ML14191B056
| ML14191B056 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Robinson |
| Issue date: | 01/12/1989 |
| From: | Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14191B055 | List: |
| References | |
| 50-261-88-26, NUDOCS 8901260201 | |
| Download: ML14191B056 (19) | |
See also: IR 05000261/1988026
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W.
ATLANTA, GEORGIA 30323
JAN1 2 1m
ENCLOSURE 2
Report No.:
50-261/88-26
Licensee:
Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name:
H. B. Robinson
Inspection Conducted:
September 12-16, 1988
Team Leader:
L
(
ar//1
V
-,T.
R. Collins
te Signed
Team Members:
C. H. Bassett
R. B. Shortridge
Accompanying Personnel:
C. M. Hosey
Approved by: Q_
C. M. Hosey, Sectiqn Chief
Date Signed.
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This was a special, announced assessment in the area of the licensee's
program to maintain occupational radiation exposures as low as reasonably
achievable (ALARA).
Results:
The licensee now has in place many of the elements of an adequate
ALARA program.
Program strengths noted during the inspection included source
term reduction efforts, good general worker knowledge and awareness of ALARA
concepts and responsibilities, and holding management accountable for achieving
exposure goals.
However, increased support and involvement of management is
required if
the program is to be fully successful.
Several weaknesses were
also identified in the ALARA program that should be addressed to ensure that
collective annual personnel radiation dose is reduced to the maximum extent
possible. These weaknesses were in the areas of:
-
Exposure goal formulation,
and management involvement in achieving
established goals, Paragraphs 3.c and d.
-
Total
number
of personnel
onsite with measurable exposure,
Paragraph 4.b.
8901260201 890112
ADOCK 05000261
Q
PNU
-
Audits of the ALARA program, Paragraph 8.
-
ALARA Sub-Committee effectiveness, Paragraph 3.,a.
-
Man-hour estimation for each job, Paragraph 3.'b.
Within the areas inspected, no violations or deviations were identified.
REPORT DETAILS
1. Persons Contacted
Licensee Employees
J. Adams, Daily Planning
R. Chambers, Performance Engineering, Supervisor
- G. Cheatham, Environmental and Radiological Control Manager (Brunswick)
R. Cox, Modification Engineering
C. Dietz, Project Manager
J. Epperly, Construction Coordinator
M. Failes, Mechanical Planner
B. Flanagan, Engineering Design
B. Hammond, ALARA Coordinator
J. Harrison, Environmental and Chemistry, Project Specialist
C. Lapp, Fuels Engineer
.*R. Mayton, Principal Health Physicist
D. McCaskill, Operation, Shift Foreman
- B. Meyer, Principal Health Physics Specialist (Corporate)
D. Miller, Mechanical Maintenance Supervisor
- D. Morgan, Plant Manager
D. Nelson, Operations Supervisor
R. Pearce., Outage Planning, Senior Specialist
A. Poland, ALARA Specialist, (Shearon Harris)
D. Quick, Maintenance, Manager
J. Sheppard, Operations, Manager
- D. Smith, Environmental and Radiological Control Manager
B. Snipes, Training, Supervisor
- R. Starkey, Project Manager (Brunswick)
- B. Webster., Health Physics Manager (Corporate)
Other licensee employees contacted during this inspection included
engineers, technicians, maintenance, and office personnel.
Nuclear Regulatory Commission.
L. Garner, Senior Resident Inspector
- R. Latta, Resident Inspector
- Attended exit interview
2. Background (83528/83728)
Between
1974 and
1987,
the annual collective radiation dose at the
Robinson Plant exceeded the national average twelve out of the thirteen
years. The average collective dose for all U.S. PWRs over this period was
499 person-rem per year, per reactor.
Robinson had the second highest
2
cumulative, average collective dose of this period with an average of
1,025 person-rem per year.
Since 1980, 83% of the station's collective dose resulted from 11 outages,
9 of which were caused by steam generator problems. The steam generators
were replaced in 1984.
The licensee formed a task force in 1985 to
propose a Radiation Exposure Reduction Program. The goal of the program
was to lower collective dose at CP&L facilities to within industry
standards. The key elements of the program were to improve supervisor
responsibility and accountability in radiation safety, personnel dose
reduction, and radwaste volume reduction.
Increased emphasis was placed on exposure accountability in 1986, and in
1987, each unit (department) was charged with the responsibility for their
dose goals.
Unit goals for 1987 were approved by Unit Managers and
submitted to the ALARA Coordination group
in September.
