IR 05000338/1991005
| ML20029C050 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/08/1991 |
| From: | Gloersen W, Potter J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20029C039 | List: |
| References | |
| 50-338-91-05, 50-338-91-5, 50-339-91-05, 50-339-91-5, NUDOCS 9103250170 | |
| Download: ML20029C050 (11) | |
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$ 1 1 1931 Report Nos.:
50-338/91-05 and 50-339/91-05 Licensee:
Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos.:
50-338 and 50-339 License Nos.: NPF-4 and NPF-7 Facility Name: North Anna 1 and 2 Inspection Conducted:
February 4-8, 1991 Inspectors:
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Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine unannounced inspection was conducted in the area of occupational radiation safety during extended outages and included an examination of: audits and appraisals, planning and preparation, training and qualification, internal exposure control, control of radioactive materials and contamination, surveys and monitoring, maintaining occupational exposures ALARA, and shipping of-low-level wastes for disposal and transportation.
Results:
In the areas inspected, two violations were identified for failure to leak test a sealed source and for failure to calculate correctly the total amount of radioactivity in a radwaste shipment.
Based on interviews with licensee management, supervision, personnel from station departments, and records 9103250170 910311 PDR ADOCK 05000338 Q
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review, the inspectors found the radiation protection program to be managed i
acceptably. The licensee's programs for external and internal radiation l
exposure controls were effective and functioning adequately to protect the r
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F REPORT DETAILS 1.
Persons Contacted Licensee Employees J. Breeden, Supervisor, Radiological Analysis G. Clark, Supervisor, Quality Assurance E. Dreyer, Supervisor, hP Technical ' rvices
a G. Henry, Radiologicci Engineer
- M. Isham, Supervisor, HP Operations T. Johnson, Supervisor, Quality Assurance G. Kane, Station Manager
- P. Kemp, Supervisor, Licensing X. Licklider, ALARA Technician M. Marino, Supervisor, Instrumentation and Control (I & C)
- R. Saunders, Assistant Vice President-Nuclear W. Sims. ALARA Technician J. Smith, Manager, Ovality Assurance
A. Stafford, Superintendent, Radiological Protection
- J. Stall, Assistant Station Manager W.- Thorton, Director, HP and Chemistry (Corporate Office)
Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personnel.
Nuclear Regulatory Commission
- M Lesser, Senior Resident Inspector
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Attended exit meeting held un February 8,1991
2.
Organization and Management Controls (83750)
The inspector reviewed changes made to the licensee's organization, staffing levels, and lines of authority er they related to radiation protection, and verified that the changes
- not adversely affected the licensee's ability to control radiation e,posures or radioactivity. It was noted that there were no major changes to the organization since the last inspection.
No violations or deviations were identified.
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3.
AuditsandAppraisals(83750)
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Technical Specification (TS) 6.5.2.8 requires that audits of plant activitiesbeperformedunderthecognizanceoftheQualityAssurance(QA)
Department and that the audits shall encompass, in part, the following:
(a) the conformance of plant operation to provisions contained within the TSs and applicable license conditions at least once per 12 months; and y.m-y i
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(b) the Process Control Program (PCP) and implementing procedures for processing ano packaging radioactive wastes at least once per 12 months.
The inspectors discussed the audit and surveillance program related to radiation protection, radioactive waste management, and the PCP with licensee representatives. The inspectors noted that no new audits had been conducted since the last inspection in the -areas noted above. The last audits in the areas of radiation protection and the PCP were N-89-15 Health Physics Program, 9/15/89-and N-90-03, Radiological Environmental Monitoring, Of fsite Dose Calculation Manual, and Process Control Program, dated February 12, 1990.- The next health physics _(HP) audit was scheduled for August 1991. The licensee used the guidance contained in ANSI 18.7-1976/ANS 3.2 for establishing the frequency of HP audits, which was
once per-two years.
