IR 05000338/1993026
| ML20059K754 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/27/1993 |
| From: | Boland A, Pharr E, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059K749 | List: |
| References | |
| 50-338-93-26, 50-339-93-26, NUDOCS 9311160176 | |
| Download: ML20059K754 (19) | |
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UNITED STATES nah NUCLEAR REGULATORY COMMISSION
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. REGloN 11
S 101 MARIETTA STREET, N.W., SUITE 2900
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eE ATLANTA, GEORGIA 303234199
- t 00T 2 01983
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Report Nos.:
50-338/93-26 and 50-339/93-26 Licensee:
Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7 Facility Name: North Anna 1 and 2 Inspection Conducte - September 27 - October 1, 1993 A
l Inspectors-W
/b/27 /93 A. T. Boland, Radiation Specialist Datie Signed f
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16 21 QB E.B.fharr,RaMt n Specialist Date Sfgned Ioh'l!T5 Approved M'
Dat'e Sig'ned
W. H. Rankin, Chief 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)
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program involved review of health physics (HP) activities primarily associated with the current Unit 2 refueling outage. Specific areas evaluated included organization and management controls; RP training; audits and appraisals; external and internal exposure programs; operational and administrative controls; control of radioactive material and contamination; surveys and monitoring; and As low As Reasonably Achievable (ALARA) program implementation.
Results:
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Based on interviews with licensee personnel, records review, and observation
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of work activities in progress, the inspector found the RP program to be functioning adequately to protect the health and safety of plant workers. RP staffing levels appeared adequate-to support ongoing Unit 2 outage activities.
The RP technician training program appeared comprehensive with the initial and continuing training programs considered a program strength. The licensee's self-assessment programs were conducted in accordance with the applicable.
requirements and were c:pable of identifying areas for program improvement.
9311160176.933029
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PDR ADOCK 05000338 G
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Internal and external expcsure control programs continued to be effectively implemented with all exposures less than 10 CFR Part 20 limits. The licensee's efforts. in reducing contaminated area, maintaining overall housekeeping standards, and pursuing respirator usage reduction were also considered program strengths. The ALARA program was effective in controlling collective dose. Overall, the RP program was conducted in accordance with 10 CFR Part 20 and procedural requirement.
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REPORT DETAILS
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Persons Contacted Licensee Employees
- E. Dreyer, Supervisor, Health Physics Technical Services
- R. Evans, Jr., Health Physics Supervisor - Operations
G. Henry, Senior Staff Health Physicist
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l D. Horn, Staff Health Physicist M. Johnson, Senior Quality Assurance Auditor
L. Jones, Supervisor, Radiological Engineering
- G. Kane, Station Manager
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- P. Kemp, Supervisor, Licensing
- J. Leberstien, Staff Engineer, Licensing N. Nicholsen, Senior Staff Health Physicist
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T. Peters, Supervisor, Exposure Control P. Quarles, Supervisor, Quality Auditing
- R. Saunders, Assistant Vice President, Nuclear Operations J. Schlesser, Staff Health Physicist C. Smith, ALARA Coordinator
- J. Smith, Manager, Quality Assurance
- A. Stafford, Superintendent, Radiation Protection
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- J. Stall, Assistant Station Manager, Nuclear Safety and
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Licensing
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- W. Thornton,. Director, Health Physics and Chemistry Services (Corporate)
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Other licensee employees contacted included engineers, technicians, and office personnel.
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Nuclear Regulatory Commission D. Taylor, Resident Inspector
- J. York, Acting Senior Resident Inspector
- Attended October 1, 1993, Exit Meeting
2.
Radiation Protection Organization and Management Controls (83729)
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l The inspector reviewed and discussed with-licensee representatives the
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organization and staffing for routine operations as well as the current'
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Unit 2 outage. Since the last inspection of this area conducted January 15 through February 11, 1993, and documented in Inspection l
Report (IR) 50-338,339/93-01, dated March 12, 1993, licensee representatives stated that' the position of Supervisor, Health Physics Operations - RadWaste had been eliminated. The Supervisor, Health
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Physics Operations-had been assuming the position on an acting basis for.
sometime, and effective June 1, 1993, assumed this function permanently.
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With the realignment of responsibility, the duties of the Supervisor,
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Health Physics Operations now included decontamination and waste
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In addition, the position of Environmental w.c.pliance Coordinator was shifted to report j
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directly to the Assistant Plant Manager, Nuclear Safety and L.icensing.
i No other changes were noted in the lines of authority or organizational structure for the RP function.
t The inspector noted that the licensee continued to' maintain a core of
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approximately 57 permanent health physics and decontamination technicians. At the time of the onsite inspection, licensee
representatives stated that one decontamination technician position was vacant as well as a chemistry technician position.
In addition, the
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licensee maintained a core contractor staff of seven individuals which
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included a planner supervisor, four working foreman, and two ALARA I
technicians. The inspector did not note any significant changes in the
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RP staffing levels for the routine organization.
