulation of task specific goals would permit the personnel who actually received the exposure to contribute toward accomplishment of the goal and would provide a better perspective for managers on the ALARA status of the station's exposur Job Histories The inspector discussed with licensee representatives historical job exposure data that was available for review when preplanning radial ogi cal wor The Personnel Radiation Exposure Management Sys tern ( PREMS) computer data base permitted the generation of a listing of all RWPs and associated summary exposure data for all work performed on a given system or location since 198 The RWP listing was cross referenced to the ALARA review control number for the jo * *

This control number could be used to access a hard copy file of all of the documents associated with that RWP, such as, the RWP request, the RWP and forms used to document the exposure estimate, pre-job review and post-job revie The inspector reviewed the job history file for the installation and removal of the disc pressurization rig in Unit 2 containment under RWPs 87-2-2382 and 303 The inspector noted that the files contained useful information for the planning of similar task, although the RWP and RWP request for RWP 87-2-3037 were missin Licensee representatives stated they would develop a checklist to assist in ensuring that the relevant documents were included in the job history file before the file was sent to document contro Hold Program Licensee procedure HP 5.4.30, ALARA Pre-job and Post-job Reviews, April 9, 1987, required that the applicable department be notified when RWPs reach 100 percent or more of projected exposure and that a hold be placed on RWPs when accumulated exposure exceeds 125 percent of projection. The licensee 1s ALARA staff generated a daily computer printout showing the dose status of each RW A flag appeared on the printout for RWPs when the actual dose had reached the dose estimat When the actual dose reached 125 percent of the estimate, a flag and message was printed which stated that a hold was required to be placed on the job until the dose estimate could be reevaluate The inspector reviewed the daily RWP dose status report for March 14, 1988, and noted that RWP 88-1-0026, General Entry Unit 2 Reactor Containment Mode 1 and 2, was listed as having an dose estimate of 774 millirem and an actual dose of 1,906 millire The RWP was flagged with the statement:

11Job supervisor caution. - 246 percent of projected dose expende RWP hold require Contact station ALARA coordinator immediately.

The RWP had not been placed on hol Licensee representatives pulled the file for the RWP and determined that the dose had exceeded 125 percent of the estimate on January 5, 1988, and that subsequent entries had been made under the RW The inspector then reviewed a *listing of RWPs with effective dates between July 1, 1987, and March 15, 1988, and noted that there were an additional 36 RWPs that had been flagged as requiring a hold because the actual dose was greater than 125 percent of the estimat Licensee representatives stated that they* had no means of demonstrating that holds had been placed on those RWP Licensee representatives stated that they would evaluate means of enhancing their program in this are Personnel were logged onto RWPs at the controlled area entrance by health physics personnel using a computer terminal which accessed the licensee 1s PREM Licensee representatives stated it may be possible to provide an automatic lock to prevent personnel logging in on RWPs that were in excess of the estimate.

6 Licensee Initiatives The development of the licensee's ALARA program has been evolutionary with implementation of a number of improvements since its formal implementation in 198 The licensee developed a photo album of routine work locations to provide documentation of equipment locations and to facilitate pre-job briefing In 1987, the licensee began installing a computerized videodisc information management system {VIMS) to replace the photo librar The VIMS, when fully implemented, will enable individuals to observe any plant location by way of videodis In 1986, the licensee began using television monitors {video bulletin boards) installed at the station to promote ALARA awareness periodically displaying ALARA informatio In 1987, station ALARA procedures were revised to bring the procedure into agreement with the licensee's radiation protection plan approved in 198 The intent of the revision was to enhance the program by increasing visibility for the ALARA program, provide better accountability and responsibility*for dose expended and to improve the daily implementation of the ALARA progra Also in 1987, the licensee's Corporate ALARA group completed a ALARA Action Plan and Source Term Reduction Stud This stu~y specified initiatives to reduce collective dose The action items have personnel assigned as responsible for completio However, target dates for completion have not been established to ensure the timely complet'ion of the action items, nor have milestones been established to track progress in completing the action item.