In addition, the licensee perfermed an assessment of the radiation protection area during the period from September through December 1990.
The licensee had previously conducted assessments in other program areas.
This assessment was not as in depth and technical as a QA audit, however, as a management tool, the assessment was considered a program enhancement.
The assessment provided management a quick overview of contamination control; control of contaminated areas, equipment, and material; internal and external radiation exposure controls; preparation and shipment of radioactive material; and friskir.g techniques.
No violations or deviations were identified.
Planning and Preparation (83750)
The inspectors reviewed the licencee's augmentation of the HP staff to support the North Anna Power Station refueling outage. Evidence of good management support for the HP program was noted in that the licensee had hired an ample supply of HP contractors, inluding the following: (1) 120 HP technicians (23 junior technicians, 91 ANSI 3.1 technicians, 2 ALARA technicians, 14 foremen, and 1 planner supervisor); (2) 3 practical factor instructors (1 ANSI 3.1 and 2 juniors); (3) 64 decontamination technicians (1 coordinator,7 foremen,28seniortechnicians,28juniortechnicians);
(4)23dosimetrytechnicians;and(5)2instrumenttechnicians.
The inspectors also examined other indicators of management support for the radiation protection program. In addition to management allocating sufficient resources to install temporary shielding in the U1 containment (approximately 13 tons), the following equipment purchases and/or facility modifications needed for the radiation protection program were noted:
Ten portable Flanders HEPA ventilation units were purchased and put
into service in December 1990 (five rated at 1000 cfm and five rated at2000cfm).
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- One Nuclear Data stand-up whole body counter was purchased in January
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Approximately 1500 digital alarming dosimeters, eight readers, and
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one calibrator were purchased and placed into service in April 1990.
- Additional portable survey instruments were purchased in July 1990 to support the U1/U2 outages.
- Facility modification during suurer 1990 resulting in a new ALARA briefing room.
No violations or deviations were identified.
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5.
Training and Qualifications (83750)
10 CFR 19.12 requires the licensee to instruct all individuals working or frequenting any portions of the restricted areas in the health protcction aspects associated with exposure to radioactive material or radiat seN in precautions or procedures to minimize exposure, and in the purpose and function of protection devices employed, applicable provisions of the Connission Regulations, individuals responsibilities and the availability of radiation exposure data.
The inspectors reviewed changes in the licensee's training program, policies, and goals relating to the radiation protection program and discussed the changes with licensee representatives. The inspectors verified that the changes should not adversely affect the licensee's
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program.
Several' areas of the iip training program were raviewed.
The particular i
areas were:
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HP Technician Qualifications;
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GeneralEmployeeTraining(GET);
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Advanced Radiation Worker Program;
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HP Technician Development Program; and
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Qualification and continuing education program for HP instructors.
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Selected resumes for contracted HP technicians hired for coverage during the current outage were reviewed.
All were found to comply with ANSI 3.1 requirements.
The respiratory protection section of GET was attended by the inspectors.
The lecture covered the philosophy and practical factors of respiratory protection along with the proper inspection and donning of full face respirators.
Following the lecture, students were interviewed as to their G
confidence in using the respirator following their training.
All stated that they felt confidcnt in the handling and use of respirators and felt the training was effective in preparing them to perform tasks requiring respiratory protection.-
The inspectors found the program to be adequate
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in providing the workers with inf ormation and procedures for the effective use of respiratory protection equipment.
The Advanced Radiation Worker (ARW) Training Program for selected I & C workers, operators, first line supervisors, and other selected-personnel was reviewed.
This program provides training to allow the individual to perform independent HP job coverage.
This coverage is only for the individual, not to support a team of workers.
There currently are 332 employees certified as ARWs.
The program consists of twenty hours of classroom lecture and twelve to fif teen hours of in-plant tasks.
The combination of the lectures and tasks provided the student with the knowledge :and practical experience to perform basic surveys, respond to
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unusual events, and the handling / control of cadioactive materiais.
