IR 05000395/1993028
| ML20059G399 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 01/11/1994 |
| From: | Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059G392 | List: |
| References | |
| 50-395-93-28, NUDOCS 9401240145 | |
| Download: ML20059G399 (9) | |
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I UNITED STATES
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101 MARIETTA STREET, N.W., SUITE 2900
l ATLANTA, GEORGIA 30323 0199
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W 13 R Report No.:
50-395/93-28 Licensee:
South Carolina Electric and Gas Company Columbia, SC 29218 Docket No.-
50-395 License No.:
NFP-12 facility Name:
V. C. Summer Nuclear Station Inspection Conducted: December 13-17, 1993
_[ 7!N Inspector:
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R. B. Shortridge
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Date/ Signed Accompanying Personnel:
W. T. Loo Approved b h hi
/ Il 9Y W. H. Rankin, Chief ate' Signed Facilities Radiation Protection Section
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Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
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 staffing, audits and appraisals, training and qualifications, external and internal exposure controls, control of radioactive material, and ALARA program implementation.
Results:
Overall, the RP program was effectively implemented.
The HP technician staffing appeared adequate to support outage activities. The licensee continued to implement effective internal and external exposure control programs, with all exposures being less than 10 CFR Part 20 limits.
Additionally, a significant reduction in the use of respirators during the year resulted in a positive correlation with reduction in external exposures associated with the various jobs.
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9401240145 940113 PDR ADDCK 05000395 G
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i REPORT DETAILS 1.
Persons Contacted Licensee Employees
- W. Baehr, Manager, Health Physics (HP) and Radwaste Services-
- J. Berley, Nuclear Licensing and Operating Experience (NL&OE)
- M. Fowlkes, Manager, NL&OE
- R. Goff, Supervisor, Oil / Environmental Lab
- M. Jordan, Supervisor, HP
- C. McKinney, NL&OE
- K. Nettles, General Manager, Station Support
- S. Reese, Licensing Specialist
- G. Taylor, General Manager, Nuclear Plant Operations
- R. White, Nuclear Coordinator, SCPSA i
Other licensee employees contacted included engineers, technicians, and office personnel.
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Nuclear Regulatory Commission
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- T. Farnholtz, Resident Inspector
- R. Haag, Senior Resident Inspector
- Attended December 17, 1993 Exit Meeting 2.
Organization and Staffing (83750)
The inspector reviewed and discussed'with licensee representatives ~
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changes made to the RP organization since the last inspection of this area conducted March 29 - April 2, 1993, and documented in Inspection Report (IR) 93-12.
Cognizant licensee representatives stated that no
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major changes had occurred since the last inspection. The Manager of-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. specialists which reported directly to the applicable group supervisor. At the time of the onsite inspection the position of ALARA supervisor was still vacant, as well as two staff health physicist positions. The licensee stated that they do intend to fill the health physicist positions as soon as possible.
Also, as the steam generator replacement project (SGRP)
nears the September 1994 start date the newly obtained contract HP personnel will replace licensee HP personnel as they are transferred to the SGRP. The licensee did not see any significant problem in providing an adequate supervisory umbrella over the SGRP HP organization.
Licensee representatives stated that current planning calls for 80 contract HP personnel to supplement the stations' HP staff for the SGRP. Approximately 36 senior and 24 junior HP technicians with 16 decontamination (decon) personnel and four radiological engineers comprise the mix for the 80 contract personnel.
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Based on discussions with licensee representatives, review of planned-
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organizational changes, and observations of activities in progress, no concerns were identified regarding the licensee's organization and staffing.
The staffing levels appeared adequate to support ongoing and planned outage activities.
No violations or deviations were identified.
3.
Audits and Appraisals (83750)
During the onsite inspection, the inspector reviewed the licensee's
self-assessment program for identification and correction of j
radiological deficiencies. The inspector particularly reviewed
Radiological Incident Reports (RIRs) and Radiological Deficiency Reports
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(RDRs), and audits of varying aspects of the RP program performed by the licensee's Quality Assessment (QA) group. The inspector also reviewed the methods for responding to and correcting identified deficiencies.
The inspector reviewed those documented deficiencies which were identified during the period from January to December 1993.
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During review of RIRs and RDRs, 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 contained substantive findings and that appropriate corrective
actions to these problems were identified in the reports.
