IR 05000338/1992026
| ML20127G951 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/31/1992 |
| From: | Boland A, Bryan Parker, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127G859 | List: |
| References | |
| 50-338-92-26, 50-339-92-26, NUDOCS 9301220127 | |
| Download: ML20127G951 (18) | |
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tM % d UNITED STATES 4[0, . NUCI EAR REGULATORY COMMISSION
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'% , , , , , /g DEC 31 1992 Report Nos.: 50-338/92-26 and 50-339/92-26 Licensee: Virginia Electric-and Power Company Glen Allen, Virginia 23060 Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7 Facility Name: North Anna 1 and 2 Inspection Con ed: No ber 30 - December 4, 1992 Inspectors: _r f /s/8 A._9 /2/7/[17 A. ~
oland Date ' Signed 12/7/f'72 B. A rker Date' Signed Accompanying Peryonnel 'C. Hinson pf, Approved,by b
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- d f/ d-Date Signed ge W.'H 'Rankin, Chief
'^e facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, announced inspection of the licensee's radiation protection (RP)
program involved review of health physics (HP) activities primarily'related to the Unit 1 Steam Generator Replacement Project (SGRP) scheduled to begin January 2, 1993. The evaluation included ALARA planning and evaluations,.
collective dose estimates, organization and staffing, radiation protection training, procedures and work controls, and short and long term source
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reduction initiatives. In addition, routine operational health physics activities reviewed included external exposure controls, control of radioactive material, and observat son of activities in progres Results:
Within the areas reviewed, no violations or deviations of regulatory requirements were identified. The licensee continued to implement an-effective contamination control program, and external exposure controls .
appeared adequat Regarding the SGRP, the RP supervisory organization 1 establish 2d for the outage were knowledgeable and experienced, and no concerns i -were noted regarding the planned level of RP. staffing. Although the SGRP HP
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training program had not been fully implemented at the time of inspection, the l ptogram appeared comprehensive, with particular enhancements noted regarding
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9301220127 921231 PDR ADOCK 05000338
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training for general employees,- supervisors.and technicians. Review o selected ALARA job evaluations, Radiation Protection Job Guides,. procedures, and-work controls identified no concerns, and the licensee had thoroughly evaluated lessons learned during similar replacement: projects at other-facilities.- Facility and equipment upgrades were noted and should be a- . _
contributor to overall dose reduction. In general _ the licensee's plann.ing and-ALARA' initiatives for the SGRP appeared appropriate, and the collective dose projection of 540 person-rem appeared achievable and comteasurate with' the work scop ', ;
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REPORT DETAILS Persons Contacted Licensee Employees
- Atwood, Director, Nuclear Security
- Bowling, Manager, Nuclear Licensing and Programs D. Eldridge, Supervisor, SGRP Training
- M. Gettler, Manager, Steam Generator Replacement Project (SGRP)
- G. Henry, Radiation Protection Supervisor, SGRP
- G. Kane, Station Manager
- P. Kemp, Assistant Station Manager, Nuclear Safety and Licensing
- L. Leberstein, Staff Engineer, Licensing L. Lee, Senior Chemist
- T. Maddy, Superintendent, Security
- N. Martin, Supervisor, Security P. Quarles, Supervisor, Quality Assurance S. Roth, Bechtel
- J. Schlesser, ALAPA Coordinator, SGRP
- J. Smith, Manager, Quality Assurance F. Short, SGRP Training
- J. Stall, Assistant Station Manager, Operations and Maintenance
- A. Stafford, Superintendent, Radiation Protection
- Wigley, Manager, Operations and Maintenance Support S. Wilke, Project Engineer, SGRP Other licensee employees contacted included engineers, technicians, and office personne Nuclear Regulatory Commission
- C Hendren, Office of Nuclear Reactor Regulation (NRR) -
- M. Lesser, Senior Resident inspector
- 0. Taylor, Resident inspector
- A. Tillman, Security Inspector, Region II
- Indicates those persons attending the December 4, 1992 Exit Interview Organization and Staffing (83750)
The inspector reviewed and discussed with licensee representatives changes made to the RP organization since the last NRC inspection of this area conducted April 20-24, 1992, and documented in Inspection Report (IR) 50-338, 339/92-12. Regarding the routine RP organization, the inspector was irJormed that the position of Supervisor, Health Physics Operations (RadWaste) had recently been vacated. At the time of the onsite inspection, the position was being filled on an acting-basis by the Supervisor, Health Physics Operations. In addition, a Decontamination Technician position, also in the RadWaste group, had been recently vacc h d Licensee representatives informed the inspector
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that no actions were being taken to fill _the technician position, and-following the first of 1993, the position would no longer be allocated to the RP organization. Accounting-for the loss of this position, approximately 11 Decontamination Technicians and four Senior _ ,
