IR 05000395/1993012
| ML20036A554 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 04/28/1993 |
| From: | Forbes D, Pharr E, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20036A548 | List: |
| References | |
| 50-395-93-12, NUDOCS 9305120068 | |
| Download: ML20036A554 (15) | |
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gM UNITED STATES
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.fo, WUCLEAR REGULATORY COMMISs10N
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o REGION ll S
E 101 MARIETTA STREET, N.W.
- ATLANT A, GEORGI A 30323
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APR 2 91993
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Report No.:
50-395/93-12 Licensee: South Carolina Electric and Gas Company
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Columbia, SC 29218 Docket No.:
50-395 License No.:
NFP-12
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Facility Name:
V.C. Summer Nuclear Station
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Inspection Cond t d':
arcf29-Ap--
2, 1993
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d d Z f T~5 Inspectors:
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E.B.Phpr-D&te Sligned A~1)
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D. B. Forbes Date Signed--
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Approved b D
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W. H. Rankin, Chief D' ate Signed
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Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
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j SUMMARY Scope:
t This routine, unannounced inspection of the licensee's radiation protection (RP) program involved a review of health physics (HP) activities primarily associated with Refueling Outage 7.
This review included organization and
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staffing, self-assessment programs, training. and qualifications, internal and
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external exposure controls, control of radioactive material, outage planning and preparation, and ALARA program implementation.
Results:
Overall, the RP program was effectively implemented. The.HP technician-staffing appeared adequate to support outage activities. The training program
'for HP technicians'was conducted in accordance with' approved procedures. The licensee continued to implement effective internal and external exposure control programs, with. all exposures being less than 10 CFR Part 20' limits.
The use of the'recently implemented electronic dosimetry system appeared to have been an effective contributor in maintaining outage exposures.ALARA.
Additionally, a significant reduction.in the use of respirators during steam
generator work resulted in a positive correlation with reduction in external-exposures associated with the job evolution. One Inspector Followup Item i
(IFI) was identified regarding the completion and implementation of a generic
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i 9305120068 930429 i
PDR ADOCK 05000395 G
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. temporary shielding program. This program should be a definite program enhancement for reducing dose rates and subsequent collective exposure associated with various brief but high exposure _ outage work activities. Also, a Non-Cited Violation (NCV) regarding the licensee's failure to post as required by '10 CFR 19.11 was identified.
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REPORT DETAILS
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1.
Persons Contacted
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Licensee Employees
- W. Baehr, Manager, Health Physics (HP) and Radwaste Services
- A. Barth, Design Engineering
- J. Berley, Nuclear Licensing and Operating Experience (NL&OE)
- C. Bowman, Manager, Maintenance
- B. Christiansen, Manager, Technical Services
- M. Fowlkes, Manager, NL&OE
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- M. Jordan, Supervisor, HP
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- A. Koon, Project Coordinator, Nuclear Operations Department (N0D)
- D. Lavigne, General Manager, Nuclear Safety
- C. Price, Engineering Services
- M. Quinton, GMES
- L. Shealy, SEQE
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- J. Skolds, Vice President, Nuclear Operations
- G. Taylor, General Manager, Nuclear Plant Operations
- A. Torres, Associate Manager, Quality Control
- R. Waselus, Manager, Systems Engineering
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- B. Williams, Manager, Operations Other licensee employees contacted included engineers, technicians, and office personnel.
Nuclear Regulatory Commission
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- L. Keller, Resident Inspector, Region II
- J. Stohr, Division. Director, DRSS, Region II
- Attended April 2, 1993, Exit Meeting 2.
Organization and Staffing (83729)
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The inspector reviewed and discussed with licensee representatives changes made to the RP organization since the last inspection of this i
area conducted November 30 to December 4, 1992,'and documented in Inspection Report (IR) 92-22. Cognizant licensee representatives stated-that in January -1993, the Manager, Chemistry and Health Physics assumed the position title of Manger, Health' Physics and Radwaste Services and would serve as the primary Radiation Protection Manager (RPM)-'as
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described in the Final Safety, Analysis Report (FSAR).' The positions. of Associate Manager, Health Physics and Associate Manager, Chemistry were eliminated.