An
annual
collective .dose goal for 1987 was established at 450 person-rem. Robinson
experienced 5 outages in 1987,
and exceeded the annual collective dose
goal by 11 %, which was 36 % above the national average of 368 person-rem
per reactor.
A goal of 450 person-rem. was set for 1988,
which included an outage
scheduled to begin in the last quarter of the year.
However, a
justification for an additional 100 person-rem was-submitted to the Plant
Nuclear Safety Committee
(PNSC)
to cover
two
major modifications,
Resistance Thermocouple Detector (RTD)
removal and Service Water System
work, to be included i.n the fall outage. The licensee expected that the
collective dose.at Robinson would again be above the industry norm.
Table 1 shows a comparison of the Robinson collective annual dose with
that of the average PWR collective annual dose.
TABLE 1
Comparison of Robinson Annual Collective Dose with Average Collective
Dose from Commercial Pressurized Water Reactors
PWR Average Dose
Year
Per Reactor (Rem)
Robinson Dose (Rem)
1974
331
672
1975
318
1,142
1976
460
715
1977
396
455
1978
429
963
1979
516
1,188
1980
578
1,852
1981
652
733
1982
578
1,426
1983
592
923
3
1984
552
2,880
1985
416
311
1986
397
539
1987
368
499
3.
Program To Maintain Radiation Exposures ALARA (83528/83728)
The following procedures, which implement the station ALARA program, were
reviewed by the inspectors:
AP-016
Radiation Work Permit (RWP) Administration
ERC-003
Temporary Shielding Procedure
ERC-006
ALARA Program
ERC-007
ALARA Goals
HPP-006
Radiation Work Permits (RWPs)
PLP-001
Plant Nuclear Safety Committee and Safety Review Programs
PLP-016
Radiation Work Permit (RWP) Program
a. Organization
The licensee ALARA organization consisted of a permanent staff with
an ALARA Coordinator and two health physics (HP)
technicians.
An
additional HP technician was assigned as a HP/maintenance coordinator
to plan mechanical maintenance tasks.
The licensee established an ALARA subcommittee in 1981 as a standing
subcommittee
of the
PNSC.
The primary function of the ALARA
subcommittee was to act as an advisory group to the PNSC on plant
ALARA related topics. The ALARA subcommittee membership evolved from
6 members in 1983,
to 18 primary members in 1988,
which included a
chairman, vice chairman,
secretary, and members from operations and
from the other major station departments. Ten alternate members were
also selected. The committee routinely meets monthly to review and
discuss plant ALARA related topics. The inspectors noted that with
the exception of the chairman,
vice chairman,
and secretary, new
subcommittee members and alternates are appointed annually.
The inspectors reviewed the minutes of the ALARA
subcommittee
meetings held for the period of February 1983 through August 1988.
The minutes indicated that ALARA Followup Items (recommendations to
reduce dose), once approved by the subcommittee, were frequently not
assigned to anyone for action.
This resulted in inadequate or
incomplete resolution of the followup items.
The subcommittee,
dissatisfied with the progress being made on resolving the ALARA
Followup Items, developed ALARA Problems Reports (APRs).
Management
endorsed the program for opening up the suggestion program to all
plant personnel.
In 1987,
19 APRs were submitted,
11 of which were
completed.
4
In 1986
during an inspection,
the NRC expressed a concern to plant
management about the poor attendance at ALARA subcommittee meetings;
maintenance and instrumentation/control
representatives missed 50% of
the subcommittee meetings. In 1987, subcommittee meeting attendance
did not improve.
An i.nspector attended the September 1988 ALARA subcommittee meeting
and noted that outstanding ALARA Followup Log items were discussed in
detail, with the responsible person for the action providing a
current status. A brief status of annual collective dose for 1988
was given but there was no disscussion of methods to manage the dose,
or how to reduce the rate of collective dose accumulation to get back
to the projected dose goal .
The projected -dose for September was
63.975 person-rem and the actual dose was 98.780 person-rem. At the
close of the meeting,
the
new Vice President of H. B. Robinson
Nuclear Project
challenged
the
subcommittee to
uphold
its
responsibility and stated that historically the annual collective
dose had been unacceptably high and that he was prepared to make
tough decisions to reduce collective dose.
In discussions with licensee representatives after the meeting, the
inspectors learned that supervision and management were not members
of the subcommittee and that subcommittee members typically could not
make commitments for their departments.
The inspectors. discussed
with licensee management the need to improve the efficiency of the
subcommittee
by
improving
attendance and
management
participation and support for the ALARA subcommittee.
b. Work Reviews
Licensee
procedure,
PLP-016, Radiation Work Permit Program,
Revision 6, dated July 1-, 1988, required a pre-job review when the
initial exposure for the work requiring a Special RWP was projected
to be one person-rem but less than ten person-rem.
