ML17345A689

Eddy Current Testino

Reactor

Assembly/

Disassembly

In Service Inspection

Plant Decontamination

Primary Valve

Naintenance

and Repair

Insulation

Removal

Replacement

44

22

23

24

19

59

107

64

66

60

135

59

84

57

81

136

60

30

67

54

29

71

52

36

24

25

26

38

51

37

16

50,

48

46

45

30

18

Reactor

Coolant

Pump Seal

Replacement

12

6

3

8

6

20

17

Nanway Removal/

Replacement

Instrumentation

Repair

and

Calibration

6

--

7

19

6

31

41

22

16

12

Job

83

84

85

86

87

88

NUREG/CR-

4254

Ava,

Secondary

Side

And Repair

Fuel Shuffle/

Sipping And

Inspections

Operations-

Survei llance,

Routines

and Valve

Lineups

10

9

6

7

8

35

8

10

18

20

11

19

13

Cavity

Decontamination

3

4

3

6

Pressurizer

Valve

Inspection, Testing,

and Repair

11

7

40

24

Radwaste

System

Repair, Operation,

And Maintenance

6

32

23

18

17

10

Residual

Heat

Removal

System

Repair

And

Maintenance

3

10

7

17

The inspectors

noted that, for most jobs

reviewed,

the licensee's

dose

performance

per job

was

higher

than the industry

average

indicated

in

NUREG/CR-4245

( 1974-1984 data)

~

b.

Control of Contaminated

Areas

The

inspectors

reviewed

the

licensee's

program for controlling

contamination

in the

RCA of the plant.

For the years

1987

and 1988,

the licensee

had the highest

percentage

of contaminated

area

versus

RCA in comparison

to the

other plants

in Region II.

In 1987,

34 percent (/) of the

RCA was contaminated.

In January of 1988,

33%,

or 22,985

square

feet (ft~) of the

RCA was contaminated.

This was

reduced to 11,239 ft'r 16'~ of the

RCA in June.

However,

due to the

Unit 4 refueling outage,

the contaminated

square

footage

in'creased

to

29'y

December

1988,

The licensee

has estiblished

a

1989 goal of

104

contaminated

square

foctage.

The

large

percentage

of

contaminated

RCA was identified as

a weakness.

c.

Dose Reducti on Initiatives

During

discussions

on

dose

reduction

initiatives,

licensee

representatives

stated

that

the Unit 4 refueling

outage

was their

first experience

with holding vendors

accountable

for their dose

by

contract.

A major Nuclear

Steam Supply System Yendor, with previous

plant specific experience,

was contracted

to perform

a fixed scope of

refueling related work.

The vendor established

that it would require

more

than

120 person-rem

to perform the

work outlined.

In accord

with the

proaram

to maintain collective

dose

ALARA, the licensee

reviewed

the

jobs

involved

and

estimated

the

work

could

be

accomplished

for 72 person-rem.

The vendor

was able to complete the

work within the

amount

contracted

and

earned

an

incentive

by

completing the job at

65 person-rem.

The inspection

team indicated

that this

was

a positive

means

to help reduce

maintenance

dose

and

was indicative of an innovative

means

to cont'rol

dose

ALARA.

4.

Organization

(83528/83728)

a.

ALARA Staff

The licensee

ALARA organization

consisted

of a staff of eight

Zone

Coordinators

(AZCs)

reporting

through

two

ALARA Shift

Supervisors

to the

ALARA Supervisor.

An

ALARA Technician

and

a

Shielding Technician

also reported directly to the

ALARA Supervisor.

Licensee

representatives

stated

that

the

ALARA Organization

was

a

temporary

group that reported

to the NR-/IT and that

a proposal

was

before the

ALARA Comnittee to establish

the

ALARA Organization

as

a

permanent

group.

(1)

Staff Responsibilities

The

ALARA Shift Supervisor

was

responsible

for reviewing the

performance

of the

AZCs, attending

pre-job planning meetings,

and maintainino

an awareness

of the dose status of all radiation

work permits

(RWPs).

The Shielding Technician

was responsible

for interfacing with engineering

and crafts to ensure

prompt and

proper

documentation

of

surveys

to

show

the

shielding

effectiveness.