Performance (83528/83728)

In discussions with the inspector, licensee representatives stated that unscheduled outage days in 1987, due to a steam generator tube rupture, as well as efforts by the station.staff to eliminate leaking valves and components and to decontaminate as much of the plant as p'ossible, contributed to the collecti~e dose exceeding the national averag The sections below discuss the station I s performance on reducing collective dose for a number of repetitive task Exposure Performance on Repetitive Work The inspector discussed with licensee representatives their ability to apply lessons learned from previous jobs in order to reduce collective dos Using the licensee's PREMS computer, exposure data from three repetitive tasks performed during refueling outages were obtaine *

Job:

Repack RHR Valves in "A" Cubicle Year Person-Rem Man-Hours 1984 1.092

1985 0.715

1985 0. 722

1985 1.063

1986 1.015

1986 1.396

1987

,2,425

Job:

Remove Unit 1 11C 11 Steam Generator Manways Year Person-Rem Man-Hours 1984 0.168

1985 0.905

1987 0.240

Job:

Install Unit 1 IIBII Steam Generator Diaphragm Year Person-Rem Man-Hours 1982 1.308 364 1984 0.808 143 1985 0.845

1987 1.406

The inspector discussed this data with licensee representatives. The man-hour data did not appear to correlate well with the corresponding person-rem dat Licensee* representatives stated that th~ man-hour data from PREMS was the total amount of time between a worker 1s entry and exit from the controlled area which may be considerably longer than the time actually spent in a radiation area at the job sit Licensee representatives stated that some of the jobs discussed above with higher doses in 1987, had been performed by contractors whereas the work had been performed during previous outages by 1 i censee personne The inspector reviewed the preplanning package for the 1987, steam generator diaphragm installation wor The work had an initial approved dose estimate of i.016 person-rem, which was approximately 20 percent higher than the average amount of dose the 1 i censee had use*d the two previous occasi ans when performing the work themselve The licensee indicated that the dose estimates for the work in 1987, was found in information provided by the contracto Licensee representatives stated that they would review dose estimates for contractors for consistency with the licensee 1 s exposure history for the wor * *

NUREG/CR-4254 The inspector reviewed NUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power Plants:

Study on High-Dose Jobs, Radwaste Handling, and ALARA Incentives, April 1985, with licensee ALARA personne 1 *

NUREG/CR-4254 contains data on doses experienced throughout the industry for typical high dose job The inspector compared the licensee's exposure history for several of those jobs described in the NUREG as indicated in the following table:

Job Unit S/G Tube U-1 Plugging U-2 Reactor U-1 Disassembly, U-2 Assembly and Fuel Sipping S/G Manway U-1 Remove/Replace U-2 S/G Sludge U-1 Lancing and U-2 Inspections Cavity Decon U-1 U-2 ISI and U-1 Remove/Replace U-2 Insulation Snubber Inspection RHR Repair and Maintenance Scaffolding U-1 U-2 U-1 U-2 U-1 U-2 Licensee Exposure

86

51.995 51. 354 10.808 9.117 4.505 75.423 48.348 1.125 5.958 4.347 49.535 17.398 6.246 2.389 30.275 27.386 1.059 6.895 19.884 24.193 47.228 47.206 5. 775 13.345 11. 598 7.297 3.387 3.745 94.872 3.745 55.717 38.260 4.363 2.624 12.045 14.379 NUREG/CR-4254 Avg

57

11

64 110

30 The inspector determined that for most of the jobs reviewed, the licensee's dose performance compared favorable with the industry averages indicated in NUREG/CR-4254 (1974-1984 data).

• 9 Containment Power Entries The inspector discussed with licensee representatives entries made by personnel into containment with the reactor at power which have beeri made since 198 The number of entries and exposure received each year were as follows:

Year No. of Entries 1983 1984 1985 1986 1987 1988 (as of 2/88)

280 220 349 267 193

Total Person-Rem 34.795 28.969 16.755 22.920 12.101 2.583 The licensee has a subatmospheric containment and personnel making power entries are required to wear self-contained breathing apparatuses (SCBAs).

Entries were typically made to perform survei 11 ances and to respond to operating con di ti ans such as to investigate unidentified reactor coolant leakag During the personnel interviews, some individuals stated that entries had been made during power ascension following an outage to perform maintenance on valves that had been overlooked during the outag Indications that the justification for each entry may not have been critically reviewed was that entries were made on a standing RWP and for such entries shift personnel could authorize the entry. Also, as discussed previously, one of the. standing RWPs for power entries was well in excess of its estimated exposure and had not been placed on hold for several month The inspector discussed with licensee representatives the reduction in the number of containment power entrie Licensee representatives acknowledged that proper planning could eliminate entries for overlooked-work, but seem doubtful that significant reductions were possibl.