Retraining.for_ARWs is required on an annual basis.
The inspectors found this program to be effective in providing workers trained as ARWs to
. adequately perform their own coverage for minor RCA tasks.
The inspectors reviewed the curriculum of the Health Physics Technician-Development Program (HPTDP).
The HPTDP is a four year combined classroom and in-plant on-the-job. training -task which is broken into seven steps.
Each step covers a number of specific HP responsibilities and disciplines.
The trainee-is assigned to that discipline during that particular s.zp of the program.. Modules _HPTDP-7 "Airborrc Radioactivity Control" and HPDTP-8
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" Radiation Protection Instrumentation" were reviewed and were found to'be concise and thorough'in their respective subject natter.
Four system training sessions are included throughout the training program. -Once the trainee has completed the program he is_then enrolled in the'HP technician d
continuing training program.
Qualifications and continuing training for the HP instructors was reviewed and found to-be adequate to ensure the instructors development in their-i fields of instruction and' in their development -of-effective teaching-techniques.
No violations or deviations were identified.
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'6.
' Internal Exposure Control'(83750, 83720)
q 10 CFR 20.103(b) requires ~.t;e 11ceni
. use process or other engineering-controls, to the ; extent practicat. '
to _ limit-concentrations of radioactive material in air to leveh celow that specified in Part 20,.
Appendix B, Table 1,, Column 1 or. limit concentrations, when averaged-over l
the number of hours in any week ~during which individuals are in the area, to less than 25 percent of specified concentrations.-
The use 'of process and engineering controls: to limit airborne radioactivity concentrations in the plant was discussed with-licensee representatives-and-the use.of-such controls was observed during tours of
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The inspectors determined that the licensee had recently placed a new stand-up whole body counter in service at their in-processing facility.
The inspectors reviewed the licensee's calibration and quality control procedures and determined the licensee's methods were appropriate. The inspectors observed the whole body counter operator perform daily quality control checks. The inspectors also reviewed the calibration records for i
one of the older bed type detectors and determined that the licensen's calibration records did not show source activities used in calibrating the instrument. However, the sources used were traceable to the National Institute of Standards and Technology (NIST) and the licensee was able to
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provide the radioactive source strength information utilized in the l
calibration during the inspection.
No violations or deviations were identified.
7.
Surveys, Monitoring, and Control of Radioactive Material and Contamination (83750,83729)
surveys as (1) )may be necessary for_ the licensee to comply with the 10 CFR 20.201(b requires each licensee to make or cause to be made such
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regulations and (2) are reasonable under the circumstances to evaluate the i
extent of radioactive hazards that may be present.
10 CFR 20.203 specifies the posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material.
Additional requirements for control of high
radiation areas are contained in TS 6.12.
l During tours of the plant, the inspectors observed the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contamination areas, radioactive material areas, and the labeling of radioactive material and noted no apparent problem areas.
During these tours, the inspectors noted a generally clean and tidy facility and-extensive efforts by the licensee to reduce the contaminated areas in the plant, including the Auxiliary Building Decon Building, and Fuel Building. As of December 31, 1990 the total contaminated area at the i
station was 4,478 square feet. The goal for 1990 was 5,000 square feet.
l The inspectors reviewed the plant procedures which established the licensee's radiological survey and monitoring program and verified that the procedures were consistent with regulations, TSs, and good 'HP practices.
The _ inspectors reviewed selected records of radiation and contamination
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surveys. performed-during the last six months, and discussed the survey results with licensee representatives.
During tours of the plant, the inspectors observed HP technicians properly performing radiation and contamination surveys. In addition, the inspector performed independent
radiation surveys in the Unit 1 Reactor Building and verified that the areas were properly poste _ _ _.. _. _. _ _ _ _ _ _ _ _. _ _ _ _. _ _ _
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The inspectors also reviewed the licensee's program for controlling radioactive materials, including calibration sources, and the leak testing program for those sources. TS 3/4.7.11 establishes requirements for leak testing of sealed sources. The TS requires that each sealed source in use containing radioactive material either in excess of 100 microcuries beta and/or gamma emitting material or 5 microcuries alpha emitting material be tested for leakage and/or contamination at least once per six months.
