ML18152A257
| ML18152A257 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/12/1994 |
| From: | Rankin W, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A258 | List: |
| References | |
| 50-280-94-26, 50-281-94-26, NUDOCS 9411030078 | |
| Download: ML18152A257 (17) | |
See also: IR 05000280/1994026
Text
UNITED STATES
NUCLEAR REGULATOAY COMMISSION .
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
October 12, 1994
Report Nos. : 50-280/94-26 and 50-281/94-26
Licensee: Virginia Electric and Power Company
Docket Nos.:
50-280 and 50-281
License Nos.:
Facility Name:
Surry 1 and 2
Inspection Conducted:
August 29 - September 2, September 7 - 12, and
.
.
Sept'::er 27 - 28'. 1994
Inso/Jctor:~})~ -:6-~
~
F. N. Wright
r--)
Approved by: r?..10-:::bZ \\( (. ~
W.
. Rankin, Chief
Facilities Radiation Protection Section
Radiological Protection and Emergency Preparedness Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection of the licensee's Radiation Protection
(RP) program w~s made to review the implementation of the revised 10 CFR
Part 20 requirements.
The evaluation was made utilizing Temporary
Instruction 2515/123, "Implementation of the Revised 10 CFR Part 20." The
review focused primarily on the areas of: high and very high radiation areas;
Total Effective Dose Equivalent/As Low As Reasonably Achievable program
implementation; planned special exposures; and dose to the embryo/fetus for
declared pregnant woman.
Results:
Revisions to the RP program incorporating new requirements of 10 CFR Part 20
were made effective January 1, 1994.
The inspection included interviews with
licensee personnel, procedure and record reviews, and observations made during
tours of the licensee's radiological controlled areas.
The new requirements,
as focused by* the inspection procedure, were appropriately incorporated into
the RP program.
The inspector spoke favorably of the radiation protection
implementing procedures, which for the most part, appropriately addressed the
revised requirements and of the housekeeping in observed facilities.
One
violation was identified for failure to adhere to radiation protection
9411030078 941012
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2
procedures for access to posted and controlled very high radiation areas
(Paragraph 3).
In addition, one non-cited violation.was identified
concerning the use of a checklist, for access into a posted and contrplled
very high radiation area, that was not procedurally controlled and approved
(Paragraph 3) .
I.
Persons Contacted
Licensee Employees
REPORT DETAILS
- M. Biron, Supervisor, Radiological Engineering
+*W. Benthall, Supervisor, Licensing
- D. Boone, Quality Assurance
+#P. Cherry, Corporate Licensing
- D. Christian, Station Manager
B. Dorsey, Supervisor, Exposure Control
- D. Erickson, Superintendent, Radiation Protection
K. Ewell, Ftiel Handling Coordinator
- A. Friedman, Superintendent of Nuclear*Training
+*B. Garber, Licensing
B. Hilt, Nuclear Training
- J. McCarthy, Assistant Station Manager
- D. Miller, Supervisor, Health Physics Operations
- D. Nace, Radiological Engineering
M. Olin, Supervisor, Health Physics Technical Services
- A. Price, Assistant Station Manager
- R. Saunders, Vice President, Nuclear Operations
+D. Sommers, Licensing
D. Sweany, Training
- B. Thornton, Corporate Health Physics
N; Urquhart, Supervisor, Nuclear Training, Radiological Protection
D. Whiti, Health Physics Shift Supervisor
Other licens~e employees contacted during the inspection included
technicians, maintenance personnel and administrative personnel.
Nuclear Regulatory Commission
- A. Belisle, Sectio~ Chief, Division of Reactor Projects, Region II
- M. Branch, Senior Resident Inspector
- D. Kern, Resident Inspector
+#W. Rankin, Facilities Radiation Protection Section Chief, Region II
- D. Tamai, Resident Inspector
- S. Tingen, Resident Inspector
- D. Verrelli, Branch thief, Division of Reactor Projects, Region II
- Attended September 2, 1994 Exit Meeting
- Participated in September 12, 1994 Teleconference
+Participated in September 27, 1994 Teleconference
Abbreviations used throughout this report are defined in the last
paragraph.
- 2.
2
Preparation and Training for Implementation of the Revised 10 CFR
Part 20 Requirements {TI 2515/123). *
Training was reviewed to determine whether HP technicians, contractor HP
technicians and radiation workers were receiving appropriate
instructions concerning the revised 10 CFR Part 20 requirements for
their work assignments.
10 CFR 19.12 required that licensees instruct all individuals working or
frequenting any portion of the restricted areas in:
health protection
aspects associated with exposure to radioactive material or radiation;
precautions or procedures to minimize exposure;
purpose and function of
protection devices employed;
applicable provisions of the Commission
Regulations;
individuals responsibilities; and availability of
radiation exposure data.