The review was
required to be conducted by the ALARA staff, a member of the ALARA
subcommittee,
the entire ALARA subcommittee or the job coordinator.
All non-routine tasks with a projected exposure of ten person-rem but
less than twenty-five person-rem was required to be reviewed by
cognizant supervision. A review by the station ALARA subcommittee
was required
for
all
non-routine work estimated to exceed
25 person-rem.
In determining whether or not a job met the guidelines for an ALARA
review, a Pre-Submittal
Request
Form
was
submitted by a
.coordinator for the work, to the Radiation Control (RC) group.
The
Pre-Submittal RWP form specified the estimated number of man-hours to
be worked as well as the work location and a description of the work
to be performed.
A HP technician from the RC group then made an
estimate of the person-rem which was likely to be expended performing
the job. Following the exposure estimate,' the form was forwarded to
5
the ALARA section for action and the appropriate review if the
estimate exceeded the one person-rem limit.
The licensee's procedure,
PLP-016, required a post-job ALARA review
for all tasks controlled by a Special RWP that resulted in radiation
exposure of three person-rem or more or at the ALARA Specialist's or
the Job Coordinator's discretion.
However,
the ALARA specialist
stated that, as a good practice, post-job reviews were performed for
all work requiring a pre-job review,
if
possible,
and as time
permitted. The post-job ALARA review was performed to document the
success or failure of any special exposure reduction techniques
employed, problems encountered that had an effect of exposure,
and
any other reason for deviations.
From the post-job reviews, the
ALARA specialist compiled job history files to be used for future
reference for major or unusual jobs.
The inspectors reviewed selected pre-job and post-job reviews
performed during
1987
and
1988,
and verified that the required
information concerning man-hours, person-rem, and problems noted with
the job were documented and that lessons learned from prior jobs were
considered during reviews involving work of a similar nature. During
1987,
the licensee indicated that 97% of the station's dose had
undergone review and
was
expended during work that
had
been
preplanned.
During the review of the selected pre- and post-job reviews, the
inspectors noted that, in over half of these reviews, the man-hour
estimates and the person-rem estimates varied by 60% or more from the
actual man-hours worked or 49% or more from the actual person-rem
received or both. The inspectors discussed these discrepancies with
representatives from the ALARA group because it was not apparent from
the post-job reviews why the totals were so different. The licensee
indicated that some of these instances involved jobs in which the
scope of the work changed.
However,
the estimates had not been
changed or revised but had been left as originally stated. Licensee
representatives also indicated that, even though the procedure did
not require another job review when the scope of the work changed,
another ALARA review was usually performed.
The inspectors indicated that, due to the many discrepancies of
greater than 60-49% between the estimated and the actual man-hours
and person-rem, respectively, the licensee's method of estimation
needed to be improved and some method developed to allow revision of
their estimates once established. The licensee indicated that the
main problem with the process was the man-hour estimates submitted
for each job. The man-hour estimates were typically too high and
often included hours not required to be spent by the workers in a
radiation area.
In reviewing the man-hour estimates and other
information used to determine the person-rem estimates such as area
dose rates, the inspectors concluded that the man-hour estimates were
the major cause of the discrepancies between the estimates and the
6
actual man-hours worked and person-rem received.
More accurate
person-rem estimates may allow management to focus attention on
problem jobs sooner.
c.
Radiation Dose Goals
1. Licensee procedure, ERC-007, ALARA Goals, Revision 2, dated July
1, 1988, described the process used to establish the plant's
unit's and subunit's goals.
It
was the ALARA subunit's
responsibility to
implement. the procedure
and
the
Specialist's responsibility to establish annual goals for the
plant, units and subunits. The goals were derived from the work
scheduled for the year as projected by each unit. Other factors
were also taken into consideration such as:
duration of jobs,
manpower, survey information, and previous histories, if
available.
Once all the units'
and subunits' goals were
calculated, the station's goal was obtained from the total.
2.
For
1988,
the station's collective radiation dose goal was
450 person-rem based on normal operation and a fall outage.
This goal
had. been established before it
was known that the
outage schedule was to include RTD bypass elimination work which
would require the expenditure of approximately 87 person-rem and
service water piping work in the pump bays which would require
approximately 25 person-rem.
The licensee indicated that the
total projected collective dose for 1988 would probably be
550 person-rem.
d. Management of Collective Dose
1. The inspectors reviewed the methods used by the licensee to
manage dose. in achieving the annual collective dose goal.