The

ALARA Technician

was

responsible

for

maintaining job histories,

generating

a weekly dose/work report

on man-hours

and

dose

expended

on each

RWP,

and development

of

the

annual

dose

report,

The

AZCs

were

responsible

for

overseeing

coordination

of all

work taking

place

in their

respective

zones with the priority of reducing

dose at the job

site.

(2)

ALARA Zone Coordinators

Licensee

representatives

stated

that the work performed

by the

AZCs has

been

a positive force in reducing collective person-rem

at the station.

The

AZC concept

was

a result of initiatives by

the

MR-/IT to

reduce

collective

dose

by direct

job site

surveillance

of

personnel

experienced

in

techniques/methods.

The licensee

stated

that they considered

the

49% reduction

in collective

dose

from 1987 to

1988 to be

largely the effort of the

AZCs,

ALARA group,

and acceptance

of

the

ALARA program at the station.

Eight

HP technicians

were

assigned

as

AZCs for the Unit 4

refueling

outage

in September

1988.

Four

were assigned

to day

shift and four

AZCs provided coverage for the night shift.

The

ALARA group

and

AZCs were temporarily established

to support the

outage

and report directly to the MR-(IT.

All data collected

by

the

ACZs are in a job history report format and are input weekly

to the MR-/IT.

The inspection

team reviewed the

ACZ concept in

detail

and

evaluated

the

reports

they

generated.

The

AZC

reports outlined their participation in mock up taining, pre-job

planning

and

post

job

interviews,

as

well

as

job

critiques/reports. for specific jobs.

Based

on the inspection

team's

review of AZC reports,

the team determined that the

AZCs

were

able

to

document

in detail

that

8% of dose

accumulated

during

the

outage

was

unnecessary.

The

information

was

transmitted

to the MP-(IT on 'a weekly basis

to be evaluated

at

the

end of the refueling

outage.

The inspectors

noted that,

during

some

weeks,

unnecessary

dose

ranged

as

high

as

28K.

Through March IO, 1989,

51.5 of 631.9 collective dose

was proven

to

be the result of poor planning, job coordinating

personnel

errors,

or repetitive work.

During an interview with an AZC, an inspector inquired about the

acceptance

of the

AZC program

by plant workers.

The

AZC

indicated that, at first, the

AZCs were in a difficult position,

in that they were constantly critiquing jobs.

However, the

AZCs

have

been able to develop

a good working relationship with plant

workers

and this rapport

has

resulted

in the collective effort

to reduce plant dose,

Based

on interviews with licensee

personnel

and

a review of

data,

the inspection

team determined

that the work to date

by

the

AZCs appeared

to be

one of the most comprehensive

and best

documented efforts to reduce

dose in Region II.

The inspection

team

recommended

that the

ALARA group

and the

AZC concept

be

adopted

and

formalized

by incorporating their functions

and

responsibilities

into plant procedures.

The team also suggested

that

the

data

regarding

accumulation

of unnecessary

dose

be

analysed

during the outage rather

than waiting until the end of

the

outage.

This

should

allow the licensee

to incorporate

needed

changes

ano

recommendations

for job

improvement .in

a

timely manner

and

help

reduce

job site

dose

as well.

The

licensee

agreed

with

the

recommendation.

The

lack

of

formalization of the

AZC concept

was identified as

a weakness.

ALARA Coordinating

Committee

The

ALARA Coordinating

Committee

was

established

to appraise

the

effectiveness

of the

ALARA program,

review job exposure

records

and

review relevant

experience

at other plants,

and

review job task

data

for

ALARA planning.

The

group

included

representatives

from key station

departments.

Additional duties

included

dose accountability

and awareness,

planning

and scheduling

for outages,

and

the

review of repetitive

jobs

resulting

in

unnecessary

dose.

The inspector

reviewed the monthly meeting minutes

for 1986 through

1988,

and determined that overall attendance

at the

meetings

from June of 1987 to November

1988 was approximately

48%.

During 'this .time period,

key departments

such

as

operations

and

technical

support

did not attend

any

meetings.

Instrument

and

Control

(IKC) ard

maintenance

attended

only

14'A

and

28% of the

meetings

respectively.

The

inspectors

discussed

attendance

and

effectiveness

of the

ALARA Coordinating

Committee

with licensee

management

and

the

licensee

agreed

that

improvement

in attendance

should

increase

the committee's

effectiveness

and that this would be

addressed.