The licensee's initial radiological protection NET training course was
required for all Virginia Power radiation workers prior to their
radiation work assignments at the station.
Prior to 1994, all radiation
workers were required to attend an abbreviated NET retraining class
annually.
In January of 1994, the licensee implementing changes to the
NET retraining program.
The new training plan only required licensee
radiation workers attend a classroom NET retraining session every three
years.
In the other years, licensee personnel were required to review
the NET Training Manual and certify their completion of the self-study
activities on a "Required Self-Study Receipt." Contract employee
radiation worker retraining requirements did not change and their
participation in an annual retraining class was required.
The 1993 NET
training programs for radiation workers provided the students with an
overview of the significant changes to the revised 10 CFR Part 20
requirements.
The inspector reviewed the instructor guides and the NET
Manual, Rev. 6, dated June 6, 1994.
The NET manual appropriately
addressed the, new terminology, revised dose limits, DPW policy, posting
of very high radiation areas, and PSEs.
However, neither the NET Manual
or the instructor guides addressed TEDE ALARA concept relative to work
in airborne radioactivity areas.
The inspector also determined that the
topic was not addressed in the NET test.
In interviews with the NET
instructors the inspector determined that the concept had. been addressed
in the classroom, even though the instructor guides did not specifically
list it as a topic of discussion or instruction.
In response to the
finding, the training department initiated a revision to the instructor
guides and developed a set of questions concerning the TEDE ALARA
concept.
The licensee was in the process of developing a computer based
training program for NET.
The inspector noted that the TEDE ALARA
concept was adequately addressed in the computer based retraining course
and that there was a TEDE ALARA problem for the students to demonstrate
their understanding of the topic.
In a limited number of interviews
with station employees the inspector did not identify a lack of
understanding concerning the TEDE ALARA concept.
In addition to
theformal introduction to the revised 10 CFR Part 20 requirements, the
licensee utilized other methods to provide the staff with information on
the revised requirements.
The licensee provided information on the
3
changes with the station video monitors, a continued source of
information for plant personnel. A pamphlet, "10 CFR 20 Revision,
Standards for Protection Against Radiation," outlining the significant
changes, was also provided to the staff.
The inspector reviewed the revised 10 CFR Part 20 training presented to
the site HPTs.
In 1992, the HPTCTPs for HPTs included a session related
to implementation of the revised 10 CFR Part 20 requirements.
Each
session was approximately 1 day in length and included reviews of
applicable regulations, comparisons of old and new regulations, licensee
policy and procedures for implementation of the requirements, and series
of questions and answers on the revised requirements.
The inspector
reviewed the following lesson plans:
0
0
0
HPTCTP-4-LP-54, "Orientation to the revised 10 CFR 20;"
HPTCTP-4-LP-55, "10 CFR 20 Update/Procedure Training;" and
_HPTCTP-4-LP-60, "Revised 10 CFR 20 (Dose Assignment)."
In 1993, the HPTCTP continuing training, rel~ted to the revisions to
10 CFR Part 20, concentrated on the application of the requirements in a
new series of draft radiological protection procedures.
The licensee
had previously established a Part 20 working group to prepare for the
implementation of the revised 10 CFR Part 20 requirements.
The working
group, made up.of representatives from Surry, North Anna and Corporate
Office, had been responsible for preparing SNSOC ready procedures in
draft form prior to the January 1, 1994, implementation date.
The draft
procedures were incorporated into the HPT continuing*training sessions
as they became available. The training process permitted the students
to become familiar with the revised requirements and the licensee's new
procedures for implementing those requirements. Student suggestions and
recommendations for the implementing procedures were also considered for
procedure improvements during the process.
The inspector reviewed the
following lesson plans utilized in 1993 HPTCTP:
0
HPTCTP-4-AG/APE-l, "Special Training Radioactivity Effluent
Monitoring Program Draft Procedures Developed to Implement the
- Requirements of the Revised 10 CFR 20;"
0
HPTCTP-3-AG-6, "Use of H.P. Draft Procedures - 1032.XXX Series;"
0
HPTCTP-3-AG/APE-8, "Task Training Completion of NRC Forms 4 and
5; II .
0
HPTCTP-3-AG/APE-10, "Task Training Manipulating PREMS;"
0
HPTCTP-4-LP-68, "Special Training Review of HP Draft Procedures
1032.050, 1042.XXX, and 1081.010 Series;"
0
HPTCTP-4LP-69, "Special Training Internal Dose/Bioassay Program
IAW HP-1041.XXX Draft A Procedures;"
0
HPTCTP-4-LP-70, "Special Training Procedure Changes/Industry
Events;" and
0
HPTCTP-6-TS-5, "HP-1061.021, Draft A Contaminated Skin Dose
Assessment."
3 .
