IR 05000338/1993001
| ML20056C094 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/12/1993 |
| From: | Boland A, Bryan Parker, Rankin W, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20056C091 | List: |
| References | |
| 50-338-93-01, 50-338-93-1, 50-339-93-01, 50-339-93-1, NUDOCS 9303300062 | |
| Download: ML20056C094 (23) | |
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,#p # %gfg NUCLEAR REGULATORY COMMisslON 2 o REGION 11
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101 MARIETTA STREET, ATL ANTA. GEORGI A 30323
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BAR 1 2 1993 Report No /93-01 and 50-339/93-01 Licensee: Virginia Electric and Power Company '
Glen Allen, VA 23060 Docket No and 50-339 License Nos. NPF-4 and NPF-7 Facility Name: North Anna 1 and 2 Inspection Con ted: uary 15-22, February 1-5 and 11, 1993 Inspectors: % 'A M 03//2/97 A. B 'and, R ion Specialist Date Signed
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B. Pa ker, Ra tion Specialist nhzin Date Signed
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E. Tefta, P.E., Senior Radiation Specialist Date ' Signed Accompanying Personnel: C. Hinson Approved by: /d 0 3/ .3 W. Rankin, Chief )[ Date Mgned Facilities Radiation Prot (4 tion Section /
Radiological Protection and Emergency .
Preparedness Branch t Division of Radiation Safety and Safeguards ,
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SUMMARY Scope: ;
This routine, announced inspection of the licensee's radiation protection :
program involved review of health physics activities related to the current '
Unit 1 outage, and associated steam generator replacement project. Th specific areas evaluated included program Organization and Management Controls, Health Physics Technician Training, Operational and Administrative !
Controls, Internal and External Exposure Monitoring and Assessments, ,
Radioactive Haterial and Contamination Controls, and ALARA program .
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Results:
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The radiation protection organization and staffing appeared adequate to !
support ongoing outage activities. The health physics technician training for steam generator replacement project workers was conducted in accordance with approved procedures. The internal and external exposure control programs were 9303300062 930312 PDR ADOCK 05000338 O PDR <
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effectively implemented with all exposures less than 10 CFR _Part 20 limit Contamination. control and housekeeping practices were consistent with the stage of outage activitie Identified program strengths included the supplemental steam generator replacement project training for workers and supervisors, implementation of upgraded facilities and equipment-for the steam generator replacement project, continued implementation of a proactive respirator reduction program, and overall ALARA program implementatio Weaknesses regarding the implementation of the Radiation Work Permit program and the posting of notices to workers as well as the control of flammable material in proximity to radioactive material were identified. With the noted exceptions, the licensee's radiation protection program was conducted in accordance with approved procedures, and functioned adequately to protect the health and safety of plant worker Two non-cited violations were identified: NRC-identified Non-cited Violation of Technical Specification 6.11 for the failure to follow Radiation Work Permit Procedures (Paragraph 6.a) NRC-identified Non-cited Violation of.10 CFR Part 19.11 for the failure to adequately post required notices to workers (Paragraph 6.b)
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REPORT DETAILS Persons Contacted Licensee Employees J. Breeden, Supervisor, Radiological Analysis K. Burnette, Supervisor, Station Safety and Loss Prevention E. Dreyer, Supervisor, Health Physics Technical Services D. Eldridge, Supervisor, Steam Generator Replacement Project *
(SGRP) Training ,
R. Evans, Jr., Health Physics Supervisor - Operations l
- M. Gettler, Manager. SGRP i
- G. Henry, Radiation Protection Supervisor, SGRP
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- G. Kane, Station Manager -
- P. Kemp, Supervisor, Licensing ;
- J. Leberstien, Staff Engineer, Licensing !
L. Lee, Senior Chemist- I L. Jones, Supervisor, Radiological Engineering l T. Peters, Supervisor,. Exposure Control l D. Plemen, Health Physics Supervisor - Operations, SGRP
- B. Shriver, Acting Assistant Station Manager, Nuclear Safety l Licensing ;
C. Smith, ALARA Coordinator :
- J. Smith, Manager, Quality Assurance '
- A. Stafford, Superintendent, Radiation Protection ,
- J. Stall, Assistant Station Manager, Nuclear Safety and Licensing
- Thornton, Director, Chemistry and. Health Physics )
(Corporate)
Other licensee employees contacted included engineers, technicians, and office personne Nuclear Regulatory Commission
- Lesser, Senior Resident Inspector
- Attended Exit Meeting on February 5, 1993 Organization and Management Controls (83729)
The. inspector reviewed and discussed with licensee representatives, changes made to the radiation protection-(RP) organization, since the-last inspection of this area conducted November 30 - December 4,1992,-
and documented in Inspection Report (IR) Nos. 50-338, 339/92-26. -The inspector noted that no significant changes had been made to the organizational structure or lines of authority as they related to the routine RP function. The position of Supervisor, Health Physics i
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Operations (RadWaste), continued to be vacant with the position being filled on an acting basis by the Supervisor, Health Physics Operation In addition, the licensee continued to maintain a core technician staffing of 57 health physics (HP) and decontamination technician As discussed in IR Nos. 50-338, 339/92-26, the licensee had established a separate RP organization for the steam generator replacement project (SGRP). This group was distinct from the routine organization and was responsible for coordinating and supporting only activities related to the project. Health physics activities related to non-SGRP (balance-of-plant (B0P)) work were managed through the routine RP organizatio Although much of the core SGRP organization was in place during the previous inspection, most of the technicians for the SGRP and routine outage organizations had not yet arrived onsite. During this inspection, the inspector noted that the licensee had implemented the overall staffing plan consistent with that previously reviewed. As of January 18, 1993, 227 supplemental HP personnel were onsite to support the utility staff for the outage. This staffing included 94 Senior HP Technicians, 20 Junior HP Technicians, two ALARA personnel, six Trainers, two Radiation Work Permit Writers, 67 Decontamination personnel, 20 Dosimetry personnel, 12 Foreman, three Instrument Technicians, and one Planning Superviso Consistent with the licensee's previous planning, no Junior HP Technicians were assigned to the SGRP. The licensee experienced a high return rate for Senior HP Technicians assigned to the replacement projec During the inspection, the inspector attended various outage planning meetings related to both the B0P and SGRP activities. Work activities occurring during the inspection period included the reactor head lift, upper internals lift, defueling, main steam and feedwater pipe cuts, rigging and transport of the steam generators, insulation removal, and pipe end decontamination. The inspector observed good participation in the meetings by HP personnel and appropriate emphasis was placed on HP-related concerns by outage management. In addition, adequate coordination and communications were observed between the SGRP and B0P HP personne Based on discussions with licensee representatives and observations of activities in progress, no concerns were identified regarding the licensee's organization and staffing. The staffing levels appeared adequate to support ongoing outage activitie No violations or deviations were identifie . Radiation Protection Training (83729)
10 CFR Part 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
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l individual's responsibilities; and in the availability of radiation ;
exposure data, y The inspector reviewed the licensee's training program which had been !