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The inspector reviewed the following QA audits and surveillances:
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QA Surveillance 26-RFM-92-L, Health Physics Instrumentation, dated
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August 18, 1992 QA Surveillance 08-WVP-92-L, Control of Radioactive Material,
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dated October 6, 1992-i QA Surveillance 30-RFM-92-L, Self Reading Dosimetry, dated-
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November 13, 1992 QA Surveillance 20-RBB-92-L, Source Control, dated December 14,
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QA Surveillance 1-REM-93-C, Special Nuclear Material, dated
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January 8, 1993
QA Surveillance 2-RFM-93-L, Reactor Building Entry and Neutron
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Exposure Accountability, dated February 3, 1993
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QA Surveillance 1-BEM-93-C, Receipt of New Fuel and Control i
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Components, dated February 9, 1993 QA Surveillance 5-WVP-93-L, Health Physics Activities, dated
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March 19, 1993
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QA Surveillance 5-SMC-93-L, Health Physics Control Point, dated
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March 25,-1993
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QA Surveillance 3-RFM-93-M, Radiological Analytical Services,
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dated April _1, 1993
QA Surveillance 4-RFM-93-L, Reactor Building Tour, dated April 6,
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1993 QA Surveillance 5-RFM-93-W, Reactor Building and Reactor Cavity
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' Tour, dated April 8, 1993
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QA Audit-93009-0, Station Radiation Control, dated November 8,
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1993 f.
QA Surveillance 93108-0, Station Radiation Control, November 29,
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1993 The inspector reviewed each audit / surveillance for findings, adverse
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trends, substance, corrective action and timeliness of correction, and documentation, and found the self assessment process to be working
efficiently.
No violations or deviations were identified.
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Training and Qualification (83750)
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.
During preparation for trouble shooting the "B" Incore Drive Unit inside containment the licensee held several pre-job briefings. The inspector attended the briefing, as it was part of qualification for the job.
Since the unit was operating, special precautions were required.
Primarily, the licensee was concerned with ambient heat and secondarily-
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with radiation and contamination.
Dose rates at the job site at 100 percent power were not anticipated to be more than 20 millirem per hour; however, the ambient temperature was greater then 100 degrees
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Fahrenheit which requires a reduced stay time of 89 minutes in containment. The licensee stated that the incore drive motor in the control room would be tagged out but electrical power would have _to be turned on at the drive box _in containment to support operation and verification of the correction of the problem of the drive not operating in the slow speed. The inspector noted that the pre-job briefings appeared to be comprehensive and good communication between groups was observed.
The licensee experienced a number of job delays and this caused the inspector to adjust his schedule over several days. On
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4-l December 16, 1993, the inspector informed the health physics control point to be sure the inspector was notified if the entry at power was to be made that day. However, the inspector was not notified as requested, and did not observe the work as desired. Upon inquiry, licensee management informed the inspector that the HP control point had announced for the NRC inspector over the gaitronics but the gaitronics was not working in the building housing the resident inspectors office where he was at the time. Therefore, the inspector was not able to make i
a performance based assessment, during this inspection, as to how plant personnel perform operations radiologically.
Similar work activity will be scheduled for observation during future inspection activity.
No violations or deviations were identified.
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External Exposure Controls (83750)
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Whole Body Exposure 10 CFR 20.101 requires that no licensee possess, use, or transfer i
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; 18.75 rem to the hands, forearms, feet and ankles; and 7.5 rem to the skin of the whole body.
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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 maximum whole body exposure for an individual to date in 1993 did not exceed the licensee's administrative limit of 1000 mrem, whole body, without an exposure extension pre-approved by site i
management.
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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 accredited by the National Voluntary Laboratory Accreditation
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The inspector reviewed selected areas of the licensee's dosimetry
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program and observed no changes-since the last inspection.
During tours of the plant, the inspector observed workers wearing
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appropriate personnel monitoring devices including
- l Thermoluminescent Dosimetry (TLDs), digital alarming dosimeters
_(DADS), and Pocket Chambers. -The inspector did not observe any
inadequacies with licensee selection and use of DADS was reviewed and discussed with the licensee's ALARA and calibration personnel.
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The inspector did not note any inadequacies with the licensee's use of the EDs.
No violations or deviations were identified.
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Internal Exposure Controls (83750)
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.
10 CFR 20.103(b)(1) requires the licensee, as a precautionary procedure, to use process or other engineering controls, to the extent practicable,
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to limit concentrations of radioactive materials in air to the level below those which delimit an airborne radioactivity area as defined in 20.203(d)(1)(ii).
To date this year the licensee has been successful in reducing the number of full face respirators from approximately 3,600 in_1992 to approximately 1,200 in 1993. To support the reduction, the licensee reviewed approximately 1,000 air samples taken during routine work in the radiologically controlled area (RCA) of the plant and found only
five were greater than 0.25 percent of the maximum permissible
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concentration (MPC).