The poor attendar ce at the

ALARA Coordinating

Committee

was identified as

a weakness.

ALARA Suggestion

Program

In discussions

with licensee

representatives,

the inspectors

learned

that there

was

no formal program prior to 1989 for ALARA suggestions.

However,

in January

1989,

the licensee

implemented

a "Bright Ideas

Program" to elicit ideas for plant improvement from personnel

and to

generate

interest in,

and

awareness

of, ways to reduce

dose at the

station.

This prooram is coupled with incentives

but is only open to

licensee

personnel.

The inspectors

indicated that there

may

be

a

problem with the

program

because

"bright ideas"

associated

with

recommendations

for reducing

dose

are

not currently

scheduled

for

review by the

ALARA Review Board.

Licensee

representatives

agreed to

consider this potential

problem.

ALARA Review Board

The plant

ALARA Review Board was established

to provide guidelines to

implement

ALARA concepts

in all aspects

of facility construction

and

operation,

and

to provide radiation

protection

input to facility

design

and

operationa'1

planning.

The

group

was

comprised

of

managers,

supervisors,

and. technicians

from key station departments.

The inspectors

reviewed

the quarterly minutes

of the

ALARA Review

Board

meetings

from 1983

through

1988.

Based

on the

review of

meeting

minutes

and interviews with plant manager

and supervisors,

the inspectors

determined

that the

ALARA Review Board

was actively

involved in efforts to reduce

dose

at the station.

The minutes

reflected

good participation

by members

from key departments,

an

aggressive

approach

to investioating

and implementing

dose reduction

action items,

and

an active roll in pursuing

methods currently used

in the industry to reduce out of core =source

term.

5.

Training (83528/83728)

The inspectors

reviewed the licensee's

training program to determine

which

groups

of employees

received training in

ALARA policies

and practices

beyond what was given in basic

General

Employee Training (GET).

a ~

b.

Mock-up Training

The licensee

provided specific

ALARA training to individuals involved

with

steam

generator

maintenance

and

non-destructive

=testing

activities

and

individuals

involved

with

other

maintenance

activities.

It was apparent

to the inspectors

that the licensee

had

placed

a significant amount of emphasis

and resources

in the mock-up

training program for maintenance

personnel.

In addition to the steam

generator

mock-up for the

channel

head,

the licensee

had

a mock-up

training facility established

in the nuclear training center.

Some

of the

pump

and value mock-ups included:

reactor coolant

pump seal;

connoseal

charging

pump; safety injection pump; residual

heat

removal

pump;

boric

acid

transfer

pump;

and

a

waste

gas

compressor.

Additionally, the

inspectors

reviewed

Lesson

Plan

Number

1302402,

Revision 0, dated

November 3,

1988, entitled "Refueling Activities,"

which was basically

a pre-outage

slide presentation.

The lesson

plan

covered

methods

to reduce

exposure

and discussed

A2C's function, use

of shielding,

and multi-badging.

During the review of the mock-up

training

program,

the inspectors

noted that

HP personnel

were not

involved with the mock-up training exercises.

Additionally, the use

of protective clothing

(PC)

and respirators

(when applicable)

have

not

been

used

to simulate

working conditions

during the training

sessions.

The licensee

had identified this weakness

in the mock-up

training

program

and

was

considering

using

personnel

and

PC/respirators

during future training sessions

to ensure realistic

job/training conditions.

The lack of

HP involvement in maintenance

department

mock-up training was identified as

a weakness.

Additional

ALARA Training

With regard to specific

ALARA training provided to other work groups,

the

inspectors

noted

that

the

design

engineering

group

was

not

provided with specific

ALARA training other than what was provided in

GET.

The inspectors

discussed

with licensee

representatives

the

benefits

from specific

ALARA training for the engineers,

especially

since

those

individuals are involved with plant

and

system

design-

change

reviews that ultimately could effect workers'oses.

The lack

of desion-related

ALARA training 'for design engineers

was identified

as

a weakness.

c.

Continuing

HP Training

The inspectors

also reviewed the licensee's

contractor

and continuing

HP training

programs.

The inspectors

observed

that there

was

no

retrainina

or requalification

program for returning

contract

technicians.

