IR 05000424/1993022
| ML20059D818 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/15/1993 |
| From: | Forbes D, Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059D816 | List: |
| References | |
| 50-424-93-22, 50-425-93-22, NUDOCS 9311030012 | |
| Download: ML20059D818 (13) | |
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' UNITED STATES
/p neog%,4 NUCLEAR REGULATORY COMMISSION REGloN 11
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101 MARiETTA STREET, N.W., SUITE 29%
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ry ATLANTA, GEORGIA 30323-0199
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%,*...+l OCT 1 C 1933 Report Nos.: 50-424/93-22 and 50-425/93-22 Licensee: Georgia Power Company P. O. Box 1295 Birmingham, AL 35201
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t Docket Nos.:
50-424 and 50-425 License Nos.:
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Facility Name:
Vogtle 1 and 2 Inspection Conducted: September 20-24, 1993 Inspectors:
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/0/5/U R. B. Shortridge u
Date Signed
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't D. B. Fp'es Dat'e Signed i
/ f//8 Approved y:
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. A W. H. Rja kin, Chief Date Signed
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Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch
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Division of Radiation Safety and Safeguards SUMMARY
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Scope:
This routine, announced inspection was conducted in the area of occupational
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radiation safety and included an examination-of organization and staffing; audits and appraisals; training and qualification; external exposure control;
internal exposure control; control of radioactive materials; and maintaining
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occupational exposures as low as reasonably achievable (ALARA).
Results:
In the area inspected, no violations or deviations were identified.
Based on interviews with licensee management, supervision, personnel from station departments, and records riview, the inspector found that the radiation protection program continues to satisfactorily protect the health and safety of workers and the public.
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9311030012 931015 PDR ADOCK 05000424 G
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a REPORT DETAILS
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1.
Persons Contacted Licensee Employees
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- J. Beasley, General Manager
- C. Christiansen, Supervisor, SPER
- R. Dorman, Manager, Training and Emergency Preparedness
- K. Duquette, Plant Health Physicist
- G. Frederick, Manager, Maintenance
- W. Gabbard, Nuclear Specialist I, Technical Support
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- W. Kitchens, Assistant General Manager
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- I. Kochery, Superintendent, Health Physics M. Kurtzman, Supervisor, Health Physics / Chemistry Training
- R. LeGrand, Manager, Health Physics and Chemistry
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- J. Lucot, Supervisor, Health Physics
- G. McCarley, Supervisor, ISEG
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- A. Parton, Superintendent, Chemistry
- M. Seepe, Supervisor, Radwaste
- M. Sheibane, Supervisor NASC
Other licensee employees contacted during the inspection included technicians, maintenance personnel, and administrative personnel.
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Nuclear Regulatory Commission
- B. Bonser, Senior Resident Inspector
- Denotes attendance at exit meeting held on September 24, 1993.
2.
Organization and Management Controls (83729)
The inspector reviewed the licensee's management structure with regard to radiation protection (RP) organization since the last NRC inspection of this area conducted on June 14-18, 1993, and documented in Inspection Report (IR) 50-424, 425/93-15. Cognizant licensee representative stated that the structure and reporting chain for the RP function had not changed since the last inspection. The licensee appeared adequately staffed although some reduction was noted since the last inspection from approx' lately 52 foremen and technicians to approximately 48.
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i During the current Unit 2 refueling / cycle three outage (U2R3). the licensee employed approximately 70 centractor personnel mainly consisting of senior and junior health physics (HP) technicians, and dosimetry technicians. The licensee was using a slightly lower amount of contractor staff during the U2R3 refueling outage as compared to approximately 80 contractor personnel used during the Unit I refueling /cucle 4 outage (UlR4).
Licensee representatives attributed
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this reduction in staff partially to the high number of contractor technicians returning to the site with previous plant experience.
Approw;mately 67 of the 70 contractor technicians were returnees.
No violations or deviations were identified.
3.
Audits and Appraisals (83729)
Technical Specification (TS) 6.4.2.8 requires that audits of plant
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activities be performed under the cognizance of the Safety Review Board (SRB) and that the audits shall encompass, in part, the conformance of plant operation to provisions contained within the TSs and applicable license conditions at least once per 12 months.