Decontamination Technicians remained to support this function. Further, four HP Shift Supervisors were recently transferred to the SGRP, and the positions were filled with plant technicians, and contractor' technicians were used to backfill the shifted staff. The inspector noted that all '
other supervisory _ and staff positions in the RP group were filled, and the licensee continued to maintain adequate staff to conduct routine RP--
function The most significant change in the licensee's organization was the establishment of a separate temporary RP group for the SGR The inspector discussed in detail with licensee representatives the RP organizational structure for the SGRP. The inspector noted that the SGRP RP organization, although ultimately reporting to the Superintendent RP, was distinct from the routine RP organization and; dedicated to the-project. The primary SGRP organization consisted of the Radiation Protection Supervisor supported by-two Radiological Engineers, a RadWaste and Decontamination Supervisor, a HP Operations Supervisor, an ALARA Coordinator, and a Training Supervisor. Other core organizational positions consisted of contractor supervisory personnel, ALARA Specialists, Trainers, Radiation-Work Permit (RWP) Writers, and-four HP Shift Supervisors. The latter were recently transferred from the routine plant organization. The inspector noted-that this core supervisory group was fully staffed at the time of-the inspectio ,
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During the inspection, the inspector noted that the key contractor personnel were functionally co-located with the licensee personnel to facilitate communications. Observation of various activities _during the week indicated good _ coordination and interface between contractor and utility personne .
Overall, for the upcoming outage, the licensee planned to hire a total of approximately 218 supplemental HP personnel to support outage activities,-including approximately 11 Decontamination Technician.* from-Surry. For the SGRP project itself, the peak supplemental staff was -
planned to be approximately 89, including 38 Senior HP Technicians, six HP Foreman, 18 Decontamination Technicians, two Decontamination Foreman,
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seven Yard Senior HP Technicians, six Senior Dosimetry Technicians, one Instrument Technician, and-five Practical Factors Technicians.. The licensee stated that no Junior HP Technicians-were going-to be' utilized for the SGR Further the licensee stated, that all technicians planne for.the SGRP were returnees with the exception of.one;-however, this individual has experience with three prior replacement _ projects. The returnee rate ~for the Balance of Plant _(B0P) contractorostaff was_also
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expected to-be good, at approximately 95-percent. At the. time of the-inspection, approximately 14 contractor technicians had arrived onsite,
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.with the majority scheduled to arrive in mid-December.
- Based on- the licensee's organization for the outage and the division o responsibilities between the SGRP and the B0P, the inspector did not <
identify any concerns regarding the staffing levels for the SGRP. In addition, the inspector noted that personnel involved in the project
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were knowledgeable and experienced with respect to previous replacement project No violations cr deviations were identifie . Radiation Protection Training (83750)
10 CFR 19.12 requires, in part, that the licensee instruct all individuals working in or frequenting any portion of a restricted area in the health protection aspects associated with exposure to radioactive material or radiation; in precautions or procedures to minimize exposure; in the purpose and function of protection devices employed; in the applicable provisions of the Commission regulations; in the individuals's responsibilities;-and in the availability of radiation exposure dat s The inspector reviewed the licensee's training program which had been established for the SGRP including General Employee Training -(GET),
contractor health physics technician training, ALARA training, and work mock-up trainin As part of the SGRP, the licensee planned to augment the . employee
. training program in various areas. First, approximately.45 minutes was-to be added to GET in order to provide all personnel .onsite with an overview of the SGR The added training was to consist of a slide show presentation explaining the need for=the SGRP and the basic plan ofs project execution. During'the inspection, the new' training was'being'
finalized but had not yet been implemented. The' licensee-indicated that the majority of outage contractors would arrive in mid-December 1992l (subsequent to the inspection) and the new training would be incorporated'into GET at that_ time.. The inspector inquired about the training of those individuals already onsite and was_ informed _that the 45-minute training session would most likely be given to those already onsite in a one-time, large group, GET-update briefing. The inspector-
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reviewed the draft lesson plan for the GET training addendum and noted:
that the training was informative and interesting, yet'brief and
- uncomplicated. The additional training was considered a strength to the-licensee's overall' employee training. progra .