For the current Unit 2 outage, the licensee employed approximately 177 contractor personnel during the peak staffing period to supplement
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the routine RP organization. This number included approximately 62 senior technicians, 21 junior technicians, 61 decontamination
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personnel, and 14 dosimetry technicians, in addition to various working foremen and support personnel. The technician staffing was similar to that utilized in the previous 1992 Unit 2 outage as documented in IR 50-
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338,339/92-12.
Discussions with the licensee and review of current staffing rosters revealed that greater than 90 percent of the contractors hired for the current outage had worked either at North Anna
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or Surry during the last fuel cycle. The inspector noted that the licensee's high contractor returnee rate was particularly positive with
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respect to training and personnel familiarity with the plant.
Based on discussions with licensee representatives and observation of
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activities in progress, the RP staffing levels appeared adequate to
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support ongoing outage activities, and the changes in the routine organization did not appear to adversely impact RP operations.
In addition, the inspector discussed with licensee representatives anticipated changes in the RP program and procedures related to implementation of the new 10 CFR Part 20 requirements. The inspector..
noted that the licensee had established milestones for the completion of key activities prior to January 1, 1993. Clear assignments of responsibility had been made for the involved groups including RP,
training, licensing, computer services, and emergency planning.
Licensee representatives stated that approximately 88 percent of all designated tasks were complete, and Station Nuclear. Safety Operating Committee (SNSOC) review of procedures was scheduled for November 1993.
In addition, the licensee had initiated indoctrination of plant personnel on the new regulations during the monthly departmental safety meetings. The inspector observed one such session and noted that an overview video tape as well as a summary pamphlet were presente.
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In general, the inspector determined that the licensee appeared to be making appropriate progress in preparing for the implementation of the new regulations.
No violations or deviations were identified.
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Radiation Protection Training (83729)
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10 CFR 19.12 requires, in part, that the licensee instruct all l
individuals working in or frequenting any portion of a restricted area i
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i exposure; in the purpose and function of protection devices employed; in
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the applicable provisions of the Commission regulations; in the
individual's responsibilities; and in the availability of radiation
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exposure data.
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Nuclear Employee Training (NET)
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l The inspector reviewed the licensee's program for providing radiation protection training to licensee employees..The inspector noted that NET appropriately included regulatory
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exposure limits, biological effects of radiation exposure, L
maintaining exposures ALARA, plant security, emergency.
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exposure concerns. Additionally, the inspector noted that NET also included a basic introduction to revised 10 CFR Part 20 terminology, exposure limits, and philosophy changes, with l
emphasis on respirator reduction and reasons for this reduction, i
Based on recent licensee increases in the number of personnel contamination events (PCEs) and instances of personnel not having adequate knowledge of. their Radiation Work Permit -(RWP)
requirements, the licensee stated that these program areas had received increased focus during NET. The inspector was further informed that the licensee was currently considering'the addition of a training video or a revision'to the NET material to inform workers of management's commitment to and to stress the need for knowledge of and adherence to RWP requirements.
The inspector informed licensee representatives that NET appeared
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to be thorough and well prepared and appropriate for informing plant workers as required by 10 CFR 19.12.
L No violations or deviations were identified.
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HP Technician Training During the onsite inspection, the inspector reviewed the
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i licensee's initial training program for HP technicians and the i
continuing training program offered to the HP staff.
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During discussions with licensee representatives, the inspector was informed that the licensee presently had eleven HP technicians
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included in their initial HP Technician Development Program. The
=i inspector noted that this program was prefaced by 17 weeks of general foundational-level training which included topics related to mathematics, classical physics, chemistry, electricity, and nuclear physics. This foundational training program was designed
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to provide appropriate academic backgrounds for technicians entering the Development Program. After successfully completing the written examinations, at least 80 percent correct, for each I
foundational training topic, the employees were then admitted to the Development Program. The inspector reviewed the Technician Development Program and noted that it was a three year program,
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divided into seven six-month steps.
Each step included classroom training, independent study, and on-the-job training.
The inspector also noted that each step contained task per evaluations, which qualified the technician to perform;formance independent tasks. The inspector reviewed the seven step curriculums and
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noted that training topics and performance evaluations included
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items related to basic HP theory, radiological surveys, airborne radioactivity control, instrumentation, respiratory protection, routine and special HP coverage, count room operations,
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environmental monitoring, plant systems, dosimetry, radioactive
material and contamination control, RWPs, and ALARA program. The
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inspector noted that in addition to completing performance evaluations the technicians were also: required to successfully complete written examinations following each step.
The inspector reviewed training records for selected HP
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technicians presently involved in the Technician Development Program and noted that the individuals had successfully completed the foundational-level training program and were progressing
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through the Development Program as examinations and task i
performance evaluations were completed for each of the seven step curriculums. The inspector also verified that these technicians had received NET and respiratory protection training, as required for all radiation area workers, to maintain their qualifications
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current.