It should

be noted that this finding and the contractor

HP training

program

was

reviewed

during

the

maintenance

team

inspection

(Inspection

Report

No.

50-250,

251/88-32)

and

the

aforementioned

inspection report should

be referred to for a detailed

discussion.

With regard

to the continuing

HP training program,

the

inspectors

reviewed

O-ADl~i-360, "Radiation Protection

manual

Health

Physics

Training,"

dated

Parch

22,

1988.

Additionally,

the

inspectors

reviewed

the continuing health

physics training proaram

lesson

plan for 1989/cycle

1, 1988/cycle 2,

and

1988/cycle

1.

Some

of the topics covered in the lesson

plans included:

Radiography Safety

Incore !nstrumentation

Chemical

Volume Control

System Filter Chanoe

Outs

Plant Safety

Personnel

Decontamination

Hot Particles

Sources of Radiation

PWR Overview

The inspectors

discussed

the

scope

of the training with licensee

representatives.

The

licensee

committed

. tc evaluate

adding

the

following subjects

in future training

cycles:

conduct

evaluations

for active

RWP work; participate in mock-up training for

radiological control; perform pre-job

and post-job reviews; initiate,

track,

and

complete

ALARA projects;

interface with scheduling

and

outage

management

groups for processing

work documents;

perform

a

shielding review; and use of the Nuclear Information Management

System

(NIYiS).

The lack of 'a retraining or requalification

program for

returning radiological

control

HP technicians

was identified as

an

weakness,

d.

Program

Improvements

The

inspectors

also

discussed

the

licensee's

self-identified

improvements

for the

ALARA training

program.

Some

of the

items

recently identified by the licensee

included:

Develop more formal preoutage/prejob

training

Develop "system cleanliness"

control training program

10

Upgrade

the

GET

program to include

ALARA policy discussions,

suggestions

program,

and hot particles

Develop specific

exposure

reduction training for engineers

and

HP personnel

Develop

component

location video displays

to aid in equipment

location

The inspectors

recognized

the licensee's

initiative to improve the

ALARA training.

6.

ALARA/RWP Procedure

Implementation

(83528)

The

inspectors

reviewed

the following

HP procedures

that pertained

to

ALARA practices:

O-ADM-360, Radiation Protection Man/Health Physics Technician

Training, March 22,

1988

O-ADM-600, Health Physics

Manual,

March 31,

1988

O-ADN-701, Plant

Work Order Preparation,

October 26,

1988

O-HPA-001, Radiation

Work Permit Intitiation and Termination,

December 2,

1988

O-HPA-005,

Yian-Rem Reporting,

Yiay 22,

1985

O-HPA-006,

ALARA Program, July 9,

1987

HP-55, Temporary Shielding,

January

14,

1986

PTP 100-14,

ALARA Evaluation, July 23,

1984

a.

Post-job

Reviews

The

inspectors

reviewed

the

licensee's

criteria for conducting

post-job

ALARA reviews,

and

observed

that

procedures

O-ADM-600,

Health Physics

Manual

and O-HPA-001, Radiation

Work Permit Initiation

and

Termination,

required

post-job

reviews

when the total

actual

collective

dose

was

greater

than

50

person-rem.

Additionally,

0-ADYTA-600 required

a post-job review to be conducted

by the corporate

group

when

the

actual

collective

dose

~ was

greater

. than

100 person-rem.

The post-job

review

was

intended

to capture

the

success

or failure of the

ALARA techniques

used for the task.

The

inspectors

reviewed

the post-job reviews that were performed for the

present

outage

and previous

outage.

It was observed

that only one

formal

post-job

review

was

performed

during

the

present

outage

(reactor

head ductwork).

During the previous outage,

only one formal

post-iob

review

was

preformed

(control

rod drive

mechanism

weld

repair)

and

one informal post-job review was performed

(environmental

qualification electrical

splice work).

The inspectors

discussed

the

post-job

review prooram with licensee

representatives,

noting that

few formalized

post-job

ALARA reviews

were

conducted

and

the

unrealistically high criteria for requiring

a post-job

ALARA review.

The licensee

agreed that the post-job

ALARA review criteria should

be

revised

so that

more jobs would be critiqued for later application

towards

dose

reduction.