established for the SGRP including General Employee Training (GET), ,
l contractor HP technician training, ALARA training, and work mock-up ?
training, and noted many augmentation j i
First, approximately 35 minutes was added to GET in order to provide all i personnel onsite with an overview of the SGRP. The added training l consisted of a slide show presentation explaining the need for'the SGRP
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and the basic plan of project execution. The inspector reviewed the ;
I slide presentation and noted that it provided a basic understanding of .
! the steam generator replacement organization and site facilities. Basic !
plant layout, reactor operation, radiation work permit (RWP), ALARA and !
HP procedures and practices were also provided. Tne presentation I provided a good overview of outage activities. At the time of l inspection, approximately 390 workers had viewed the SGRP orientation !
slide show. Licensee representatives indicated that 23 workers were i l lacking the training and that their management had been notifie l 1 ;
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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 training was designed to motivate the supervisors to l promote the ALARA concept within their working groups / sections. The l licensee representatives in charge of the training, reported that the i training was completed for onsite personnel, and indicated that a . lot of !
positive feedback had been received about the training. They also !'
indicated that, due to the excellent response, other classes may be held for some of the contractors' headquarters personnel. The licensee hoped that the promotion of the ALARA concept from the supervisory level would ;
have a positive effect on the overall collectivi dose for the SGRP and j other outage activitie l Third, the licensee added a portion of SGRP-related training to the i 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 HP Technicians. A !
written examination of 100 multiple choice questions was given at the l end, with a 70 percent score required to pass. Each exam was slightly different in that it was randomly generated by a computer utilizing a
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large bank of questions. By licensee procedure, Junior HPs were not :
required to take the exams, although most generally chose to. The l additional SGRP training consisted of three more days of training for !
all HPs with another 50-question examination at the end. Again, the l passing grade was a 70 percent score, and only Senior HPs were required i
- to take the exam. As previously mentioned, no Junior HPs were hired for !
i work involving the SGP.P, and Junior HPs were always required to work l under the supervision of Senior HPs during BOP activities. Also, all HP i shift supervisors and foremen took the SGRP training. The inspector ;
reviewed selected training records with licensee representatives, and j noted that all cf the contract HPs (Juniors and Seniors) passed the ,
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site-specific training with one exception. That individual was hired as :
a Senior HP, and due to failing the entrance examination part of GET, !
was downgraded to a Junior H Likewise, all of the contract HPs 1 (Junior and Senior) passed the SGRP-specific training with a few [
exceptions. Two Senior HPs failed the 50-question SGRP exam the first ;
time, but after a short review, both passed after taking a second exa j In addition, three Junior HPs failed the 50-question SGRP exam; however, ;
one of them chose to take another exam and passe i
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Along with the enhanced training,. additional job performance measures l (JPMs) were added to the Production Work Evaluation Records (PWERs). i These tasks, as well as all of the other HP-related tasks, were !
" hands-on" demonstrations that had to be satisfactorily completed prior !
to conducting work. The inspector noted that all of the enhanced HP _!
technician training appeared extensive and thoroug r Finally, the inspector reviewed portions of the ongoing mock-up training F conducted by the licensee. Specific mock-up activities for the project i included resistance temperature detector (RTD) bypass removal, !
mechanical cutting of the reactor coolant system (RCS) piping, !
decontamination of RCS pipe ends, installation and removal cf shielding, !
installation and removal of the tripod debris dams, various welding and machine activities, radiography setup, operation of the steam generator transport cart, placement of the new steam generator, and the cold leg ,
elbow removal. -The inspector reviewed the mock-up training conducted j for the RTD bypass removal, and verified the training of the individuals i that were required by the licensee to receive mock-up training and i participated in the demolition. The inspector toured the SGRP mock-up j facility, and noted that the licensee had made a good effort to make the j mock-ups as realistic as possible, including the placement of cameras, j simulated shielding, and support structures to simulate actual working !
conditions. In addition, the inspector attended initial mock-up l training for the contract RCS pipe end decon workers, and noted that the l session included discussions on how the work was to be performed, and i appropriate emphasis on dose reduction and housekeeping technique i l
During facility tours, the inspector was accompanied by various contract i and licensee HP technicians. All the technicians appeared familiar with l site HP procedures, site layout, and plant systems, and were aggressive f in improving the RP program. Overall, the inspector concluded that the !
license had established and conducted a comprehensive training program .l for the SGR j i
No violations or deviations were identifie l 1 External Exposure Controls (83729) l
10 CFR Part 20.101 requires, that no licensee possess, use, or transfer !
licensed material in such a manner as to cause any individual -in a :
restricted area, to receive in any period of one calendar quarter a- !
total occupational dose in excess of 1.25 rem to the whole body, head I and trunk, active blood forming organs, lens of the eyes, or gonads; i
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t 18.75 rem to the hands, forearms, feet and ankles; and 7.5 rem to the !
skin of the whole bod i I Whole Body Exposure Monitoring l The inspector reviewed 1993 first quarter external exposure records for workers involved with RWP No. 93-2-3002, RTD Bypass ,
Demolition. Discussions with licensee representatives revealed .
that multiple badging was provided for these workers due to the l potential for non-uniform exposure, for the records reviewed, the
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maximum whole body exposure received for this job evolution was ;
1100 millirem, by self-reading dosimeter (SRD).