The inspector also reviewed continuing training presented to the-t HP technician staff since January 1, 1993. The inspector noted t
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that the licensee's annual continuing training program consisted of a minimum of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. The inspector was informed that the
licensee had scheduled approximately 170 hours0.00197 days <br />0.0472 hours <br />2.810847e-4 weeks <br />6.4685e-5 months <br /> of continuing l
training for the technicians during 1993. The inspector also noted that the licensee was scheduled to complete two outages during the year. During discussions with licensee representatives-the inspector was informed that, as applicable to their job function, contractor technicians which had been onsite longer than
six months, as well as the technicians in the HP Technician
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Development Program were included in the continuing training
program.
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The inspector reviewed training outlines and noted that the
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continuing training material included review of recently
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implemented procedures and major revisions to existing procedures,
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exposure concerns and industry events, various plant systems, emergency response, and revised 10 CFR Part 20. The inspector-
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also noted that training, as well as task performance evaluations,
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was provided for new instrumentation. The inspector was informed that specified tasks were also reviewed annually to determine the
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need for retraining and requalification to the task, due to task and/or program revisions or deficient field performance. During discussions with licensee representatives the inspector noted that e
revised Part 20 training during the current year had specifically addressed procedural changes resulting from the revisions,. while
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earlier training sessions had mainly provided an overview of the regulatory revisions and how these revisions would apply to plant radiation protection activities.
The inspector also noted that each training. session required completion of a comprehensive written examination with at least'
70 percent correct, as well as satisfactory demonstration of
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applicable tasks as presented during the training week. The inspector reviewed training records for selected HP technicians,
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including long-term contractor technicians and technicians in the
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Technician Development Program, and verif'ed their participation in and successful completion of continuing training, to include task performance evaluations.
The inspector informed licensee representatives that their development and continuing training programs for HP technicians appeared to be appropriately inclusive and indepth of radiation protection topics and a positive initiative in providing for a
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well-rounded and knowledgeable HP staff. The inspector considered these training programs to be a strength to the overall HP program.
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No violations or deviations were identified.
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Contractor Technician Training
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During the onsite inspection the inspector reviewed the licensee's program for providing training to contract HP. technicians prior to the scheduled refueling outage. The inspector noted that each
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senior qualified HP technician was required to initially pass, with at least 70 percent correct, an HP fundamentals examination.
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Following successful completion of this test the contractor was then enrolled in the licensee's site-specific training course.
The inspector noted that site specifics included administrative policies, licensee procedures, and performance and documentation requirements for conducting surveys, job coverage, and' radioactive
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material control. The inspector also noted that recent industry events and lessons learned from previous outages were also included in this 12 to 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> training session. A condensed
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version, approximately eight hours in length, was presented to-those returning contractors which had been onsite during the
previous year.
Following completion of the training, the contract
technicians were required to complete a written' examination with a j
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minimum of 70 percent correct, and to complete a required reading
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list of pertinent licensee procedures, which wtce highlighted
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during site-specifics training. The inspector also noted that first-time contractors were also required to comp?ete Job Performance Measures (JPMs) to demonstrate their proficiency in performing expected job functions. Technicians were-required to requalify on JPMs only if a dramatic procedural change had taku
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place since their last time onsite or if declining proficiency was noted.
The inspector informed licensee representatives that their program
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for providing training to and ensuring the knowledge level and competency of their contractor HP technician staff was comprehensive and appropriate.
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No violations or deviations were identified.
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4.
Audits and Appraisals (83729)
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Technical Specification (TS) 6.5.2.8 requires that audits of plant.
activities be performed under the cognizance of the Management Safety Review Committee and that the audits encompass, in part, the following-(a) the conformance of plant operation to the' provisions contained within the TSs and applicable licensee conditions at least once per 12 months; and (2) the performance of activities required by the
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Operational Quality Assurance Program to meet the criteria of Appendix B
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to 10 CFR Part 50 at least once per 24 months.
The inspector reviewed quality assurance audits related to the RP function which had been performed since the last NRC inspection of this-area, conducted January 15 through February 11, 1993, and documented in j
IP,50-338,339/93-01. The audits reviewed included Report No. 93-08'
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Radiological Protection Audit, dated September 22, 1993, conducted July 7 through August 5, 1993, jointly for Surry and North Anna, and an assessment of the North Anna National Voluntary Laboratory Accreditation Program (NVLAP) dosimetry program, dated May 4, 1993, conducted from March 17 through April 20, 1993.