4
The licensee conducted the following HPTCPT training in 1994:
0
HPTCTP-6-TS-6, "10 CFR 20 Revisions - Radiological Protection,"
and
0
HPTCTP-4-72-DRR, "IO CFR 20 Following Implementation."
The traitiing provided the student a review* of the significant changes
resulting from the implementation of the revised requirements, and
provided an opportunity for the HPTs to identify strengths and/or
weaknesses in the radiological protection program areas impacted by the
revised requirements.
The inspector reviewed the licensee's lesson plans for contract HPTs and
determined that the training included a review of the licensee's
procedures incorporating the changes of the revised 10 CFR Part 20
requirements prior to their HP work assignment.
In general, the training programs for radiation workers and HPTs
included sufficient instructions concerning revisions to 10 CFR Part 20
and appeared appropriate for the students needs.
No violations or deviations were identified.
High and Very High Radiation Areas (Tl 2515/123)
This area was reviewed to evaluate the licensee's implementation of
r.equirements specified for the control ,of HRA and VHRA as prescribed in
Paragraphs 20.1601 and 20.1602 of 10 CFR Part 20, "Subpart G-Control of
Exposure from External Sources in Restricted Areas."
Paragraph 20.1601, "Control of Access to High Radiation Areas," states
in part (a);
"The licensee shall ensure that each entrance or access
point to a HRA have one or more of the following features:
(3)
Entryways that are locked, except during periods when access to the
areas is required, with positive control over each individual entry."
Paragraph 20.1602, "Control of Access to Very High Radiation Areas,"
states; "In addition to the requirements in 20.1601, the l~censee shall
institute additional measures to ensure that an individual is not able
to gain unauthorized or inadvertent access to areas in which radiation
levels could be encountered at 500 rads or more in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 1 meter
from a radiation source or any surface through which the radiation
penetrates."
Paragraph 20.1101, "Radiation Protection Programs," (a) states; "Each
licensee shall develop, document, -and implement a radiation protection
program commensurate with the scope and extent of licensed activities
and sufficient to ensure compliance with the provisions of this part."
TS 6.4.B states procedures for personnel radiation protection shall be
prepared consistent with the requirements of 10 CFR Part 20 and shall be
approved, maintained and adhered to for all operations involving
personnel radiation exposure.
5
Paragraph 20.1601.(c) provided a licensee may apply to the Commission
for approval of alternative methods for controlling access to HRAs.
The
licensee's alternative control measures for entry into HRAs were
described in the licensee's TS.
Licensee TS 6.4.8.1 states, in part, "In lieu of the "control device" or
"alarm signal" required by paragraph 20.1601 of 10 CFR 20, each high
radiation area in which the intensity of radiation is greater than
100 mrem/hr but less than 1,000 mrem/hr shall be barricaded and
conspicuously posted as a high radiation area and entrance thereto shall
be controlled by requiring issuance of a Radiation Work Permi_t." A
footnote,to this TS requirement related to the use of RWPs was:
"Health Physics personnel shall be exempt from the RWP issuance
requirement during the performance of their assigned radiation
protection duties, provided they comply with approved plant radiation
protection procedures for entry into high radiation areas."
In addition, any individual or group of individuals permitted to enter
such areas were to be provided with one or more of the following:
0
A radiation monitoring device which continuously indicated the
radiation dose rate in the area;
0
A radiation monitoring device which continuously integrated the
radiation dose rate in the area and alarmed when a preset
integrated dose was received; or
0
An individual quali.fied in radiation protection procedures who was-
equipped with a radiation dose rate monitoring device, responsible
for providing positive control over activities within the area and
made periodic radiological surveys as specified by HP in a RWP.
In addition to the requirements of TS 6.4.8.1, Paragraph 6.4.8.2
required:
0
Areas assessable to personnel with the intensity of radiation was
greater than 1,000 mrem/hr, but less than 500 rads/hr at one meter
from a radiation source or any surface through which radiation
penetrates shall be provided with locked doors to prevent
unauthorized entry; and
~
Keys shall be maintained under the administrative control of the
Shift Supervisor on duty and/or the senior station individual
assigned responsibility for radiation protection.
VPAP-2101, "Radiation Protection Program," Rev. 6, dated July 28, 1994,
established Virginia Power's Radiation Protection Plan, which set forth
the requirements of the Radiation Protection Program for Surry and
North Anna.
Section 5.2, of VPAP-2101, stated in part, "Station
Radiological Protection Department is responsible for ensuring
procedures, personnel, and other resources are established to implement
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6
the Station Radiation Protection Program."
The inspector reviewed .the
following licensee procedures for posting, entry requirements and key
controls for HRAs:
0 .
HP-1081.10, "Radiation Work Permits: Preparing and Approving,!'
Rev. 5, dated, January 24, 1994, provided instructions for Shift
Supervisors Health Physics and RWP Writers to prepare and approve
RWPs as required by VPAP-2101.