l The inspector was informed that the remote monitoring '
teledosimetry system (RMS) as well as SRDs were utilized for the ;
multiple badging discussed above. According to the licensee, the ,
RMS worked effectively in monitoring and controlling doses during .
the work evolution. However, for those body areas monitored using *
SRDs, the knees and elbows, the licensee experienced discrepancies :
between the SRDs and thermoluminescent dosimeters (TLDs), with the l SRDs being higher. Although on average the discrepancy was l roughly seven percent, in some cases the SRDs were significantly ;
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higher. The licensee attributed the discrepancy to the higher probability of drift due to hitting and knocking of the elbows and i knees. Subsequent to the RTD removal, the RMS was utilized to l monitor general area dose rates in the cubicles as well as for i specific job evolutions such as pipe end decontamination. The
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measured dose rates were able to be viewed from the containment i access facility as well as the HP Control Points in containment, t when activated; and the system had the capability to trend dose ;
rate information. The inspector considered this system an *
enhancement to the licensee's overall progra ;
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During facility tours, the inspector observed workers appropriately wearing their TLDs and digital alarming dosimetr No concerns were identified related to the use of dosimetry l device ,
i The inspector concluded that the licensee monitored whole body _i doses adequately and these exposures were within 10 CFR 20 limit !
No violations or deviations were identifie , Exposure to Skin Procedure HP-6.1.20, Personnel Contamination Monitoring and Decontamination, dated November 1, 1990, required that a skin dose ;
assessment be initiated if skin particle contamination greater ;
than 100,000 disintegrations per minute (dpm) was detected. HP Procedure HP-6.1.21, Contaminated Skin Dose Assessment, dated .
November 1, 1990, further detailed guidance for determining skin ]
dose due to surface contaminatio !
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Since January 1, 1993, the licensee had two contamination events ,
requiring the performance of skin dose assessments. The inspector reviewed the licensee's evaluation of the incidents which involved a 200,000 dpm " hot" particle on the cheek and a 300,000 dpm contamination (100,000 dpm hot particle and 200,000 dpm area) on the hand near a wound site, respectively. For both events, the ;
licensee appropriately determined isotopic content, stay times, ~!
and skin doses in accordance with procedural requirements. The skin doses assigned were 1.49 rem and 0.745 rem, respectively, and j did not result in cumulative quarterly exposures to the ;
individuals in excess of regulatory requirement ;
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Regarding the licensee's actions. associated with the wound 1 contamination, additional assessments were performed to determine !
the potential intake through the wound site. After initial !
decontamination efforts, approximately 2000 dpm of contamination l ru.ained in the wound. Successive whole body counts as well as ,
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wound counts were performed using a high-purity germanium gamma spectrometer. Based on the counting results, the licensee ;
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determined that 1.84E-3 microcuries (uCi) of soluble cesium-137 l activity was initially deposited in the wound, and using ICRP-2 l methodology calculated a 0.08 millirem committed dose to the total ;
body (critical organ). Such a dose may be considered negligibl Based on the review, the inspector noted no concerns regarding the !
licensee's technical methodology or dose assignment for high-activity skin contamination events.
l No violations or deviations were identifie l l t Internal Exposure Controls (83729)
l 10 CFR Part 20.103(a)(1) states, that no licensee shall possess, use, or 4 transfer licensed material in such a manner as to permit any _ individual .
l in a restricted area to inhale a quantity of radioactive material, in any period of one calendar quarter greater than the quantity which would - i result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks, at uniform ;
concentrations of radioactive material in air specified in 10 CFR l Part 20, Appendix B, Table 1, Column ;
l Respiratory Protection and Breathing Air Quality I i
10 CFR Part 20.103(c)(2) permits, the licensee to maintain and to i implement a respiratory protection program that ' includes, as a -i minimum: air sampling to identify the hazard; surveys and i bioassays to evaluate the actual exposures; written procedures to select,. fit and maintain. respirators; written procedures regarding l the supervision and training of personnel and issua.nce of records; !
and determination by a physician prior to the use of respirators, j that the individual is physically able to use respiratory i protective equipmen l l
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10 CFR Part 20, Appendix i. Footnote (d), requires, adequate !
respirable air of the' quality and quantity in accordance with .
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30 CFR Part 11.121 requires, that compressed, gaseous breathing -l air meets the applicable minimum grade requirements for Type 1 j
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gaseous air set forth in the Compressed Gas Association (CGA)
Commodity Specification for Air, G-7.1 (Grade D or higher !
l quality) .
The inspector reviewed the licensee's overall program for !
providing adequate respiratory protection and breathing air. With l regard to in-plant service air, the licensee maintained a i dedicated compressor for use in the decon facility and two dedicated service air compressors. These compressors were used !
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mainly for breathing parposes, although some other uses included e smal' -ir-driven tools and pumps. A separate instrument air systt <as in use for air-driven valves, etc. All three of the i
. aforementioned compressors were oil-free, and each was connected !
- to a reservoir system or holdup tan The inspector verified 5 3 that the air produced by the compressors met the Grade D requirements. They were tested periodically on an as-neede ; casis, the last check being performed in January 1993. On the !
service air systems, the inspector also noted that dedicated ;
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. breathing air fittings were used to avoid equipment confusion, and !
that eight breathing air manifolds were maintained for use with service air. In-line monitors were used to monitor for carbon
- monoxide, carbon dioxide, and cumulative hydrocarbons with alarm !
setpoints at 10 parts per million (ppm), 1000 ppm ,and 20 ppm, f
respectivel .l
i The inspector also reviewed the licensee's respiratory protection !
program with regard to self-contained breathing apparatus (SCBA). l
- Due to the licensee's subatmospheric containment design, the
- licensee was required to have SCBAs with enriched oxygen concentrations (35 percent oxygen, 65 percent nitrogen) for use l during at-power containment entries. These were in addition to ;
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, SCBAs containing atmospheric compressed air (approximately 20 ;
percent oxygen). At the time of inspection, the licensee was
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maintaining 29 primary and 15 standby SCBA bottles with the 35/65 mixture and 10 with compressed air. The inspector noted that the licensee had two individuals on staff that were factory-certified !
by Mine Safety Appliance Company (MSA) to perform SCBA i maintenanc ;
The inspector was informed of a study in which the licensee ,
participated with Lawrence Livermore National Laboratory (LLNL). 1 The study was conducted to support a 10 CFR Part 20.103(e) request i
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- NRC for specific authorization to use 35/65 SCBAs in- l containment, at reduced pressure, under both routine and emergency ?