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Second, the licensee developed a training session for contractor -
supervisors that focused on ALARA issues and methods. According to the licensee,-the traini,g was designed to motivate the supervisors to promote the ALARA concept within the their working groups / section Most of the contractor trainees that were participating in the: training had been onsite since February 1992, but were now receiving this ALARA training so it would be " fresh" during the upcoming outage. The licensee representatives in charge of the training indicated that they had received a 10t of positive feedback about the training and reported
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excellent participation in the sessions thus far. The licensee expected the additional ALARA promotion at the worker level to have a positive effect on the overall collective dose for the SGRP and other outage activitie The inspector noted the supervisor ALARA training to be another strength in the licensee's training progra Third, the licensee added a portion of SGRP-related training to the site-specific training sessions for contract HP technicians. The routine HP training consisted of two days of training specific to the North Anna site for all incoming junior and senior HPs-. A written examination of approximately 100 multiple choice questions was given at the end, with 70 percent score required to pass. Junior HPs were not required to take the test. The additional SGRP training was designed to be three more days of training for all HPs with an another 50-question examination at the end. Again, the passing grade was a 70 percent score, and only senior HPs would be required to take the test. As noted above, no junior HPs were hired for work involving the SGRP. Also, junior HPs are always required to work under the supervision of senior ,
HPs. Along with the enhanced training, additional job performance measures (JPMs) were being developed and added to the Production Work Evaluation Records (PWERs). Thus, these tasks as well as all of the other HP-related tasks would have to be satisfactorily completed prior to conducting work. As noted above, outage contractors were due to -
arrive in mid-December 1992 subsequent to the inspection and the new HP-SGRP training would be started at that time. The inspector noted that the enhanced HP technician training appeared extensive and thoroug However, the-inspector informed the licensee that the training would be reviewed further following implementatio Finally, the licensee had established an extensive program for mock-up
. training on specific SGRP-related tasks. The program consisted of approximately 19 mock-up activities and included both qualification on the specific work evolution to be performed as well as- ALARA and health physics practices. In accordance with Radiation Protection Guideline, VIII.A, SGRP Health Physics Mock-up' Training; dated September 22,'1992, the licensee had established specific performance-criteria-for each mock-up, and satisfactory completion of health physics performance measures were required to be evaluated by; a qualified trainer / evaluato Specific mock-up activities planned for the project included resistance-temperature detector (RTD) Sypass removal, mechanical cutting of the se-- a-T- " * -' s +---a wae ur-2 m--w vm -s- me w m e-= - + - -+--- ,r
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reactor coolant system (RCS) piping, decontamination of RCS pipe ends, installation and removal of shielding, installation and removal of the ,
tripod debris dams, various welding and machine activities, radiography i set-up, operation of the steam generator transport cart,-placement of R the new steam generator, and the cold leg elbow removal (if the three- a cut method is required). :
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The inspector toured the SGRP mockup facility and noted that the licensee had made a good effort to make the mock-ups as realistic as possible, including the placement of cameras, simulated shielding, and support structures to simulate actual working conditions. Although no actual qualification mock-ups were reviewed during .the inspection,- the -
inspector directly observed various workers practicing on various_ mock -
ups including the full steam generator shell and support tower, RCS pipe cutting operations, and girth weld techniques. In addition, the inspector attended ALARA Mock-up Briefings for shielding and decon workers as well as RCS welders. The inspector noted that the sessions
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included discussioris on how the work was to be performed and appropriate emphasis on dose reduction and housekeeping technique Although at the time of the inspection the program hac'. not yet. been
. fully implemented, based on the current review, the faspector concluded
, that the licensee had established a comprehensive training program for the SGR No violations or deviations were identifie . Planning and Preparation (83750)
10 CFR 20.l(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures as low as reasonably achievable, , Outage Collective Dose Projection As of October 30, 1992, the licensee'sicollective dose projection for the SGRP was approximately 540 person-rem, of which _