Licensee proceudres
ERC-006,
ALARA Program and ERC-001,
Goals, defined how the ALARA program functions and how goals are
established but did not specifically state who was responsible
for achieving established goals.
Licensee representatives stated that, in reviewing the intended
work scope of their proposed five-year plan,
they did not
believe it was possible to bring the station's annual collective
dose within the industry norm for PWRs until 1992.
2.
The inspectors discussed with licensee management representa
tives whether or not contractors were held accountable for
achieving established dose goals. The inspectors were informed
that specific contractors were
not held
accountable for
person-rem expended on assigned tasks.
The inspectors stated
that contractors should be held accountable for doses received
since it
is a major contributing factor toward the annual dose
projection. If this program were approved and successful, it
would be beneficial in reducing the station's annual doses.
7
3.
On
August 31,
1988,
the
collective
station
dose
was
98.780 person-rem measured against a projection for the end of
August of 63.975 person-rem.
During the program review, the
inspectors did not
observe .any
management initiatives or
directions to recover from this situation of being over the dose
projection.
Based on the attendance at ALARA Subcommittee
meetings, interviews with managers,
supervisors,
and ALARA
coordinators, the inspectors determined that station management
and unit/subunit mangers were not involved with dose management
on a frequency necessary to ensure that the station's annual
collective
dose. goal
was
met.
Licensee
management
representatives indicated that .they were in a reactive mode
rather than a :proactive mode to keep collective dose within
established goals.
e.
Job Histories and Post.Outage Reports
Through discussions with licensee representatives,
the inspectors
reviewed historical job exposure data that was available for review
when preplanning radiological work.
The Radiological Information
Management System (RIMS)
computer data base contained data covering
all RWPs and was cross referenced to the ALARA review control number
for the job. This control number could be used to access the hard
copy files of the documents associated with that RWP.
The most
current data, typically for 1986 through 1988, were maintained by the
ALARA staff. This.data consisted of the Pre-Submittal request, the
pre-job review,
the RWP used to perform the work, the post-job
review, if required, and other related documentation such as survey
data and notes made during the course of the job.
Records for work
which occurred prior to 1986 were available on microfiche.
The inspectors reviewed selected job history files that were being
maintained in the ALARA group's work area. The inspectors noted that
the files contained useful information for the planning of similar
tasks.
The inspectors also reviewed the licensee's post outage reports that
had been written and issued following the past five outages. These,
too,
were
used to document various jobs,
the suggestions for
improvements, and other historical data. It was noted, however, that
the post outage reports did not fully or adequately describe the
problems that had been encountered.
The solutions to the problems
were frequently discussed but the source of problems encountered and
the root causes were not identified so specific problem areas could
be resolved prior to the next outage. The inspectors indicated that
this was a weakness and that the post outage report could be a better
resource document for future planning if the problems noted during a
specific job and groups responsible for -the difficulties were
identified in detail. In addition, a formal method for incorporating
8
lessons learned should be established and incorporated into planning
for future outages.
The licensee acknowledged this and indicated
that the matter would be investigated.
f. Hold Program
After reviewing the procedures dealing with .the RWP program, HPP-006,
Radiation Work Permits, Revision 15, dated July 1, 1988, and PLP-016,
Radiation.Work Permit Program, Revision 6, dated July 1, 1988, the
inspectors noted that there was no mention of any type of a hold that
could be placed on jobs covered by RWPs that were approaching or that
had actually-exceeded the estimated dose projections for those jobs.
The licensee indicated that, although there was no formal hold point
for such jobs when they exceeded the person-rem estimate, the HP
technicians covering the work were cognizant of the exposure status
and would inform the ALARA group when such problems occurred.
At
that point a review of the work would take place to evaluate the
reasons for the .problems
and what corrective actions could be
employed to counter the trend. The licensee.indicated that this was
not always a formal review but usually involved a review by a member
of the ALARA group. The inspectors informed the licensee that other
stations had found an automatic "hold" placed on the RWP when the
exposure estimate was about to be exceeded to be beneficial.
This
allowed everyone involved to reassess the work and reconsider the
dose minimization techniques used to
that
point.
Licensee
representatives stated that they would consider incorporating hold
points in their RWP program.
4.
Performance (83528/83728)
In discussions with.the inspectors, licensee representatives stated that,
in the past, equipment problems such as steam generator tube leakage and
unplanned or emergent work have been the biggest contributors to the
collective dose exceeding the national average.
The following sections
discuss the station's performance
on
reducing collective, dose for
repetitive tasks.
a. Exposure Expended on Rework
The inspectors discussed with licensee management representatives
whether a program had been established to identify exposures received
resulting from rework.