q The inspector reviewed in detail Audit Report 93-08, the associated audit plan, and auditor observation notes as well as discussed the-
conduct of the audit with a senior auditor. The inspector noted that the audit team included appropriate expertise in the RP area including a i
previous health physics supervisor, radwaste and shipping' supervisor, and a Corporate technical specialist. The audit appeared to
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comprehensively evaluate the major RP program areas including internal
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and external exposure control, radiological surveys and contamination -
i control, instrumentation,. ALARA, RP work controls, control of radioactive material, duties and responsibilities, and corrective
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actions associated with plant, NRC, and previous quality assurance l
findings. The inspector determined that the audit encompassed procedure
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and documentation reviews as well as field observations. The audit-
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identified program strengths, enhancements, and findings, the latter of which required a documented, formal response. With regard to audit findings, the inspector noted a finding regarding worker awareness of RWP requirements prior to entry into the Radiological Controlled Area (RCA). At the time of the onsite inspection, the licensee had not yet
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formally responded to the finding (due October 22,1993); however, initial corrective actions had been implemented. The actions consisted of posting personnel at the entrance to the RCA to address worker RWP concerns; increased surveillance at the RCA access to monitor worker awareness of RWP requirements; and enhancements to NET. Additional surveillance activities indicated improvements in this area, and during the onsite inspection the inspector observed workers appropriately reviewing and complying with RWPs. Completion of the licensee's quality assurance process and final corrective actions associated with the audit findings will be reviewed during future inspections.
Based on the review of this program area, the inspector concluded that the quality assurance audit program rel'ted to the RP function was capable of identifying program deficiencies and was. conducted in accordance with TS requirements.
In addition, the inspector reviewed the licensee's internal program for self-identification of weaknesses related to the RP program and the appropriateness of corrective actions taken.
Specifically, the inspector reviewed 1993 Deficiency Reports (DRs) related to the RP function. This system was utilized by the licensee to document, investigate, and track items of concern. The inspector noted that
approximately 80 DRs had been identified during the period January 1 through September 28, 1993. The inspector was informed that recently the threshold for initiating a DR had been reduced resulting in the apparent increased number of identified issues.
Review of selected DRs identified during the period noted that this program was being utilized to identify and correct radiation protection deficiencies, and the
threshold for DR initiation appeared appropriate.
In addition, the
inspector noted that several DRs had been written since the beginning of i
the Unit 2 outage associated with personnel accessing the RCA with their digital alarming dosimeters (DADS) in the " pause" mode. The licensee
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had recognized the adverse trend and had initiated corrective actions.
The licensee believed that the root cause of the problem was human error i
associated with removal of the DAD from the reader prior to it being
turned to the "on" mode and dose / dose rate parameters programmed.
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licensee was evaluating possible modifications to the computer to eliminate the problem, and had posted an individual at the RCA entrance i
to monitor DAD status prior to entry. Since increased surveillance at the RCA entrance, the licensee informed the inspector that approximately
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six individuals out of 16,467 attempted entries had a similar problem.
The licensee's ongoing efforts in this area appeared appropriate, and no other adverse performance trends were noted.
No violations or deviations were identified.
5.
External Exposure Controls (83729)
10 CFR 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 and trunk, active blood forming organs, lens of the eyes, or gonads;
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18.75 rem to the hands, forearms, feet and ankles; and 7.5 rem to the skin of the whole body.
10 CFR 20.101(b)(3) requires the licensee to determine an individual's accumulated occupational dose to the whole body on an NRC Form-4 or equivalent record prior to permitting the individual to exceed the limits of 20.101(a).
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Multibadge/ Extremity Exposure Monitoring Le inspector reviewed in detail external doses and dosimetry requirements for personnel associated with RWP 93-2-3015, Perform l
Steam Dome Cut, Pre-heat Old Lower Assembly / Top Hat, and Weld out Top Hat Shield, and RWP 93-2-3017, Rig Out/In Steam Domes and P.ig/ Set Top Hat Shield Plate on Old Steam Generator lower Assembly. The inspector noted that, as appropriate, the RWP included provisions for relocation of whole body dosimetry which was consistent with the procedural criteria established in Health Physics Administrative Procedure (HPAP) 1031, External Exposure
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Control Program. The relocation criteria required that the following conditions be met for a specific task: (1) whole body dose rates greater than 100 millirem per hour (mrem /hr); (2) whole body exposure likely to exceed 100 mrem; and (3) a specifically defined whole body location will receive'the highest whole body dose which may exceed 1.5 times the chest dose. The inspator noted that for the workers logged in on these RWPs that the average dose per worker was approximatcly 40 mrem with only two workers exceeding 100 mrem for a single entry.
These two workers.
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received 153 and 160 mrem, respectively. Discussions with the licensee and review of pertinent documentation noted that dosimetry was not relocated for work on these RWPs; however, in pre-job briefings workers were informed of the need to maintain distance from the tube bundles prior to top hat placement and the
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use of the lower assembly as shielding.
Based on the inspector's review of this area, the licensee's. actions with respect to these job evolutions were appropriate and consistent with procedural l
requirements.
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No violations or deviations were identified.