Several

methods for establishing

post-job

ALARA review criteria were

discussed

with the

licensee

including

consideration

of the following:

(1) estimated collective dose

less

than

one

person-rem

and

the

actual

dose

is greater

than

one

person-rem

and

150K greater

than

the

estimate;

(2) estimated

collective

dose

is oreater

than or equal

to one person-rem

and the

actual

dose .in

150~ greater

than

the estimate;

and

(3) estimated

collective dose is greater

than or equal

to five person-rem

and the

actual

dose is greater

than

25~ of the estimate.

Also discussed

was

the

involvement of the

ALARA Coordinating

Committee

in post-job

reviews

when

the

estimated

dose is greater

than or equal

to five

person-rem

'and the actual

dose

is

150K greater

than the estimate.

The post job ALARA review program

was identified as

a weakness.

b.

Exposure Tracking

The inspectors

observed

that the licensee

manually tracks

the time

spent in performing jobs in high radiation areas.

This process

was

labor-intensive

for the

HP staff.

As

a result,

the licensee

was

unable

to provide job-specific man-hour

information

on

a real

time

basis

and obtaining collective dose

data for,a specific job was often

delayed.

Through discussions

with the licensee,

the inspectors

noted

that the licensee

had

budgeted

funds to install

a

NIMS which would

have

as

one

of its functions

the ability tc track job-specific

man-hours.

c.

Exposure Correlation

The

inspectors

reviewed

the correlation

between

the

TLD and

PIC

measurements

for 1988,

The following is

a

summary of the

data

reviewed:

Table

3

PIC and

TLD Correlation

month

1/88

2/88

3/88

4/88

5/88

PIC,

Person-rem)

75

39

132

18

41

TLD

Person-rem

63

. 29

103

12

Ratio

~(PIC/TLD

1.19

1.34

1.28

1.50

1.41

.

6/88

7/88

8/88

9/88

10/88

11/88

12/88

18

13

23

63

223

202

157

12

11

7

12

41

160

171

126

1.64

1.86

1.92

1.54

1.39

1.18

1.25

In general,

during outage

months,

the licensee's

PIC readings

were

25~ greater

than

TLD measurements.

During non-outage

months,

the

PIC/TLD ratios

were

much larger.

On the average,

the

PIC readings

were approximately

55~ greater

than

TLD measurements.

The inspectors

and

licensee

representatives

discussed

these

discrepancies

and the

need to investicate

the reasons

for them.

The licensee

believed that

part of the problem

may be

due to the practice of resetting

the PIC

after

exitino

the

RCA,

even if

no significant

exposure

was

accumulated

on the ion chamber.

The licensee

believed that the

PIC

dose tracking computer operators

may have the tendency

to enter, for

example, five milliroentgen,

even if the individual's PIC indicated

a-

value close to zero.

The licensee

was considering

the adoption of

a

policy of not resetting

the

PIC to zero after

each

use.

The

discrepancies

in correlations

of

PIC

and

TLD measurements

was

identified as

a weakness.

d.

Dose Estimation

The inspectors

also

reviewed

a

summary of

12 completed

RWPs with

particular attention to the comparison of actual collective dose

and

budgeted

or estimated

collective dose.

Of the

12 completed

RVPs,

seven

were

over the estimate,

ranging

from approximately

=125~ to

710K.

The difficulty in making realistic

man-hour

estimates

for

collective

dose

was

discussed

with the

licensee.

The licensee

perceived

the

man-hour

estimation

problem

as

three-fold:

(1) unplanned

work as

a result of Engineering

Department evaluations;

(2)

new work scope for which

no historical

data

are available for

man-hour estimates;

and

(3) low man-hour estimates

from the Planning

Department.

Although the

licensee

was

aware

of the

m'an-hour

estimation difficulties, there

were

no

apparent

proposals

for a

solution,

The

inspectors

stressed

the

importance of the

design

engineers

to work more closely with the planners

and schedulers

so

that the

amount of unplanned

work could

be minimized.

The licensee

understood

and

acknowledged

the inspectors'oncerns.

The

poor

coordination of work and

low man-hour estimates

were identified as

a

weakness.

7.

Audits and Appraisals

(83538)

The inspectors

reviewed

both Corporate

audits

and plant Quality Assurance

(QA) audits for calendar

year

1988.

Additionally, the inspectors briefly

reviewed

a draft of the Turkey Point

ALARA Design Review Report conducted

by Westinghouse

on

December

12-15,

1988.