Dose Reduction Initiatives H1gh Radiation Areas (HRAs)

The inspector reviewed radiation survey records for the licensee 1 s HRA The 1 i censee controlled 17 HRAs with dose rates between 100 and 1,000 mi 11 i rem/hour and 15 HRAs with dose rates greater than 1,000 millirem/hou The number of HRAs controlled by the licensee was comparable to other PWR However, the 1 i censee planned to conduct a study of the number and reasons for entries into the HRAs with a goal to either reduce the number of entries and/or reduce the ambient dose rates in the are *

10 Chemistry Control (1)

Reactor Coolant pH Control In a letter to the licensee*s fuel vendor dated January 27, 1988, the licensee requested that the fuel vendor consider approval to operate the North Anna plant with an increased reactor coolant system pH of The licensee made the request based on data obtained from evaluations at the Ringhals site in Swede Licensee representatives stated that they are convinced that a reduction in out of core radiation levels may be achieved by increasing the reactor coolant p The method for increasing the reactor coolant pH and maintaining a constant pH of consist of maintaining a constant lithium concentration of approximately 3.5 parts per million (ppm) lithium-7 from the beginning of core life (900 ppm boron) and to gradually increase the system pH to approximately 7. This point occurs at a boron concentration of 650 ppm (approximately 30-60 days into the cycle).

From this point in core life, the system pH is maintained at 7.4 by employing a coordinated boron-lithium progra The initial system pH using this approach is approximately This approach to reactor coolant chemistry control is reported to be effective in lowering primary coolant system corrosion rates and in reducing out-of-core radiation field Evaluations have been documented in Electric Power Research Institute (EPRI) reports which indicate that operation with system pH values greater than 7.3 result in a zero or slightly positive temperature coefficient of solubility for cru Any corrosion products formed at this pH would have a tendency to deposit on cooler system surfaces and not in the core region where they would become activate Reduction of radiation levels in Steam Generator channel head centers have been experience This program if approved and successful should reduce station personnel doses, and radwaste volumes generated and shippe (2)

Reactor Coolant Filters The licensee was evaluating the use of sub-micron filters for reactor coolant, on-line cleanu The sub-micron filters were to be installed on the Spent Fuel Pit (SFP) and Primary Mix Bed (PMB) demineralizer filter system Initially a 6 micrometer (um) filter will be installed and their filter sizes will be progressively decreased to the sub micron range in order to allow for removal of smaller sized particulates.

The inspector reviewed an Engineering Work Request (EWR)

No.88-033, dated February 4, 1988, which was approved for the *

installation of the new filter elements which will provide better filtration than the existing filter element The new 6 um and 1 um filter elements will remove much finer material than the existing*3 um nominal filter element By removing finer material, the incidence of 11Hot Particles 11 should be reduced, as well as the overall crud product activity in the Reactor Coolant System (RCS) to be cleane This reduction of 11Hot Particles 11 and Crud Activity levels in the RCS should enhance the licensees success in achieving its ALARA goal (3)

Hydrogen Peroxide Shock The licensee was evaluating the use of hydrogen peroxide to shock (i.e., controlled crud burst by chemical addition) the reactof coolant primary system which would oxygenate the reactor coolant system (RCS) and help remove Co-58 and Co-60 at Mode 5 operation, with the RCS at less than or equal to 200° The procedure normally used by the licensee during RCS cool down prior to refueling outages calls for the addition of hydrogen peroxide while the system is solid to promote a controlled crud burst. This procedure had been deviated from save clean-up time during the two previous refueling outages by performing the hydrogen peroxide addition after the RCS has been drained to mid-nozzl Unit 1 data collected by the licensee indicated that there has been a substantial decrease in the amount of soluble activity available for purification after the crud burst occurs when the hydrogen peroxide addition is performed in this matte In addition, radiation levels in the steam generator channel heads of both units have recently increased indicating a possible relationship between the manner of oxygenating the RCS prior to refueling and out-of-core dose rate Fuel Integrity The licensee had experienced fuel failure in Unit 1 during Fuel Cycle 4 from November 1982 to May 198 Vacuum sipping performed following Cycle 4 discovered that 17 failed fuel assemblies contained 25 failed fuel pin The failure mechanism was determined to be debris-induced frettin A single failure was indicated in Unit 1 Cycle 5, during September 1984 to November 1985, but the data indicated that the assembly was in the fuel scheduled to be*

discharged and an examination of the fuel was not conducte Unit 1 Cycle 6 during December 1985 to April 1987, contained two failed fuel assemblies, each with one failed fuel pi The failures were found using UT testing and the failure mechanism was determined to be baffle jetting. The current fuel cycle, Unit 1, Cycle 7, April 1987 to present, appears to have no failed fue Unit 2 Cycle 3, during May 1983 to *August 1984, had four failed fuel assemblies discovered

'.

using vacuum sipping following Unit 2 Cycle No other fuel failures have been found in Unit 2 which is currently in Cycle The licensee has implemented a fuel integrity monitoring and chemistry measurement evaluation program which includes allowable levels of dose equivalent 1-131 (DEI) in the Primary Coolant Syste The DEI is monitored on a daily basis, under equilibrium and transient conditions, with respect to the technical specification limit of one mi crocuri e per m,il l il iter (1 uCi /ml).