Contrary to the TS requirements, the licensee failed to to test for leakage a Victoreen High Range Field Calibrator containing a 250 millicurie Cs-137 source during the period from June 11, 1987 to February 6,1991. During that time period, the calibrator was used on at least seven occasions. This problem was identified as a violation of TS 3/4.7.11 (VIO: 50-338/91-05-01 and 50-339/91-05-01).
During the onsite inspection, the licensee had initiated an investigation into the problem area noted above. The licensee also initiated corrective
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leak testing sources prior to issue. On February 6,1991, the licensee performed a leak test of the field calibrator immediately after the discovery that the retwired leak test had not been performed, and the results indicated that the removable contamination was less than the limit of 0.005 microcuries.
One violation for failure to perform a leak test of a field calibrator wa identified.
8.
Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA)_
l (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 radiation exposures a low as reasonably achievable. The recommended j
elements of an ALARA program. are contained in Regulatory Guide 8.8, l
Information Relevant to Ensuring that Occupational Radiation Exposure at i
Nuclear Power Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures ALARA.
Regulatory Guides 8.8 and 8.10 provide information relevent to attaining goals and objectives for planning and operating light water reactors and
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provide general philosophy acceptable to the NRC as a necessary basis for
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a program of maintaining occupational exposures ALARA.
The inspectors
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discussed with licensee management, ALARA initiatives, including _ source term reduction effort. One of the major initiatives the licensee was planning was-the removal and replacement of the resistance temperature
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detectors (RTD) bypass manifold. The RTD removal and replacement project was scheduled for 1992 on Unit I and 1993 on Unit 2.
The inspectors also discussed the station's 1990 collective dose and the 1991 year to date collective dose with licensee representatives. In 1990, the North Anna Power Station collective cose was approximately 610 person-rem and there were 75 scheduled outage days. The licensee had established a 1990 goal of 643 person-rem, which was reasonable given the
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amount of schcduled work activities. The licensee's 1991 station goal was 513 person-rem. As of February 8,1991, the station collective dose was 268 person-rem. The licensee was ending week four of a scheduled nine week Unit 1 outage. The licensee had budgeted 450 person-rem for the Unit 1 outage.
No violations or deviations were identified.
9.
SolidRadioactiveWaste(86750)
10 CFR 20,311 requires a licensee who trat,5fers radioactive waste to a land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.5b and meets the waste characteristic requirements of 61.56. It further establishes specific requirements for conducting a quality control program and for maintaining a manifest tracking system f or all shipmentt.
The inspectors reviewed the methods used by the licensee to assure that waste was properly classified, met the waste forms and characteristics required by 10 CFR 61 and discussed the use of these requirements with ticensee representatives.
No violations or deviations were identified.
10. Transportation of Radioactive Materials (86750)
10 CFR 20.311 (b) requires each shipment of radioactive waste to a land disposal facility to be accompanied by e shipment manifest that indicates as completely as practicable; a physical description of the waste; the volume; radionuclide identity and quantity; the total radioactivity; and
the principal chemical form.
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10 CFR 71.5 (a) requires each licensee who transports licensed material outside the confines of its plant or other place of use, or who-delivers licensed material to a carrier for transport, to comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation -(DOT) in 49 CFR parts 170 through 189.
49 CFR 172.2 requires a person, who offers. hazardous material for transportation. to describe the hazardous material on shipping papers.
49 CFR 172.203--(d)(1) requires the description for a shipment of radioactive material to include the name of each radionuclide in --the radioactive material and the activity contained in each package of the shipment in terms of curies, mil 11 curies, or microcuries.