Although this report

was

a

13

draft, the inspectors

noted that this assessment

identified several

good

dose

reduction

and

source

reduction initiatives that were in place

or

planned

and

several

sugaestions

for additional

plant

improvements.

The

Corporate

audits referred to above

were basically performance

based plant

walkthroughs of the

RCA and did not address

the

ALARA program.

The plant

gA audits

focused

on radiation protection,

postings,

and high radiation

areas.

Only one of the

seven audit reports

reviewed identified an

program related

finding.

The inspectors

found, in general,

that the

audits

lacked

the

depth

to identify radiological

and technical

issues

necessary

for ALARA improvement.

8.

Interviews

(83528/83728)

a

0

Employee Discussions

The inspectors

discussed

with licensee

employees

their knowledge,

involvement,

and perspective

of the utility's ALARA Program,

including

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

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

on what events

or conditions

had helped

reduce

personnel

doses.

(1)

Employees

All employees

interviewed entered

the

RCAs 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

Radiation

Protection

Training

portion of GET.

This portion of is training in referred to as

Red

Badge Training in the

GET program.

Each of the

employees

knew that they

had

a basic responsibility for 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 and

knew that

a daily dose printout was available

at the entrance

to the

RCA.

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

has

an

ALARA goal.

The employees

knew that they could find out their section's

goal

from the

HP staff.

ALARA Program Involvement

The

employees

interviewed

had not received

any

ALARA training

other

than that given in the

GET course.

A larae

number of

those

interviewed

had received

some informal

ALARA training on

jobs requiring

ALARA pre-job planning

and on-the-job training.

Employees

reported

frequent

discussions

of ALARA objectives

on

major jobs during outages

with co-workers

and supervisors

and

also

AZCs.

The employees

reported

good

and open communications

with the

AZC and

HP staffs.

Only a small fraction of employees

interviewed

had

participated

in the

formal

"Bright Ideas"

suggestion

program.

Other employees

reported that they had made

suggestions

to supervisors

informally and

had

not

used

the

formal sugoestion

program believing it was only for "significant

suggestions."

It was

determined

that currently

the "Bright

Ideas"

program incentives

were only available to the licensee's

employees.

A majority of the backfit and plant modification

work

was

scheduled

for contractors.

The licensee

agreed

tc

evaluate

the

use

of the "Bright Ideas" incentive

program with

contractor personnel.

Findings

Host of the

employees

had suggestions

on

how the

ALARA Program

could be improved.

The suggestions'ncluded

better planning

and

scheduling

of work to ensure

that

appropriate

equipment

and

tools were readily available to perform task expeditiously.

The

majority of employees

had opinions

on what had contiibuted 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 action 'had contributed to increases

in personnel

doses:

poor maintenance

planning

and scheduling in

the

past;

proficiency of contract

personnel;

and failure to

include

input

from craft maintenance

personnel

on

proposed

engineering

changes.

Overall the employees

expressed

a positive

feeling

on management's

support for ALARA and

HP.

.The use of

the Turkey Point

news letter

"To the Point"

and the

TY video

screen

news monitors which provided periodic

ALARA messages

were

deemed positive by the employees

during the interview.

b.

Hanagement

Discussions

The inspectors

discussed

with licensee

manaaers

and supervisors

the

utility's ALARA Program,

including their knowledoe of

ALARA goals,

concepts,

policies

and

procedure

documents,

individual

responsibilities,

personal

exposure,

and

personal

exposure limits,

and their involvement in special

ALARA training,

communication with

15

co-workers

and supervision,

and participation in the

ALARA suggestion

proaram;

and

the managers'r

supervisors'erspective

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.

Managers

and Supervisors

All individuals interviewed

entered

the

RCAs

on

a weekly to

monthly basis

depending

on plant conditions.

Knowledge cf ALARA Program

Each individual interviewed

was familiar with the basic

concepts

taught

in the

GET program

and

knew that they

had

a

basic

responsibility

for

implementing

the utility's

program

by performing

a task

in

a

manner consistent

with the

utility's

ALARA policy.

In

general,

the

managers

and

supervisors

interviewed

were

knowledgeable

of the

current

,

radiatior.

exposure

and

exposure

limits for their departments.