This was accomplished through the use of a computer code, which plotted the daily iodine isotopic concentrations in the primary coolant system, based on measurements performed by station chemists, and calculated the DE During refueling outages the licensee performed analysis of each fuel assembly that was suspect of fuel degradatio After these tests were performed (ultrasonic test) and the fuel assembly had been determined to be defective, the entire fuel assembly was replaced by a new fuel assembly known not to be defectiv All of the fuel assemblies that were determined to be defective were later reconstituted by replacement of individual fuel pin Ambient Radiation Levels in Auxiliary Building During tours of the facility, the inspector performed radiation surveys in the Auxiliary Buildin The ambient radiation level in main passageways appeared to be generally in the range of 1 to 3 mi 11 i rem/hou The inspector noted that many areas were posted with radiation area signs indicating general area radiation levels were elevate The inspector determined that the ambient radiation levels in the Auxiliary Building appeared.to be higher than one normally encounters at nuclear power stations and discussed this observation with licensee representative Part of the. cause for these dose rates appears to be that systems which may be enclosed at other facilities are located in open spaces, such as the pipe penetration are Licensee representatives stated they have attempted to reduce ambient radiation levels by identifying and

• flushing hot spots and by cleaning tanks on an established schedul The inspector also observed the use of shadow shields around components with elevated radiation level Other Licensee Initiatives The licensee has purchased and installed video cameras and monitors for the purpose of providing. remote observati ans of some high radiation area In addition, the licensee began using surveillance mirrors to observe equipment behind _shield wall In 1983, the licensee began considering the installation of permanent reactor head shield The head shields were installed in Units 1 and

2 in 198 The head shie1ds resu1ted in dose rate reductions near the rea~tor vesse1 head of 50-60 percen In 1985, a review of historica1.data at North Anna and Surry was performed to identify dose intensive tasks to generate a candidates 1ist for the deve1opment of specific radiologica1 work practice The work practices were designed to describe methods and techniques to perform radio1ogica1 work activities and reduce dose to radiatio Radio l ogi ca 1 work practices were deve 1 oped* for snubber inspection/maintenance, eddy current activities and reactor head removal/rep1acement activitie In 1985, the 1icensee insta1led a system to fi1ter materia1 entering the f1oor drains in radiologica1ly contro11ed areas to prevent hot spot formation-in radwaste system pipin The licensee identified and removed a number of 1arge bore snubbers for steam generator and reactor coolant pump supports which required a large expenditure of radiation dose to maintai The licensee began using extended life (10,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> rated) 1ight bu1bs in the reactor auxiliary bui1din An evaluation revea1ed that a savings of 2 person-rem annually would be realized by the rep1acement of existing lighting with extended 1ife 1ight bulb In the second quarter of 1987, the station procurred a multi-stud tensioning/detensioning syste In addition, va1ve packing was rep1aced with superior live-load packing, on selected valves to reduce 1eakage and contamination of areas and reduce the maintenance/radiation dose required for the 1ess re1iable valve packin A request for an engineering study was submitted to engineering and construction for cobalt rep1acement in primary valve The study was to investigate means of eliminating coba1t-bearing stellite from va1ves to reduce out-of-core dose rate Comp1etion was schedu1ed for Ju1y 15, 198 At the time of the assessment, the licensee had the following initiatives underway:

Corporate ALARA was representing Virginia Power on an ad hoc committee with other uti1ity representatives to work with Westinghouse E1 ectri c Corpora ti on in development of a full reactor coo1 ant _system decontamination progra In March, Westinghouse E1ectric Corporation issued a proposed list of engineering eva1uations to be performed for materia1 eva1uations (chemica1 reactions with plant systems) necessary to grant fina1 approval for the decontamination progra Severa1 years may be required before all engineering eva1uations are comp1ete and fina1 approva1 is grante *-

North Anna was performing a pilot program i nvol vi ng enhanced filtration to lower out-of-core activit The test was being conducted on the spent fuel pit water using *the refueling purification system filter housings with sub-micron sized parti-cle If testing proves successful in lowering Co-60 levels in the pool water, consideration would be given to using the filter elements in the primary coolant purification syste Training in housekeeping during valve maintenance to prevent migration of cobalt into piping system Replacement of inconel fuel grids with zircaloy grids to reduce incore cobalt sources during next refuelin Establish a priority list of valves with high cobalt/stellite content to be replaced with valves that contain little or no cobalt/stellit.