The Associate Manager, Chemistry assumed the position title' -
of Manager, Chemistry..
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The Manager, Health Physics'and Radwaste Services had a staff of six -
supervisors and five staff health physicists reporting 'directly to him.
Each of the six support groups had a senior specialist and other
t specialists which reported directly to the applicable group supervisor.
At the time of the onsite inspection the position _of ALARA supervisor-
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was vacant, as well as two staff health physicist positions. Also, two of the five senior specialist positions had not been permanently allocated. The inspector was also informed that one specialist and one staff health physicist would be reassigned to Quality Services to assist
in performance of program audits.
Following completion of. the ongoing
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outage the licensee expected to finalize the organizational structure
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and staffing.
Following this recent reorganization, the licensee maintained a core i
technician staffing of 64 health physics (HP) technicians and six
supervisors. As a result of the elimination of many of the middle management positions within the Radiation Protection (RP) program, the licensee hoped to enhance both the depth and breadth of supervisory resources.
For Refueling Outage-7 (RFO-7), the inspector noted that
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approximately 125 contractor technicians were employed to supplement the
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routine staff. This number included senior technicians, junior technicians, and health physics clerks.
Based on discussions with licensee representatives, review of planned organizational changes, and observations of activities in progress, no e
concerns were identified regarding the licensee's organization and staffing. The staffing levels appeared adequate to support ongoing and
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planned outage activities.
No violations or deviations were identified.
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3.
Audits and Appraisals (83729)
During the onsite inspection, the inspector reviewed the licensee's self-assessment program for identification and correction of radiological deficiencies. The inspector particularly reviewed Health Physics Problem Reports (HPPRs), the recently implemented Radiological Incident and Deficiency Reporting system, which will replace the HPPRs, and audits of varying aspects of the RP program performed by the licensee's Quality Assessment (QA) group. The inspector.also reviewed
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the methods for responding to and correcting identified deficiencies.
The inspector reviewed those documented deficiencies which were identified during the period from November 1992 to April 1993.
During review of HPPRs, the inspector noted that these reports were utilized to identify, track, and trend any poor radiological work practice or violation of HP procedures. The inspector noted that the reports consisted of substantive findings and that appropriate.
corrective actions to these problems were identified in the reports.
The inspector reviewed the newly implemented Health Physics Procedure (HPP-161), Radiological Incident and Deficiency Reporting, Revision 10.
This procedure provided instructions and forms to RP personnel for the purposes of-reporting, assessing, tracking, and trending radiological incidents and deficiencies.
Radiological Incident and Deficiency Reports for-1993 were also reviewed by the inspector and were determined-to be adequately documented in'accordance with licensee procedure.
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i Additionally, the inspector reviewed audits of the RP program as i
performed by the licensee's QA group. The inspector noted that these
audits included, but were not limited to, a review of the training for the unit staff, review of the radwaste program, and plant tours and
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surveillances.
During the surveillances the QA auditors observed plant i
housekeeping, dosimetry use, instrument calibration, personnel monitoring, radiological postings and HP controls during hydrogen peroxide injection activities, and plant personnel and HP activities at'
the RCA entrance point.
The inspector noted that the audits identified
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deficiencies, which required a timely response, as well as ' enhancement i
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items. The inspector found the audits effective in identifying radiological deficiencies, with appropriate followup investigations and
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corrective actions to ensure closure of the identified findings.
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In general, the inspector found the licensee's mechanisms for self-identification of RP program deficiencies to be well planned and
documented, with items of substance relating to the RP program being appropriately identified. Additionally, corrective actions to. audit findings were accomplished in a timely manner.
No violations or deviations were identified.
4.
Planning and Preparation (83729)
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The inspector discussed with licensee representatives the planning and preparation for the current outage which included the 10 year Reactor Vessel Inservice Inspection (ISI) and steam generator work.
