IR 05000338/1990019

Insp Repts 50-338/90-19 & 50-339/90-19 on 900820-24. Violations Noted But Not Cited.Major Areas Inspected: Licensee Radiation Protection Program Consisting of Review in Areas of External & Internal Exposure Control

ML20059N104
Person / Time
Site:	North Anna
Issue date:	09/14/1990
From:	Gloersen W, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059N102	List: IR 05000338/1990019 ML20059N101
References
50-338-90-19, 50-339-90-19, NUDOCS 9010100106
Download: ML20059N104 (12)

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< UNITED STATES NUCLEAR REGULATORY COMMISSION ,

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REGION il

< S 101 MARIETTA STREET.N.

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E* ' 's ATLANT A, GEORGI A 30323

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' g****+,/ SEP i 91990

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Report Nos.: '50-338/90-19 and S0-339/90-19' i

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Licensee: Virginia Electric and Power Company- *

L Glen Allen, VA 23060

. Docket Nos.: 50-338 and 50-339 License Nos.:~ .NPF-4'and NPF-7;  ;

Facility Name: North Anna 4 and 2_ ,

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i Inspection-Conducted: August 20-24, 1990

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Inspector- -

YM ats Signed

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Approved by: f fd '

T~ . Piittiir,,

t ect on Chief ghtefSigned Facilities Radiation Protection Section ,

Emergency Preparedness Radiological Protection '

Branch Division of Pidiation Safety and Safeguards ,

SUMMARY Scope:

This routine, unannounced inspection of the licensee's radiation protection

. program consisted of a review in the areas 'of. external and internal exposure control; changes in the program; . control of radioactive material and-contemination; the program to maintain doses as low ase reasonably uchievabic; previous inspection findings; andJInformation Notices.-

Results: ,

l In the areas inspected, one licensee-identified non-cited violation was identified for failure to post a high radiation area.in the decon bay area on

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July 13, 1990, in accordance with-Technical Specification 6.12.1.- In general, the licensee's radiation protection program was functioning adequately to- _

protect the health and safety of the occupational radiation workers. ;It was=

noted that the licensee's 1989 collective - dose of 1,614 person-rem significantly exceeded the initialt goal of 994 person-rem which was la_te'r ,

revised to 1,580 person-rem. Contributing factors to.the' higher than projected collective dose included: (1) extended simultaneous dual unit outages;- .

(2) removal and' replacement of steam generator tube plugs; (3) removal' of large bore snubbers; and (4) performing the ten year in-service inspection (ISI). -As~

of' August 20, the licensee's collective dose for 1990 was 66 person-rem. The licensee had projected a ' year end. goal of 643 person-re PDR ADOCK h33 pg Q

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REPORT DETAILS

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' Persons C'ontacted q

Licensee Employees ,

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• E. Dreyer, Supervisor, Health Physics (HP) Technical Services

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E. He11erman, Check HP- ,

G. Henry, Radiological Engineer 1 L.. Jones, Supervisor, Radiological Engineering '

• G. Kane, Station. Manager _ .

• P. Kemp,;Supervis)r, Licensin ,C !

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T. Peters, Supervtsor, Exposure Control _-

• J. Peyton, Licensing ;j D. Ross Supervisor,~HP Operations and Radwaste- .,

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• J.-Smith, Manager, Quality Assurance , ""~ l

• J. Stall, Superintendent, Operations

• W.~ Thorton, Director, HP and-Chemistry Services (Corporate) o y:

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Other licensee employees contacted during: this1. inspection included engineers, technicians, and administrative personne [:

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,. Nuclear Regulatory Commission l- -r l *L. Engle, Project Manager (NRR) '

-l l * Lesser, Senior Resident Inspector (RII) 3

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• Attended exit interview :i Audits and Appraisals (83750) L ,

The inspector reviewed the experience of the licensee' in identifying abd j correcting deficiencies or weaknesses related<to othe control of radiation =

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i or radioactive material. The licensee's_first level'of reporting problems re'ated to radiological procedures or worki: practices, which requir supervisory action for proper resolution, is to' initiate a Radiological Problem Report (RPR). The licensee also documents individual personnel contamination events (PCEs) and significant PCEs . (see Paragraph 6)'In'

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performs investigation addition, ereports Radiological of Incident-Reports (RIRs) are written for significant RPRs _or PCEs 'that require the a review by the Assistant Station Manager. The: licensee also has a station- '

Deviation Report System that was intended to document' plant wide problems,_

however _HP, radiological protection,- and radiological events have also been documented in the station deviation . rep' ort system. The inspector- o reviewed a sampling of various reports,noted above (see also. Paragraph 6).