The

managers

and

supervisors

understood

where

the

requirements

originated

and what corporate

and plant documents

described

the

ALARA program objectives.

All the managers

and

supervisors

interviewed

knew their department's

ALARA goals

and

knew that their

annual

performance

appraisal

contained

elements for which they were held accountable

in meeting their

ALARA goals.

ALARA Program

involvement

The majority of the managers

and supervisors

interviewed

had not

received

any

ALARA training other than that given in the

GET

"Red Badge"

course.

Each department

had

a dedicated

individual

to serve

on the'LARA Review Committee

(ARC), which met

on

a

quarterly basis

or as needed.

The

ARC members

represented

their

departments

in discussions

of

ALARA objectiveness

for major

outage

jobs with coworkers

and

supervisors.

None of the

managers

or

supervisors

interviewed

had participated

in the

formal

"Bright

Ideas"

suggestion

program

with

an

suggestion.

However,

generally

most

of the

managers

or

supervisors

interviewed

were

aware of formal or informal

suggestions

submitted

by their departments

in the

past

or

current year.

These

ALARA suggestions

were usually submitted

by

employees

during

a pre-job briefing.

There

appeared

to

be

a

strong

management

commitment to use innovative initiatives

and

excell in collectiv'e person-rem

reduction.

Findings

All managers

and supervisors

interviewed

had sugoestions

on how

the

ALAPA program could

be improved.

The suggestions

included

16

9.

Chemistry

recommendations

for better

scheduling

and

planning of work;

ensuring

that

appropriate

equipment

and

tools

were

readily

available,

and

a

commitment to increase

the

awareness

of the

ALARA concept to all levels of plant personnel.

At the start of

the

Unit 4 outage,

some

26

unapproved

and

unscheduled

Plant

Change

and

Yiodifications

(PCNs)

were

working through

the

approval

process

for the outage work.

In addition, at least ten

PCNs

have

been initiated

and were to be worked prior to outage

completion.

This unanticipated

and unplanned

work has resulted

in significant increases

to the person-rem totals

thus far in

the

unit

outage.

Person-rem

reductions

associated

with

efficient, well

planned

jobs

have

not

been

realized.

As

a

result,

at the time of the

team visit, contractor

person-rem

goals were. being overrun

by approximately

250K.

The majority of managers

and supervisots

had opinions regarding

the

contributors

to

decreases

and

increases

in

personnel

exposures.

Individual

managers

and

supervisors

interviewed

believed that the following actions

had contributed to exposure

reduction:

use of AZC, use of temporary shielding,

and

reduced

work activities in high radiati'on areas.,

Individual managers

and

supervisors

interviewed

believed

that

poor planning

and

scheduling

of maintenance

had

contributed

to

increases

in

collective dose.

Also, several

personnel

interviewed believed

that namino

a permanent

Radiation Protection

Manager replacement

would provide

a strong leadership

and program stability.

The

inspectors

discussed

the water

chemistry

program with cognizant

licensee

representatives

and

reviewed

pertinent

procedures

with the

objective of determining water chemistry's role in dose reduction.

Licensee

representatives

stated that prior to shutdown,

hydrogen peroxide

was

added to the Reactor

Coolant

System.

This resulted

in crud releases

from components

to the coolant,

which

was

cleaned

up

by the

letdown

demineralizers.

The inspectors

reviewed the coolant activity curves for

the Unit 3 outage

in 1987.

These

curves

showed that coolant activity

increased

sharply

upon addition of the hydrogen peroxide,

then decreased

with use of the demineralizers.

Another method

was throuoh lithium-boron coordination

and constant lithium

(pH) control.

This program

had

been

used for the past three years,

and

the licensee

stated

that the

dose

in the vicinity of the hemispherical

bottom head of the steam generator

"bowl" dose

has trended

downward during

this period.

This type of chemistry control kept radioactive materials

suspended,

rather than plating out.

The letdown dpmineralizers

then could

remove the crud.

The licensee

representative

stated that

when Unit 4 is

started

up,

elevated

pH control will be used.

It was anticipated that

initial coordination

would be at

a

pH of 6.9, then, later in core life,

17

increasing

to

a

pH of 7.2.

The licensee

would eventually coordinate at

a

pH of 7.4 if fuel vendor approval

was received.