Licensee management representatives stated
that they had a system to identify repetitive work or
system
failure. However, no program was established to track jobs that were
considered rework due to personnel error,
lack of the
proper
qualifications of personnel or failure to identify the cause rather
than the symptom.
Also,
no method or
system existed to track
exposure resulting from such rework.
Establishment of a program to
track repetitive work/rework and the doses expended due to such work
may result in a more comprehensive analysis of the causes of the
9
problem, more rapid solution to the problem, and an overall reduction
in the station's annual collective dose.
b.
Number of .Personnel With Measurable Exposure
The number of workers with measurable exposures was discussed with
licensee representatives.
The data in Table 3 were taken from
statistical summary reports required by 10 CFR 20.407.
Measurable
dose was defined'as dose large enough to be detected by personnel
monitoring devices (greater than 100 mrem).
As can be seen for the
years 1983 through 1987, H. B. Robinson had approximately 201 percent
more workers with measurable dose than the industry norm for a
typical PWR.
Licensee representatives stated that they were aware
that the reduction in the number of workers with measurable exposure
would result in a reduction of collective dose at the station and
placed a limit of 1500 total personnel onsite for the 1988 Unit 2
refueling outage.
Table 3
Comparison of H.B. Robinson with Industry Norms for
Average Number of Personnel with Measurable Dose Per Reactor
83* 84**
85*** 86*** 87****
Number of Personnel With
2,244 4,127 1,378
1,571
1,397
Measurable Dose
PWR Industry Average of Personnel
1,065 1,117
1,012
1,086
978
With Measurable Dose
Percent of Industry Norm
210
369
136
145
143
- Steam Generator Repair Outage
- Steam Generator Replacement Outage
- Seismic Support Repair Outage
- Refueling Outage
c.
The inspectors reviewed NUREG/CR-4254,
Occupational Dose Reduction
and ALARA at Nuclear Power Plants: Study on High-Dose Jobs, Radwaste
Handling,
and ALARA
Incentives,
dated April 1985, with licensee
personnel.. NUREG/CR-4254 contains data on doses experienced
throughout the industry for typical high dose jobs.
The inspectors
compared the licensee's exposure history for several jobs described
in the NUREG as indicated in Table 4.
10
Table 4
H. B. Robinson Dose Summary for High Dose Jobs (Person-Rem)
NUREG/
CR-4254
Job
'83
'84 .
'86
'87
Avg.
Snubber, Hanger
242
33
--
110
Anchor, Boch
Inspection/Repair
Reactor Disassembly/
Assembly-Fuel Sipping--
137
51 .48
48
Plant
Decontamination
15
156
19
28
45
Primary Valve
Maint./repair
--
41
7
24
30
Insulation
Removal/Re
placement
4
41
15
5
18
S/G Secondary Side
Repair/Maint.
33
164
18
6
11
Fuel Shuffle/
Sipping/Insp.
---
34
3
11
9
Operations
Surv, Routines/
Valve Lineups
.
---
150
52
14
7
The inspectors determined that for most jobs reviewed, the licensee's
dose performance was higher than the industry average indicated in
NUREG/CR-4254 (1974-1984 data).
5.
Dose Reduction Initiatives
a. Chemistry Control
(1) Reactor Coolant pH Control
In a letter to the licensee's fuel vendor dated November 6,
1986,
the licensee requested that the fuel vendor consider
approval to operate the Robinson 2 plant with an increased
reactor coolant system pH of 7.0 - 7.4.
The licensee made the
request. based on data obtained from evaluations at the Ringhals
site in Sweden. Licensee representatives stated that they were
convinced that a reduction in out of core radiation levels could
be achieved by increasing the reactor coolant pH.
On December 3, 1986, the licensee received approval from their
fuel vendor to increase Lithium at the beginning of Fuel
Cycle 12 from 2.0. ppm up to 2.2 ppm while maintaining a pH of
7.0 -
7.4 throughout the cycle.
The licensee subsequently
implemented this program at the beginning of Fuel Cycle 12 and
has seen Radiation level reductions. of approximately 30% in
various areas inside containment. However, at the time of the
inspection, no
entries
had
been
made
inside
the
steam
generators.
Thus the actual reduction of radiation levels in
this area has not been determined.
This program appears to be successful and should reduce station
personnel doses.
(2) Reactor Coolant Filters
The licensee was evaluating the use of sub-micron filters for
reactor coolant on-line cleanup. The sub-micron filters were to
be installed on the Spent Fuel Pit (SFP)
and Reactor Coolant
System (RCS)
filtration
systems in 1989.