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Exposure to Skin Licensee Health Physics Procedure HP-6.1.20, Personnel Contamination Monitoring and Decontamination, requires that a skin
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dose assessment be initiated if skin particle contamination-greater than 100,000 disintegrations per minute (dpm) is detected.
In addition, Procedure HP 6.1.21, Contaminated-Skin Dose
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Assessment, details guidance for determining skin dose due to surface contamination.
The inspector reviewed personnel contamination reports for the period May 1 through September 30, 1993,- and noted that the.
licensee had two hot particle events which required calculation' of
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skin dose, both of which occurred during the current Unit 2 outage.
Review of the two events in detail noted that they were-associated with a 630,000 dpm knee exposure during scaffolding (
werk at the "B" and "C" feedwater nozzles and a 160,000 dpm nasal i
exposure during "B" resistance temperature detector (RTD) removal.
The inspector noted that the resultant exposures were significantly less than the 75 microcurie-hour (uci-hr)
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enforcement threshold, and final exposures assigned to the workers were 3.353 rem and 0.803 rem to the skin of the whole body, respectively.
Licensee representatives stated that comparative calculations were performed for the knee exposure utilizing the VARSKIN code; however, this method has not yet been approved in
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procedures for assigning dose. The inspector did not note any concerns regarding the licensee's technical methods for performing
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either of the exposure assessments, and personnel exposures were appropriately updated to the individual exposure history files.
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The inspector also reviewed 1993 exposure records for selected
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individuals which had been associated with entries into the containment building at power. During review of the RWP, surveys,
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and dosimetry records associated with the entries, the inspector j
verified that the licensee was implementing appropriate radiological surveillances and was calculating and recording individual skin doses due to noble gas exposures appropriately.
For the records reviewed the inspector noted that the maximum assigned beta skin dose was 11 mrem. The inspector also verified
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that for the individuals reviewed their exposure records for skin
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dose were evaluated and updated appropriately, with all being l
within regulatory limits.
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No violations or deviations were identified.
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Thermoluminescent Dosimetry Program 10 CFR 20.202(c) requires, in part, that dosimeters used to comply with 10 CFR 20.202(a) shall be processed and evaluated by a dosimetry processor holding current accreditation from the-
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National Voluntary Laboratory Accreditation Program (NVLAP) for the types of radiation for which the individual is monitored.
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i During the onsite inspection, the inspector discussed the licensee's dosimetry program with cognizant representatives. The inspector noted that since the previous inspection conducted January 15 through February 11, 1993, and documented in IR 50-338,
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339/93-01, the licensee had implemented a new dosimetry system.
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The Panasonic UD-802 thermoluminescent dosimetry (TLD) system was implemented for dose determination for the third quarter of 1993.
Each dosimeter utilized four elements, two lithium borate and two calcium sulfate phosphors.
Based on differing filter media, element correction factors, and element response ratios, the
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licensee's algorithm determined the type of radiation detected by the TLD and subsequently determined the dose equivalent at specified tissue depths. The inspector was informed that the licensee's algorithm calculated dose equivalents at 7 milligrams
2 per square centimeter (mg/cm ) for skin dose, 300 mg/cm for lens
- of the eye dose, and 1000 mg/cm for deep dose. The inspector was also informed that the minimum TLD sensitivity for each element
l response was 10 mrem. The inspector noted that the TLDs were normally processed quarterly by the onsite dosimetry group. The inspector also noted that the licensee was NVLAP accredited in all
eight dosimetry categories for use of their new TLD system. The inspector did not identify any concerns with the licensee's
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implementation or subsequent use of the new TLD system.
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During discus; ions with licensee representatives the inspector was
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informed that although the Panasonic TLD was capable of and i
accredited for measu ing neutron exposure, the licensee continued
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to assign neutron dose based on survey results. The inspector
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reviewed neutron survey results and individual dosimetry records
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associated with power entries into containment. The inspector verified that the licensee was implementing appropriate radiological surveillances and was calculating and recording i
individual doses due to neutron exposures appropriately.
For the
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records reviewed the inspector noted that the maximum assigned neutron dose was 55 mrem. The inspector verified that exposure
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records were being updated appropriately to include the deep dose
due to neutron exposure. The inspector also verified that for i
those records reviewed all whole body doses were within regulatory
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limits.
No violations or deviations were identified.
6.
Internal Exposure Controls (83729)
10 CFR 20.103(a)(1) states that no licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a quantity of radioactive material in any
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period of one calendar quarter greater than the quantity which would 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.
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concentrations of radioactive material in air specified in 10 CFR Part 20, Appendix B, Table 1, Column 1.
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Respiratory Protection
' t 10 CFR 20.103(c)(2) permits the licensee to maintain and to I
implement a respiratory protection program that includes, at a l
minimum: air sampling to identify the hazard; surveys and
bioassays to evaluate the actual exposures; written procedures to l
l select, fit and maintain respirators; written procedures regarding
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the supervision and training of personnel and issuance of records;
and determination by a physician prior to the use of respirators,
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that the individual is physically able to use respiratory protective equipment.