(e.g. fire fighting) conditions. A series of tests were performed t
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including flame-testing of the_35/65 SCBA equipment. One f recommendation was made as a result of the study regarding '
replacement of rubber facepieces on 35/65 SCBAs with silicone j facepieces. This was based on a finding that the rubber !
facepieces continued to burn around the exhalation valve after !
l flame-testing due to the enriched oxygen.- At the time of :
1 inspection, the licensee had equipped all 35/65 SCBAs with !
silicone facepieces in response to the study's finding. In :
another related matter, the licensee was investigating the effects j of replacing old SCBA brass parts with parts made of aluminu !
This was due to the fact that aluminum burns under enriched oxygen ;
conditions. The results of this investigation were pendin l The inspector was informed that the licensee purchased the 35/65 i air and compressed air in large 300 cubic feet bottles and, via a ;
cascade-type system, filled the SCBA bottles as needed. When the !
inspector requested verification that the purchased breathing air [
met Grade D requirements, the licensee's records were not readily i available. In response to the inspector's inquiry, the licensee i promptly ceased the use of all non-essential breathing air until :
the question was resolved. By the end of the inspection period, !
the licensee had verified that all bottled breathing air onsite, i as well as past inventories, met the Grade D requirements. During i
the investigation into the matter, the licensee identified a minor ,
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problem with the blanket purchase order (PO) used to buy the ;
bottled air in that it only specified " Breathing Air," but did not !
specify " Grade D or better." The licensee changed the P0, i requiring that it specify Grade D as well as requiring that the l certificate of conformance provided with each bottle indicate the '
air supplied meets or exceeds Grade D requirements. In addition, the licensee agreed to make some minor procedural revisions that included a requirement that the blanket PD contain the .
aforementioned requirements each time the P0 was rewritten or :
reissued (i.e. at least once each year).
The inspector reviewed records for selected employees signed in on )
RWPs 93-2-3002 and 93-2-3004 for work associated with RTD l demolition and insulation removal, respectively, and who utilized l respiratory protection. The inspector verified that for the !
records reviewed, each worker had successfully completed GET, was trained to use respiratory protective equipment, fit-tested, and medically qualified in accordance with licensee procedural requirement During the inspection, the inspector noted the licensee's continued proactive approach to respirator reduction. Engineering controls as well as face shicids and dust masks were used effectively to reduce the overall usage of respirator In particular, the inspector noted that respirators were not used for RCS pipe cuts nor the majority of insulation work. Regarding the latter, the licensee placed personnel in respirators upon i identification of extremely high contamination levels, and/or high l
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airborne concentrations.. As noted later in this report, some '
minor uptakes associated with contamination events resulted; [
however, the licensee's efforts in overall respiratory reduction j were considered a program strengt j l
Overall, the inspector concluded that the licensee maintained an adequate respiratory protection program for protecting worker ..
No violations or deviations were identifie :
b. Whole Body Counting and Exposure Tracking i i
10 CFR Part 20.103(a)(3) requires, in part, that the licensee, as !
appropriate, use measurements of radioactivity in the body, .
measurements of radioactivity excreted from the body, or any l combination of such measurements as may be necessary for timely !
detection and assessment of individual intakes of radioactivity by j exposed individual i
Procedure HP-6.1.20, Personnel Contamination Monitoring and l Decontamination, dated November 1, 1990, required that for facial j contamination events exceeding 1000 dpm or determination of 'i positive nasal swabs that special bicassays be performe !
Procedures HP-5.2B.ll, dated October 1, 1985, and HP-5.2B.20, !
dated October 1,1985, provided guidance for bioassay evaluation, and calculation of intakes based on bioassay results, :
respectivel The inspector reviewed selected records for the period January 1 ;
through Febraary 5, 1993, detailing individuals reported to have !
positive facial contamination. The cases reviewed were primarily i associated with steam generator insulation removal, and the' j inspector noted that special whole body analyses were conducted in ;
accordance with procedural requirements. For the records i reviewed, all calculated uptakes were less than one ' percent !
Maximum Permissible Body Burden (MPBB), less than the licensee's action limit for further evaluation. Overall, the inspector noted that the licensee was identifying increased small uptakes of radioactive material due to the decreased respirator usage; however, the licensee stated that no uptakes greater than five )
percent of MPBB had occurred in 1992 or to date in 199 In addition, the inspector reviewed the licensee's methodology for tracking Maximum Permissible Concentration-hour (MPC.-br)
assignments based on either airborne radioactivity measurements or bioassay results. The inspector determined that the licensee continued to track MPC,-hrs based on a rolling 7-consecutive day I period, as required. Evaluation of documentation for selected airborne radioactivity samples greater than 25 percent MPC, noted that MPCArs were calculated and assigned to personnel, as required. For the records reviewed, the maximum cumulative 1993 I
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MPC,-hr assignment was 1.441, below that requiring an evaluatio :
In response to previous NRC comments related to the licensee' .
methodology for exposure assignments (IR Nos. 50-338,339/92-12) i when both bioassay and air sampling were used to calculate MPC -br assignments, the licensee instituted a procedural chang ;
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Rather than conservatively assigning both calculations for a given exposure, the licensee required that an evaluation be performed to determine the most accurate assignment, either based on bioassay or air sampling. Since the procedural change, the licensee ,
informed the inspector that only one such evaluation had been :
performed associated with a December 1992 letdown filter changeout ,
in which 14.21 MPC,-hrs were assigned to a technician based on i bioassay. The licensee's review and exposure assignment with the l respect to the event were appropriat r Based on the above, the inspector concluded that no internal ;
contaminations in excess of five percent MPBB or the 40 MPC,-hour l control limit requiring an evaluation had been identified for -
calendar year 1992 or to date 199 ?
No violations or deviations were identifie l
! Operational and Administrative Controls (83729) .