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approximately 36 person-rem was associated with the RTD piping elimination. However, the lice."ee continued to target for a collective dose goal of approximately'500 person-rem The 5_40 person-rem projection was-the latest revision from previous estimates of 688 and 572_ person-rem,' and reflected final job scopes and person-hour estimates determined by the licensee and the contractor. The earlier dose estimates incorporated person-hour estimates based on industry averages. In addition, the current projection was based on a_two-cut process.for steam generator removal (one cold leg- and one hot leg). If a three-cut-method (two cold leg and one hot leg).must be utilized to allow-for installation of one or more of the new steam generators,- th licensee estimated approximately 12 addi_tional person-rem per generator would be required. The inspector noted, however, i'i'
the-12 person-rem did not include any additional pipe
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decontamination that would also be required. The licensee's dose estimates for major work evolutions associated with the SGRP were as follows: {
Work Evolution Dose Estimate frem)
RTD Bypass System Removal 35.794-Cut RCS Piping and Install Supports 43.818 Machine Weld Edge, Perform Welding of RCS Pipe, and Remove Supports 75.103 Install and Remove Scaffolding 30.672 Perform RCS Pipe End Decon and Install / Remove Internal Shielding 23.768 Remove / Install S/G Lower Support feet and Remove Hot Leg Whip Restraints 21.665 Steam Dome Cut, Preheat Lower Assembly,-
and weld-top hat shield 22.509 Remove / Install Insulation 53.378 Install / Remove Shielding 19.944 Remove / Replace Blowdown Piping 26.779-Remove / Replace / Modify RCS Small Bore Piping and Valves 23.580 Total 377.010-As of November 30, 1992, the licensee had expended approximately 7.2 person-rem during the two previous refueling outages for SGRP'
wor These activities included optical templating, bio-shield ,
cutting, engineering walkdowns, and health physics surveys. - This
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dose was not included in the current estimate and will be added' to the collective-dose at the completion of the projec '
In addition to the above, the. licensee had established dose and personnel contamination goals for both utility and contractor
. personnel. The personnel contamination goal was 110 for;the SGR Licensee representatives stated that' contract incentives were employed to encourage contractor achievement or betterment of established goal The dose goal for the entire 110 day-outage, including the SGRPf dose, was set at approximately 901 person-rem. Major jobs that are expected to expend significant portions of the B0P dose. of 361 person-rem include -installation of the new RTD:. system (66 person-rem), hanger inspection / repair (38 person-rem), and decontamination activities;(21 person-rem).
Overall,. the licensee's dose estimates for the SGRP and other outage activities appeared realistic,1 achievable and commensurate
. with the' work scop No~ violations or deviations were identifie ,
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7 Preplanning and Lessons Learned Assessment The inspector discussed with licensee representatives pre-outage planning activities including evaluation of lessons learned from
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previous steam generator replacement project In particular, the inspector reviewed and disuussed with SGRP ALARA personnel a-Lessons Learned Report, dated Octobe'r 19, 1992. The report addressed RP lessons learned and their potential applicability to
, the North Anna project from past SGRPs at Plants ~ D.C. Cook, Surry, Palisades, Point Beach, and H.B. Robinson. Review of several of the lessons learned items revealed that the licensee had appropriately evaluated the items for applicability and/or initiated actions to address the potential concern. Several of the items discussed with the licensee included potential alarming of area radiation monitors during steam generator inovement, use of heavy-mil plastic suits, closed _ circuit television (CCTV) setup for viewing at both the HP Control Points in containment and the Containment Access facility (CAF), and RCS tripod and internal shielding. In addition, the inspector noted that the licensee had also visited Millstone _to evaluate selected ongoing SGRP activitie During the onsite inspection, the inspector observed the conduct-e of an RP SGRP planning meatin The_ meeting was conducted to specifically address progress on outstanding action item Approximately 57 items were being tracked with individuals clearly assigned for each item. The inspector noted that the status of each item was discussed in detail, and-the licensee appeared to have control of the items remaining for ' completio Based on the above, the inspector concluded that the licensee's preplanning and research for the'SGRP-was thorough, and t
appropriate consideration had been-given to previous lessons learne No violations or deviations were identifie Steam Generator Drop Analysis The -inspector ev:ewed the licensee's analysis of potential off-site consequer.ces aesulting from an old steam generator dro accident durin9 the SGRP_ outag The two-drop scenarios-of-interest _were a six-foot drop off the transport cart and c 20 foot
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drop from the equipment hatch platform. The 30 foot drop scenario
- was found-to be- the-primary ' concern as it could possibly result in breach of the steam' generator at the. nozzle end cap welds. The
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, licensee informed the inspector that a device would be used-to
alleviate the possibility of breaching the steam generator from a
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six foot-drop. The device, an impact. ring, is-designed to lock in:
place around the steam generator and act as a shock absorber" in csse of a-drop during movement.