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Specifically, the inspector discussed with licensee representatives increases in staffing, special training, health physics involvement in
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outage planning, licensee control over HP technicians, and dose reduction methods to be employed. During observation of ongoing outage activities, the inspector noted that the planning and preparation ~and
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implementation of planned techniques had'been successful in maintaining exposures ALARA and work scope as scheduled.
The inspector also discussed with licensee representatives planning and
preparations being performed for the upcoming outage which was_to
include the replacement of the steam generators.
Scoping work for the replacement of the steam generators was occurring during the ongoing outage and was significantly attributing to the overall current outage:
exposure. The inspector noted that the licensee was in the process of-
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developing a procedure for use of a temporary generic shielding program.
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During a previous NRC inspection conducted March 23-27, 1993, with details documented in IR 93-11, the inspector identified a weakness in
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the licensee's lack of pipe shielding during an ISI on Reactor Coolant o
System (RCS) associated piping. The inspector noted that the contact
dose rate on the RCS piping was.approximately 450 millirem per hour
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(mrem /hr).
Cumulative exposure for the NRC inspector and the two examiners performing the ISI was 167 mrem.
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During the current inspection, the inspector discussed with cognizant.
licensee representatives the referenced incident as well as the licensee's temporary shielding policy. The inspector was informed that the licensee's current policy for shielding installations did not routinely allow for shielding blankets to be placed directly onto piping for safety related seismically qualified systems.
Instead for such'
systems, the licensee policy required construction of the necessary i
scaffolding support for lead blankets over and around the subject
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piping.
Following discussions with licensee representatives and tours
within the bioshield, the inspector noted that construction of scaffolding and subsequent hanging of lead blankets would not be dose effective for much of the outage activities which take place in RCS loop areas, including the work activities witnessed by the previous
inspector. These activities, which include ISI, snubber, and M0 VATS
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activities, are dose intensive evolutions but are relatively short in duration and very mobile, thus making the construction of scaffold
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shielding non-ALARA. However, during discussions with ALARA and shielding personnel the' inspector was informed that shielding placed
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directly on piping would be more effective in reducing general area dose rates in the loop areas than scaffold shielding and would not ' require the exposure associated with construction of scaffolding.
At the time of the onsite inspection the licensee's engineering group.
was completing a procedure which would identify an acceptable amount of temporary generic pipe shielding for specified pipe diameters.
Based on a generic safety review the engineering group would calculate the amount of allowable temporary shielding for specific piping diameters. The inspector noted that prior to use of this spot shielding a lim'ted engineering review would still be required to determine that ceitain requirements be met. These would include that the system to be shielded
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be supported seismically, an anti-falldown review be performed with positive results, and the system be depressurized and at ambient temperature.
Although the inspector recognized the extensive use of scaffold shielding that was used by the licensee during the ongoing outage, the.
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inspector also discussed the benefits that could result.from implementation of the temporary generic pipe shielding policy. Based on
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the extensive work to be performed in the RCS loop areas during the
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upcoming steam generator. replacement-outage, the inspector stressed the need for completion and implementation of the generic. shielding procedure in order for the licensee to maintain exposures ALARA during.
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the replacement outage. The licensee acknowledged the inspector's comments. The inspector informed licensee representatives that
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completion of this procedure and implementation of the generic shielding program would be tracked as an Inspector Followup Item (IFI) (IFI: 50-395/93-12-01).
No violations or deviations were identified.
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5.
Radiation Protection Training (83729)_
10 CFR 19.12 requires the licensee to instruct all individuals working in or frequenting any portions of the restricted areas in the health protection aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protection devices employed, applicable -
provisions of the Commission Regulations, individual's responsibilities and the availability of radiation exposure data.
The inspector reviewed the licensee's training program for outage contractor technicians. The inspector noted that prior to receiving site specific training, the contractors had to successfully complete a Health Physics Fundamentals examination. 'The inspector noted that the training material and examination appropriately addressed radiation fundamentals relating to basic HP theory, biological effects of radiation, radiation detection and instrumentation, dosimetry, associated calculations, and 10 CFR Part 20 requirements.
