ML18152A293
| ML18152A293 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/23/1989 |
| From: | Bassett C, Hosey C, Lauer M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A294 | List: |
| References | |
| 50-280-88-49, 50-281-88-49, IEIN-88-032, IEIN-88-062, IEIN-88-063, IEIN-88-32, IEIN-88-62, IEIN-88-63, NUDOCS 8902070024 | |
| Download: ML18152A293 (16) | |
See also: IR 05000280/1988049
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N,W;
ATLANTA, GEORGIA 30323
JAN 2 7 1989
Report Nos.:
50-280/88-49 and 50-281/88-49
. Licensee: Virginia Electric and Power Company
Glen Allen, VA
23060
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.: DPR-32 and DPR-37
In~pection Conducted:.* De~ember 12-16, 1988
- .Inspectors:.*. ~VV\\ ~*,..
.
C. Bassett
.
~ . * .
M.~
I /-i. 3 / f1
Date Signed
~~¥d
I t<:)Ji
Date Signed
SUMMARY
Scope:
This routine, unannounced inspection of the licensee's radiation
protection program consisted of a review in the areas of organization and
management controls; training and qualification; external and internal exposure
control; control of radioactive materials and contamination, surveys and
monitoring; and the program for maintaining radiation doses as low as
reasonably achievable (ALARA).
The inspection also included a review of
1 i censee actions concerning previous enforcement items, inspector fol fowup
items and information notices.
Results: rhe 1 icensee has made several changes in the health physics
organization and has initiated varfous actions ~irected at improving the
radiation protection program at the station. The adequacy and effectiveness of
these changes and actions have yet to be determined~
However, the current
radiation protection program appears to be adequately protecting the health and
safety of the public and licensee employees.
During the inspection, weaknesses
were again noted in the areas of procedural compliance and reliance on past
radiological history for specific work task without making an adequate
evaluation of current conditions.
Within the scope of the inspection, two violations were identified:
Failure to evaluate adequately the extent of the radiation hazards
present prior to and during decontamination work in the Unit 1
reactor cavity which resulted in failure of the licensee to provide
extremity dosimetry as required by procedure.
Failure to follow procedures for attaching temporary_ shielding to
piping.
1.
Perscns Contacted
License~ Empioyees
. REPORT DETAILS
- W. Cook, Supervisor, Operations, Health Physics
- D. Densmore, Assistant Supervisor, Dose Control and Bioassay, Health.
Physics
- D. Erickson, Superintendent, Health Physics
C. Foltz, ALARA Coordinator, Health Physics
A. Friedman, Superintendent, Nuclear Training
- B. Garber, Supervisor, Technical Services, Health Physics
- E. Grecheck,* Assistant Station Manager, Nuclear Safety and Licensing.*
M. Hotchkiss, Supervi-oi, Radiological Engineering, Healt~ Physics
- M. Kansler, St~tion Manager
- G. Miller, Licensirig Coordinator
L. Morris, Supervisor, Radwaste and Decontamination, Health Physics
- F. Wolking, Senior Staff Health Physiiist, Corporate
Other licensee employees contacted during this inspection* included
engineers, operators, technicians, and administrative personnel.
Nuclear Regulatory Cammi ssi.on
- W. Holland, .Senior Resid~nt Inspectdr
L. Ni~holson, Resident Inspector
- Attended exit interview
2.
Occupational Exposure, Shipping~ and Transportation (83750)
a.
Organization and Management Controls
The licensee is required by Technical Specification (TS) 6.1 to
implement the plant organization specified in T.S Figures 6.1-2. The
responsibilities, authority and other management controls are further
outlined in Chapters 12 and 13 of the Final Safety Analysis Report
(FSAR). TS 6.1 also specifies the composition of the Station Nuclear
Safety and Operating Committee (SNSOC) and outlines its function and
authority .. Regulatory Guide 8.8 specifies certai1_1 .functions and
responsibilities to be assigned to the Radiation Protection Manager
and radiation protection responsibilities to be assigned to line
management.