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The inspector reviewed and discussed with contractor personnel Calculation No. 21809-M-02, dated September 18, 1992, which outlined the assumptions and methodology for the assessment of offsite doses due to a breach of the steam generator. The calculation utilized previously measured steam generator dose rates and waste stream isotopic data to estimate the radioactivity contained within the steam generators. Using conservative assumptions, a total activity of 234 curies was determined (per generator) consisting primarily of iron-55, cobalt-59, and cobalt-60. Further, the calculation assumed that approximately 10 percent of the steam generator contents would be released due to the drop and that one percent of this would be in a form that was transportable to the exclusion area boundary approximately _
1350 meters away. Utilizing North Anna !SAR dispersion factors and meteorology and Regulatory Guide 1.109 dose conversion factors, exclusion boundary doses were determined to be approximately 0.027 millirem to the whole body and 6.8 millirem to the lun The inspector noted that the drop analysis dose assessment methodology was similar to that performed for other SGRPs, and no concerns were noted. The doses at the exclusion area boundary o were minimal and a small fraction of the 10 CFR Part 100 limit No violatione or deviations were identifie . Work Scope and Controls (83750)
The inspector reviewed Design Change (DC) 90-13-1, Steam Generator Repair, and DC 89-40-1, RTD Bypass Elimination, as well as discussed with licensee personnel the scheduling and the manner in which various work activities were to be performed. In addition, the inspector .--
reviewed and discussed the following ALARA Evaluation (AE) packages to determine the appropriateness of radiological controls:
AE !00, RTD Bypass System Demolition
- AE lb2, Rig In/0ut, Transport, and Prepare Unit 1 Steam Generator Lower Assemblies
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AE 103, SGRP Rigging / Jacking Operations in Unit 1 Containment
AE 104, .SGRP Scaffolding Installation and Removal
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AE 106, Template, Cut, Machine, Weld and F0SAR RC Pipe
AE 107, RCS Pipe Ending Decon and Internal Shielding
- -AE 112, Radiography of RC-Nozzles and Girth Weld
AE 118, Decon Facility Operation The inspector noted that the various AEs contained the draft RWPs which supported the activities, person-hour estimates, dose projections, and historical radiation surveys, and described the various contamination
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establishment of low dose waiting areas, and_ use of temporary shielding The inspector noted that each AE was reviewed by the Station ALARA Committee or the ALARA Coordinating Committee, as required, depending'on'
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the exposure estimate. In addition, each AE required an ALARA re-evaluation during work evolutions when 50 and 90 percent of the dose projection was received, and required work to be stopped and re-evaluated if actual doses reached 125 percent of the projectio Other measures discussed with the licensee included:
(1) establishment of " street clothes" clean areas in containment during feedwater, Main Steam Line, and Girth Welding; (2) RCS pipe end decontamination and use of the tripod debris dams and internal shielding; (3) RTD piping removal and handling procedures; (4) scaffolding planning to ensure dose effective utilization; (5) maintaining secondary water level as long as possible to reduce dose; (6) methods of girth and pipe welding; (7) methods of RCS pipe -
cuts; and (8) the process of withdrawing the steam generators from containment and transporting them to the storage facilit Regarding the latter, the inspector was informed that prior to removal from containment, the licensee plans to decontaminate the generators to less than 10,000 disintegrations per minute (dpm) per 100 square centimeters and apply a water based encapsulant paint to prevent any spread of residual contamination. The nozzles will be capped with a circumferential weld and the aforementioned impact ring will be added to protect the generator in the event of a drop accident. The inspector noted that RP will escort the steam generators as they are transported to the Old Steam Generator Storage Facility since the path is out of the protected and restricted areas. The travel route and surrounding area are planned to be evacuated with health physics verification of restricted area boundary dose rates as the generators are transporte In addition, thermoluminescent dosimeters (TLDs) will be placed along the route to determine actual exposure. The inspector noted no concerns regarding the licensee's preparation for the removal and transpor _
In general, through the review of the selected ALARA packages and Radiation Projection Job Guides (RPJGs), and discussions with licensee ALARA personnel, the inspector noted no concerns regarding the radiatien protection and contamination control requirements and measures planne The inspector noted, however, that many RWPs were still in draft at the time of the inspection, and many of the RPJGs and Work Procedures and Inspection Requirements (WPIRs) continued to be revised and/or develope No violations or deviations were identifie . Facilities and Equipment (83750)
For the SGRP, the licensee made various facility and equipment upgrades including the new Decontamination Facility, the CAF, CCTV, upgraded communications equipment, a remote monitoring system, and the Old and New Steam Generator Storage Facilities. Following is a brief discussion of each:
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- Decontamination Facility: This temporary facility, located in the protected area, was constructed solely for the decontamination of tools, equipment, and various other materials generated from the SGR The licensee estimated approximately 6500 cubic feet (ft )
of metals and other non-compactibles to be generated by the project, of which approximate b 80 percent should be able to be decontaminated to less that detectable activity at the facilit The facility is designed for both abrasive liquid and carbon dioxide (C02 ) cleaning. It also utilizes a 4000 cubic feet per minute (CFM) HEPA ventilation unit which has a local alarm for low flow, low differential pressure, and loss of power. At the time of the inspection, the facility had not yet been declared fully operational. The licensee was in the process of testing the HEPA -
unit, establishing HP controls, installing a whole body frisker, and completing procedures and a decontamination scheduling pla a
- Containment Access Facility (CAF): lhe CAF is also a temporary facility located within the protected area which was established to provide a dedicated facility for the HP control of SGRP work and personne BOP workers will continue to use the normal HP Control Point for access to the RCA. According to the licensee, )
the facility can accommodate approximately 700 workers and was designed to be self-sufficient. Change rooms, dosimetry control, RWP briefings, and all normal HP Control Point activities are to e be conducted from the facility for the SGRP. The facility will also have video " surrogate tour" (Videodisc Information Monitoring System (VIMS)), CCTV, radio communications, and remote monitoring system capabilities. Workers are to access the normal RCA via a tunnel that will be constructed between the two areas, and upon exiting the RCA they will process through the normal personnel decontamination area (PDA). The licensee stated that the number of whole body friskers in the PDA was being increased to 8 to -
acconnodate the higher traffic. At the time of the onsite inspection, this facility nor the tunnel had been completed or fully stocked with supporting equipmen Closed Circuit Television (CCTV): Licensee representatives stated that approximately 15 cameras were available for use during the outage,11 of which had been designated far use. According to the licensee, two cameras were going to be tc lized te monitor the containment general area, and three woulo be utilized in each generator cubicle. In addition, the CAF will contain five screens to allow viewing of each cubicle and the general area camera Viewing capability will also be available at the containment HP Control for each generator cubicle. This system will be beneficial in allowing personnel to view / monitor workers from low dose area Remote Monitorina System (RMS): For the SGRP and use thereafter, the licensee purchased a RMS which provides personnel teledosimetry capability for real-time dose and dose rate data e
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monitoring and recording. Specifically, a number of personnel wearing multiple dosimeters each can be individually monitored from a remote location, In addition, the licensee plans to implement the continuous air monitoring capability of the system, if the necessary equipment arrives in time for the outage. The '
licensee plans to use the system for personnel monitoring primarily for the RTO removal, and following completion of that work, the system will be used to monitor area radiation level Licensee representatives stated that computer terminals tracking individual dosimeter readings within a cubicle will be monitored at each respective HP Control Point within containment. In addition, the CAF will have separate terminals for monitoring each cubicle as well as the master terminal which will- track all the active dosimeters. Use of this system should allow for rapid =
identification of potential dose problems as well as reduce the dose associated with health physics coverag Radio Communications: The licensee purchased and tested new radios for communications between workers and health physics during the outage. The system included three active channels plus a repeater channel to allow communications outside of containmen Workers, the HP Control Points, and the CAF will all have radio communications capabilities. The inspector observed a demonstration of the radio system and audibility appeared good, even while using a respirato * New Steam Genera W Storage Facility: This is a temporary hangar-type structure bui't to protect the steam generators from the elements until they are installed. The structure is a metal building with large sliding doors to facilitate movement of the generators and is located outside the protected are Old Steam Generator Storage Facility: This is a large reinforced
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concrete structure located in a field within the owner-controlled area built to store the old steam generators until such time as
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the site is decommissioned. One end of the. structure was left open during construction and will be closed and sealed once the-old steam generators are' situated insid Overall, the licensee's ~ investment in improved facilities- and equipment for the outage was considered a program strengt No violations or deviations were identifie . Dose Reduction Initiatives (83750) Outage Activities The inspector discussed with licensee representatives various dose reduction initiatives for the outage including RTD Bypass elimination,'early boration and' peroxide shock, hot spot . flushing, and use of temporary shielding.