Following successful completion of HP Fundamentals, the contractors were required to complete Site Orientation Training which encompassed plant policies concerning security, emergency planning and response, industrial safety, quality assurance, and radiation awareness. The contractors also received site specifics training and on-the-job training which when successfully completed verified their qualification.
to perform various tasks related to their job classification.
Additionally, the contractors received respiratory protection training and respirator qualification, training on the licensee's forms for documentation and incore instrumentation system, as well as an industry events update.
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The inspector reviewed the training material and examinations and training records for selected contractors. The inspector noted that the information presented was sufficient to train contractors on plant i
policies.
During records review the inspector verified the individuals'
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knowledge of the presented information by successful completion of.
examinations, and qualification to job-related tasks. The inspector also noted that the licensee presented a brief training of the recently
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implemented electronic dosimetry (ED) system. The inspector reviewed
the training video and noted that the training appropriately addressed the use of EDs, the different alarms, and how to respond to an alarm.
No violations or deviations were identified.
6.
External' Exposure Controls (83729).
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Whole Body Exposure 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, a
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head and truck, active blood forming organs, lens of the eyes, or gonads; 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 a-Form NRC-4 or equivalent record prior to permitting the individual to exceed the limits of 20.101(a).
The inspector discussed and reviewed the cumulative whole body exposures for selected plant and contractor employees.
Licensee representatives confirmed that all whole body exposures assigned since the previous NRC inspection of this area were within 10 CFR Part 20 limits.
Review of pertinent records revealed that the
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maximum whole body exposure for an individual for the first quarter of 1993 did not exceed the licensee's administrative limit of 1000 mrem, whole body, without an exposure extension pre-approved by site management. At the time of the inspection, 30 exposure extensions had been assigned.
During selected review of the exposure extensions, the inspector verified that the licensee had complete and documented lifetime exposures for those individuals. The inspector noted that none of these exposure extensions exceeded regulatory limits nor the licensee's administrative limit of 2500 mrem to the whole body.
No violations or deviations were identified.
b.
Personnel Dosimetry 10 CFR 20.202(a) requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipment.
10 CFR 20.202(c) requires that dosimeters used to comply with 10 CFR 20.202(a) shall be processed and evaluated by a processor r
accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for the types of radiation for which the
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individual is monitored.
The inspector reviewed selected areas _of the licensee's dosimetry program and observed no changes since the last inspection.
During tours of the plant, the inspector observed workers wearing.
appropriate personnel monitoring devices _ including
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Thermoluminiscent Dosimetry (TLDs), EDs, and Pocket Chambers.
Licensee selection and use of EDs was reviewed and discussed with the licensee's ALARA and calibration personnel. The inspector did
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not note any inadequacies with the licensee's use_ of the EDs.
In fact, the inspector noted that.use of the ED telemetry system for many high exposure jobs during the ongoing outage appeared to have been beneficial in maintaining exposures ALARA.
No violations or deviations were identified.
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7.
Internal Exposure Controls (83729)
i 10 CFR 20.103 establishes the limits for exposure of individuals to concentrations of radioactive materials in the air in restricted areas.
Section 20.103 also requires that suitable measurements of-concentrations of radioactive material in air be performed to detect _ and evaluate the airborne radioactivity in the air.
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10 CFR 20.103(a)(3) requires, in part, that the. licensee, as
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appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of.
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individual intakes of radioactivity by exposed individuals.
The inspector reviewed bioassay results, counting techniques, and survey-
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documentation since the last NRC inspection conducted November 30 -
December 4,1992, for selected individuals identified in' personnel contamination reports as having positive skin contamination 3.
The inspector _was informed by licensee' representatives that five positive internal contaminations-had been identified to date in 1993. All of the internal contaminations were a low percentage of the Maximum Permissible Body Burden (MPBB) and Maximum Permissible Organ Burden (MP0B).
Based on the above, the inspector concluded that the licensee was effectively controlling internal contaminations with no exposure' greater -
than the 40 Maximum Permissible Concentration-hour (MPC-hr) control-limit identified.