0
HP-1032.060, "Radiological Posting and Access Control," Rev. 0,
dated December 7, 1993, provided instructions for posting
radiological areas and implementing access controls.
0
HP-1032.061, "High Radiation Area Key Control," Rev. Ot dated
December 7, 1994, provided instructions to HP Operations for
verifying entry requirements, determining key type, issuing and
accounting for keys to locked HRAs.
The licensee's radiation protection plan, VPAP-2101 made the following
distinctions for HRAs:
0
HRA - Areas accessible to personnel, having a whole body dose rate
in exce*ss of 100 mrem/hr, 30 centimeters from the source;
0
HRA Exceeding 15 Rem/hr - High radiation areas accessible to
personnel, having a whole body dose rate greater than
15,000 mrem/hr, 30 centimeters from the source; and
0
VHRA - Areas accessible to personnel, having a dose rate exceeding
500 rads/hr, 1 meter from the source.
TS 6.4.B.2 required areas with the intensity of radiation greater than
1,-000 mrem/hr, but 1 ess than 500 rads/hr at one meter from source, be
locked to prevent unauthorized entry into such areas and the keys shall
be maintained under _the control of the Shift Supervisor on duty and/or
the senior station individual assigned the responsibility for health
physics and radiation protection.
The inspector reviewed the licensee's HRA key controls with licensee
representatives and determined that the HP Shift Supervisor maintained a
HRA key cabinet and check-out logbook for the control of HRA keys.
The
keys to locked HRA and HRAs exceeding 15 rem/hr were maintained in a key
cabinet on a wall in the HP work area. Licensee personnel reported that
there were only two plant areas that were posted and controlled as
VHRAs, the Unit 1 and Unit 2 Incore Sump Rooms in the Reactor
Containment Buildings.
The licensee controlled the Incore Sump Room as
a VHRAs due to the potential and significant radiological hazards to
personnel associated with the withdrawal of incore detectors from the
core into the Incore Sump Room.
licensee personnel pointed out that the
radiation lev~ls in the Incore Sump Room were usually less than
- e
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7
100 mrem/hr and had not met the definition of a VHRA (500 rads/hr)
during any of the recent entries made into the rooms.
During the review
of the HRA key issuance log, the inspector noted that the logbook did
not contain a copy of Attachment 4, "Very High Radiation Area Key Log,"
of HP-1032.061.
When the inspector inquired about the key issue to the
Incore Sump Rooms lic~nsee personnel made available two foldets out of
the Health Physics Operations Managers office.* Each folder contained a
log of key issuance to the Incore Sump Room, some copies of RWPs, "CL-10
Incore Sump Room Entry" forms and the keys for the locks securing access
to the Incore Sump Rooms.
The key issues were documented on "Incore
Instrumentation Sump Room - Key Control Log" forms that were not
controlled or described by the licensee's procedures. The*Unit 1 folder
showed keys to the Unit 1 Incore Sump Roo~ had been issued approximately
17 times in the period of January 27, 1994 through March 23, 1994.
The
Unit 2 folder showed that keys to the Unit 2 lncore Sump Room had been
issued approximately 6 times during the period of June 6, 1994 and
June 18 1994.
The inspector reported to licensee personnel, that the key issuance did
not appear to have been made in accordance with the requirements of
HP-1032.061 and requested copies of the material in the two folders and
recent radiological surveys of the areas for further review.
The
inspector also reported that all of the RWPs in the folders did not
appear to have been SNSOC approved as required.by VPAP-2101,
Section 6.3.12. The inspector noted that the staff did not appear
familiar with the requirement.
The licensee provided the additional
documentation to the inspector that afternoon.* That evening the
inspector determined that, of the documentation provided at that time,
only 2 of 5 RWPs found in the licensee's 1ncore Sump Room folders had
actually received SNSOC approval, as required by the Radiation
Protection Plan for entries into a posted and controlled VHRA area.
Additionally, the keys were not issued and documented in accordance with
the requirements of licensee procedure HP-1032.061, for any of the
23 key issues to the Incore Sump Room.
The inspector also determined
that a checklist, "Incore Sump Room Entry Checklist" utilized to provide
1 and document certain radiological protection controls for issuing keys
and granting access into the Unit 1 and 2 Incore Sump Rooms was not
addressed in radiation protection procedures and was not procedurally
controlled and approved.
The following morning, and just prior to the exit meeting, the inspector
reported to the Superintendent of Radiation Protection that:
1) There
appeared to be violations related to failure to follow procedures for
HRA access and key controls; and 2) A violation for the use of a
checklist, utilized in preparations for access and radiological controls
into a posted and controlled very high radiation area, that was not
controlled by written and approved procedures.