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The. current outage schedule _ indicated that the RTD system was to be eliminated on approximately Day 10. By removal of the system-early on, the licensee anticipates an dose reduction factor of two to five. As indicated previously, the inspector noted that.the lower dose rates were factored into the latest SGRP dose projection. Long term dose benefits will be seen not only through reduced general area dose rates but also through less maintenance associated with the retrofit equipment. The licensee estimates the dose savings in the future due to RTD removal to be 60 person-rem per outag The inspector was informed-by the licensee _that if Unit I did not go offline unexpectedly before the scheduled January 2,1993, -
outage start date, then a controlled shutdown using an early boration and peroxide shock would be undertaken. The Corporate Chemist has been researching the technique for some time with other plants in-order to optimize the potential benefit The licenser also participates in the Electric Power Research Institute (EPRI) study being conducted on the techniqu According to the licensee, North Anna does not have good historical data on the use of early boration/ peroxide shock because the technique has never been fully and pr_operly implemented. Past attempts included errors which resulted in dose rates eithar not being significantly lowered, or in some cases, even being elevated, defeating the purpose of the technique. The licensee indicated that-the potential benefits of using the technique outweigh the inherent risks such that another attempt was justified. However, due to the lack of historical data in using the technique, the 1icensee did not factor the potential benefits of a " good" early boration/ peroxide shock into the overall dose estimates. As indicated above, the_ licensee's dose projection for the SGRP is 540 person-rem, but the licensee has- a -
" goal" of 500 person-rem. If the early boration technique is utilized to its full potential, the licensee could possibly save all of_ the 40 person-rem difference- through significantly lower general area do e rate The licensee also plans to flush known " hot _ spots" _during the initial phases of shutdown.- The hot spots scheduled for flushing include the Pressurizer Spray Valves and -the Bypass Valve. Again, these flushings were not factored into the dose projection, and could provide for significant dose saving' The inspector reviewed a number of temporary shielding requests (TSRs). The requests mainly involved lead blanket shielding that will either be hung _like curtains for shadow-shielding or wrapped arrund piping where close contact is required. Seismic and design loading (dead weight) evaluations were performed as required. -The inspector noted that many of the requests did not contain-calculations of the net _ dose _ savings--that were expected if the -
shielding requests were approved. The inspector was-informed that,-in those cases, it was known that there would be a net dose
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saving and that calculations would be performed as part of the post-job evaluations af ter actual dose rates before and af ter shielding were know Overall, the inspector had no concerns with the licensee's plans to reduce dose during the outag No violations or deviations were identifie b. Long Term Initiatives in addition to the inherent exposure reduction features of the new steam generators such as the use of Inconel-690 tubes, quatrefoil --
tube support plates, and additional handholes, the inspector discussed various other long term dose reduction initiatives considered for implementation. These includ-3d electropolishing of the steam generator bowl, implementation of a modified boron-lithium chemistry program, and stellite valve replacemen The licensee considered electropolishing the steam generator bowls, but decided against it after researching the matte The steam generators were initially ordered with a specification that the roughness of the bowls be no greater than 63 RMS (roughness of a surface is measured using the unit RMS). The licensee received the steam generators with a roughness of approximately 20 RM According to the licensee, very little dose would be saved in the future if, starting at 20 RMS, electropolishing was don Therefore, based on their analysis, the licensee opted to not electropolish and only mechanically polish the bowl As part of the initial justification for not electropolishing the steam generator bowl, the licensee planned implementation of a -
modified boron-lithium chemistry program following replacement of i
the steam generators to reduce the potential for plating of corrosion and activation products on steam generator surface However, since that time, the fuels group re-evaluated this and recommended that until all fuel in the core is replaced with low tin cladding that implementation be postponed (would be accomplished within the next few outages). The basis for the decision was the potential for higher cladding corrosion due to the tin content coincident with high operating and exit temperatures at North Anna. At the time of the inspection, however, the licensee stated that based on recent EPRI studies regarding the effectiveness of the modified chemistry program, a final decision regarding implementation had not been determine Progress in this area will be followed during future inspection In addition to the source term reduction initiatives discussed above, the inspector was also informed that the licensee planned to replace approximately 11 valves during the outage with r1
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non-stellite trim valve This was considered a positive _ step by_
the licensee in the implementation of their five-Year Source Term Reduction Pla Overall, the inspector had no concerns with the licensee's long term plans to reduce dos No violations or deviations were identifie Routine Radiation Protection Activities (83750) External Exposure Controls Technical Specification (TS) 6.12.2 requires that areas accessible to personnel with radiation levels greater than 1000 mR/hr be provided with locked doors to prevent unauthorized entry in addition to the requirements of TS 6.1 _
The inspector reviewed licensee Deficiency Report data for the period May 1 through December 1, 1992, and noted no examples of the failure to properly limit access to locked high radiation area Two previous examples of such failures were identified in