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Additionally, the inspector reviewed and discussed with licensee representatives the program for testing.and qualifying breathing air as Grade D, calibration of gauges, and the presence of carbon monoxide monitoring equipment, particularly as it related to preparation for and ongoing RFO-7 activities.
Following these discussions and plant tours, which included observation of outage activities, the inspector did not identify any concerns with the licensee's program for. supplying-
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breathing air. The inspector also inspected respiratory equipment' fit test, storage, and maintenance facilities The inspector.noted that the supplied air hood and hoses available for use were compatible per manufacturer's instructions.
No violations or deviations were identified.
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8.
Surveys, Monitoring, and Control of Radioactive Material and Contamination (83729)
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Surveys
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10 CFR 20.201(b) requires each licensee to make or cause to be
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made such surveys as (1) may-be necessary for the licensee to
comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be present.
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The inspector reviewed the plant procedures which established the licensee's radiological survey and monitoring program and verified that the procedures were consistent with regulations,: Technical Specifications, and good HP practices.
The inspector reviewed selected records of radiation and contamination surveys performed during the period from January through April 1993, and discussed the survey results with licensee representatives.
During tours of the plant, the inspector also observed HP technicians performing radiation and contamination surveys. The inspector noted that performance and documentation of radiation and contamination surveys was appropriate.
During facility tours, the inspector independently verified radiation and/or contamination levels in radioactive waste areas, radioactive material storage areas, various Auxiliary and Waste Processing Building areas, and the Containment Building. The inspector noted that all containers, materials, and areas were properly labeled, posted, and/or safeguarded in accordance with the radiation hazard present.
No violations or deviations were identified.
b.
Posting and Labeling 10 CFR 20.203(f) requires, in part, each container of licensed material containing greater than Appendix C quantities to bear a durable, clearly visible label identifying the radioactive contents and providing. sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
During plant tours, the inspector-generally observed excellent housekeeping and contamination control practices. The use of plastic and masslin was observed at many job sites in an effort by the licensee to effectively control contamination. Traversed areas.were observed being decontaminated frequently which also minimized the use of. personnel contamination clothing in the Containment Building.
The inspector also toured the' Radwaste Warehouse which.was located in an outside Radiologically Controlled Area (RCA). The. inspector noted that the area was properly posted and radioactive materials 1 were labeled appropriately. The inspector noted several radioactive material. storage containers located outside the -
Warehouse but'still within the. RCA which were labeled properly.
However, the labels on the containers were very faded and nearly unreadable due to weather exposure. The inspector discussed with licensee representatives the prudence of ensuring that labels on-radioactive materials containers in outside storage areas be-
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surveyed periodically in order that the labels be clearly readable-
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so that individuals handling or using the containers, or working in the vicinity thereof, could take precautions to avoid or minimize exposures..The licensee resurveyed the containers and
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replaced the faded labels with labels which clearly identified the contents and provided radiation levels.
Licensee representatives
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also indicated that their current program for ensuring the
integrity of radioactive labels on outside storage containers would be reviewed to ensure its effectiveness.
No violations or deviations were identified.
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Radiation Detection and Survey Instrumentation i
During facility tours, the inspector noted that survey
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instrumentation and continuous air monitors in use within the RCA were operable and displayed current calibration stickers. The inspector further noted an adequate number of survey instruments-were available for use, and background radiation levels at
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personnel survey locations were observed to be within the licensee's procedural limit of 200 counts per minute (cpm).
No violations or deviations were identified.
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Personnel Contamination Events As of March 31, 1993, approximately 61 Personnel Contamination Events (PCEs) had occurred in 1993. Discussions with licensee representatives and review of PCE data revealed that 24 were skin
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contaminations and 37 were clothing contaminations.
For those PCE's occurring since the last inspection of this area, the inspector noted that none met the licensee's threshold for performing skin dose calculations.
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Operational and Administrative Controls (83729)
a.
Radiation Work Permits (RWPs)
The inspector reviewed Health Physics Procedure (HPP-401),
Revision 10, which provided detailed instructions on the
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preparation and processing of RWPs and Standing Radiation Work
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Permits (SRWPs). SRWPs were used primarily for low dose job
evolutions.