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, Radiation Work Permits (RWPs) l Virginia Power Administrative Procedure (VPAP) 2101, Radiation [
i Protection Plan, Rev. 4, specified the requirements for initiating !
and using the RWP system. Further, Section 6.8.7.d requires that prior to performing work, workers shall read the applicable RW ;
The inspector reviewed selected routine and outage RWPs for
' appropriateness of the RP requirements based on work scope, !
j location, and conditions. The RWPs evaluated included those associated with the upper internals lift, cut / removal of main steam and feedwater piping, steam generator insulation removal, ,
RCS pipe end decontamination, and transport of the old steam !
generators. For the RWPs reviewed, the inspector noted that they appropriately addressed radiological protection concerns and i
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provided proper control measures for the work describe i In addition, the inspector observed pre-job briefings conducted .
for workers associated with these RWPs. The briefings were i determined.to be thorough and included reviews of current t radiation surveys with emphasis on high dose areas and low dose ,
waiting areas, protective requirements, ALARA considerations,
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dosimetry usage. dose limits, and the methods of work performanc ,
In particular, the inspector noted that in some cases the video :
tour system (VIMS) was utilized to brief workers and develop a !
practical work approach. The interaction between RP and the !
workers during the briefings was considered effectiv j
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During review of HP Control Point activities on January-18'and 19, :
1993, the inspector observed numerous workers checkiiig out digital i alarming dosimeters, and logging into the dosimetry system on an j RWP without first reading the RWP, as required. Review of RWP i historical records, noted that many of the noted' individuals had l previously logged in under the RWP; however, the licensee confirmed that one individual identified had not previously read ,
the applicable RWP prior to entry into the radiologically- !
controlled area (RCA). In response to the finding, the licensee :
initiated Deviation Report (DR) No.93-122. The inspector !'
informed licensee representatives that the failure to follow RWP procedures was a violation of Technical Specification 6.1 ,
The inspector discussed with licensee representatives the overall l process for using the RWP system. The inspector noted~that by logging into the dosimetry system, the worker was acknowledging ;
that they read, understood, and would comply with the RWP, as per- '
a sign posted on the dosimetry issuance computer. However, for multiple entries under the same RWP, no mechanism was in place to !
advise the worker that the RWP may have been revised; thus, i checking the RWP upon each entry would be necessary to assure no -
revisions since the previous entry. The inspector acknowledged i that additional mechanisms were in place to inform workers of the [
RWP requirements, such as foreman review and briefing of workers i and pre-job briefings for high dose jobs; however, these factors l did not supplant the requirement for the worker to personally read !
and understand the RW ;
Immediate corrective actions implemented by the licensee included i posting HP Technicians at each of the dosimetry issuance points to remind workers to read their RWP, televising a video notice to !
workers informing them of their responsibilities in this regard, j and posting a listing of recently revised RWPs at each Control l Point to be observed by workers entering the RCA. In addition, the licensee was exploring a long-term revision to the computer log-in system to address RWP acknowledgement or revision I Based on the corrective actions implemented by the licensee and observation of generally good work practices in the field, the I inspector informed the licensee that the criteria specified in j Section VII.B of the enforcement policy were met; therefore, the i
, violation would not be cited (NCV Nos. 50-338, 339/93-01-01).
One non-cited violation for the failure to read RWPs prior to entry into the RCA was identifie I b. Notices to Workers 10 CFR Part 19.11(a) and (b) require, in part, that the licensee post current copies of Part 19, Part 20, the license, license
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conditions, documents incorporated into the license, license-
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i amendments, and operating procedures, or that a licensee post a !
notice describing these documents and where they may be examine j 10 CFR Part 19.ll(d) requires, that a licensee post NRC Form-3,
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Notice to Employees. Sufficient copies of the required forms are !
l to be posted to permit licensee workers to observe them on the way j to or from licensed activity location !
During the onsite inspection, the inspector observed the posting i of NRC Form-3 as well as a reference noting the. location and availability of other required information at the various I locations required by licensee administrative procedures. These locations, which included the Service Building Entrance, Machine Shop, and normal RCA access point, were previously considered :
adequate in that they were located at predominant traffic areas !
and could be observed by the majority of workers performing j licensed activities. However, in December 1992, the licensee j opened an additional security personnel access point on the west j l
end of the protected area to facilitate operations during the :
SGRP; and during the onsite inspection, the inspector observed j this to be a major access and traffic point for workers, ;
particularly SGRP personnel. With the advent of this additional :
personnel access point as well as the containment access facility ;
(CAF), which was the primary RCA processing area for SGRP workers, i l the aforementioned postings were not located such that a majority l
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of these workers could observe them. Of particular concern to the -
inspector were those workers utilizing the CAF for RCA acces ;
Upon identification by the inspector, the licensee took action to !
post the required notices at the CAF dosimetry checkout location, i and committed to instituting a procedural change to post required i notices at the security access gates so as to assure observation :
by all workers entering the plan :
Based on the above, the inspector informed the licensee that the !
failure to properly post the required notices was a violation of 10 CFR Part 19.11, but the violation would not be cited because the criteria of Section VII.B of the Enforcement Policy were met (NCV 50-338, 399/93-01-02). At the exit meeting, licensee ;
management expressed dissenting comments regarding the finding and j indicated their position that the original posting locations were ;
adequate to inform workers; although, the licensee's commitment to !
corrective actions was not changed. On February 11, 1993, the i inspector confirmed with licensee representatives that the l postings had been added at the Security Gates and that a i procedural change to maintain the postings was to be initiate j One non-cited violation for the failure to properly post notices !
to workers was identifie t
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7 -. Control of Radioactive Material and Contamination, Surveys', and
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, Monitoring (83729) Surveys, Posting and Labelling ;
During tours of selected areas of the Containment, Auxiliary Building, Instrument Calibration Facility, tool storage areas, ,
Fuel Handling Building, yard storage areas, Warehouses No. 5 and ;
9, New Steam Generator Storage Facility (NSGSF),'Old Steam l Generator Storage Facility (OSGSF), and Decontamination Facility, l the inspector performed numerous independent surveys for i comparison of actual contamination levels and exposure rates j against postings. With the exception of two temporary plastic !
drain tubes routed to floor drains which had pulled out of the drain fixture and slightly contaminated the floor, no unexpected-contamination or exposure rates were identified. The licensee !
took prompt action to cleanup the identified floor contaminatio In addition, the licensee's control of locked high radiation areas ;
was appropriate; particularly noted was the Waste Solids facility )
- follcwing storage of RCS pipe end and the loop rooms decontamination wast ,
i The inspector toured the licensee's concrete radiography cell !
located just outside the protected area and discussed the ongoing j radiography operations with the two radiographers present. A cobalt-60 source'with an activity of approximately 200 curies was jl being prepared to use for new steam generator girth weld i
examinations and the radiographers had to leave the source exposed !
for extended periods of time in the cell using a collimato .
