IR 05000424/1993015
| ML20046B748 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/12/1993 |
| From: | Forbes D, Bryan Parker, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20046B742 | List: |
| References | |
| 50-424-93-15, 50-425-93-15, NUDOCS 9308060144 | |
| Download: ML20046B748 (12) | |
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[((#""'4(g UNITED STATES
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NUCLEAR REGULATORY COMMisslON
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o REGION 81 e
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101 MAFilETTA STREET, N.W.
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f ATLANTA, GEOR GI A 30323 JUL l 2 1993
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Report Nos.:
50-424/93-15 and 50-425/93-15
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Licensee: Georgia Power Company P. O. Box 1295 Birmingham, AL 35201
Docket Nos.:
50-424 and 50-425 License Nos.: NPF-68 and NPF-81
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Facility Name: Vogtle 1 and 2
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InspectionConducped: June 4 -18,1993 i
Inspectors:
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07f/2 e/7 B.A.jarker Date Signed IbJLB 6.Yn6D 7A/43 D. B. Forbes
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Dath Signed Approved byf'
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kM 7!9!93'
W. H. Rankin, Chief Date Gigned Facilities Radiation Protection Section i
Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, announced inspection was conducted in the area of occupational radiation safety and included an examination of organization and staffing;
audits and self-identification; training and qualification; external exposure j
cor. trol; internal exposure control; control of radioactive materials; and
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maintaining occupational exposures as low as reasonably achievable (ALARA).
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Results:
In the areas inspected, no violations or deviations were identified.
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strengths were identified in the areas of ALARA, engineering controls, and shutdown chemistry. Based on interviews with licensee management, supervision, personnel from station departments, and records review, the inspector found that the radiation protection program continues to satisfactorily protect the halth and safety of workers and the public.
9308060144 930712 PDR ADDCK 05000424 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- M. Aj1 uni, Manager, SAER
- B. Ansley, Nuclear Specialist, Plant Hodifications
- J. Beasley, General Manager M. Burke, Specialist, SAER
- S. Chesnut, Manager, Technical Support t
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- W. Copeland, Supervisor, Materials K. Duquette, Plant Health Physicist
- W. Gabbard, Nuclear Specialist I, Technical Support
- J. Gasser, Supervisor, Outage Scheduling
- D. Huyok, Manager, Nuclear Security
- W. Kitchens, Assistant General Manager
- I. Kochery, Superintendent, Health Physics
- M. Kurtzman, Supervisor, Health Physics / Chemistry Training
- R. LeGrand, Manager, Health Physics and Chemistry
- J. Lucot, Supervisor, Health Physics
- G. McCarley, Supervisor, ISEG
- A. Parton, Superintendent, Chemistry J. Sills, Plant Chemist
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C. Tressler, Foremen, Dosimetry C. Tynan, Supervisor, Technical Support Other licensee employees contacted during the inspection included technicians, maintenance personnel, and administrative personnel.
Nuclear Regulatory Commission
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P. Balmain, Resident Inspector B. Bonser, Senior Resident Inspector
- R. Starkey, Resident Inspector
- Denotes attendance at exit meeting held on June 18, 1993.
2.
Organization and Management Controls (83750)
The inspector reviewed the licensee's management structure with regard to radiation protection.
Since the last inspection, the position of Manager of Health Physics and Chemistry was reassigned to an individual who formerly held the position. The transition occurred in January 1993, and the former Manager was assigned to Operations. The Manager of Health Physics and Chemistry oversaw the general program and reported to the General Manager. The Superintendent of Health Physics managed the day-to-day activities related to radiation protection through two Health Physics Supervisors. A support staff consisting of the Plant Health Physicist and three nuclear specialists assisted with investigations,
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1 evaluations and other special projects. The licensee appeared adequately staffed although some reduction was noted since the last
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inspection from approximately 52 foremen and technicians to i
approximately 48.