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The inspector reviewed selected RWPs for appropriateness of the radiation protection requirements based on work scope, location, and conditions. The inspector reviewed RWPs indicating a high
potential for' exposure during the outage such as 10 year ISI,
reactor head work, steam generator maintenance, stuck reactor head stud removal, and steam generator replacement scoping.
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inspector observed the adherence of plant workers to the RWP
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requirements and discussed the RWP requirements with plant workers at the job site.
For the RWPs reviewed, the inspector noted that appropriate protective clothing, respiratory protection, and.
dosimetry were required.
In particular, the inspector noted that special RWP 93-0108 related to reactor vessel ISI (including the core barrel lift), as well as the associated pre-job briefing attended by the inspector, appropriately addressed radiological concerns.
The inspector observed briefings conducted for workers prior to entering the RCA. The briefings included contamination levels, radiation levels, and low dose waiting areas. The inspector considered the interaction between RP and the workers entering the RCA to be adequate.
The inspector found the licensee's program for RWP implementation
to adequately address radiological protection concerns, and to provide for proper control measures.
No violations or deviations were identified.
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Notices to Workers t
10 CFR 19,11(a) and (b) require, in part, that the licensee post current copies of 10 CFR Part 19, Part 20, the license, license
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conditions, documents incorporated into the license, license
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amendments and operating procedures, or that a licensee post a notice describing these documents and where they can be examined.
10 CFR 19.ll(d) requires that a licensee post form NRC-3, Notice
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to Employees. Sufficient copies of the required forms are to be posted to permit licensee workers.to observe them.on the way to or from licensee activity locations.
During tours of the licensee's facility the inspector observed postings as required by 10 CFR 19.11. The inspector noted that at the security auxiliary access portal (AAP).the required postings did not include 10 CFR Parts 19 and 20, the license, pertinent i
documents relating to the license, operating procedures, nor a
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notice describing where these documents could be examined.. The inspector did note, however, that the postings were posted i
appropriately at=the entrance to the RCA so as.to be observed by all plant workers entering the area.
However, the inspector
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observed a temporary RCA entrance which had been set up during the
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outage for plant workers involved with steam generator activities.
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The inspector noted that the 10 CFR 19.11 required postings were
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not posted at this secondary entrance to the RCA. The inspector
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was informed that many of these workers entered the protected: area
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through security's primary access portal (PM'). The inspector-noted the required postings were not posted at the PAP but were-posted in a hallway of the Service Building.
However, during discussions with workers the inspector was informed-that many did
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representatives that the failure to appropriately post the j
required documents so as to be observed.by all workers on their
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way to and from licensed activities was an apparent violation of
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10 CFR 19.11 (VIO 50-395/93-12-02).
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.i Prior to the end of the onsite inspection, the licensee posted' the
required documentation at the temporary entrance to the RCA and
also corrected the postings at the AAP, to include a notice j
informing workers where 10 CFR Parts 19 and 20, the license, pertinent documents relating to the license,; and operating procedures were-located for review.. The inspector informed-
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licensee representatives that based on their actions,_the criteria:
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specified in Section VII.B of the Enforcement Policy were met and-l therefore the violation was not being cited.
i One NRC-identified non-cited violation (NCV) for failure to post._
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required documents in accordance with 10 CFR 19.11 was' identified.'
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Program for Maintaining Expo'sures As low As Reasonable' Achievable -
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10 CFR 20.l(c) states that persons engaged in activities under licenses i
issued by the NRC should make every reasonable l effort to maintain-
_1 radiation exposures as low as reasonably achievable.
M The inspector reviewed and discussed with cognizant licensee.
representatives ALARA program implementation and initiatives for:1992
and 1993, to date, which included outage _ and non-outage periods. -The'
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inspector was informed that the collective dose through. December 31,
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1992, was.approximately 27 person-rem, as compared to the licensee's
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1992 original goal of 20 person-rem. This dose was_ attributable.