The inspector reported
the extent of the problem (number of violations) could not be made at
that time, in that, the inspector did not have*all of the licensee's
documentation concerning all of the 1994 entries into the Incore Sump
Rooms.
The inspector requested copies of documentation showing the
8
"Tag-Out" of the incore detectors during Incore Sump Room entries, all.
_ RWPs utilized in access to the In core Sump Rooms and the CL-10 forms
completed for each entry. At the NRC inspection exit meeting, the
inspector reported that there were examples of procedure violations, as
described above, and that the findings would remain an unresolved item
pending a review of additional documents the RP staff had previously
agreed to provide to the inspector in the following week.
The inspector
received the information on September 7, 1994.
The additional
information provided to the inspector included documentation of Incore
Detector "Tag-outs", copies of all RWPs utilized in accessing the Incore
Sump Room, RWP Briefing Attendance Sheets and the identification of the
RWP that was uti_l ized by the personnel assigned a key to the Incore Sump
Room.
The licensee also reported that one key issuance indicated in the
licensee's logbook had not been made, reducing the number of key issues
and entries into the Unit 1 Incore Sump Room to 16 and the total number
of entries into the Unit 1 and 2 Incore Sump Rooms to 22 for 1994.
The
licensee indicated the issue correction on the log-sheet following the
inspectors request of the documentation.
Following the review of the submitted documentation, the inspector
determined that there were several examples of failure to adhere to'
written, controlled, and approved procedures for access to the Incore
Sump Room.
The findings were discussed with licensee representatives in*
a teleconference on September 12, 1994.
The findings included the
following:
0
In 1994, keys to the Unit 1 or Unit 2 Incore Sump Room were issued
to personne 1 ut il i zing 7 different RWPs.
Of the 7 RWPs ut il i zed
location (94-2-2076, 94-2-2047-(Rev. 5 only}, 94-2-2090 and 94-2-
3097}.
Section 6.8 of VPAP-2101 stated that the primary method of
controlling work that involved radiological hazards was the RWP
system.
Section 6.8.7.d stated, workers, before start of work
shall read applicable RWP and ask questions about any part of the
RWP that they do not understand. Section 5.11 of VPAP-2101
required Station personnel be responsible for conducting work with
a high level of performance in radiological protection including
following posted, written and RP verbal radiological instructions.
Section 6.3.1 stated, in part, that if a worker was to enter a
posted HRA, it was the worker's responsibility to verify he or she
was authorized by an RWP to enter the area.
In 1994, six of
twenty-two personnel entries into the Incore Sump Rooms, posted
and controlled very high radiation area, were made with a RWP that
did not address the licensee's controls and requirements for entry
into the Incore Sump Rooms.
Two of the RWPs, 94-2-2001 and 94-2-
3001, utilized by four licensee personnel to enter into the Incore
Sump Room specifically excluded the Incore Sump Room as a work
location for those RWPs.
The inspector reported that failure of
six radiation workers, assigned keys to controlled VHRAs, to enter
the Incore Sump Rooms, on the correct RWP as required by VPAP-
2101, was a violation of TS 6.4.B requirements for failure to
adhere to radiation control procedures. *
~~-
-
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9
VIO 50-280, 281/94-26-01:
FIRST EXAMPLE:
Failure of six
radiation workers to follow procedures and utilize the appropriate
RWP for access into a posted and controlled VHRA.
0
Procedure step 6.3.12.c. of Section 6.3.12, "Access Controls for
Very High Radiation Areas," of VPAP-2101, required "Specific SNSOC
approval shall be required for planned entry into the area." The
inspector determined that during the period of January through
June 1994, the licensee failed to obtain SNSOC approval for RWPs
94-2-2076, 94-2-2047 (Rev. 5}, and 94-2-2090 utilized for entry
into posted and controlled very high radiation areas.
The
inspector stated that failure to obtain SNSOC approval for RWPs
controlling access to the Incore Sump Rooms was a violation of
TS 6.4.B. requirements for failure to adhere to radiation control
procedures.
SECOND EXAMPLE:
Failure to follow radiation control procedures
requiring SNSOC approval for three RWPs utilized to control work
in the Incore Sump Room, a posted and controlled VHRAs.
0
Step 6.4.2 of licensee procedure HP-1032.061, "High Radiation Area
Key Control," Rev. O, dated December 7, 1994, required persons
receiving a key for access into VHRA review the requirements of
Attachment 1, "Requirements and Responsibilities To Enter A Locked
High Radiation Area." Attachment 4, "Very high Radiation Area Key
Log," of 1032.061 provided the licensee with documentation of the
"responsibi.l ity review" by signature when the keys were issued.
Step 6.4.3, required the following information be recorded on
Attachment 4, RWP number applicable to entry; gates or areas to
be entered or key to be used; key requester printed name,
signature, and TLD badge number;
Health Physics coverage
technician printed name, signature, and badge number; key issue
date and time; initials of person issuing the key, and remarks.