This reduced staffing did not adversely impact function / performance in the area of radiological controls.
i During the most recent outage (Unit I refueling outage (UIR4),
March 13 - April 27,1993), the licensee employed approximately 80 contractor personnel mainly consisting of senior and junior health
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physics technicians, and dosimetry technicians. The licensee was planning to use a slightly lower amount of contractor staff during the upcoming U2R3 refueling outage scheduled in the Fall of 1993.
No violations or deviations were identified.
3.
Audits and Self-Identification (83750)
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Technical Specification (TS) 6.4.2.8 requires that audits of plant activities be performed under the cognizance of the Safety Review Board (SRB) and that the audits shall encompass, in part, the conformance of plant operations to provisions contained within the TSs and applicable license conditions at least once per 12 months.
The inspector reviewed two Quality Assurance (QA) audits of Health Physics (HP) and Radiation Protection, OP02-92/35 and OP02-93/10, performed since the last NRC inspection conducted July 20-24 and 31, 1992, and documented in inspection report (IR) 92-16. The inspector i
noted that the audits appeared to adequately assess the program and were well-planned and documented.
The audits contained items of substance relating to the program and valid nonconformances were identified. The inspector noted thorough investigations and responsive commitments by management to effect corrective actions for the deficiencies identified.
i The inspector also noted a high level of management visibility for audit
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findings and subsequent responses, in that, the Vice President-Nuclear was responsible for final review and approval.
The inspector reviewed the licensee's plant-wide self-assessment program for identifying programmatic issues. The Deficiency Card (DC) program ms open to any employce wn) identified a potential problem / incident.
. cllowing identification of deficiencies, DCs were documented and i
referred to the responsible department for investigation of the incident and determination of root cauce and corrective actions to prevent recurrence. DCs were also reviaed to determine reportability as necessary.
During discussions with licensee personnel, the inspector
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was informed that plant action items were issued as a result of a DC and were maintained in a weekly open item update for tracking purposes.
Quarterly trending reports were developed to assist in tracking and trending DCs, QA findings, NRC violations and other issues that required j
resolution and corrective action. The inspector noted that the methed
for trending' identified deficiencies and for tracking open items to final and approved resolution appeared effective.
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- I The inspector also reviewed Radiological Incident Reports (RIRs)
initiated during 1992 and 1993 to date. The inspector noted that 14 RIRs were written in 1992 and four had been written in 1993 to date.
These included RWP violations, procedural violations, and poor work practices resulting in personnel and/or area contamination. During review of the identified RIRs, the inspector noted thorough investigations, appropriate and comprehensive corrective actions, as well as visibility with the responsible department manager.
No violations or deviations were identified.
4.
Training and Qualifications (83750)
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10 CFR 19.12 requires, in part, that the licensee instruct all individuals working in or frequenting any portions of a restricted area in the health protection aspects associated with ey;osure to radioactive material or radiation; in precautions or procedures to minimize exposure; in the purpose and function of protection devices employed; in the applicable provisions of the Commission regulations; in the individual's responsibilities; and in the availability of radiation
exposure data.
a.
General Employee Training (GET)
Licensee Administrative Procedure 00700-C, General Employee
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Training, Revision (Rev.) 12, dated January 11, 1993, specifies training and retraining requirements for personnel permanently or temporarily employed at the Vogtle site.
Licensee Procedure
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00701-C, Specialized Employee Training, Rev. 7, dated December 16,
1991, provides specialized employee training and retraining
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requirements for courses such as First Aid, Respiratory
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Protection, Radworker ALARA Training, Transportation, Hazardous i
Materials, and Crane Operator Training. The inspector discussed the GET process with cognizant licensee personnel assigned to the training division and reviewed GET training lesson plan GE-LP-00117-04-C, General Employee Training, Rev. 4, dated October 8, 1993. GET was divided into two levels, depending on the degree of access required for personnel entering the Vogtle site.
Level I
training was provided to employees needing unescorted access to only the protected area.
For workers needing unescorted access to i
the radiologically controlled area (RCA), level II training was required, in addition to Level I.