Interviews (83528/83728) Employee I~terviews Licensee employees were* interviewed to' assess their knowledge, involvement, and perspective of the uti 1 ity I s ALARA Progra An ALARA questionnaire was prepared prior to the inspection and was utilized during each interview to ensure each employee's ALARA awareness and involvement was evaluated uniforml The employee questionnaire was prepared to evaluate the employee's knowledge of ALARA goals, concepts, policies and procedure documents; individual responsibilities, personal doses and personal dose limits; the employees involvement in special ALARA training, communication with co-workers and supervision, and participation in the ALARA suggestion program; and the employees perspective on how to improve the ALARA program, what events or conditions have caused increased personnel doses, and what events or conditions had helped reduce personnel dose (1)

Employees All employees interviewed entered the radiological controlled areas on a daily to weekly basis depending on plant condition (2)

Knowledge of ALARA Program Each of the employees interviewed was familiar with the basic ALARA concepts taught in the General Employee Training (GET)

program and knew that they had a basic responsibility for imple-menting the utilities ALARA program by performing tasks in a manner consistent with the utility's ALARA polic In general the employees knew their current radiation exposure and their

'**

exposure limit. The employees had a poor understanding of where the ALARA requirements originated or what corporate and plant documents described the ALARA program objective Most of the employees interviewed did not know their section's ALARA goa (None of the Mechanical Maintenance personnel interviewed knew their ALARA goal..)

However, the employees did know that they could find out their section's goals from the ALARA staf (3)

ALARA Program Involvement The majority of employee's interviewed had not received any ALARA training other than that given in the GET cours A majority of those interviewed had received some informational ALARA training on jobs requiring ALARA pre-job planning and on-the-job trainin The employees reported frequent discussions of ALARA objectives on major jobs during outages with coworkers and supervisor The employees also reported good communications with the ALARA and Health Physics staff Only a small fraction of employees interviewed had participated in the formal ALARA suggestion progra Other employees reported that they had made suggestions to supervisors informally and had not used the formal ALARA suggestion program believing it was only for "significant ALARA suggestions."

(4)

Perspective Only a couple of employees had suggestions on how the ALARA Program could be improve The suggestions included better plannihg of work to ensure appropriate equipment and tools were readily available and use of work gloves that could allow a mechanic to perform fine work expeditiousl Neither suggestion had been submitted to the ALARA suggestion program by the interviewed employee The majority of employees had opinions on things that had contributed to decreases and increases in personnel exposure Employees believed that the following actions had contributed to exposure reducti ans:

use of temporary shielding, special tools, permanent shielding such as the reactor vessel head shielding, reduced work activities in high radiation areas from better job evaluations, flushing of various system components and lines, increased ALARA staff with job followup, implementation of the hot particle program and the training received in.the Advanced Radiation Worker Training progra Employees believed that the following actions had contributed to increases in personnel exposures:

poor maintenance scheduling in the past, operating with failed fuel during the 1983 through 1985 period, and an inexperienced mechanical maintenance staf The employees stated that the mechanfca l maintenance staff was now more experienced and the problem was not as great as in previous year One employee reported that in the past work had been scheduled to be completed during a startup in the containment building under

adverse conditions and in higher radiation field The employee believed a lack of planning and the urgency to get th~ plant back up on line had been the reasons for the work occurring during startu Management Interviews Licensee managers and supervisors were i ntervi_ewed to assess their knowledge of the utilities ALARA Progra An ALARA questionnaire for managers and supervisors was prepared prior to the inspection and was utilized during each interview to ensure each manager and supervisor's ALARA awareness and involvement was evaluated uniforml The manager and supervisor's questionnaire was prepared to evaluate the manager's or supervisor's knowledge of ALARA goals, concepts, policies and procedure documents, individual-responsibilities, personal exposure, and personal exposure limits; the manager or supervisor's involvement in special ALARA training, communication with coworkers and supervision,- and participation in the ALARA suggestion program; and the manager or supervisor's perspective on how to improve the ALARA program, what events or conditions have caused increased personnel exposures, and what events or-conditions has helped reduce personnel radiation exposure (1)