Licensee' representatives stated that so far this year they had received five low-level uptakes and have reduced
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collective dose by a postulated 30 percent for jobs that in the past would have required respirators but were performed without respirators.
No violations or deviations were identified.
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Surveys, Monitoring, and Control of Radioactive Material and
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Contamination (83750)
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Surveys i
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 radioactive hazards that may be present.
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The inspector reviewed the procedures that were under revision for revised part 20. Many of the procedures establish the licensee's radiological survey and monitoring prograni.
The review was to
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determine consistency with revised part 20, and consisted of the following procedures:
Health Physics Procedure (HPP)-150, Requirements for
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Issuance and Use of Personal Dosimetry HPP-152, Radiation Control Area Access Control
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HPP-153, Administrative Exposure Limits
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HPP-158, Contamination Controls for Areas, Equipment, and
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Materials HPP-160, Control and Posting of Radiation Control Zones
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HPP-302, Radiation and Con; amination Survey Techniques
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HPP-402, Radiological Survey Requirements and Controls for
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Reactor Building and Incore Pit Entries HPP-403, Radiological Controls for Nuclear Work Activities
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HPP-410, HP Routine Surveys
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HPP-505, Issuance and Termination of Personal Dosimetry
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HPP-518, Exposure Documentation Control
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Upon completion of the review the inspector discussed several issues with licensee representatives regarding methods of implementation of revised part 20 requirements.
None of the issues were items of non-compliance.
The inspector reviewed selected records of radiation and contamination surveys performed during the period from April through December-1993, and discussed the survey results with licensee representatives. During tours of the plant, the inspector ~also observed HP technicians performing radiation and
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contamination surveys. The inspector noted that performance and documentation of radiation and contaminati surveys was appropriate.
-p 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.
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Posting and Labeling
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10 CFR 20.203(f) requires, in part, each container of licensed material containing greater than Appendix C quantities to bear a
.i 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
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exposures.
During. plant tours, the inspector generally observed adequate
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housekeeping and contamination control practices. The use of plastic and maslin was observed at many job sites in an effort by
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the licensee to effectively control contamination. The licensee's control of contaminated areas of the RCA was exemplary. The licensee consistently controls radiologically a minimum of contaminated area in.the total area of the plant.
Consistently this figure is less than 1,000 square feet. Also, during outages plant workers can enter most areas in the reactor building without donning protective clothing.
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Radiation Detection and Survey Instrumentation During. facility tours, the inspector noted that survey 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 personnel survey locations were observed to-be within the licensee's procedural limit of 200 counts per minute, d.
Personnel Contamination Events As of December 2, 1993, approximately 194 Personnel Contamination Events (PCEs) had occurred in 1993.
In April alone there were 82 PCEs. Discussions with licensee representatives and review of PCE
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data revealed that many of the PCEs were due to reducing the use of full face respirators.
The bulk of the PCEs' occurred during the outage in April. The -licensee attributed a postulated savings of 30 person-rem over projection largely to performing work out of respirators.
No Violations or deviations were identified.
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Program for Maintaining Exposures As low As Reasonable Achievable (83750)
10 CFR 20,1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures as low as reasonably achievable.
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The inspector reviewed and discussed with. cognizant licensee representatives ALARA program implementation and initiatives for 1993 and 1994, to date, which included outage and non-outage periods.
The licensee continued to use sub-micron filtration to reduce the size of particles in the reactor coolant.
Filter. sizes have been reduced from 20 microns at the start of the program to 0.45 sub-micron downstream of the demineralizers and just prior to the seal water injection filters.
Shutdown chemistry has been particularly effective in reducing out-of-cora source term and subsequently collective dose. Through strict control of the lithium / boron ratio during shutdown and associated cleanup phases the licensee was able to reduce radiation dose rates on the reactor coolant loops by 40-60 percent overall after shutdown for
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RF08. Through December 8, 1993, the licensee only had 9.991 person-rem
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attributed to operating dose.
RF07 resulted in 266 person-rem for its 58 day duration. To date the licensee is well under its projected collective dose goal for the year.
Based on the above, the, inspector informed licensee representatives that ALARA initiatives currently in use appeared to be resulting in substantial dose savings.
No violations or deviations were identified.
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Exit Interview The inspection scope and results were summarized on December 17, 1993, with those persons indicated in Paragraph 1 above. The general program areas reviewed and the inspection findings were discussed in detail.
Licensee representatives acknowledged the inspector's comments and no
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dissenting comments were received.
The licensee was informed that no proprietary information was reviewed during this inspection.
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