The inspector determined that during the period of January 27
through June 18, 1994, the licensee failed to.adhere to radiation
control procedure HP-1032.061 and document the "responsibility
reviews," and other information required by Attachment 4, for all
(22} key issues to the Unit 1 and 2 Incore Sump Rooms, posted and
controlled VHRAs.
The inspector stated that failure to document
the "responsibility reviews," and other information required by
Attachment 4 for key issues into the Incore Sump Rooms was a
violation of TS 6.4.B., "Requirements for failure to adhere to
radiation control procedures."
THIRD EXAMPLE:
Failure to issue keys to a posted and controlled
VHRA in accordance with licensee procedure HP-1032.061.
Various operating and maintenance procedures for the Incore Detectors
required the user to notify Health Physics prior to movement or
maintenance of the detectors and to require "tag-out" of the detectors
during periods when personnel access into containment buildings was
permitted.
The inspector determined that the incore detectors had been
10
made inoperable, using a "tag-out" procedure, throughout all periods
when entries into the Incore Sump Room were made in 1994.
The Health Physics staff was utilizing an "Incore Sump Room Entry"
checkl,ist, commonly referred to as "CL-10" to prepare for entries into
the Incore Sump Rooms.
The checklist was used to ensure certain
radiological protection measures and controls were made prior to
granting access and issuance of keys to the Unit 1 and 2 Incore Sump
Rooms.
The CL-10 checklist documented:
Approval of HP Operations
Supervisor to enter the area; HP Operations verification that detectors
were not exposed and the detector drive systems had been "tagged out;"
radiological survey requirements; and key issuance for access to the
areas.
However, the inspector determined that the use of the CL-10
checklist was not described or procedurally controlled and approved.
The inspector stated that the use df the CL-10 checklist was a violation
of TS 6.4.B. requirements, in that, it was a procedure utilized by the
licensee for certain radiological protection measures that was' not
procedurally controlled or approved.
Licensee corrective action for the
violation included incorporating the "CL-10 Incore Sump Room Entry"
checklist into a higher tier litensee procedure, HP Procedure 1032.061.
This NRC identified viol~tion is not being cited because criteria
specified in Section VII.B of the Enforcement Policy were satisfied.
NCV 50-280, 281/94-26-02: Violation of Technical Specification 6.4.B
requirements for use of a procedure that was not controlled and
approved.
The safety significance of the violations was low due to the fact that
the Incore Sump Room did not have entries with dose rates in excess of 1
rem/hr.
However, the numerous examples of individuals failing to comply
with radiation protection procedures indicated the need to re-evaluate
the adequacy of existing access control procedures and/or staff
awareness of those procedures to ensure the procedures were controlled
and implemented.
-
During tours of the plant, the inspector noted that the licensee's
posting and control of radiation areas, HRAs, contamination areas, and
radioactive material areas were generally adequate. All HRAs were
locked as required.
No deviations were identified.
4.
Declared Pregnant Women and Embryo/Fetus Doses (TI 2515/123)
This program area was reviewed to determine that the licensee's program
for DPW met the regulatory requirements and that doses to the
embryo/fetus were within the regulatory limits.
The licensee's DPW policy was clearly described in VPAP-2101.
The
definition of a DPW was provided in Section 4.0, "Definitions" and the
licensee's dose limits for a DPW were specified in Section 6.3.2 which
11
agreed with the limits of 10 CFR 20.1208(a) and (d). The licensee's
procedures permitted workers three options including:
1.
Elect to declare pregnancy, become a DPW, and work within
the regulatory and administrative embryo/fetus dose limits;
2.
Elect not to declare pregnancy, not be a DPW, and work
within occupational dose limits; and
3.
Elect to withdraw DPW status, no longer be a DPW and return
to work within occupational dose limits.
VPAP-2101 clearly stated that the choice to declare or not to declare
pregnancy was strictly voluntary, a DPW may choose any of the options
- and could withdraw her declaration at any time.
HP-1031.020,
Administrative Dose Control, Rev. 0, dated December 7, 1993, reflected
the DPW program requirements of VPAP-2101.
Section 6.3.5, of VPAP-2101 described the licensee's administrative dose
control for DPW's.
The Exposure Control staff initially set the DPW
dose limit to zero to prevent a DPW from obtaining dosimetry and
entering the RCA prior to an embryo/fetus dose determination.
The
Exposure Control group performed WBCs and determined any internal dose
to embryo/fetus, determined external dose and with an estimated date of
conception estimated TEDE dose to the embryo/fetus.
Licensee procedure
HP-1041.024, "Embryo/Fetus Dose: Internal Dose Calculation" provided
instructions for calculating embryo/fetus dose due to internal
radionuclides in DPW at time of conception and due tri intakes of
radionuclides during pregnancy.