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The inspector also reviewed Radiological Incident Reports (RIRs) for 1993. The inspector noted that six RIiis have been written in 1993.
These included Radiation Work Permit (RWP) violations, arocedural 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.
The licensee had not performed any audits since the last inspection,.
however, Quality Assurance (QA) was performing an audit on the RP program during the inspection.
No violations or deviations were identified.
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4.
Planning and Preparation (83729)
Planning and preparation for the U2R3 outage was discussed with cognizant licensee representatives.
Specific areas discussed included duration of the outage, shielding work packages, training
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qualifications, job histories for specific evolutions such as refueling operations, rehctor coolant pump maintenance, and steam generator maintenance. The inspector reviewed a work package for performing radiography on a steam valve, reviewed the worksite setup, and also observed the interface between HP personnel and the workers during the pre-job briefing. The pre-job briefing included current radiation levels, contamination and radiation surveys to be performed, use and control of equipment, and personnel access control during performance of work.
Based on records review and observations of briefings performed, the inspector found the licensee's planning and preparation was adequate in addressing radiological controls.
No violations or deviations were identified.
5.
Training and Qualifications (83729)
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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 exposure to radioactive
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material or radiation; in precautions or procedures to minimize exposure; in the purpose and function of protection devices employed; in
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the applicable provisions of the Commission regulations; in the individual's responsibilities; and in the availability of radiation exposure data, a.
General Employee Training (GET)
During a review of RIRs, the inspector noted that the corrective
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actions for 93-002 involved training. The RIR was written to document the unauthorized removal of temporary shielding from the Unit 1, number four main coolant pump. The RIR noted that the shielding had been reinstalled incorrectly which made RP believe
that workers who removed the shielding were not knowledgeable of j
the requirements for accountability and authorization for removal.
l Based partially on this, RP recommended that the event be included
in GET. The inspector followed up three recommendations which included incorporation of the event into the GET requalification i
lesson plan, the GET handbook, and initial GET radworker lesson pl ans. A review of licensee data showed that all three recommendations had been incorporated in the oppropriate
documents. The inspector also noted that the event was covered in
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several pre-job briefings.
i 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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Contractor Health Physics Training i
l The inspector reviewed training and required reading packages for I
contractor HP personnel. Licensee procedure 40001-C, Health
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Physics Department Personnel Selection, Training and
QualifMtion, Revision (Rev.) 12, dated September 1,1993, -listed qualification requirements for contractor HP technicians. The senior contractor HPs are requfrtd to successfully complete the Northwest Utilities Examination prior to performing work at Plant Vogtle.
Discussions with lite-e.>oresentatives and procedure review indicated senior contt etor. ' technicians may be trained to perform specific tasks ant u li-ied to independently perform those tasks.
Required readin w.uded sight specific procedures and industry events. The inspector reviewed selected resumes and examinations for the contractor HP technicians and verified compliance with ANSI 3.1-1981 requirements. During tours of the i
facility, the inspector interviewed contractor HP technicians and observed the techn'cians providing job coverage.
The inspector determined the licensee's program for contractor HP technicians training was adequate and conducted in accordance with approved procedures.
No violations or deviations were identified.
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6.
External Exposure Control (83729)
10 CFR.20.101 requires that no licensee possess, use, or transfer licensed material in such a manner as to cause any individual in a
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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 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
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skin of the whole body.
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10 CFR 20.202(a) requires each licensee to supply appropriate monitoring i
equipment to specific individuals and requires the use of such equipment.
During tours of the plant, the inspector observed workers wearing appropriate personnel monitoring devices.
The licensee had established an annual goal of 619 person-rem for a two outage year.
Discussions with cognizant licensee representatives indicated the actual person-rem l
to date was tracking well below the pre-established goal of 619 person -
The licensee has established a goal of 180 person-rem for U2R3 rem.
with an outage challenge from plant management of 160 person-rem. The licensee was tracking slightly above the outage challenge as of outage
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day 12.
The inspector discussed the cumulative whole body exposures for
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plant and contractor employees.
Licensee. representatives indicated and
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the inspector confirmed that all whole body exposures assigned since the previous NRC inspection of this area were within 10 CFR Part 20 limits.