Both levels of training required personnel to pass an examination with a minimum passing score of 70 percent.
Based on the review of selected training procedures and course outlines, the inspector determined that the licensee's GET program met the provisions of 10 CFR 19.12.
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Respiratory Protection Training
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Licensee Procedure GE-LP-00201-06, Respiratory Protection
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Training, Rev. 6, dated May 14, 1993, provides training on the hazards of airborne radioactive contamination and the methods employed to reduce these hazards. The inspector discussed the
'l respiratory training program with cognizant licensee personnel.
l The respiratory protection training process included lectures, i
demonstrations, respiratory equipment fit test, medical
examinations, practical abilities examinations and written
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examinations. Based on these discussions, the inspector determined the licensee's program for respiratory training to be
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adaquate in scope, c.
Continuing Training For Health Physics Personnel The inspector reviewed various licensee lesson plan packages presented during continued training sessions for health physics employees. The reviewed training consisted of lectures and problem solving exercises which were job performance based.
The licensee has also been conducting training on licensee changes
to work practices and procedures that will be affected by the licensee's January 1, 1994 implementation of the revised
Based on discussions with licensee personnel and a review of lesson plans, the inspector determined continuing training for HP
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personnel was adequate.
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d.
Notices to Workers 10 CFR 19.11(a) and (b) require, in part', that the licensee post
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current copies of 10 CFR Parts 19 and 20, the license, license conditions, documents incorporated into the license, license amendments and operating procedures, or that a licensee post a notice describing these documents and where they may be examined.
I 10 CFR 19.ll(d) requires that a licensee post Form NRC-3, Notice to Employees.
Sufficient copies of the required forms are to be posted to permit licensee workers to observe them on the way to or
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from licensed activity locations.
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During the inspection, the inspector verified that Form NRC-3 was posted properly at various plant locations permitting adequate worker access.
In addition, notices were posted referencing the i
location where the regulations, license, procedures, and
supporting documents could be reviewed.
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No violations or deviations were identified.
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5.
External Exposure Control (83750)
10 CFR 20.101 requires that no licensee possess, use, or transfer
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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
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occupational dose in excess of 1.25 rem to the whole body, head and
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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 20.202(a) requires each licensee to supply appropriate monitoring
equipment to specific individuals and requires the use of such
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equipment.
During tours of the plant, the inspector observed workers wearing appropriate personnel monitoring devices. The insp:-ctor discussed the l
cumulative whole body exposures for plant and contractor employees.
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Licensee representatives indicated and the inspector confirmed that all
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whole body exposures assigned since the previous NRC inspection of this
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area were within 10 CFR Part 20 limits. The licensee had not granted
any administrative dose extensions in 1993 above the licensee's administrative limit of 2000 millirem as of June 14, based on interviews with the licensee and a review of the licensee's exposure records.
The licensee has utilized Electronic Direct Reading Dosimeters (EDRDs)
since plant startup in lieu of self-reading pocket ionizacion chambers.
l EDRDs were used for all entries into the radiologically-controlled area
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(RCA) with alarm setpoints for dose rate and integrated dose set i
according to the RWP requirements and the work to be performed. The i
site collective EDRD dose was accumulated and tracked by a computerized system and compared monthly to the site collective thermoluminescent
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dosimeter (TLD) (official dose) after the TLDs were processed.
Generally, there was a correlation of approximately 97 percent between the TLDs and EDRDs.
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The inspector inquired about an issue regarding TLD/EDRD correlation that was raised during the last inspection in July 1992. As discussed j
in IR 92-13, the licensee identified a problem in which monthly EDRD
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doses were underestimating official TLD doses. Thir. prompted the licensee to conduct a study, also discussed in IR 92-13, which resulted
in some changes to the EDRD system software. According to the licensee,
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since completing the study and the system changes, similar problems have not been experienced.
The inspector discussed and reviewed the licensee's procedures for
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issuance and usage of EDRDs for all entries into the RCA.