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IR 50-338, 339/92-12 as a non-cited violation. During tours of various plant areas, the inspector verified that all locked high radiation areas were properly secured as required. Inadditjon, the inspector observed that .several areas (such as the Demineralizer Alley and the Waste Solids Area) had been downgraded from locked high radiation area status since the previous inspection. Licensee representatives stated that this cffort had been ongoing, and the number of locked high radiation areas had been reduced to approximately nine. The inspector observed no-concerns in this are Also, during tours of the Auxiliary Building, the inspector observed use of- flashing green lights to designate Low Dos Waiting Areas; however, all such areas were not denoted with similar lights. The licensee stated that the lights were being -
tested, and the program for their implementation had not yet been finalized. The inspector noted the licensee's initiative _in_this area and the apparent ALARA benefits, particularly in high dose gradients areas. However, the presence of the lights had not been incorporated in GET so workers would understand their meaning. At-the exit, the licensee stated that upon finalizing the scope of-the program, the appropriate material would be incorporated into GE From a review of-the licensee's Radiation Protection Summary
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Report,--the inspector noted that the station collective dose-through October 31, 1992,_ was approximately 583 person-rem-as compared to a prorated goal of 604 person-rem. Approximately 450 person-rem of this exposure was associated with the forced Unit 1 outage and the Unit 2 refueling outage conducted earlier-
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this year, and is addressed in NRC IR 50-338, 339/92-12. In general, the remaining dose expended was associated with routine operations, and the inspector was informed that the licensee had recently achieved its lowest dose month- since 198 Based on the limited review of this area, the licensee appeared to be adequately controlling external exposure No violations or deviations were identified, Control of Radioactive Material At the time of the onsite inspection2 the licensee tracked approximately 1500 square feet (ft ) of floor space as-contaminated with approximately 200 ft* of the total due to ongoing maintenance activities. This equated to about 1.5 percent ,
of the 95,520 ft 2radiologically controlled area (RCA).
Discussions with licensee RP personnel noted that this was less than the target goal of 2600 ft .2 In addition, the inspector noted that through October 31, 1992, approximately 140 personnel contaminations had occurred in 1992 compared to a prorated goal of 178 for the same perio During tours of the Auxiliary Building, Spent Fuel Building, and several waste storage and processing areas, the inspector noted-continued use of excellent contamination control practices by the licensee. These practices included the labeling of contaminated floor drains as well as the use of specially designed gratings to accommodate drain hoses, replacement of pipe flashing with a bakelite material to facilitate decontamination, sticky pads at step-off pad and egress points, use of " green" board as a barrier for highly contaminated areas, maintenance of floor coatings, and use of catch containments, where appropriat Regarding-the latter,.the inspector was informed that the licensee maintained:
approximately-13 catch containers in service (not all on contaminated-systems), nine of which required an outage for-initiation of the.needed repair Further, the inspector was '
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informed due to the status of facility contamination, there are no areas which require dressout by operators for the-conduct of their routine surveillances. Overall, the -inspe_ctor observed excellent-- '
radioactive material conditions and housekeeping practice In addition, the inspector verified through independent-
-measurement as well as direct cbservation that radioactive
- . materials were posted / labeled in accordance-.with the radiation
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hazard present with one noted exception. .During tours of.the Auxiliary Building, Elevation 244 feet, the inspector observed three hot spots which were labeled " Hot Spot," but did not: include information regarding the associated dose rates. Investigation byc
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the licensee noted that two of the labels were remnants 'of the old sticker system used to label _ hot spots, and the third was missing; (
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the dose rate because it had fallen off the hot spot tag. The
,- dose rate label was retrieved by'the licensee in the vicinity-of-the tag. Subsequently,_ the licensee conducted surveys of the
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piping areas in question and determined-that the labeled areas did not meet the hot spot criteria, and the labels and/or. tags were.
L removed. The levels ranged from 100-300 millirem per hour contact and 15-300 millirem per hour general area. During tours of other -
plant areas, no similar posting discrepancies were noted.-
Based on the inspectors observations and data review, the licensee appeared to be effectively controlling contamination at its-sourc No violations or deviations were identifie Program Implementation The inspector observed an evolution in which a Unit I refueling cleanup filter was changed out. A tent with a dedicated HEPA ventilation -system was erected over the work area and appropriate measures were taken to prevent the spread _of contamination and lessen the amount of radiation dose received. The filter was removed without incident and placed in a shipping cask for disposal. The inspector noted-that the licensee had prepared for the job well and utilized good controls during the job executio No concerns were noted by the inspecto No violations or deviations were identifie . Exit interview (83750)
The inspection scope and results were summarized on December 4, 1992, with those persons indicated in Paragraph I above. The inspector--
summarized the scope and-findings of_the inspection. ;The licensee
.: acknowledged the inspector's comments, and no dissenting comments were f received from the licensee. Although proprietary information and/o l i-processes were reviewed during the inspection, the proprietary ~ nature of these documents or processes have been deleted in this repor .
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