During the initial exposure, the inspector independently verified !
the posted boundary readings and found readings all around the !
rope boundary to be 0.5 milliroentgen per hour (mR/hr) or les l No problems were noted with the postings or the radiographers' !
equipment or technique j i
The inspector reviewed the licensee's program for the control of }
radioactive sealed sources. Procedure HP-7.1.21, Control of !
Radioactive Sources, dated June 12, 1991, described the general j program for the accountability, labelling, storage, annual :
inventory, and leak testing requirements for such sources. The !
inspector reviewed documentation for selected sealed sources and i determined that leak testing was conducted on a six-month basis as required. In addition, the inspector reviewed the accuracy of the licensee's inventory syste For the sources reviewed, the ,
inspector noted that the inventory properly reflected the l location, receipt, or disposal of the source. Overall, the i licensee's program in this area appeared to be working adequately i with no items of concern identifie 'l
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On January 19, 1993,- the inspector observed waste water from a CAF !
collection tank being pumped into tank truck for ultimate disposal !
offsite; however, at the time of the transfer the water had not l
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been analyzed for the presence of radioactive material. The !
inspector noted that the licensee had intended on analyzing the ;
water prior to the transfer; but, an apparent miscommunication ;
resulted in the premature transfer. The licensee initiated DR l No.93-136. The waste water was subsequently counted to environmental lower limit of detection (LLD) levels and the .
presence of very small quantities of cobalt-60 (2.03E-8 uti/ml !
versus LLD of 1.5E-8 uCi/ml LLD) and cesium-137 (1.58 uCi/ml l versus LLD of 1.8E-8 uti/ml LLD) were identified. The. licensee i disposed of the 500 gallons of water at the_ North Anna sewage j facility which processed similar wastes from other plant ,
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locations, and accounted for the activity as a batch releas Additionally, any activity will be again accounted for if effluent :
from the sewage facility exceeds effluent LLDs. Review of the :
survey results indicated that the tank truck was rinsed and released as clean. The licensee's followup actions pertaining to this situation were considered appropriat j Overall, the inspector noted that areas and materials were surveyed, posted and safeguarded in accordance with the radiation hazards presen No violations or deviations were identifie i b. Area and Personnel Contamination !
The licensee maintained approximately 96,000 square feet (ft2) ]
excluding containment, as radiologically-controlled. As of ;
December 31, 1992, the licensee tracked 308 square feet (ft') -
(0.32%)2of the RCA as contaminated, as compared to a goal of ;
2600 ft (2.7%) which primarily reflected the minimum core are l Licensee representatives stated that late in the year, several i areas which had been previously maintained as contaminated, such ,
as the laundry area, were decontaminated to achieve this
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performance level. During the onsite inspection, the contaminated i area tracked by the licensee ranged from 3800 to 5000 ft2(4.0 to ,
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5.2%), primarily related to ongoing maintenance activitie ,
During tours of the RCA, the inspector noted good housekeeping and i contamination control practices. Considerable material movement, l storage, and staging were noted, particularly in containment; >
however, this was consistent with the level of ongoing work -
activity and the stage of the outage. _The inspector noted -
appropriate HP controls over material, and particular strengths noted were the segregation of high-level trash from major work j areas and thoroughfares, and maintenance of the clean area around l the equipment hatch including the use of double barrier ;
I For 1992,142 personnel contamination events (PCEs) had occurred ;
compared to a goal of 192. As of February 5, 1993, the licensee i had 54 PCEs, which was slightly under the prorated goal of 5 ;
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Review of PCE logs noted that, in general, contaminations were low level; however, the licensee continued to see a number of facial contaminations, primarily attributable to the _ decreased use of respirator The inspector reviewed licensee actions for responding to and documenting PCEs. Through observations at the HP Control Point and review of selected PCE reports, the inspector noted that the licensee was identifying, documenting and responding to PCEs consistent with procedural requirements. Further, the inspector noted that the licensee continued to focus management attention on PCE reduction through temporary RCA restrictions and conduct of one-on-one sessions with each contaminated worker. The inspector attended one such session held by the Superintendent, Radiation Protection, and found it to be constructive and a positive initiative toward fostering improvements in worker awarenes During the onsite inspection, the licensee' initiated DR 93-208 in response an HP technician's concern with the North Anna PCE policy, the potential for being fired for multiple PCE occurrences, and whether the policy fostered an. atmosphere for under-reporting of PCEs. Interviews of various contract technicians by the inspector noted that there were some apparent worker concerns. regarding the PCE evaluation process as well as varying interpretations of the licensee's stated policy. At the exit, the inspector informed licensee management that their:
aggressiveness in PCE reduction had fostered significant improvements; however, there was a need to ensure that the appropriate message was being communicated and-understood by workers. The licensee stated that in response to the DR'an evaluation of worker understanding of the policy would be conducted as well 'as field observations to determine if PCEs were actually being under-reported. Licensee actions related to the DR will be reviewed during future inspection No violations or deviations were identifie Radiation Detection and Survey Instrumentation During facility tours, the inspector noted adequate numbers of surveys instruments were available for use, and survey instruments and continuous air monitors in use within the RCA were operable, source checked in accordance with licensee procedures, and displayed current calibration sticker In addition, background radiation levels at survey locations were observed to be within an acceptable rang No violations or deviations were identifie . .- . - -- . . ~ . . . ._
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' Facility-Tours and Outage Observations'(83729)
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. During the Unit 1 outage, the inspector observed facility operations and j selected work activities to evaluate the implementation.and :
effectiveness of the licensee's RP program. The various activities l observed were as follows: l Upper Internals lift: !