For selected records reviewed the inspector verified that users of
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respiratory protective equipment were appropriately trained, fit-
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tested, and medically qualified in accordance with regulatory and
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procedural requirements. The inspector reviewed the licensee's respiratory protection training material and noted that the
material was appropriately inclusive, including the licensee's policy to limit respirator use when external exposures could be reduced, as required by the revised 10 CFR Part 20. The inspector
also noted that the licensee utilized a fit-testing booth to perform their annual fit-tests for applicable personnel. The inspector verified that in accordance with accepted regulatory
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guidance the licensee was appropriately calculating a fit-factor
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and required a satisfactory fit-factor greater than 10 times the j
protection factor for a negative pressure mask when performing these quantitative fit-tests.
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Additionally, the inspector discussed the overall implementation j
of the respirator usage reduction program during the current i
Unit 2 outage. At the time of onsite inspection, the licensee had used approximately 415 respirators. Although the outage was not
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yet completed, this represented a downward trend from the 1992 I
Unit 2 outage in which 2342 respirators were issued. Also, the inspector noted that significant reduction efforts were-j implemented for the Unit 2 RTD bypass elimination. The licensee l
stated that for Unit 2 only 58 respirators had been issued; whereas, for Unit 1, 313 respirators were used.
As discussed in
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Paragraph 9 of this report, this reduction was considered one of the contributing factors for the reduction in overall collective dose for this job evolution.
This area of the licensee's program continued to be considered a program strength.
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No violations or deviations were identified.
b.
Whole Body Counting and Exposure Tracking 10 CFR 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
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combination of such measurements as may be necessary for timely i
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I detection and assessment of individual intakes of radioactivity by i
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l Decontamination, requires that special bioassays be performed when
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facial contamination events exceeding 1000 dpm or positive nasal'
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swabs are detected.
In addition, the inspector-reviewed
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Procedures HP-5.2B.11, Bioassay Data Evaluation and Followup,
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HP-5.28.20, Calculation of Maximum Permissible Concentration-hours l
(MPC-hrs) Based on Bioassay Results, and HP-5.2B.22, Calculation
of Dose from MPC-hr Exposure Data, which provided additional t
guidance for bioassay evaluation and calculation of intakes.
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l The inspector reviewed selected personnel contamination reports
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for the period July 1 through September 30, 1993, detailing individuals reported to have positive facial :or nasal contamination.
For the cases reviewed, special whole body analyses were conducted in accordance with procedural requirements, and all calculated uptakes were less than five-
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percent of a maximum permissible organ burden (MP0B). The maximum uptake noted by the inspector was approximately 3.5 percent MP0B.
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for a pipe hauler associated with RTD bypass elimination. As discussed in previous reports, the licensee continued to
l experience an increase in small uptakes associated with decreased
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respirator usage; however, no 1993 exposures as determined from whole body count results met the licensee's threshold for calculation of an MPC-ur assignment. No concerns were noted by the inspector regarding tt is aspect of the licensee's program.
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In addition, the inspector reviewed the licensee's program for tracking MPC-br exposures based on airborne radioactivity measurements. No signifir. ant changes were noted in the program since the last inspectica of this area documented in IR 50-338, 339/93-01.
Evaluation of records for elevated air samples associated with Unit 2 outage RWPs 93-2-2188, Perform Check Valve Inspection / Replacement, and 93-2-2207, Cutout and Replace Valve / Transmitters, noted that personnel exposures were properly calculated, documented and entered into the HP computer. One-minor discrepancy was noted regarding a 0.19 MPC-hr exposure received on July 9,.1993, but assigned to the affected individuals-on July 22, 1993. The inspector determined the individual exposures during the period did not exceed the 2 MPC-hr per day or 10 MPC-br per week threshold established in 10 CFR 20.103(a)(3),
and no other such discrepancies were identified.
Review of MPC-hr assignments for the period January 1 through September 29, 1993, noted that the maximum, cumulative quarterly exposure assignment for an individual was 4.82 MPC-hrs. Although airborne exposures were a small fraction of regulatory 1-
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i requirements, the inspector noted that 1993 exposure assignments appeared to be trending higher than previous years. This can be z
primarily attributed to reduced protection factors associated with i
decreased respirator usage.
Based on the above, the inspector concluded that no internal
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contaminations in excess of the 40 MPC-hr control. limit requiring.
an additional evaluation had been identified through September 29,
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1993.
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No violations or deviations were identified.
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7.
Operational and Administrative Controls (83729)
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a.