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primarily to normal operating ' conditions and an unanticipated mini-
outage to investigate and repair a steam' generator-. secondary manway
' leak, which attributed approximately 9 person-rem.:
j For RFO-8, the licensee had estimated 460 person-rem and established:a
'I challenging goal 390 person-rem,, based. on estimated doses from ALARA-
pre-job evaluations.
Significant work evolutions contributing to the 1_
il dose estimate included:ISI. (18 person-rem), MOVATST(9 person-rem),-
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Snubbers / Hangers (13 person-rem),-Steam Generator replacement preparatory work:(30.4. person-rem),' Stuck Head Stud _ Removal :(10 person
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rem), Reactor Head Work (21.2 person-rem),. Fire Detection System
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replac.ement/ maintenance (10.97 person-rem), Temperature and Pressures
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Detector Systems replacement / maintenance (32.15 person-rem).; and Steam j
~GeneratorLmaintenance (109.6 person-rem).
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.The inspector reviewed the ALARA pre-job evaluations for the' steam
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In general, the evaluations. considered appropriate dose reduction
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Particular dose reduction' items of note included the use _of.
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i a specially designed shadow shield box to be used to encase workers during pressurizer surge line hanger modifications, and the planned use
of remote cutting methods for the two steam generator tube pulls.
Discussions with ALARA personnel and workers involved in RFO-7.
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activities revealed several dose reduction efforts. These included:
(1) increased use of temporary shielding based on engineering analyses; (2) increased use of video monitoring; (3) use of remote dose
monitoring; (4) overall reduction in the use of respiratory protective-
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equipment based on successful implementation of engineering controls to reduce airborne concentrations; (5) improving chemistry pH during plant
operation; and (6) implementation of peroxide during shutdown in
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combination with ultra-filtration to remove corrosion products. At the
time of inspection, the licensee had not yet fully quantified the overall radioactivity removal, however they had determined the controlled shutdown to be successful based on plant chemistry and dose rates.
In addition, the inspector observed selected portions of steam generator
mockup training and also observed mockup dry runs for the core barrel i
lift prior to the evolution being performed. Both mockup evolutions
involved HP personnel and included techniques to minimize exposure and the spread of contamination. The licensee filmed the core barrel lift and steam generator operations to improve both performance and dose
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reduction' efforts for future jobs. The inspector observed the core
barrel lift on a closed circuit monitor set up for control room personnel.
Although unanticipated delays increased cumulative exposure
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associated with the evolution, the inspector noted that the licensee's exposure control efforts during the job were implemented appropriately.
Additionally, the inspector noted that the ALARA Committee was required
to review work activities with a projected dose of greater than
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10 person-rem.
If the pre-job exposure estimate was greater than 5
person-rem, an ALARA pre-job review meeting was performed.
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Documentation of the pre-job review meeting was included with the RWP package and reviewed during the pre-job briefing. The' inspector reviewed selected ALARA pre-job reviews which had a pre-job exposure estimate greater than 1 person-rem, in which a. pre-job review meeting
was held with the job supervisor and/or workers and documented with the
RWP package.
In addition, licensee representatives provided to the
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inspector a Daily Exposure Report generated for ALARA personnel to track i
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specific RWP exposure by job in order to enhance performance and dose reduction at the management level.
Based on the above,'the inspector-informed licensee representatives that-
ALARA initiatives associated with the current outage were a program
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strength.
j No violations or deviations were identified.
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11.
Exit Interview
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The inspection scope and results were summarized on April:2,:1993,.with l
those persons indicated in Paragraph 1 above. The general program areas
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reviewed and the inspection findings were discussed in detail.
Licensee representatives acknowledged the inspector's comments and'no_ dissenting l
commer,ts were received.
The licensee was informed that although i
proprietary information was reviewed dui ng this inspection, such i
i material would not be included in the report.
Item Number Description and Reference
50-395/93-12-01 IFI - Regarding the licensee's completion and l
implementation of a generic temporary shielding
program, prior to the steam generator replacement project during RFO-8 (Paragraph 4)-.
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50-395/93-12-02 NCV - Failure to post required documents in i
accordance with 10 CFR 19.11 (Paragraph 9.b).
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