Initially a
25 micrometer (um) filter would be installed and thereafter the
filter sizes would be progressively decreased to the sub-micron
range.
This program, if approved and successful, should be effective in
reducing crud activity levels in the
and enhance the
licensee's success in achieving its ALARA goals.
(3) Hydrogen Peroxide Shock
The licensee was evaluating the use of hydrogen peroxide to
shock (i.e., controlled crud burst by chemical addition) the
reactor coolant primary chemistry system which would oxygenate
the RCS and help remove Co-58 and Co-60 at Mode 5 operation,
with the RCS at less than or equal to 2000 F.
The procedure, used by the licensee during RCS cooldown prior to
refueling outages, calls for the addition of hydrogen peroxide
while the system is solid to promote a controlled crud burst. In
the past,
the hydrogen peroxide addition had been performed
after the
RCS had been drained to mid-nozzle.
Current data
available has indicated there has been a substantial decrease in
the amount of soluble activity available for purification after
the crud burst occurs when the hydrogen peroxide addition is
performed in this manner. The licensee is planning to implement
this program during the November 1988 refueling outage.
If
approved and successful, this program should further enhance the
licensee's success in achieving its ALARA goals.
12
b.
Fuel Integrity
During the period of 1983 to 1987, the licensee had not experienced
fuel failure to the degree that could be directly related to the
increase of personnel doses inside the RCA.
The licensee has. implemented a fuel integrity monitoring
and
chemistry measurement evaluation program which includes allowable
levels of dose equivalent Iodine-131 (DEI)
in the Primary Coolant
System. The DEI is monitored on a daily basis, under equilibrium and
transient conditions, with respect to the technical specification
limit of one microcurie per gram (1 uCi/gm).
During refueling outages, the licensee has a program for analysis of
each fuel assembly that is suspected of fuel degradation.
If these
tests are required to be performed (ultrasonic test) and the fuel
assembly has
been determined to be defective,
the. entire fuel
assembly would be replaced by a new fuel assembly known not to be
defective. All of the fuel assemblies determined to be defective
would later be reconstituted by replacement of individual fuel pins.
6. Interviews (83528/83728)
a. Employee Interviews
Licensee
employees were interviewed to assess their knowledge,
involvement,
and perspective of the utility's ALARA program.
An
ALARA questionnaire was prepared prior to the inspection and was
utilized .during each interview to ensure -that each employee's ALARA
awareness
and involvement was evaluated uniformly.
The employee
questionnaire was also prepared to evaluate the employee's knowledge
of ALARA goals, concepts,
policies and procedure documents;
individual responsibilities, personal doses, and personal dose
limits;
the employee's involvement in special ALARA training,
communication with co-workers and supervision, and participation in
the ALARA suggestion program; and the employees perspective on how to
improve the ALARA program,
what events or conditions have caused
increased personnel doses, and what events or conditions have helped
reduce personnel doses.
(1) Employees
All employees interviewed entered the radiological controlled
area
(RCA)
on a daily to weekly basis depending on plant
conditions.
(2) .Knowledge of ALARA Program
Each of the employees interviewed was familiar with the basic
ALARA concepts taught in the General Employee Training (GET)
program and knew that they
had a basic responsibility for
13
- implementing the utility's ALARA program by performing tasks in,
a manner consistent with the utility's ALARA policy. In general
the employees knew their current radiation exposure and their
exposure limit. The employees generally were aware of where the
ALARA requirements originated and what documents described the
ALARA program objectives.
Most of the employees interviewed
knew that each of their sections had an
ALARA goal,
but
generally were unaware of -the goal that was established.
However, the employees did know that they could find out their
section's goals from the ALARA staff.
(3) ALARA Program Involvement
The majority of employees interviewed had not received any ALARA
training other than that given in the GET course. A majority of
those interviewed had received some informal ALARA training on
jobs requiring ALARA pre-job planning and on-the-job training.
The employees reported frequent discussions of ALARA objectives
on major jobs during outages with co-workers and supervisors.
The employees also reported good communications with the ALARA
and HP staffs. Only a small fraction of employees interviewed
had participated in the formal ALARA suggestion program. Other
employees reported that they had made suggestions to supervisors
informally and had not used the formal ALARA suggestion program
believing it was only for "significant ALARA suggestions."
(4) Perspective
Most of the employees had suggestions on how the ALARA Program
could be improved. The suggestions included better planning and
scheduling of work to ensure that appropriate equipment and
tools were readily available to perform tasks expeditiously.