No violations or deviations were identified.
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Internal Exposure Control (83729)
a.
Bioassay Program 10 CFR 20.103(a)(3) requires, in part, that the licensee, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
I As of September 23, 1993, the licensee had experienced 37 " positive" whole body counts in 1993, of which nine were identified during the U2R3 outage. The licensee considered any count that gave a result greater than the minimal detectable activity for any nuclide other than potassium-40 to be " positive."
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The maximum exposures received by individuals were determined to be minor amounts of cobalt-60, and all exposures were well below the 40 Maximum Permissible Concentration-hour (MPC-hour) control'
measure.
No problems were noted by the inspector during a review of selective records of the bioassay program.
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b.
Respiratory Protection Program 10 CFR 20.103(b)(1) requires that the licensee use process or other engineering controls to the extent practicable to limit concentrations of radioactive materials in the air to levels below those which delimit an airborne radioactivity area as defined in
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10-CFR 20.203(d)(1)(ii).
10 CFR 20.103(c)(2). permits the licensee to maintain and implement
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a respiratory protection program that includes, at a minimum:
air sampling to identify the hazard; surveys and. bioassays to evaluate the actual exposures; written procedures to select, fit, and maintain respirators; written procedures regarding supervision and
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training of personnel and issuance of records; and determination by a physician prior to the use of respirators, that the individual user is physically able to use respiratory protective
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equipment.
The inspector examined respiratory equipment for physical integrity which included respirators, bubble hoods, hoses, and manifolds. An individuals qualifications for being issued respiratory protection equipment is provided on.a daily printout to the respiratory issue station.
Discussions were held with licensee representatives on testing and qualifying breathing air as Grade D.
For the tests reviewed, breathing air met Grade D.
requirements.
Observations, discussions with licensee representatives, and
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review of selected records indicated the licensee has continued to enhanced the respiratory protection program by increasing the effective use of portable worksite ventilation systems on jobs that would have previously required respirators to be worn. The licensee's efforts in respirator reduction had been identified in the previous report as a program strength.
The inspector reviewed the following procedures associated with the respiratory program:
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47001-C, Selection and.Use of Respiratory Protection Equipment, Rev. 8, dated November 12, 1991
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47005-C, Inspection, Repair, and Storage of Respiratory
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Protection Equipment, Rev. 5, dated May 27,1992
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47009-C, Operation and Use of Portable Ventilation Units, Rev. 9, dated September 9, 1993
No violations or deviations were identified.
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8.
Surveys, Monitoring, and Control of Radioactive Material (83729)
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 comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be present.
10 CFR 20.203 specifies the posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactivity areas
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and radioactive material. Additional requirements for control of high radiation areas are contained in TS 6.12.
During tours. of the plant, the inspector reviewed the licensee's posting and control of radiation i
areas, high radiation areas, airborne radioactivity areas, contamination areas, radioactive material areas, and the labeling of radioactive material.
a.
Routine Surveys The inspector reviewed licensee procedure 43000-C, Radiation and Contamination Surveys, Rev. 10, dated July 15, 1992, which
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provides guidelines for performing radiation / contamination surveys
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In addition, the inspector reviewed selected records of radiation and contamination surveys performed since the last inspection and discussed survey results with licensee representatives. During i
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tours of the Auxiliary Building and containment, the inspector observed HP technicians performing release surveys of materials, radiation surveys, and contamination surveys.
No concerns were noted by the inspector.
b.
Posting and Labeling During tours of the plant, the inspector reviewed the licensee's program for posting and controlling areas with respect to the aforementioned requirements as outlined in licensee procedure
' i 43005-C, Establishing and Posting Radiation Controlled Areas and High Radiation Area Access Control, Rev. 11, dated August 23,
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No discrepancies were noted in areas inspected. The inspector further verified that locked high radiation areas were locked and' posted, as required, and for those areas which could l
not be locked that flashing lights and postings were used to warn workers. The inspector reviewed licensee procedure 46017-C, Control, Monitoring and Removal of. Materials in Radiation Control Areas, Rev. 13, dated May 6, 1992. Specific instructions provided in this procedure included: identification and marking of-material; gagging and wrapping material; movement of radioactive materials; storage areas; tools and equipment release; solid trash monitoring; and liquid monitoring. The inspector noted that all containers, material, and areas observed were properly labeled, posted, and/or safeguarded in accordance with the radiation hazard present.