The inspector observed licensee calibration technicians perform six month calibration
and diagnostic checks of selected EDRDs. An issue was also discussed
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with the licensee regarding a recent problem identified by a major EDRD
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vendor in which certain hardware / software combinations cause double dose
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to be reported. The licensee was aware of the problem, but had not t
experienced similar problems with the equipment in ne at the Vogtle
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i site. The licensee was maintaining approximately 600 EDRDs for use with i
a certain fraction out of service at any given time for maintenance. At i
the time of inspection, the licensee was in the process of upgrading to
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newer, more sophisticated models of EDRDs from the same vendor.
No problems were noted with the licensee's methods or procedures regarding the issuance, usage, or calibration of EDRDs.
No violations or deviations were identified.
6.
Internal Exposure Control (83750)
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Bioassay Program 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,
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i measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by l
exposed individuals.
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As of June 17, 1993, the licensee had experienced 28 " positive" whole body counts in 1993. The licensee considered any count that
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gave a result greater than the minimal detectable activity for any i
nuclide other than potassium-40 to be " positive." The maximum
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exposures involved two individuals who ingested minor amounts of
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cobalt-60 (less than 20 microcuries), and both exposures were well
below the 40 MPC-hour control measure.
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selective records of the bicassay program.
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b.
Respiratory Protection Program
10 CFR 20.103(b)(1) requires that the licensee use process or-l other engineering controls to the extent practicable to limit
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concentrations of radioactive materials in the air to levels below
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those which delimit an airborne radioactivity area as defined in 20.203(d)(1)(ii).
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10 CFR 20.103(c)(2) permits the licensee to maintain and implement a respiratory protective program that includes, at a minimum:
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sampling to identify the hazard; surveys and bioassays to evaluate
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the actual exposures; written procedures to select, fit, and
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maintain respirators; written procedures regarding supervision and i
training of personnel and issuance of records; and determination
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by a physician prior to the use of respirators, that the
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individual user is physically able to use respiratory protective i
equipment..
i The inspector reviewed and discussed licensee actions taken to reduce the number of respirators used in genen.l. The inspector noted that the licensee was aggressive in their efforts, mainly
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reducing respirator usage through the increased use of engineering
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controls. The licensee developed an effective plan for reducing high local airborne potentials by using large-diameter local area
ventilation systems, tents, containments and other techniques for removing the airborne hazard. As a result, respirator usage has
drastically declined without a significant increase in internal
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exposures. During U1R4, the licensee used less than
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500 respirators, whereas approximately 3000 and 6000 respirators
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were used during the previous outages U2R2 and UIR3, respectively.
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The licensee attempted to quantify the dose savings realized
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because of respirator reduction and calculated that 11.3 person-l rem was saved during U2R2 and 9.0 person-rem was saved during
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UlR4.
The inspector noted that the licensee's extensive use of engineering controls, resulting in a large reduction in respirator usage, was an overall program strength.
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No violations or deviations were identified.
7.
Surveys, Monitoring, and Control of Radioactive Material (83750)
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10 CFR 20.201(b) requires each licensee to make or cause to be made such l
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surveys as (1) may be necessary for the licensee to comply with the
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l regulations and (2) are reasonable under the circumstances to evaluate
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the extent of radioactive hazards that may be present.
10 CFR 20.203 specifies the posting, labeling and control requirements j
for radiation areas, high radiation areas, airborne radioactivity areas,
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and radioactive material. Additional requirements for control of high i
radiation areas are contained in TS 6.12.
During tours of the plant,
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the inspector reviewed the licensee's posting and control of radiation j
areas, high radiation areas, airborne radioactivity areas,
contamination areas, radioactive material areas, and the labeling of t
radioactive material.
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Contaminated Area
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RCA total area equals approximately 450,000 square feet (ft2).
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The licensee typically maintained 4,500 ft2 (1.00 percent) or less
as contaminated area. The amount of contaminated area peaked for l
the year during the UlR4 outage at approximately three percent of
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J the RCA.