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1+ was observed that in 1989 the licensee issued 118 RPRs and from Janeary 1 to June 30, 1990, 50 RPRs were issued. Tha most. common causes were poor work practices. RWP and HP procedure violations, and problems with HP postings. The RPR evaluations performed by the Radiological ,

Engineering staff _ were technically thorough and well written. Based on t the selected review of RPPs, there were no apparent programmatic problems identified and licensee-identified deficiencies were properly addresse i No violations or deviations were identifie .- Changes (83750).

The inspector reviewed any major changes since the last inspection in '

organization, facilities, equipment, and. programs tha.t may effect occupational radiation protection. Equipment purchases made during the ,

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last year are included in Paragraph 7 Maintaining Occupationei Exposures ALAR The inspector observed only relatively minor changes to the licensee's radiation protection organization. 'During the last inspection f (50-338, 339-89-33) - it was observed that the Radwaste/Decon Supervisor position was eliminate Since that timt. : the licensee in effect reinstated that position, although it is presently referred to as Supervisor of HP Operations (Radwaste). The position was reinstated so that the Radiation Protection Organizations at North Anna- and Surry would ,

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! In addition, the licensee has added a new position on a trial basis to the l Radiation Protection organization. The position was referred to as the <

l Check H The Check HP Program was designed to improve radiological work practices and enhance worker awareness of radiation protection standards - ,

and requirements. The Check HP was assigned; to _ observe in-plant work -

evaluations and Radiological Protection Training Session It was intended for the check HP to utilize a pro-active approach to identify and ;

correct deficiencies and to coach individuals on the importance of '

adherence to good radiation prntection work practices. The program goal '

was to improve individual and team performance in the field as well as to '

evaluate. the adequacy of Procedures and Training Programs related to H The Check HP reported directly to the Superintendent of Radiological _-

Protectio '

It was also observed that the licensee . incorporated the Radiation f Protection Plan and the Station ALARA Program into the following Virginia Powcr Administrative Procedures:

VPAP 2101, " Radiation Protection Plan," Revision 0, May 4, 1990 *

VPAP 2102, " Station ALARA Program," Revision 0, May_31, 1990 ,

No violations or deviations were identifie !

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' External Exposure Control (83750)

10 CFR 20.202(a) requires a licensee to supply appropriate personnel monitoring equipment to, and require. the use of such equipment by each individual who enters a restricted area under such circumstances that he receives, or is likely to receive, a dose in any calendar quarter in excess of 25 percent of the limits in 10 CFR 20.10 ,

10 CFR 20.202(c) requires all personnel dosimeters (except for (Hrect and indirect reading pocket ionization chambers and those dosimeters used to i

> measure ~ose to the hands and forearms, feet, and ankles) that require processing to determine the radiation dose, to be processed'and _ evaluated by a dosimetry processor holding current personnel . dosimetry accreditation from- the National Voluntary Laboratory Accreditation Program (NVLAP) of the National Institute of Standards and Technology (NIST). ,

i The inspector determined by direct observation, discussion, and a review

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of procedures that the licensee's dosimetry program was being conducted in accordance with established procedures and 10 CFR 20 requirements. The inspector also verified that the dosinetry program was accredited by NVLAP in test Categories II, IV, V, and VI The licensee was not using the personnel dosimeters to measure neutron dose equivalent, hence the licensee was not accredited in Category VII ;

The inspector also noted that the licensee was not accredited in test '

photon range); Cate Category I (accident, photon range); low-energy and Category VI (photon mixture range)