The inspector'reviewed the licensee's station organization, as well
as the responsibilities, authority and control given to management as
. they relate to the site radiation protection program.
Recent changes
in station organization were reviewed and it was verified that no
organizational changes had been made which would adversely affect the
2
ability of the licensee to implement the critical elements of the
program.
The new station health physics (HP). organization, as
discussed in NRC Inspection Report (IR) Nos. 50-280, 281/88-35, was
alsc reviewed and appe2red to be functioning adequately.
The inspector also discussed the plant organization changes with the
Station Manager and the Radiation Protection Manager to determine the
degree of support received from other members of management and the
responsibilities and authority of their positions. It appeared that
the support necessary to improve the radiation control program was in
place.
The inspector noted that management's support of the program
needed to be continually communicated to all station J)ersonnel in
order to ensure that all licensee and contract employeei are aware of
management's position on the subject.
No violations or deviations were identified.
b.
Staffing
TS 6.1 specifies the m1n1mum staffing for the plant.
FSAR Chapters
12 and 13 outline further*details on staffing as well.
The inspector reviewed the staffing level of the station HP
organization and discussed the current level with licensee
representatives.
At the time of the inspection, of the 58 authorized
positions (including shift supervisors, specialists, and
technicians), all but two were filled.
All the 38 authorized
technician positions at the station were filled with personnel who
were qualified to the requirements outlined by the American National
Standards Institute (ANSI) *standard NlS.1-1971.
Due to the outage in
progress, the licensee also had
acquired the help of 95 contractor
HP technicians and 95 personnel who were assisting in decontamination
efforts and operation of the onsite laundry facility.
No violations or deviations were identified.
c.
External Exposure Control and Personnel Dosimetry
10 CFR 20.202 requires each licensee to supply appropriate personnel
monitoring equipment to specific individuals and requires the use of
such equipment.
During plant tours, the inspector observed workers wearing
appropriate monitoring devices.
10 CFR 20.203 specifies posting and control requirements for
radiation areas, high radiation areas, airborne radioactivity areas,
radioactive material areas, and radioactive material.
Additional
requirements for control of high radiation areas are contained in
. . -.. ::-:-. .. ~*-:
3
During plant tours, the inspector observed the licensee's posting and
control of radiation, high radiation, airborne radioactivity,
radioactive material areas, and the labeling of ridi6act~ve material.
The inspec"':or determined that the posting and controls* for the
various radiological control areas were adequate.
The inspector also
verified that .various locked high radiation areas in the Unit 1 and
Unit 2 containment buildings and in the auxiliary building were being
maintained locked as required.
The licensee is required by 10 CFR 20.101 and 102 to maintain
workers' doses below specified levels.
The inspector reviewed
.selected occupational exposure hi~triries of contractor and licensee
personnel and v~rified that the licensee was requiring a ~ompleted
Form NRC-4 or its equivalent to be maintained on file in case the.
licensee needed to permit an individual to exceed the limits
specified in 10 CFR 20.lOl(a).
Through discussions with licensee
representatives and review of selected records, the inspector
determined that the radiation exposures for licensee and contractor
personnel were below the regulatory limits.
No violations or deviations were identified.
d .. Internal Exposure Control and Assessment
10 CFR 20.103(b) requires the licensee to use pr.ocess or other
~ngineeri~g controls to the extent practical, to limit concentrations
or radioactive material in air to levels below that specified in
10 CFR Part 20, Appendix B, Table 1, Column 1.
The use of process controls and engineering controls to limit
.airborne radioactivity in the plant was discussed with licensee
representatives.
Containment structures with portable ventilation
units equipped with high efficiency particulate air (HEPA) filters
were observed in use.
'
Licensee representatives stated that for this outage a glove box type
containment structure was utilized for Units 1 and 2 Reactor Cavity
Seal Ring overhauls.
This allowed workers to perform the work
without eicessive protective clothing or respirators.
The
disassembly and rebuild did not result in any personnel contamination
events.