Radiation Work Permits (RWPs)
The inspector reviewed selected RWPs associated with the ongoing
refueling outage for appropriateness of the radiation protection i
requirements based on work scope, location, and conditions. For
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the RWPs reviewed the inspector. noted that radiological concerns were appropriately addressed in that adequate protective clothing, respiratory protection, and dosimetry were required. The
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inspector also noted that during RWP preparation, proper
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consideration was given to the need for multiple dosimetry-or extremity dosimetry use. ALAPA evaluations and pre-job briefings i
were also performed as required. During facility tours the
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inspector observed the adherence of plant personnel to RWP
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requirements and had no concerns. The inspector noted that the
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licensee's program for RWP implementation adequately addressed
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radiological protection concerns and provided for proper control
measures.
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-i In addition, the inspector observed a pre-job briefing associated
with RWP 93-2-2168, Repack Valves, All Loops. The inspector noted
that the briefing included review of appropriate. health physics considerations and utilized the surrogate tour system to locate
the valves to be worked. Further, the workers were instructed on l
the use of local ventilation and the need to guard against
.i personnel contaminations as well as cautioned to read their RWP
prior to entry. Overall, the briefing was considered comprehensive.
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No violations or deviations were identified.
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b.
Termination Reports j
i 10 CFR 20.408(b) and 10 CFR 20.409(b) require that the licensee
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make a report to the Commission, and notify the individual
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involved, of the radiation exposure of each individual who has-i terminated employment. The report is to be furnished within l
30 days after the individual's exposure is determined by the i
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licensee or 90 days after the date of termination of employment or work assignment, whichever is earlier.
The inspector reviewed exposure records for selected personnel which had terminated work activities at the licensee's facility since January 1,1993, to include vendor personnel employed during both the ongoing and the previous outages. The inspector verified
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that all had been issued a termination letter within the applicable time period. The inspector noted that the licensee's progr.m was effective in providing for timely issuance of termin t en letters.
No violations or deviations were identified.
8.
Control of Radioactive Material and Contamination, Surveys, and Monitoring (83729)
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a.
Posting and Labelling 10 CFR 20.203 specifies the positing, labeling, and control i
requirements for radiation areas, high radiation areas, airborne,
radioactivity areas, and radioactive material areas. Additional j
requirements for control of high radiation and locked high
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radiation areas are contained in TS 6.12.
During tours of the plant, the inspector reviewed the licensee's program for posting and controlling areas with respect to the
aforementioned requirements, and no discrepancies were noted. The l
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inspector verified that selected high radiation areas and locked high radiation areas were posted, barricaded, locked, and/or in
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the control of health physics personnel, as appropriate. The inspector also noted the licensee's use of flashing green lights-designating low dose areas, color coded signs throughout large posted radiation areas designating various dose gradients, current l
survey maps posted outside high radiation areas, and current RWPs
posted on each elevation of the auxiliary.and containment
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buildings at major access points. The-inspector noted that all of these efforts were positive initiatives for heightening worker awareness of radiological conditions.
In addition, the inspector'
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discussed with licensee representatives the process for initially
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posting and de-posting areas as radiological conditions' change,-
and no concerns were noted.
j 10 CFR 20.203(f) requires, in part, each container of licensed i
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material containing greater than Appendix C quantities to bear a'
durable, clearly visible label bearing specific information
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regarding the contents.
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During facility tours, the inspector observed radioactive material
properly stored and labeled in accordance with procedural and regulatory requirements.
r No violations or deviations were identified.
b.
Surveys 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to
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comply with the regulations, and (2) are reasonable under the circumstances to evaluate the extent of radiological hazards that-may be present.
The inspector reviewed selected records of radiation and
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contamination surveys performed during the period January through September 1993, and discussed the results with licensee personnel.
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In addition, the inspector reviewed licensee surveys conducted to-support RWP 93-2-3019, Transport Old Steam Generator Lower Assemblies to Old Steam Generator Storage Facility and Off-load, and RWP 93-2-3018, Rig Out/In Steam Generator Lower Assemblies to Include Removal of Residual Liquid, Installation of Temporary Nozzle Covers, and Rig Lower Assembly Out of Containment.
Based on discussions with licensee representatives, review of DR 93-0251-related to several of these work activities, and other supporting documentation, the inspector determined that radiological surveys were conducted and action limits were complied with, as required.
During facility tours, the inspector verified radiation levels in
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various auxiliary building and Unit 2 containment locations and other areas of the RCA. The inspector noted that in all cases,
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areas were posted and/or safeguarded in accordance with the hazard present.
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No violations or deviations were identified.
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Area and Personnel Contamination
The licensee maintained approximately 96,000 square feet (ft )
j excluding containment, as radiologically controlled. As of September 30, 1993, the licensee was tracking approximately
4600 ft of floor space as contaminated. According to the-I licensee all of this contaminated area was associated with ongoing Unit 2 outage activities, and the " core" contaminated floor area had been reduced to zero. Thus, with the planned reclamation of the areas currently established following the outage, the licensee plans to have all floor space in the RCA designated as clean.