Through interviews with licensee personnel, the inspectors determined that the licensee had made an error in calculating the quantity of radioactivity in a shipment of radioactive waste to a land disposal facility on August 8,1990. The radioactive waste was dewatered spent
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I resin beads. The licensee analyzed a sample of the resin to determine radioactivity, and waste classificatios. The gamma identification report for the sample's spectrum analysis reported the results in radioactivity per gram.
A licensee employee made a power of ten error (low) in converting the radioactivity of Cobalt 60 from microcuries per gram to i
microcuries per cubic centimeter. The incorrect Cobalt 60 radioactivity was recorded on the isotopic analysis report and a licensee employee later entered the incorrect value in a computer program used to calculate the
'i shipment radioactivity and determine waste classification. Additionally, the licensee utilized the radioactivity of Cobalt 60 to estimate the radioactivity of other radionuclides that were difficult to measure. That created additional errors in the licensee's radioactivity estimate for
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radioactive waste shipment 90-11. The licensee's initial radioactivity estimate for the shipment was 70.7 curies.
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During the licensee's preparation of an annual radiological effluent report a licensee cmployee noted that the radioactivity of the 90-11
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shipment appeared to be low when compared to a similar shipment made in i
1990. The employee investigated the discrepancy and found the error on
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January 10, 1991. The licensee determined that the correct radioactivity
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of shipment 90-11, on the date of shipment, was 232 curies. The problem
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was documented in Deviation Report N91-30, dated January 10, 1991. The licensee notified the Radioa:tive Waste Burial Site of the error by phone
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and sent a revised manifest on January 11, 1991, showing the corrected radioactivity estimate. The licensee also reviewed similar manifests
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generated in 1990 and did not find any additional errors. The licensee's t
corrective action report was completed February 1, 1991. The report
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identified the error as a one tin.2 calculation error that had been corrected with no additional corrective action necessary.
The inspector reviewed the violation for applicably of enforcement-discretion using the criteria specified in 10 CFR 2, Appendix C, V. G. The inspector pointed cut to licensee staff that the licensee's corrective action had not included measures to prevent recurrence. The licensee began a second review of the event and determined that the radioactive waste packaging and shipping procedures did not require independent reviews of all calculations made to determine the radioactivity of radioactive waste packages. The licensee immediately revised procedures 7.1.40, Packaging and Shipment of Radioactive Material and 7.2.30, Computer programs for Radioactive Waste, to require independent verification of all manual calculations made in determining the quantity of radioactive material in a l
package offered for shipment.
Failure to report correctly the quantity of radioactivity in Radioactive Waste Shipment 90-11, made August 8,1990 to a waste dispose 1 facility, was identified as a violation of the above requirements (V10:
50-338/91-05-02 and 50-339/91-05-02).
The inspectors observed the preparation of a radioactive waste shipment of dewatered bead resin made during the inspection. The inspector performed independcat radiation surveys and verified that the radiation levels were
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well within the limits specified in 49 CFR and that the transport vehicle was properly placarded. The inspectors also reviewed the appropriate records for the shipment and discussed the shipment with licensee representatives. The inspectors reviewed plant procedures for preparation, documentation, and shipment of radioactive meterial and serified that the procedures were consistent with regulations.
One violation was identified for failure to report corrtctly the quentity of radioactivity on a waste shipment.
11.
Exit Meeting The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on February 8,1901. The inspectors summarized the scope dnd findings of the inspection, including the violations. The inspector :1so discussed the likely informational content of tie inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee d d not identify any such documents or processes as proprietary.
Dissenting comrrents were not received from the licensee.
Item Number
_De_scription and_ Reference 50-338, 339/91-05-01 VIO - Failure to perform a leak test of a field calibrator (Paragraph 7).
50-338, 339/91-05-02 VIO - Failure to report correctly the quantity of radioactivity on a waste shipment (Paragraph 10).
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