In general, housekeeping was considered satisfactory.
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b.
Personnel Contaminations t
The inspector reviewed the licensee's personnel contamination
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events (PCEs) for 1992 and 1993 to date.
PCEs were tracked as i
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either skin or clothinJ events and, according to the licensee,
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some overlap in total numbers did occur. The 1992 PCE goal was 50
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and 26 PCEs actually occurred. Thirteen of the 26 were skin
j contaminations, six were clothing and seven were skin and clothing j
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contaminations. The PCE goal for 1993 was 43, with 19 assigned for each of two outages and five for all of the non-outage periods. As of' June 11, 1993, a total of 25 PCEs had been documented. The maximum calculated skin doses were far below regulatory limits and no problems were noted with the licensee's methods or procedures.
c.
Radiation Work Permits (RWPs)
The inspector reviewed RWPs for adequacy of tne radiation
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protection requirements based on work scope, location, and conditions.
For the RWPs reviewed, the inspector noted that appropriate protective clothing, respiratory protection, and dosimetry were required. All workers entering the RCA were l
advised of their available exposure for that entry based on the l
RWP, as indicated by the EDRD reader.
Overall, the inspector found the licensee's program for RWP l
implementation to adequately address radiological protection
concerns, and to provide for proper control measures.
No violations or deviations were identified.
8.
Radiation Detection and Survey Instrumentation (83750)
During facility tours, the inspector noted that survey instrumentation and continuous air monitors in use within the RCA were cperable and
'i displayed current calibration stickers. The inspector further noted an j
adequate number of survey instmments were available for use, and background radiation levels at personnel survey locations were observed to be within the licensee's procedural limits.
No violations or deviations were identified, 9.
Program for Maintaining Exposures As low As Reasonably Achievable (ALARA) (83750)
10 CFR 20.l(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures a low as reasonably achievable. The recommended elements of an ALARA program are contained in Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures ALARA.
Regulatory Guides 8.8 and 8.10 provida information relevant to attaining goals and objectives for plannino and operating light water reactors and provide general philosophy acceptable to the NRC as a necessary basis for a program of maintaining occupational exposures as low as reasonably achievable (ALARA).
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The inspector reviewed 1992 year-end and 1993 first and second quarter ALARA Committee meeting minutes. The inspector noted that attendance at
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the meetings was adequate with representatives from a majority of the
plant departments.
Review of meeting minutes revealed that year-end and
,L outage radiological goals, as well as year-to-date radiological status
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was discussed. The inspector also noted that post-job ALARA reviews for
high dose jobs, exposure reduction initiatives, personnel ALARA
suggestions, and RIRs were reviewed and discussed at the meetings.
j The inspector reviewed the licensee's program to maintain occupational i
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exposure ALARA. During discussions with licensee representatives, the
I inspector was informed that the 1992 site collective dose was
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426 person-rem.
The licensee's site dose goal for 1992 was 425 person-rem. The lice,see's site dose goal for 1993 was set at 530 person-rem,
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which accounted for 243 person-rem per outage, 15 person-rem per unit operational dose, and seven person-rem per unit forced outage dose. The 1993 year-to-date collective dose was approximately 174 person-rem, as
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compared to a year-to-date dose goal of 261 person-rem. The recent UIR4
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j outage accounted for 168 of the 174 year-to-date dose, well below the
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original 243 person-rem cutage dose goal and below ti - 175 person-rem
" target" goal set early in the outage. Thus, the licensee felt that the annual goal o' 530 person-rem was easily obtainable Sarring any major
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unforeseen problems.
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The inspector discussed and reviewed with licensee representatives i
successful ALARA initiatives employed during the outage. The licensee
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utilizatio. 7f teledosimetry, remote video cameras, and radio
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communicacions 'or monitoring high exposure jobs were beneficial in l
maintaining espocures ALARA.
The licensee also began using remote continuois ;ir monitors during the outage to assist in monitoring
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airborne hazards in containment.