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gory III (low-energy It was determined that the licensee's thermoluminescent dosimeters .(TLDs) are calcium sulfate teflon dosimeters. Based on the energy response curves supplied by the manufacturer of the.TLDs, the re1*'ive response (ie. referred to as the R-value) is unity in the energy range from about 200: kev to 1500 ke At energies less than 200 kev, the calcium sulfate dosimeters relative j response is essentially nonlinear. This is typical for TLD materials with

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higher atomic numbers (compared to lithium fluoride TLDs) since the enhanced photoelectric prcbabilities exaggerate the response to low-energy X- or gamma rays. Since the relative response of the licensee's TLDs was i nonlinear at energies less than 200 kev, the licensee did not participate in NVLAP Categories I, III, and -V The licensee indicated that the <

typical distributions of photon and average beta. energies observed at t l the facility were greater than 200 kev; however, a. site-specific study l to verify this fact was not located. - The inspector then reviewed individual TLD records from the 1989 dual refueling outage and observed ,

that the R-values of the TLDs with doses greater than 10 mrem were  ;

approximately equal to one. Less than one percent of the TLD records I

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reviewed had R-values greater than four. As inoicated by the licensee's TLD processor, the R-value was an indication of thi incident photon energ If the R-value was less than four, then the hitfi energy photons predominated. If the R-value was greater than four, then the low photon energies predominate In addition, during tours of the RCA on August 20-23, 1990, the inm f. tor observed worker practices with regard to wearing and placement vi personnel dosimetry. ' The inspector did not identify any proble'9s with worker's dosimetry placement practice No violations or deviations were identifie . Internal Exposure Control (83750) Engineering Controls 10 CFR 20.103(b)(1) requires the licensee 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 20, Appendix B. Table 1, Column 1.

I During tours of the Auxiliary Building, the inspector observed j various engineering controls to limit the concentration of airborne

, radioactive material. These included the use of ventilation systems

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equipped with high efficiency particulate air (HEPA) filters and-containment enclosures. Specifically, the inspector observed the change out of the U2 reduced micron letdown filter 1-RP-FL-1B. This observation included a review of Mechanical Maintenance Procedure MMP-FL-l h. " Removal and Reinstallation of the Refueling Purification i

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Filter 1-RP-FL-1B, " Revision 8, dated March 26, 1990; review of Radiation Work Permit (RWP) No. - 90-2-1829 which authorized the work; and observation of the pre-job ALARA briefings. The frequency of filter change outs was determined by either increasing differential pressure (delta P) or dose rate consideration (7R/hrat18 inches).

This filter was changed due to-increasing delta P. Contact dose rates on the filter housing were 2 R/hr and 800 mR/hr at 18 inche The inspector observed that a continuous air monitor was in operation and the collection of high volume air samples which were generally representative of the air in zones occupied by worker Thes inspector discussed with the licensee the representativeness of the breathing zone air samples collected in the vicinity of the filt_er i cubicle, where the worker installs the new filte This area - l represents' the highest probability for air contaminant The

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licensee assured the inspector that adequate breathing zone samples were being collected and will continue to be en11ected in tile vicinity of the cubicle,

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i Internal Assessment ,

10 CFR 20.103, 20.201(b), 20.401, and 20.405 requires the licensee to control uptakes of radioactive material, assess such uptakes and keep records of and make reports of such uptake ;

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The license's administrative action level for investigation, as defined in HP-5.2.B.11 " Bioassay Data Evaluation and Followup" was a body burden of five percent of the' Maximum Permissible Body Burden (MPBB). Since January 1, 1990, there were no individuals whose whole body counts exceeded the licensee's action level. It should be noted that on February 27, 1990 an event occurred in which three ,

individuals had uptakes of 3.8 percent, 4.1 percent, and 4.5 percent .

MPB The predominant nuclide was Co-5 The contaminations i occurred during changeout of the Unit 2 Letdown Filter (2-CH-FL-5).