The inspector observed the upper internals lift and the HP controls !
employed during the job. The work was conducted under RWP 93-2-2008 !
with appropriate briefings. Good HP practices were used during the job -
and the inspector noted that the Radiation Protection Job Guideline !
(RPJG) was followed. No problems were noted with the exception of a :;
minor delay that extended the job. Prior to the lift, the licensee
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a planned to leave the upper internals stored on its stand inside the pool ,
, throughout defueling to minimize the dose and time needed to place the l internals on the containment floor outside the reactor cavit However, after the upper internals were placed on the stand, the licensee ;
realized that by leaving the internals in the pool, the refueling bridge I would not have complete access to the reactor vessel / fuel. The licensee j had to prepare an area outside of the reactor cavity on the containment l floor and relift the upper internals over to the prepared area, causing !
a short delay and extension of the job time. No significant problems j were noted due to the change in plans. Actual personnel doses did not i exceed those planned with the maximum whole-body exposure being less ,
than 200 millire i Defuelina Activities: '
i Based on previous problems, the refueling barriers were inspected to 1 ensure that while fuel was being off-loaded from the reactor vessel, ,
proper controls and postings were in place. The inspector observed the !
erection of the barriers and verified that it was done-in accordance i with Operations Procedure OP-4.1. Postings were consistent with the {
radiation hazard present. Personnel access to the high and extremely I high-radiation areas produced during fuel movement was effectively !
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controlled. No problems were foun The inspector also observed some actual fuel movement. Good controls were maintained throughout the process, although there was some short -
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delays due to mechanical problems with the refueling bridge. No !
problems were note !
r Feedwater Pipe Cuttino: The inspector observed feedwater pipe cutting :
operations for the "B" loop. On the initial cut, approximately four f gallons of water were spilled. The presence of water _was determined to l be a result of inadequate drainage due to a plugged drain valve. One ;
individual was wettened by the leak; however, an immediate survey of the j individual detected no contamination. The inspector observed proper i implementation of both HP and safety controls. ALARA measures noted for l
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this job evolution included maintenance of_ steam generator water levels )
to reduce general area dose rates and HEPA ventilatio i
"B" Steam Generator Ricaina and Transoort: The. inspector observed the HP controls associated with the movement of the "B" steam generator out of containment and onto the equipment platform as well as preparation activities and movement within the protected are Surveys noted that the steam generator contamination levels prior to release from containment were less 1000 dpm/100 cm2. Appropriate controls were ;
established and maintained for both high radiation and radiation areas created as a result of the steam generator radiation levels (up to 300 jl mR/hr contact), and the inspector independently verified the j appropriateness of boundary locations. Problems associated with impact ;
ring installation caused some delay in the transport of the generator as !
well as increased dose expenditure for rigging personnel. Licensee !
personnel stated that the impact ring was necessary to satisfy the j assumptions associated with a drop accident; however, engineering l
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approved changes to the installation in an attempt to improve ;
performance for "A" and "C" generator movements. HP coverage and !
monitoring during the delay periods was adequate. During transport, the !
licensee evacuated personnel along-the route as well as provided l continuous health physics coverag !
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"C" Steam Generator Lift: Initial efforts to lower the steam generator _f onto the cradle at the hatch were unsuccessful due to inadequate l clearance between the trunnion and lifting rig. Following grinding of the trunnion and lifting rig the evolution was-completed. In addition, the inspector noted that the licensee's implementation of lessons !
learned from the "B" generator lift (i.e. vacuum pump drainage and I addition of absorbent material to the bowl) were effective in reducing l the leaking of water during the lay down process. During movement and j laydown, appropriate implementation of HP controls were implemented, and j technicians were present in the area to inform personnel of area dose j rates.
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Old Steam Generator Storace Facility (OSGSF): The old stcam generator- :
storage facility, located outside the protected area, was toured by the ;
inspector. Shielding calculations for the OSGSF walls and ceiling were ;
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reviewed as well as the source term and survey results used in the !
design of the facility. The inspector did not identify any areas of j concern regarding the design calculation l
Subsequent to the placement of the "B" steam generator in the facility, l the licensee appropriately posted and roped off the high radiation area j and radiation area (less than 0.6 mR/hr for an unrestricted area), and j provided positive access control through continuous HP coverage. These controls were to remain in effect until all three generators were in the ;
facility and the facility was permanently sealed. Initial verification !
surveys conducted by the inspector noted dose rates'at the radiation i area boundary of 1.0 mR/hr with a micro-R meter; however, resurvey-using ;
an E-520 G-M instrument, found the maximum boundary level of 0.5 mR/h j-l
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Also, higher than expected dose rates were measured on contact with the exterior of the building (0.08 mR/hr versus 0.05 mR/hr design with all ,
three generators in place); however, the "B" generator was-the highest t
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activity generator, and the licensee anticipated that some shielding might be provided by the other two generators. On. February 11, 1993, subsequent to the onsite inspection, the inspector was informed that all ,
three generators had been moved to the OSGSF, the facility sealed, and !
that exterior contact dose rates ranged from 0.02 to 0.05 mR/hr, [
consistent with the design specifications. The licensee stated that l TLDs would be placed around the facility to more accurately evaluate the l ambient exposure rate :
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Decontamination Facility: The inspector reviewed the operation of the new decontamination facility and observed the results of head stud ;
decontamination and feedwater pipe decontamination. The facility u;ed either carbon dioxide (CO 2 ) pellets (Head Stud) or a grit slurry i (Feedwater Pipe) to effect radioactive contamination material remova i During the tour, the inspector noted the potential for removed .!
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contaminated material to accumulate in the receiver bins in the bottom of the grit blaster causing area dose rates to increase for workers in i the facilit In response to the inspector's observations, the licensee ;
placed a remote reading, portable dose measuring instrument in the collector bin area to monitor any unexpected dose' increase. During decontamination operations, the. inspector observed proper use of !
containment devices and respiratory protection devices. Overall, the !
licensee indicated that af ter overcoming some initial startup problems ;
in the facility, generally good success had been achieved, and most i equipment decontaminated was able to be " free-released"' from the j facilit ;
i Storace Warehouses: The inspector observed that Warehouse No. 9 was ~j setup as a dual-use warehouse and that maintenance materials were stored in the facility as well as radioactive materials. Several containers of l flammable and combustible materials were stored -in the immediate -
vicinity. Although the material was outside'the fenced Radioactive i Material Storage Area boundary, the close proximity of the flammable material was identified by the inspector as an item of concer The licensee took immediate corrective action to remove the flammable -i material and restrict the storage of this material in Warehouse No. In addition, the inspector observed that Warehouse No. 5 had several
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posted areas containing calibration sources and turbine generator spindles. During the tour, several minor items were identified to licensee personnel and were immediately corrected. These items included the following: an empty radioactive material-labeled storage tray (smears were found to be background); and several clean unused plastic :
radioactive material storage bags (surveyed clean and removed). !