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c.
Contaminated Area The total area of the radiologically controlled area (RCA) equals approximately 450,000 square feet (ft2). The licensee typically maintained 4,500 ft2 (1.00 percent) or less as contaminated area.
During tours of the plant, the inspector noted the licensee had increased the use'of herculite type containments and floor
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coverings while performing potentially contaminated work to minimize decontamination efforts required to recover space at the completion of the outage.
In general, housekeeping was considered good and licensee efforts to minimize the spread of contamination
in work spaces by use of containment and ventilation were also considered as good initiatives.
d.
Personnel Contamination The inspector reviewed the licensee's personnel contamination events (PCEs) for 1993 to date.
PCEs were tracked as either skin
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or clothing events and, according to the licensee, some overlap in
total numbers did occur.
The 1993.PCE totals as of _ September 23,
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1993, were approximately 140. The maximum calculated skin doses were far below regulatory limits and no problems were noted with the licensee's methods or procedures.
The inspector reviewed
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licensee procedure 43300-C, Personnel Decontamination, Rev. 12, dated June 23, 1993, which provided specific guidance on-decontamination methods to be employed when personnel became contaminated.
e.
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-
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personnel survey locations were observed to be within the l
licensee's procedural limits.
No violations or deviations were identified.
9.
Operational and Administrative Controls (83729)
a.
Radiation Work Permits (RWPs)
The inspector reviewed RWPs for adequacy of the radiation 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 advised of their available exposure for that entry based on the RWP, as indicated by the electronic digital reading-dosimeter (EDRD) reader. The inspector observed HP personnel conducting
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briefings for work being performed in high dose areas. During each briefing observed, the inspector noted, the RWP contained the appropriate radiological control requirements for the areas being entered. The inspector reviewed licensee procedure 43007-C,
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Issuance, Use, and Control of Radiation Work Permits, Rev. 14, dated September 20, 1993, which provides instructions for' issuance of a-RWP.
Licensee procedure 41001-C, ALARA Job Review, Rev. 8,
dated December 15, 1992, provided instructions for executing the technical and administrative processes required for ALARA job review and processing RWPs.
Overall, the inspector found the licensee's program for RWP implementation to adequately address radiological protection concerns, and to provide for proper control measures, b.
Pre-job Briefings
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The inspector reviewed RWP requirements for pre-job briefings.
The licensee has a unique system for ensuring that workers are
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informed as to whether a pre-job briefing is required. Colored overlays are placed over posted RWPs to show briefing attendance requirements.
Green indicates that a formal pre-job briefing is not required prior to starting work, yellow signifies that a one time pre-job briefing is required, and a red overlay requires a l
formal pre-job briefing each 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period the job is worked.
It is incumbent on the worker to attend pre-job briefings as required.. The inspector reviewed pre-job briefing attendance for selected jobs and workers and found that workers were attending briefings as required, and in many cases, more than required. The inspector queried workers on a random basis regarding formal pre-job briefing attendance, the requirements, and opinion on the quality and content of briefings.
No discrepancies were noted.
All personnel interviewed stated that there was no pressure to skip a briefing and go to work, that pre-job _ briefings were an accepted part of accomplishing the work, and that they had never heard of people being coerced to perform work without meeting pre-job briefing requirements.
c.
Notices to Workers 10 CFR 19.ll(a) and (b) require, in part, that the licensee post 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.
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 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 location where the regulations, license, procedures, and
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supporting documents could be reviewed.
No violations or deviations were identified.
10.
Program for Maintaining Exposures As low As Reasonably Achievable (ALARA) (83729)
10 CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain
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radiation exposures a low as reasonably achievable. The recommended i
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 provide information relevant to attaining goals and objectives for planning 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).
The inspector discussed and reviewed with licensee representatives successful ALARA initiatives and reviewed the licensee's long term radiation reduction exposure plan to maintain occupational exposure ALARA. The licensee's utilization of teledosimetry, remote video cameras, radio communications, and remote continuous air monitors for monitoring high exposure jobs were continuing to be beneficial in maintaining exposures ALARA.