The majority of employees
had opinions on .things that had
contributed to decreases and increases in personnel exposures.
Employees believed that the following actions had contributed to
exposure reductions:
use of temporary shielding, special tools,
permanent shielding such as the reactor vessel head shielding,
flushing
of
various
system
components
and
lines,
and
decontamination of contaminated areas within the RCA. Employees
believed that the following actions had contributed to increases
in personnel
exposures:
poor maintenance planning and
scheduling in the past, replacement of steam generators in 1984,
use of less experienced contract personnel,
and too many
personnel on site entering the RCA.
b. Management Interviews
Licensee managers and supervisors were interviewed to assess their
knowledge of the utilities ALARA Program. An ALARA questionnaire for
managers and supervisors was prepared prior to the inspection and was
utilized during each interview to ensure that the ALARA awareness and
14
involvement of each manager and supervisor was evaluated uniformly.
The questionnaire was prepared to evaluate the manager's or
supervisor's knowledge of ALARA goals,
concepts,
policies, and
procedure documents; individual responsibilities, personal exposure,
and personal
exposure
limits;
the manager's or
supervisor's
involvement in special ALARA training, communication with co-workers
and supervision, and participation in the ALARA suggestion program;
and the manager's or supervisor s perspective on. how to improve the
ALARA program,
what events or conditions have caused increased
personnel exposures, and what events or conditions have helped reduce
personnel radiation exposures.
(1) Entry into the RCA
All individuals interviewed entered the RCA on a weekly to
monthly basis depending on plant conditions.
(2) Knowledge of ALARA Program
Each of the individuals interviewed was familiar with the basic
ALARA concepts taught in the GET program and knew that they had
a basic responsibility for implementing the utilities'. ALARA
program by ensuring that each employee performed tasks in a
manner consistent with the utility's ALARA policy.
In general,
the managers and supervisors interviewed knew what their current
radiation exposure was and what the exposure limit was for their
departments.
The managers and
supervisors
had
a good
understanding on where the ALARA requirements originated and
what corporate and plant documents described the ALARA program
objectives. All of the managers and supervisors interviewed
knew their departments ALARA goals.
(3) ALARA Program Involvement
The majority of the managers and supervisors interviewed had not
received any ALARA training other than that given in the GET
course. Each department had a dedicated individual to serve on
the ALARA Committee,
which met
on a monthly basis or as
appropriate. The ALARA
Committee
members
represented their
departments in discussions of ALARA objectives for major outage
jobs.
None of the managers or supervisors interviewed had
participated in the formal ALARA suggestion program.
However,
most of the managers or supervisors interviewed were aware of
the number of ALARA suggestions submitted by their departments
in the past or current year.
These ALARA suggestions were
usually submitted
by
the
departments'
subcommittee
members.
15
(4)
Perspective
All managers and supervisors interviewed had suggestions on how
the ALARA program could be improved.
The suggestions included
better scheduling and planning of work, ensuring
that
appropriate equipment and tools were readily available, and
continuing to increase the awareness of the ALARA concept to all
levels of plant staff.
These methods could be accomplished
through
GET retraining,
departmental'
training, non-licensed
training or through the Advanced Radiation Worker Training
(ARWT)
Program. The ARWT Program,
as discussed in Paragraph 7,
is in the process of being revised and will be implemented as a.
pilot program during the first half of 1989.
The majority of managers and supervisors had opinions on things
that had contributed to decreases and increases in personnel
exposures.
Individual managers
and
supervisors
interviewed
believed that the following actions had contributed to exposure
reductions:
use of temporary shielding, permanent shielding
such as the reactor vessel
head shielding,
reduced work
activities in high radiation areas, flushing of various systems
components and lines, reduction of contaminated areas within the
radiological controlled area,
use of reach rods on specific
systems,
and the use of live load packing on valves inside
containment to reduce unidentified leakage and the required
frequency of repacking these valves.
Individual managers and supervisors interviewed believed that
the following actions had contributed to increases in personnel
exposures:
poor planning and scheduling of maintenance in the
past, forced outages,
replacement of steam generators in 1984,
repetitive work or rework of specific jobs, number of personnel
on site.entering the RCA,
duration of outages,
and failure to
manage dose on a daily basis to stay within budgeted goals.
7. Training (83528/83728)
The inspectors reviewed the licensee's program for ensuring that all
employees received training in ALARA beyond that given in basic GET. The
inspectors reviewed selected lesson plans for non-licensed personnel
including RC and Chemistry, Mechanical Maintenance,
Instrumentation and
Control,
and Electrical training and verified that ALARA information and
considerations were incorporated into the lesson plans.