Licensee representatives be 1 i eved that this improvenient
contributed to the significant decrease in exposure required to
complete the job.
Prior to this .outage, the most recent seal
overhaul had required 4.8 person-rem.
The current Unit 1 and Unit 2
seal overhaul required 1.8 and 0.64 person-rem, respectively.
HP Procedure HP-5.2B.50,
11Whole
Body
Counter
Operation
Chair/ND680,
11 dated October 14, 1987, requires that efficiency
calibrations be conducted every 12 months.
The inspector reviewed
efficiency calibration results completed September, 1988.
H-5.2B.50
also requires that energy calibrations, centroid and resolution
4
determination, and background checks be performed once ~er shift.
The inspector verified that those checks had been performed at the
required frequency.
- 10 CFR 20.103(c) requires that, when respiratory protection equipment
is used to limit the inhalation of airborne radioactive material, the
licensee train, medically qualify, and fit test the. individual user
of such equipment.
The inspector verified that selected individuals
issued respiratory equipment had been properly fit tested, trained,
and medically qualified.
Current quarter cumulative MPC-hour totals .
. for all individ~als at the plant were re~iewed by the inspector.
No
total. ~as _observed to exceed 10 CFR 20.103 limits.
No *violations or deviations were identified.
e.
Control of Radioactive Material and Contamination, Surveys, and
Monitoring
During plant tours, the inspector reviewed radiation level and
contamination survey results *posted outside various areas and
cubicles. *The inspector verified these radiation levels using NRC
instrumentation. * The inspector also reviewed selected records of
radiation and contamination surveys performed by the licensee during
the inspection and. discussed the survey results with licensee*
representatives.
10 CFR 20.20l(b) requires each licensee to make or cause to be made
such surveys as (1) may be necessary for the 1 i censee to comply with
the regulations in this part and *(2) are reasonable under the
circumstances to evaluate the extent of radiation hazards that may be
present. 10 CFR 20.20l(a) defines a.
11survey
11 as an evaluation of the
radiation hazards incident to the production, use, release, disposal,*
or presence of radioactive materials or other sources of radiation
under a specific set of conditions.
10 CFR 20.202 requires each licensee to supply appropriate personnel
monitoring equipment to specific individuals and requires the use of
such equipment.
TS 6~4.D requires that radiation control procedures be followed.
HP Procedure HP-3.1.3,
11 Personnel Dosimetry - Dosimetry Issue and
Dose Determination,
11 dated July 27, 1988, requires in step 4.7.3.2
that the licensee evaluate the need for extremity badges when the
expected exposure to the hands and forearms or feet and ankles is
equal to or greater than one rem per hour and the extremity to whole
- body dose (12 inches from the contact dose rate) ratio is 5:1 or
greater.
During tours of the Unit 1 containment, the inspector observed
personnel decontaminating the reactor cavity. The reactor cavity was
5
being controlled as a high radiation area, an ai*rborne radioactivity
a~ea, and a contaminated area as well as a Hot Parti~le Area.
The
latter required the use o~ addit~onal protective clothing (PCs) and
frequent (every twc hours) personnel monitoring.
It was noted that
the workers were using cloth rags to decontaminate (decon) * the
reactor cavity seal area and the surrounding areas, as well as other
areas in the vicinity of the reactor head.
The personnel performing
the work, and the HP technician in the cavity covering the work, were
wearing a full set of PCs plus a full plastic suit, rubber boots,
disposable boot covers, and full face respirators .. Those in the
cavity appeared *to be following good radiological control practices
for decon work and for maintaining exposures ALARA.
ijpon reviewing documentation of the decon activities, it was noted
that the radiation work permit (RWP) issued to cover the decon work
required continuous HP coverage and the use of the 1 i censee I s
teledose system but no special or extremity dosimetry. The teledose
system c-onsisted of integrating dosimeters with digital * readouts
which are issued to individuals in high dose rate areas or in areas
where the dose rates may vary widely.