The liuensee evaluated the event, performed a root cause analysis, and provided recommendations and corrective actions. Some of the recommendations included the use of portable ventilation units over the filter cubicle floor opening; use of containment enclosures; and better coordination between operations, maintenance, and HP to prevent a filter from remaining in a drain-downed ' condition for an extended period of time and thus allowing the condition of the filter media to become relatively dry increasing the probability of the particulates to become airborn :

In addition, the inspector reviewed the licensee's program for in-vitro bioassays, including procedure HP-5.2B.30, " Collection and I Analysis of Urine and Fecal Samples," dated October 1,1985. The licensee had a routine sample collection program for urine. Twice a year approximately 30 individuals were randomly selected from the following[operationssix sample: (8),departments mechanical and ( 8) ',were requested to(4),

instrumentation supply a urine electrical (4), chemistry (2), and HP (6)]. Non-routine samples are collected on a case-by-case basis depending on whole body counting (WBC) results and/or the nature of the event. In 1990, there were no non-routine samples collecte No violations or deviations were identifie . Control of Radioactive Materials and. Contamination, Surveys,- and Monitoring (83750) i Surveys 10 CFR 20.201(b) and 20.401 require the licensee to perform surveys i and to maintain records of such surveys to demonstrate compliance with regulatory limits, respectively.. 10 CFR 20.203 (c)(1) requires that each high radiation area be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words: Caution

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High Radiation Are CFR 20.202(b)(3) defines a high radiation are Technical Specification (TS) 6.12.1 requires the licensee for each high radiation area, in which the intensity of radiation is greater than 100 mrem /hr but less than 1,000 mrem /hr, to barricade r and post conspicuously as a high radiation area and to control the '

entrance by requiring issuance of a RWP. During a review of Station Deviation Reports, the inspector noted that the licensee had identified that on July 13, 1990 a high radiation area in the decon .

bay area of the Auxiliary Building was not posted in.accordance with !

TS 6.1 The probable cause was the improper storage of the spent ,,

filter which_had just been changed out. The dose rates at one foot from the spent filter container were greater than 100 mrem /hr but -

less than 1,000 mrem /hr.' It should be noted that.at the time of'

this event, all persons entering the Radiological Conto 11ed Area (RCA) were required to have a digital alarming dosimeter (DAD).

These devices continuously indicate the radiation dose rcte in the '

area, or continuously integrates the rediation dose rate in the area and alarms when a preset integrated do.ie (depending on the RWP) is received. Apparently, the storage location was addressed during_ the pre-job briefing, however, the precise location of the storage area was not addressed adequately. .in addition, the HP Technician failed to ensure that the filters were properly stored and the area poste The inspector reviewed the corrective actions which included: (1)

preparing and presenting a " safety topic" on the requirements for :

transport /stora  ;

I and policies; (ge2)of radioactiveinmaterial addressing based the RWP's on current Special procedures Instructions for

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than 100 mrom/hr at one foot; and (3) informing all onshift personnel of the RWP change. This licensee identified violation of TS 6.1 is not being cited because the criteria specified in Section V.G.1 of :

, the NRC Enforcement Policy were satisfied.' l

I One licensee-identified non-cited violation'(NCV) wts identified-for failure to post a high radiation area in accordanc! with TS 6.1 (NCV: 50-338,339/90-19-01),

b. Area and Personnel Contamination j The licensee maintained approximately 96,000 squace feet (fte),_

excluding containment, as radiologically controlled. Tne licensee had expended a significant amount of resources to reduce the  ;

contaminated areas of the plant during the last three years .

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The end of the year contaminated areas of the plant have decreased from 13,200 fte in 1987 to 9,800 fte in 1988 and finally to 6,700 fte ,

in 1989. As of August 13, 1990, 5,300 f t2 of the RCA was contaminated. _ The end of the year goal for 1990 is 5,700 fte, 7 During several tours of the facility, the inspector observed a generally clean plant, including freshly painted surfaces, pipes, and .