NRC Regulatory Guide 8.36, "Radiation
dose to the Embryo/Fetus provided the basis for the procedure.
If the
embryo/fetus dose exceeded 450 mrem the DPW was restricted from access
to the RCA.
If the TEDE dose to the embryo was less than 450 mrem the
licensee permitted a dose extension up to 450 mrem with efforts to limit
monthly embryo/fetus TEDE dose to 50 mrem/month.
Section 6.3.5 also
described measures to take when an individual withdrew voluntary DPW.
The inspector requested a list of individuals that had declared DPW and
attempted t6 review the individuals personnel exposure records,
maintained by the Records Department, to determine that "Voluntary
Declaration of Pregnancy" and embryo/fetus dose determination documents
were maintained as required by on 10 CFR 20.2106(e).
The inspector was
unable to find most of the required DPW documents in the individual's
exposure record files. The finding was reported to licensee management
and the licensee was able*to find the applicable documents the following
day.
Licensee representatives reported that the records had been sent
to Records Department but had not been filed in the exposure files when
they were requested by the inspector. The inspector reported a review
of the deposition of personnel dosimetry records would be made in a
future inspection as an IFI.
IFI 50-280,281/94-26-03:
Review licensee's procedures and program for
personnel exposure record maintenance.
12
During the inspection, the inspector interviewed several female
employees concerning the licensee's program for DPWs.
Through those
discussions the employees appeared to be knowledgeable of the licensee's
requirements in this area and reported the declaration was voluntary.
The inspector determined that, in general, the licensee had established
adequate policies and procedures for implementing the requirement of
10 CFR 20.1208, "Dose to an Embryo/Fetus."
The licensee DPW dose
assessments were appropriate and dose was within limits. The licensee's
- policy for DPWs, as demonstrated by its implementation, appeared to be
equitable and ALARA.
No violations or deviations were identified.
5.
TEDE ALARA and Respiratory Protection (TI 2515/123)
This area was reviewed to determine whether the licensee had established
an adequate training program, policy, and procedures to maintain worker
TEDE ALARA while performing work in airborne radioactive material areas.
10 CFR 20.llOl(b) required that the licensee use, to the extent
practicable, procedures and engineering controls based upon sound
radiation protection principles to achieve occupational doses and doses
to members of the public that are ALARA.
The inspector reviewed the following licensee procedures:
0
VPAP-2.102, "Station ALARA Program," Rev. 2, dated December 6,
1994;
0
HPAP-1042, "Respiratory Protection Program," Rev. 1, dated
December 12, 1994;
0
HP-1081.10, Radiation Work Permits: Preparing and Approving,
Rev .. 5, dated-January 21, 1994; and
0
HP-1042.210, "Respiratory Hazards Evaluation and Respiratory
protection Selection," Rev. O, dated December 6, 1993.
Section 6.4.7, "Respiratory Protection - Policy Regarding. Respirators,"
of VPAP-2101, incorporated the TEDE ALARA concept, to maintain TEDE
ALARA while working in airborne radioactivity areas, in the respiratory
protection program objectives. The licensee's respiratory protection
program policy stated actual and potential sources of airborne
radioactivity during routine operations should be identified and proper
engineering controls implemented.
The policy also stated that when
activities were conducted infrequently or were non-routine and the use
of engineering controls are impractical the use of respirators to avoid
excessive exposure to airborne radioactivity was appropriate, while
.
VPAP-2102, Station ALARA Program, required an ALARA TEDE Evaluation if
one or more of the following conditions wa~ met:
13
0
Individual estimated DDE for a RWP job while using respirator will
exceed 0.5 rem;.
0
Ratio of DDE dose rate, mrem/hr, to DAG fraction is greater than
50 and, without respirator use, individual DAG-Hour exposure would
exceed 10 DAG-Hours; or
0
Selected respirator PF is less than expected peak DAG fraction and
respirator is to be used to limit intake.
The licensee documented TEDE ALARA reviews using Attachment 21, ."TEDE*
ALARA Evaluation-720134 (Jan 94)." of VPAP-2102.
Through discussions with licensee representatives, the inspector
determined that the licensee had continued to reduced the use of
respirators in various activities. in recent years. Licensee
representatives reported that the reduction in use of respirators had
resulted in some personnel contaminations. A summary of the respirator
use, annual site dose, and PGEs are showed below.
The figures show.
increases in the number of personnel contaminations with the reductions
in respirator usage from 1993 through 1994; however, *there were no
significant doses resulting from the contaminations.
The licensee
reported that there were a total of 115 positive WBGs during the period
of January 1 through May 10, 1994. There were 3 individuals with a dose
in the range of 10-12 mrem, these were the most significant.
Approximately one third were less than 2 mrem.