The

Chemistry

Department

closely

monitored

primary

chemistry

and

calculated

Fuel Reliability Index (FRI) which was plotted

and tracked.

This index

was calculated

from measured

coolant levels of Iodine-131

and

Iodine I-134.

The Iodine-134

was

used to correct for tramp uranium in the

zircal 1oy fuel cladding.

Condensate

polishina demineralizers

were used during startups

and extended

shutdowns.

Normally these

would run for 12-13 hours before they had to be

taken off line.

A change

was

made in the precoat process,

and during the

last

startup,

the

demineralizers

were

run for

40

hours

with

no

breakthrough.

Licensee

representatives

stated

that the Chemistry Department

had

become

more

involved

in liquid

and

gaseous

effluent

releases.

Chemistry

procedurally

has

lowered allowable concentrations

in Waste Monitor Tanks

from 1E-4 microcuries

per milliliter (uCi/ml) to

1E-5 uCi/ml,

and

was

considering

ways to lower waste volume.

The Chemistry Department

was also

monitoring

a vendor's testing

program for increasing filter efficiency for

removal of cobalt in the reactor

coolant

system

by applying electrical

voltage across

the filter,

The inspectors

noted that these

actions

by the chemistry program should

contribute to lowerina collective dose.

The inspector

discussed

steam

generator

operations

and maintenance

with

licensee

representatives

with

the

objective

of

determining

the

contribution of

steam

generator

operation

and

maintenance

to

dose

reduction.

Licensee

representatives

stated- that

sludge

lancing

was

performed

during

each

outage

to reduce

deposits.

Foreign Object Search

and Retrieval

(FOSAR)

was

done using fluoroscopy.

FOSAR was

a method of

detecting

loose objects in the

steam generators

which might cause

damage

through

impact or blockage of flow channels.

Licensee

representatives

stated

that in the future the target

was to perform. 100%

eddy current

testing of the tubes,

the only constraint

being that completion of the

outage not be delayed.

A licensee

representative

stated that

ALARA principles were applied in the

conduct of steam generator

maintenance

by the following means:

Using remote devices (robotics) where possible.

Providino

HP the

complete

plan for steam generator

work to be done

during the next outage well in advance.

Combining jobs

so that several

could

be done in each entry.

18

Training of workers in advance of job.

Working closely with HP for backfit work.

These

methods

appeared

to

be effective

in

reducing

exposure.

An

aggressive

chemistry

program

and close monitoring of system

parameters

appeared

to have helped in decreasing

the

amount of sludge to be

removed

and the good condition of steam generator

tubes

noted during eddy current

testing.

12.

Followup Items

(Closed)

Inspector

Followup Item (IFI) 50-251/88-25-03;

Review licensee

action

concerning

operation

of

the

spent

fuel

pool

cleanup

filter-demineralizer to limit radioactivity concentrations

in water.

The inspectors

verified that Nuclear Chemistry Procedure

NC-99,

Sampling

the Spent

Fuel Pit, and the Spent

Fuel Pit Demineralizer Inlet and Outlet,

dated

November

10,

1988,

required that if total isotopic activity exceeds

5.0 E-3 microcuries

per milliliter, the

NWE is requested

to have the spent

Fuel Pit recirculated

through

the demineralizer, if not being performed

already.

The inspectors

reviewed

curves of the total activity found in

the

Spent

Fuel

Pits

and verified that

since

implementation

of the

Procedure,

the Unit 3 Spent

Fuel Pit remained

below 5.0 E-3 uCi/ml total

concentration,

and the Unit 4 Pit has

not exceeded

6.0 E-3 uCi/ml except

for one period in December

1988.

13.

Conclusion

(83528/83728)

Considerable

steam

generator

maintenance,

subsequent

steam

generator

replacement,

and

a

high out-of-core

source

term contributed

to high

collective'dose

in past years.

However, increased

management

support for

the

ALARA program from both plant and corporate

groups

and implementation

of the

concept for on-the-job

dose

reduction

(AZCs)

has

resulted

in

a

significant reversal

of the past trend.

The following significant issues

were identified as weaknesses

during the inspection:

Lack of health

physics

(HP) involvement in maintenance

department

mock-up training, lack of design-related

ALARA training for design

engineers,

and

minimal retraining

or requalification

program for

returning