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l equipment. In addition, the inspector. reviewed PCE reports for 1989 and through August 24, 199 In 1989, the licensee documented 586 PCEs. The licensee's 1989 goal was less.than 400 PCEs. During 1989, the licensee experienced two planned refueling outages and one unplanned outage for a total of 160 outage days. Shoe contaminations contributed 34.5 percent to the total number of PCEs. The licensee performed individual engineering evaluation of the PCEs and observed that approximately 33 percent of the PCEs were due to poor workpractice Other trends observed included particulate contaminations with no direct source or cause; working in the vicinity of radiologically controlled boundaries; and poor _ HP practice:t, including inadequate setting of radiological boundarie From January 1 through August 24, 1990, the_ licensee documented 83 PCE The licensee's 1990 goal was less than 280 PCEs. The inspector observed that monthly PCE summaries were provided by the radiological engineering group and included data evaluations and-analysis, trends, conclusions, and recommendations. The inspector reviewed PCE suninary reports from December 1989 through July 199 The recommendations from these ' reports included increasing the !

frequency of surveys in problem areas; use of enclosures'with HEPA filtrations units; Cecontaminate frequently used equipment; and clean up of the Fuel Handling Building during periods of increased activit The licensee tracked PCEs by anatomical location, skin vs clothing, department or company, plant: location, and root cause. To reduce the numbers of PCEs, the licensee initiated a program for the individuals who became contaminated to attend a coaching session with the Plant Manager or Superintendent of HP prior to resuming radiological wor i No violations or deviations were identifie Radiation Detection and Survey Instrumentation i

During tours of the facility, the inspector observed the proper use of survey instruments by HP personnel. The inspector examined ,

calibration stickers on selected radiation detection instruments in 1 use and at various areas thought the plant. Instrument use was in accordance with standard practice and all instruments examined had been calibrate No violations or deviations were identifie . Maintaining Occupational Exposures ALARA (83750)-

10 CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain i radiation exposures ALAR The reconinended elements of an ALARA program j were contained in Regulatory Guides 8.8, "Information Relevant to Ensuring i that Occupational Radiation Exposure at Nuclear' Power Stations will be l

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l ALARA;" and 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposure ALARA."

I ALARA Accomplishments The inspector reviewed the 1989 Annual ALARA Program Status. Report and selected monthly ALARA Reports for 1990. The 1989 Annual ALARA Report provided information on changes to procedures, HP staffing levels, equipment purchases, program accomplishments. ALARA controls, collective dose summary, future initiatives, and various charts and-graphs displaying collective dose statistic The licensee made several er.uipment purchases and installations that resulted in ALARA Program improvements. Six radiation attenuator door (RAD) systems were purchased to use on the steam generator primary manways to lower the general area platform dose rates. These-doors. provided an approximately 60 percent attenuation factor on general area dose rates and still allowed ventilation through the tubes. Ten AR-20s were purchased to allow for remote readout.of dose rates ir specific area Several hundred DADS were purchased to aid HP technicians covering high exposure jobs. The. DADS effectively reduced the number of times the HP technicians would pull the workers-from the job site to read their self-reading: dosimeters, thus increasing worker efficiency. Thicker reactor head stand doors were installed to alleviate the need for temporary shielding when dose rates exceed 1 R/hr at one foo f One of the major ALARA accomplishments was the Enhanced Cobalt Filtration Program which was initdated in May 1989. . This program involved the replacement of various letdown filters which had a nominal pore size of 25 microns with reduced micron filters that had a nominal pore size of-10 microns. The smaller pore micron filters

have been somewhat effective in removing Co-58 from the reactor-l coolant system thus contributing to cobalt source term reduction.

l ALMA Goals and Objectives The inspector discussed with licensee representatives the 1989 and I 1990 station collective dose goals and how the licensee tracked and met those goal Additionally, the inspector reviewed actual expended collective dose for 1989 and through August 20.-1990. In

1989, the licensee had established an initial goal of 994 person-rem a L which was based on a 62 day Unit 2 refueling outage and a 88 day !

Unit 1 Refueling /ISI outage. Due to the early shutdown of Unit I and a significant amount of out-of-scope work -.to be performed, the licensee revised its goal three times to 1,581 person-rem. The total station collective dose in 1989 was 1,614 person-rem which was.