Postings and access control in the facility appeared adequate, and no areas additional areas of concern were identifie , .
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In general, for the activities evaluated, the inspector observed the !
. implementation of- appropriate health physics controls and personnel ;
compliance with work control procedure [
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No violations or deviations were identifie t Program for Maintaining Expasures As Low As Reasonably Achievable l (ALARA) (83729) l
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10 CFR Part 20.l(c) states, that persons engaged in activities'under j licenses issued by the NRC should make every reasonable effort to !
maintain radiation exposures as low as reasonably achievabl l The inspector reviewed and discussed with cognizant licensee I representatives ALARA program implementation and initiatives for the :
current Unit 1 outage and operations during non-outage periods. The i inspector was informed that the collective dose for 1992:was'575 person- !
rem as compared to a goal of 620 person-rem. Approximately 450 person- l rem of this dose was associated with outage activities. The licensee's :
fourth quarter routine dose was low related to previous performance, and l included the lowest dose month since 1982. The licensee dose goal for i 1993 was established at 1400 person-rem which incorporated the dose for i the current Unit 1 outage and a Unit 2 outage scheduled for the fal j
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As discussed in detail in IR Nos. 50-338,339/92-26, the licensee had !
established a total goal of 900 person-rem for the Unit 1 outage, ,
including 500 person-rem for the SGRP. Based on the ALARA job i evaluations reviewed during the aforementioned inspection, the dose i
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estimate appeared realistic and commensurate with the work scope. As of l'
February 5,1993, the licensee had expended approximately 244 person-rem _
for the outage, of which 157 person-rem was SGRP-related. Review of ;
prorated dose data showed the licensee well below the estimate for:that i stage of the outag l
Review of job-specific exposure data revealed that most jobs were below their initial estimates; however, at the time of the onsite inspection very few jobs had been completed. The inspector discussed in detail RTD :
bypass removal which did exceed the' estimate, 35.7 versus 42.5 person- !
rem, by SRD. As discussed in Paragraph 4.a, approximately 2.77 person- ,
rem of the overage was attributed to the SRD-to-TLD discrepancy; ,
however, an additional contributing factor was the larger than expected !
man-hour expenditure. Licensee representatives stated that although
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i training and mock-ups were provided for the RTD workers,.most of the ,
contract workers had not performed'this evolution previously. The !
inspector noted that all three RTD systems were removed simultaneously -
which did not allow for incorporation of lessons learned during the job ;
evolution. Sixty-six person-rem was planned for completion of the RTD- :
retrofit project. RID removal _ for Unit 2 was scheduled for the '!
aforementioned fall outag l i
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The inspector discussed with ALARA personnel the results of various 1 outage dose reduction activities previously addressed in IR Nos. 50-338, 339/92-26. These areas were.as follows:
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- Controlled shutdown was implemented using early boration and ;{
peroxide shock for crud removal The reactor coolant pumps (RCPs) 1 ran for 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> and approximately 1200. curies were remove j However, preliminary licensee loop surveys did not show any !
significant reduction in dose rates; l t
- The pressurizer spray valves and the bypass valves were flushe i Although significant dose reduction was not realized, no increase i from the previous year was noted. The installation of temporary -!
shielding was used to reduce general area dose rates; i
+ RTD Bypass removal resulted in an average dose rate reduction :
factor of two for the general area; !
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reduction. Decon factors up to 100 were realized at the cold leg
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viewing capability was located in the CAF as well as the various HP
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control points in containment, with individual cameras for each cube and two general containment area cameras. The inspector observed that the-CCTV was used by RP to effectively to monitor ongoing work activities as well as used by workers-to prepare for future work evolutions. The'use of the system was viewed as an ALARA initiative which provided ;
significant dose savings. Individual camera output -information could b !
recorded and used for training and lessons learned as well as positive j reinforcement for correcting problems and lessons learne j
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Other effective dose reduction actions observed by the inspector during l the inspection included the use of flashing green lights to designate j low dose waiting areas in containment, establishment of clean areas in
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containment to facilitate work activities, the effort to minimize the number of personnel in containment during the head and upper internals lift, and the use of radios by the SGRP staff to facilitate prompt communication !
i The inspector reviewed the hotspot tracking and reduction program. As !
of the date of the inspection there were 71 hotspots being tracked. The i inspector selected several listed hotspots and visually checked the :
postings as well as independently verified radiation levels at the
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hotspots. The licensee appears to have an aggressive program to !
identify, post, track and remove hotspots. No problems were observe t
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Based on the above, the licensee's program for maintaining exposures i ALARA during the current Unit 1 outage appeared effective, and was considered a~ program strengt j j
No violations or deviations were identifie ;
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1 Exit Interview (83729) l, The inspection scope and results were summarized on February 5, 1993, .li with those persons indicated in Paragraph I above. The general program areas reviewed and the non-cited violations identified during this !
inspection and listed below were discussed in detail. Regarding the j violation of posting requirements, 1;censee management provided ,
dissenting comments and stated their position that the original posting I locations were adequate to inform workers; however, the licensee' !
commitment to corrective actions was not change !
i The inspector informed licensee representatives that although l proprietary information was reviewed during this inspection, such !
material would not be included in the repor j
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Item Number Descriotion and Reference j
50-338,339/93-01-01 NRC-identified Non-cited Violation of TS f 6.11: Failure to follow RWP Procedures ;
(Paragraph 6.a) !
50-338, 339/93-01-02 NRC-identified Non-cited Violation of 10 I CFR 19.11: failure to adequate post l required notices to workers (Paragraph !
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