In general, personnel expot
'oeared to be managed well.
U1R4 outage i
at their lowest leyels since UlRI.
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dose per day and per RWP-hot o
HP personnel exposure, a major x tributor to overall dose, continued to
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decline.
In past outages, HP cutage dose had accounted for 15-20 percent of overall dose; however, due to initiatives such as the
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j aforementioned teledosimetry, cameras and radios, lip dose during UIR4 j
accounted for only 9.7 percent of the total outage dose.
l The licensee continued to aggressively pursue containment dose rate reduction through techniques such as shutdown chemistry control and
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I temporary shielding.
The inspector noted th t the licensee's shutdown
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chemistry control program was well-supported by management and l
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coordinated well with other groups such as Operations and Maintenance.
Strict controls were used at shutdown in order to maximize the reactor coolant system (RCS) cleanup while also planning work at optimum times
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(i.e., when dose rates were the lowest). The licensee fallowed the recent guidance provided by the r M u 'c Power Research Institute (EPRI)
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regarding PWR Primary Shutdown a ' (' etup Chemistry (January 1993).
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The licensee's successfulness in area of shutdown chemistry led to i
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lower work area dose rates as evidenced by EPRI standard radiation surveys taken soon after outage start. These RCS surveys revealed that dose rates in containment during UIR4 were very near the dose rates measured during the UlR1 outage in 1988. The inspector noted that the
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licensee's shutdown chemistry control program was a significant ALARA
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initiative and was an overall program strength.
The inspector reviewed other source term reduction issues being pursued by the licensee. These included engineering controls, cobalt reduction, microfiltration, reactor head shielding, and nozzle dams.
Engineering controls were discussed in Paragraph 6.b.
With regard to cobalt reduction, the licensee identified a number of valvcs that contain
cobalt and was prioritizing the valves for replacement. To date, no valves had been replaced. With regard to microfiltration, the licensee indicated that the 25 micron RCS letdown filters may be replaced with
micron or sub-micron filters to remove smaller particulate matter from the RCS. A reactor head shielding package is scheduled to be used
during the upcoming U2R3 and UlR5 outages and the licensee is evaluating
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the feasibility of using a "zero-entry" nozzle dam to reduce personnel
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exposure further.
A new type of nozzle dam esed during UlR4 reduced steam generator " jump" dose by almost 50 percent, cutting it from a
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former level of approximately eight person-rem to the four/five
person-rem range.
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The inspector discussed the planning and preparation for the upcoming Fall 1993 U2R3 outage with 1 eensee representatives.
Specific areas
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discussed included increases in staffing, special training, equipment and supplies, health physics involvement in outage planning, licensee control over health physics technicians, and dose reduction methods to
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be employed.
Overall, the inspector noted that licensee efforts to reduce source term and general area dose rates throughout the plant were successful. The inspector informed licensee representatives that the program for
maintaining personnel exposures ALARA during both intine and outage t
activities was a strength to the overall program.
No violations or deviations were identified.
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10.
Followup on Inspector Followup Items (IFIs) (92702)
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(Closed) VIO 50-424,425/92-16-01: The inspector reviewed the
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licensee's actions taken in response to the violation and found them to be adequate. The individual involved in the incident leading' to the violation was counseled by plant management, including the General Manager, with emphasis on adherence tr procedural requirements.
In addition, the licensee required all Maintenance and HP personnel to
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review the incident report and associated procedurer and provided
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further guidance to HP personnel on the proper use/ adjustment of and response to alarming dosimetry.
No additional concerns were noted by the inspector and this item is considered closed.
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11 11.
Exit Meeting At the conclusion of the inspection on June 18,19%, an exit meeting was held with those licensee representatives indicated in Paragraph 1.
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The inspector summarized the scope and findings of the inspection and
informed the licensee that all findings were preliminary and subject to i
NRC management review and approval.
The licensee did not indicate any
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of the information provided to the inspectors during the inspection as i
proprietary in nature and no dissenting comments were received from the licensee.
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