The licensee was currently estimating an i
annual dose savings of 4 person-rem per year as a result of using
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teledosimetry.
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The inspector observed the reactor head shielding being installed in Unit 2 to reduce a major source of radiation exposure during refueling outages.
Reactor head shielding is also scheduled to be installed in
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Unit I during the next refueling outage (UIRS). The installation of head shielding will significantly reduce radiation exposure to personnel performing work on the control rod drive mechanisms and incore thermocouple conoseals. The licensee was estimating as much as 24 person-rem per outage or 32 person-rem per year-based on an average of 1.33 outages per year based on typical outage work scope. Although dose was expended during initial head shielding installation, no future radiation exposure for installation should be expended because the reactor head is a passive system and the shielding will remain permanently installed.
Based on experience at other facilities, the licensee is anticipating a reduction in dose rates as high as 50 percent
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for head work by the installation of the permanent head shield.
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1 The inspector reviewed licensee source term reduction efforts to replace the existing backflushable filter in the Reactor Coolant System (RCS)
with cartridge type filters' which can be changed out frequently in an
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effort to reduce suspended solids within the RCS process streams.
The inspector reviewed the licensee's shield designs and discussed radiological control techniques to be employed during filter cartridge change outs that will involve high anticipated dose rates.
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licensee's plan appeared well conceived and was postulated to save sinnificant exposure.
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.ne inspector reviewed ALARA Committee meeting minutes since the last inspection which included the third quarter of 1993, and noted that
attendance at the meetings was adequate with representatives from a majority of the plant departments.
Review of meeting minutes revealed that pertinent radiological issues, goals, and corrective actions _were being discussed. The inspector also noted that post-job ALARA reviews for high dose _ jobs, exposure reduction initiatives, personnel ALARA suggestions, and RIRs were also reviewed and discussed at the meetings.
The licensee continues to improve on reducing out of core source term with shutdown chemistry.
The plant tripped on September 8,1993, however, due to good planning chemistry implemented their scheduled program. After about five hours flow through the cation bed, all Chemical Volume Control System (CVCS) was lost due to a leaking diaphragm in the CVCS. After diaphragm repair and mixed bed loading, letdown flow through a new mixed bed removed the lithium.
The plant was i
held above 400 degrees until acidic conditions were achieved at-1700 hours on September 9, 1993. At 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br /> on September 10, 1993,
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the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reducing phase began (170-200 degrees with a hydrogen residual of approximately 6 cc/kg) for conditioning and dissolution of the transient crud layer.
Cobalt-58 peaked about 0.45 uCi/ml during i
this phase. The oxidizing phase was begun on September 11, 1993, at 0630 with the addition of hydrogen peroxide (140-180 degrees with an oxygen residual of approximately 2 ppm) for rapid dissolution of available cobalt.
Cobalt peaked at 3 uCi/ml after peroxide addition and the cleanup proceeded.
In both the reducing and oxidizing phase soluble
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cobalt-58 averaged 93-95 percent of the total.
Because of schedule
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maintenance of train "B" safety related equipment, the reactor was allowed to circulate in the oxidizing phase with two reactor coolant pumps ran for an extended period of time (2.5 days longer than scheduled).
The licensee estimated that cobalt-58 removed by the CVCS mixed bed was 15 curies during the cooldown phase,180 curies during the
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reducing phase, and 1,230 curies during the oxidizing phase totaling i
1,425 curies.
The inspector noted-the licensee's efforts to reduce source term and based on the above, the inspector informed the licensee representatives that the ALARA program continued to be effective in controlling exposures during the U2R3 outage. Overall collective dose expended was consistent with the work being performed.
No violations or deviations were identified.
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11.
Exit Meeting (83729)
At the conclusion of the inspection on September 24, 1993, an exit meeting was held with those licensee representatives indicated in
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Paragraph 1.
The inspector summarized the scope and findings of the
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inspection and informed the licensee that all findings were preliminary and subject to NRC management review and approval.
The licensee did not indicate any of the information provided to the inspectors during the inspection as proprietary in nature and no dissenting comments were received from the licensee.
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