I 2.1 percent over the revised goal. A summary of the major tasks and l dose expended is listed below:

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Major Tas_ks:_ Collective Dose (PERSON-REMJ Setup / Eddy Current / Repair: U-1 _ U-2 TOTA S/G tuber / plug tubes 269.098 T76.263 T6361 Removal o'r large bore 59.869 81.87,8 141.747 snubbers Perform 1D year ISI 77.856- 55.450- 133.306 All activities associated 32.023 32.157 64.180'

with refueling Decon of a11' areas o .653- 20.052- 50.705: ,

containmen Small bore snubber removal / 24.030 .23.139 47.169

- rep.lacement Secondary side S/G work '

• 32.268 10.734 .43.002

• included replacing all

"J" nozzles in S/Gs HP walkdowns/ surveys 26.262 14.321 40.583 I Repack valvec w M esterton 22.189 11.122 '33.311 Packing i

Install RCS Level Indication 20.232 9.869 30.101 I System Ops walkdowns/ valve lineups 13.464 15.'486 28.950 Install / remove scaffolding 18.299 7.780 26.079 :

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Replace Pzr Belly Bands 11.082 8.169 19.251 i Painting the Auxiliary 48.662 Building As can be -seen from that : data above, work associated with steam generator maintenance activities comprises nearly 40 percent of the total outage collective dose. . During. non-outage periods; however, the licensee has-seen a downward collective dose trend.- It terms of collective dose (person-rem) per day, the following data demonstrate the downwbrd trend:

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I Year Daily collective d,ose,during non-outage _ periods __

iPir,spjl-Lem/dyl 1984 0.598 1985 0.456 ,

1986 0.512 1987 0.437 ,

1988 0.325 1989 0.276 The licensee's year end 1990 station collective dose goal' was 643 person-rem. As of the August 20, 1990, the external collective l dose expended was 66 person-rem. The projected expenditure for the i 1990 Unit 2 refueling outage was 456 person-rem. Some. of the scheduled dose intensive work activities include: steam generator maintenance activities, snubber removal and replacement, scaffolding -

installa tion and removal, valve repacking, in-service inspections HP walkdowrs and surveys, decon activities, and refueling activitie No violatior.s' or deviations were identifie ! Previous Inspection Fir, dings (92701, 92702) (Closed)InspectorFollowupItem(IFI) 50-338,339/89-15-01: Develop a system to track and identify trends in the i *ea of: RPRs, PCEs and TLD/SRD discrepancies. The licensee indicated that tracking and-trending of radiological practices had been in effect for several month The inspector reviewed both PCE and RPR trend reports.for the second quarter 1989. The trend reports were written by the radiological engineering staff and were considered adequate for data analysis. This item is considered closed, (Closed) Violation (VIO) 50-338, 339/89-15-02: Failure to perform adequate radiation surveys necessary to prevent a worker fro receiving an exposure to radiation above the station administrative .

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limi The-inspector reviewed the corrective actions documented in the licensee's response to the Subject Notice of Violation dated July 14, 1989. The inspector verified that the corrective actions had been completed, including the maintenance procedures to control work in the fuel transfer canal are This violatior, is considered close (Closed) VIO 50-338, 339/89-33-01: Failure to survey adequately material being released for unrestricted use. The inspector reviewed the corrective actions documented in the licensee's response to the subject Notice of Violation dated February 9,1990. The inspector L verified that the corrective actions had been completed including the evaluation of the tool monitor for use at the RCA exit points for surveying material that is to be released for unrestricted use. This l

violation is considered close .

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11 Information Notices (90701)

The inspector determined that the following Information Notice (IN) had been received by the license, reviewed for applicability, distributed to appropriate personnel, and that action, as appropriate was taken or scheduled:

IN 90-08: Kr-85 Hazards from Decayed Fuel

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10. Exit Meeting

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The inspector met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on August 24, 1990. .The inspector sunmarized the scope and findings of the inspection, including the NC The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.. The-licensee did not identify any such documents or processe; as proprietary. - Dissenting connents were not received from the license Item Number Deceription and Reference 50-338, 339/90-19-01 NCV - Failure to post a high radiation area in the decon bay area on July 13, 1990, in accordance with TS 6.12.1 (Paragraph 6).

Licensee management was informed that the two violations and one IFI

! discussed in Paragraph 8 were considered closed.

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