The dose following 1992
also shows decline while the RTD removal projects were completed in 1992
anti 1993.
YEAR
91
92
93
94
NO. RESPs
9,234
10,461
2,276
368
ANNUAL
SITE.
DOSE (REMS)
509
538
387
293
PGEs
124
122
99
169 (Through *
September 2,
1994)
TEDE ALARA training is addressed in Paragraph 2 of.the report. The
inspector determined that the licensee had made efforts to maintain TEDE
exposures ALARA, while working in airborne .radioactive material areas.
No violations or deviations were identified.
6.
Planned Special Exposures (TI 2515/123)
This area was reviewed to determined whether the licensee's program for
PSEs met the regulatory requirements.
10 GFR 20.1206 permits the licensee to authorize an adult worker.to
receive doses in addition to and accounted for separately from the doses
received under the lim1ts specified in 10 GFR 20.1201 provided that
certain conditions are satisfied. Such exposures cannot exceed the dose
,.........----
~-
- -
--- -
- -- -
.-
7.
14
limits in 10 CFR 20.120l(a) in any year or five times the annual dose
limits during an individual's lifetime.
Section 6.3.13, "Dose Controls for Planned Special Exposures," of VPAP-
2101, described the licensee's policy and requirements for PSEs.
The
policy states:
"~SEs shall be authorized only in an exceptional situation, when
alternatives that might avoid the higher exposure are unavailable or
impractical.
Dose received in excess of annual limits, including doses
received during accidents, emergencies, and PSEs must be subtracted from
the limits for PSEs that the individual may receive during the current
year and during the individual's lifetime."
VPAP-2101 described the* administrative controls to initiate a PSE and
adequately addressed the requirements of 10 CFR 20.1206.
The procedure
required a PSE be documented and approved in writing prior to allowing
the exprisure to be received.
The _approval list included:
Worker~
Department Superintendent, Workers Employer Representative (if non-_
Virginia Power employee), Superintendent of Radiological Protection,
Station Manager or Assistant Station Manager, and the Vice President-
Nuclear Operations or the Assistant Vice President Nuclear Operations.
Through discussions with licensee representatives and a review of
records, the inspector determined that the licensee had appropriate
procedural guidance for allowing PSEs.
The inspector determined that
the licensee had not authorized any PSEs.
No violations or deviations were identified.
Exit Meeting (TI 2515/123)
The inspection scope and findings were summarized on September 2, 1994,
with those persons indicated in Paragraph 1.
The inspector described
the areas inspected and discussed in detail the inspection results. The
inspector reported that there appeared to be radiation protection
procedure violations concerning failure to follow procedures and use of
a checklist that was not procedurally controlled and approved.
Dissenting comments were not received from the licensee. The licensee
did not identify any documents or processes as being proprietary.
On
September 12, 1994, a teleconference was made ~ith the persons indicated
in paragraph 1 to discuss the inspectors findings following licensee'~
submittal of additional documentation associated with Incore Sump Room
entries in 1994.
At that time, the inspector reported the inspection
results listed below.
Another teleconference was requested by the
licensee and held September 27, 1994.
The licensee pointed out that
there were procedural controls for controlling movement of incore
detectors in the incore detector operating and maintenance procedures
and the licensee submitted copies of procedures indicating those_
controls.
However, that information was previously recognized by the
inspector and did not affect the findings shown below .
15
IYQg Item Number
Status
Description and Reference
50-280, 281/94-26-01
Open
Failure to follow procedures,
three examples. (Paragraph 3) .
50-280, 281/94-26-02
Closed
Failure to control and approve
procedure (Paragraph 3).
IFI
50-280, 281/94-26-03
Open
Review licensee processing and
document control of personnel *
dosimetry records
(Paragraph 4).
8.
Index of Abbreviations Used in this Report
CFR
HPT
HPTCTP
IFI
IR
mrad
mrem
NET
NRC
PF
PREMS
REV
SNSOC
TI
TS
VPAP
As Low As Reasonably Achievable
Code of Federal Regulations
Derived Air Concentration
Declared Pregnant Woman
High Efficiency Particulate Air-filter
Health Physics Technician
Health Physics Technician Continuing Training Program
Inspector Followup Item
Inspection Report
Milli-Radiation Absorbed Dose
Milli-Roentgen Equivalent Man
Nuclear Employee Training
Nuclear Regulatory Commission
Personal Contamination Event
Protection Factor
Personnel Radiation Exposure Management System
Planned Special Exposure
Radiation Control Area
Revision
Radioactive Material
Radiation Protection
Resistive Temperature Detector
Radiation Work Permit
Station Nuclear Safety and Operating Committee
Total Effective Dose Equivalent
Temporary Instruction
Thermoluminescent Dosimeter
Technical Specifications
Very High Radiation Area
Violation
Virginia Power Administrative Procedure
Whole Body Counting