The. inspectors also reviewed the status of the licensee's program for
advanced
GET which
had
been referred to as
GET III.
The licensee
suspended the GET III training in September 1987,
for evaluation of the
program. The GET III course did not qualify personnel- to provide their
own
job coverage but was designed as a one
week course given to
supervisors, lead technicians and planners to make them more aware of all
aspects of radiation control and ALARA.
Since suspending the former
16
course, the licensee had been developing a new program for advanced GET
training entitled Advanced Radiation Worker Training (ARWT).
Licensee
representatives indicated that the new ARWT course would be designed to
provide supervisors of radiation workers,.radiation workers themselves and
other personnel who plan, control, direct, and engineer work in the RCA,
specific instruction on methods, practices, and procedures to reduce their
occupational radiation dose and work more efficiently and safely in the
RCA. A final portion of the course would provide additional on-the-job
training for selected radiation workers in order to permit those,
so
trained, to perform limited additional radiation control activities, such
as surveys, concurrent with their other responsibilities associated with
completion of the job. The ARWT program was scheduled to be implemented
as a pilot program during the first half of 1989 and, following revisions
to the-pilot program, to be implemented system-wide in early 1990.
The inspectors also toured the licensee's practical. factor training areas.
One area was equipped with various mockup training aides including a model
of the steam generator lower channel head.
Another area had a working
containment structure with an associated airlock and undress area.
The
inspector determined that the licensee should be able to provide adequate
mock-up training for several complicated work evolutions.
8.
Internal Audits and Assessments
The inspectors reviewed annual audits performed by the corporate .radiation
protection group for the years 1983 through 1988.
In addition, five
internal audits, 026, 035, 060, 061 and 070,
performed by site quality
assurance were reviewed.
The purpose of the annual audit by corporate staff was to assess the
adequacy and effectiveness of. the Environmental and Radiological Control
(E&RC)
Program, through
review, evaluation,
and verification
of
implementation of the Plant Operating Manual,
Technical Specifications,
Final Safety Analysis Report and Corporate' Quality Assurance Program. The
inspectors found that the corporate audits,
in general,
were
not
comprehensive in evaluation of ALARA.
Very
few nonconformances
or
findings were identified. The inspectors determined that the audits did
not result in identifying technical
radiological issues,
that when
evaluated and corrected,
would result in significant ALARA
program
improvements. The internal audits performed by. site quality assurance
were primarily compliance audits and did not identify ALARA programmatic
problems. The inspectors discussed with licensee management the value of
comprehensive self assessments that result in program
improvements.
Licensee management representatives acknowledged the inspectors concerns
and stated that the audit and assessment program would be reviewed and
evaluated to assess the effectiveness of ALARA programmatic problems.
9. Conclusions (83528/83728)
The inspection revealed that the licensee appears to have established an
ALARA program including many of the elements required to effect dose
reduction however, they have not been totally effective. In the past, the
lack of management support and involvement in ALARA, conflicting
operational priorities, and unforeseen work items have contributed to less
than total success for the ALARA
program.
Management
support and
involvement will be required to lower the licensee's person-rem dose to a
level consistent with the PWR national average for collective dose to
personnel.
The following significant issues were identified during the inspection and
should be addressed by the licensee to increase the effectiveness of their
ALARA program.
a. Management was not involved in managing collective dose on a
frequency to achieve established dose goals (Paragraphs 3.c and d)
(50-261/88-26-01).
b. The number of personnel accessing the RCA with measurable exposure is
consistently
higher
than
the
industry norm (Paragraph 4.b)
(50-261/88-26-02).
c. The licensee's audit program, is not resulting in ALARA program
improvements (Paragraph 8) (50-261/88-26-03).
d. ALARA Subcommittee meetings have not been well attended by members or
management. (Paragraph 3.a) (50-261/88-26-04).
e. The process of estimating man-hours needed to perform a job are
frequently overestimated and
result in descrepancies between
estimates and actual man-hours worked (Paragraph 3.b)
(50-261/88-26-05).
f.
Lessons learned from outages are not formally incorporated into
planning for future outages (Paragraph 3.e) (50-261/88-26-06).
10.
Exit Interview (30703)
The inspection scope and findings were summarized on October 5, 1988, with
those persons indicated in Paragraph 1.
The inspectors described the
areas inspected and discussed in detail the inspection findings (see
Paragraph 9).
The licensee acknowledged the inspection findings and took
no exceptions. The licensee did not identify as proprietary any of the
material provided to or reviewed by the inspectors during the inspection.