Managers and Supervisors All individuals interviewed entered the radiological controlled areas on a weekly to monthly basis depending on plant

. condition (2)

Knowledge of ALARA Program Each of the individuals interviewed was familiar with the basic ALARA concepts taught in the GET program and knew that they had a basic responsibility for implementing the utilities ALARA program by performing a task in a manner consistent with the utility's ALARA polic In general the managers and supervisor interviewed* knew what the current radiation exposure and exposure limit was for their department The managers and supervisors had a good understanding on where the ALARA requirements originated and what corporate and plant documents described the ALARA program objectives. All of the managers and supervisors interviewed knew what their departments ALARA goals wer (3)

ALARA Program Involvement The majority of the managers and supervisors interviewed had not received any ALARA training other than that given in the GET cours Each department had a dedicated individual to serve on the ALARA Committee, which met on a monthly basis or as appropriat The ALARA Cammi ttee members represented their

...

8 * *

departments in discussions of ALARA objectives for major outage jobs with coworkers and supervisor None of the managers or supervisors interviewed had participated in the formal ALARA suggestion program nor did they know how many ALARA suggestions were submitted by their department within the past or current yea (4)

Perspective All managers and supervisors interviewed had suggestions on how the ALARA program could be improve The suggestions included better planning of work to ensure appropriate equipment and tools were readily available and continue to increase the awareness of the ALARA concept to all levels of plant personne These methods could be through GET retraining, depa rtmenta 1 training or through the Advanced Radiation Worker Training Program (ARWTP).

The majority of managers and supervisors had opinions on things that had contributed to decreases and increases in personnel exposure Indi vi dua 1 managers and supervisors interviewed believed that the following actions had contributed to exposure reductions:

use of temporary shielding, special tools such as the steam generator manway removal tool, permanent shielding such as the reactor vessel head shi el ding, reduced work activities in high radiation areas due to better job evaluations, flushing of various system components and lines, increased ALARA staffing, implementation of the hot particle program and the training received in the ARWT Individual managers and supervisors interviewed believed that the following actions had contributed to increases in personnel exposures:

poor maintenance scheduling in the past, operating with failed fuel during the 1983 through 1985 period, and an inexperienced mechanical maintenance staf An individual manager said that the mechanical maintenance staff was now more experienced and better trained because of the Quality Maintenance Team (QMT)

training that the licensee adopted during 198 This training has increased the quality of work performed by mechanical and electrical maintenance personnel which has reduced the number of jobs to be reworked by 12 percent during outages and 5 percent during normal operation All mechanical and electrical personnel have not attended this QMT training, however, the licensee intends to have all personnel complete this training as soon as possible. Completion of the QMT training should enhance and reduce the 1 i censee I s person-rem goa 1 s for future work inside radiological controlled area Training (83528/83728)

Inspection team members toured the licensee 1s practical factor training*

are The area was equipped with various mockup training aides including

a model of the steam generator lower head and a working containment building access airloc The inspector also determined that the licensee had incorporated various radiation protection subjects and ALARA concepts in the craft training programs for mechanical, electrical, and instrumentation and control student.

Conclusions (83528/83728)

The inspection revealed that the licensee appears to have the elements in

• place to have.an effective dose reduction program, however the effectiveness of the implementation of the recent initiatives remains to be see In the past, management support and involvement in ALARA, conflicting operational priorities and unforeseen work items have contributed to less than total success for the ALARA progra Continued licensee management support and involvement will be required to lower the licensee 1s person-rem dose to be consistent within the national average for collective dose to personne The following significant issues were identified during the inspection and should be addressed by the licensee to increase the effectiveness of their ALARA progra Dose goal formulation - goals are not based on tasks but rather on an average dose per day (Paragraph 4.c) (50-338/339/88-03-0l). Contractor craft proficiency - dose projections for contract work are not consistent with licensee experience_while performing similar work (Paragraph 5.a)(50-338/339/88-03-02). RWP hold program - entries are made on RWPs after the hold point is reached without evaluation and documentation of holds not formalized (Paragraph 4.e)(50-338/339/88-03-03). Review reasons for containment power entries to determine if the number of such entries can be reduced (Paragraph 5.c)

(50-338/339/88-03-04). ALARA Action Plan does not include a formal schedule with milestones for implementing recommendations (Paragraph 4.f)

(50-338/339/88-03-05).

No violations or deviations were identified.