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addition, the inspector was informed that the next project in this-i area to be addressed is containment, with the long range goal being to decontaminate the containment buildings to a " street l'
clothes clean" condition.
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l During tours of the Unit 2 containment as well as other plant areas, the inspector observed good contamination control practices. Overall, the material control and housekeeping was l
considered excellent, particularly considering the stage of the outage. The inspector informed licensee representatives that the arer f contamination control continued to be a strength of the RP program.
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Through September 30, 1993, the licensee had documented 209 PCEs-as compared to an annual goal of 261.
For the current Unit 2 outage, the licensee had 45 PCEs, of which 31 were associated with facial contaminations.
Review of these latter events, noted that
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i approximately half were attributable to airborne l
l radioactivity / nasal contamination while the others.were associated
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with worker practices, both apparently resulting from reduced respirator usage.
Licensee representatives stated that improvements in worker practices were being addressed in NET as j)
well as in PCE review sessions.
No violations or deviations were identified.
i 9.
Program for Maintaining Exposures As low As Reasonably Achievable (ALARA) (83729)
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10 CFR 20.l(c) states that persons engaged in activities under licenses
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issued by the NRC should make every reasonable effort to maintain radiation exposures as low as reasonably achievable.
The inspector discussed with licensee representatives, their efforts to maintain personnel exposures ALARA during the previous Unit 1 outage,
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which included the Steam Generator Replacement Project (SGRP) and the
RTD bypass elimination project, and the ongoing Unit 2 outage, during
.I which RTDs and associated equipment were also removed. The inspector I
reviewed in detail the collective dose for the RTD bypass elimination.
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For Unit 1, the licensee expended approximately 87 person-rem.
For Unit 2, the licensee had established a goal of 50.6 person-rem, and as of the time of the onsite inspection-approximately 48 person-rem had been expended with about 93 percent of the work completed.
Licensee
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representatives attributed the reduction from Unit 1 performance to
decreased respirator usage (only used for pipe cutters), expanded mock-up training, use of experienced craft personnel, and implementation of
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lessons learned from Unit I as well as Surry.
During the 96 day Unit 1 Refueling / Steam Generator Replacement Outage,
i the licensee expended approximately 565 person-rem total exposure. - The licensee's initial goals for completion of the outage were 110 days and 912 person-rem.
The SGRP was responsible for approximately 250 person-rem, while the projected exposure for the project was approximately 500 person-rem. The licensee credited exposure reduction initiatives such as extensive mock-up training, extensive use of cameras and i
communication systems, shielding packages to include water shields for the reactor head stand, remote dose / dose rate monitoring equipment, M
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green flashing lights signifying low dose waiting areas, and increased use of historical data, as being beneficial in maintaining outage exposures well below-the projected estimates. The licensee has a projected goal of 449 person-rem for the ongoing Unit 2 outage. The inspector was informed that the licensee had implemented use of remote monitoring techniques, shielding packages, and other successful initiatives evidenced during the Unit 1 outage. As well, the inspector was informed that prior to the Unit 2 outage, ALARA representatives attended each work group's monthly safety meeting and outage contractors' orientation sessions to discuss dose saving methods, expected radiation levels and low dose waiting areas throughout the auxiliary and containment tuildings', lessons learned from previous outages, and ALARA suggestions. The licensee expected these initiatives to be beneficial in maintaining cumulative exposure for the outage as projected.
The inspector was informed that the annual dose goal for 1993 was initially projected at 1403 person-rem.
Following the successful Unit 1 outage the goal was revised to 1080 person-rem.
Following three very successful, low exposure, months during the routine operating cycle, the licensee estimated exposures averaging approximately 133 mrem per day for non-outage activities, and therefore again revised their annual goal to 1065 person-rem. As of September 30, 1993.the licensee's year-to-date cumulative exposure was approximately 800 person-rem. Licensee representatives informed the inspector that they expected to complete the year staying within their projected dose goal.
The in:pector also reviewed ALARA Suggestions submitted and minutes from ALARA Committee Meetings conducted during 1993. The inspector noted that approximately 25 suggestions had been submitted and reviewed during the year.
Practical and workable suggestions were reviewed and approved as determined by the ALARA Committee. The inspector noted that the ALARA Committee met monthly to discuss lessons learned from the outages, the Steam Generator and RTD replacement projects,-pre-and post-job ALARA reviews, status and flushing of hot spots, and exposure reduction action plans for work groups, as needed. The inspector noted that both of these programs appeared to be functioning appropriately and were'
beneficial in identifying and resolving dose reduction plans.
No violations or deviations were identified.
10.
Exit Interview (83729)
The inspection scope and results were summarized on October 1, 1993, with those persons indicated in Paragraph I abova The general program areas reviewed and inspection results were discussed in~ detail.
Licensee representatives acknowledged the inspector's comments and no dissenting comments were received. No information provided to or reviewed by the inspector was identified as proprietary in nature.
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