The system allows the persons
wearing the dosimeters to monitor their own exposure and also
transmits a signal to a receiver which can be placed at a remote
location.
This enables another person to monitor the. dose being
received by those wearing the teledose dosimeters while remainfng in
a lower general ar~a dose rate area.
Through discussions with licensee personnel and records review, the
inspector learned that there had been problems with the Unit 1
reactor cavity *decon job.
During decon work in the reactor cavity
between approximately 2 and 4 a.m. on December 14, 1988, some of the
rags used in the decon effort accumulated enough contamination and/or
hot particles to cause contact dose rates in excess of one rem per
hour (rem/hr).
This was apparently noted by the personnel in the
cavity but was not known by the HP technician covering the work from
the handrail overlooking the cavity.
Toward the end of the job, the
HP technician observed the readout of the teledose system and noted
that the person gathering the rags and placing them in a bag was
receiving more exposure than others in the area.
At that point in
the job, the work was stopped and a radiation survey was taken on the
bags that had been gathered into one area.
The initial radiation
survey indicated that one of the bags had a radiation level reading
of 25 roentgens. per hour (R/hr).
When it was learned _that the
radiation levels were of that magnitude, the bags were moved tci a
locked high*radiation area for temporary storage by workers who had
. been issued extremity dosimetry.
The bags were subsequently surveyed again and two bags were found to
have a radi atfon level reading of 10 R/hr at contact and 3 R/hr
twelve inches from the bag.
The rags from each of the bags were ~lso
individually surveyed for radiation level readings at contact but no
6
.
.
surveys were taken 12 inches from the rags .. The contact results Were
as follows:
Nurrter of rags
1
3
14
17
Dcse rate (R/hr)
8.0
2.5.
1.5
1.0
The inspector reviewed radiation surveys performed during December 12
and 13., 1988, the two days preceding the decon efforts in the Unit 1
reactor cavity. * It was noted that the general area dose rates were
from 300 to 500 milliroentgen per hour (mR/hr) and from 1.5 to 5.0
R/hr near the reactor- vessel opening itself.
These were levels
.present before the reactor head was placed on the vessel.
The
general area dose rates dropped to levels from 75 to 100 mR/hr
following head replacement.
Through discussions with the licen~ee,
it was noted that, although the extremity to whole body dose ratio
was not determined through direct radiation measurement, the
possibility existed that the ratio was equal to or greater than 5 to
1.
Based on the fact that the decon workers were handling rags
reading to *8 R/hr in a' location with a general area dose rate from 75
to 100 mR/hr and based on the requirements of the dosimetry .
procedure, the *licensee acknowledged that extremity dosimetry should
have been required to be worn by those deconning the cavity. *
The inspec.tor also reviewed the contamination surveys that were
performed during December 12 and 13, 1988, in the reactor cavity.
The contamination levels on the cavity floor and on the "bathtub
ri ng
11
( approximately 3 feet down from the upper edge on the cavity
wall) were found to be from 2 to 60 million disintegrations per
minute per one hundred square centi~eters* (dpm/100cm2 ) prior to head.
replacement.
A survey taken at the approximate time of the decon
activities on December 14, 1988, showed contamination levels from
280 *thousand to 7. 5 mi 11 ion dpm/100cm 2 on the cavity floor near the
reactor vessel.
The reasons for the apparent elevated contamination levels in the
reactor cavity were discussed with licensee representatives.
The
licensee indicated that this had been the most extensive decon effort
performed in the cavity in several years.
The 1 kensee had used a
decon system that used a series of brushes and high pressure water
(WEPA system) to clean the cavity walls * . The contamination levels
had report~dly been reduced from 60 million to 14 thousand dpm/100 cm 2 *
However, the licensee did not believe that this had ca_used an
accumulation of contamination around the reactor cavity seal ring
because the water from deconning the walls had been mopped up or
directed into the transfer canal drainage system .
. Licensee representatives did indicate that strong backs, installed to
hold down the seal ~ing in the event of a postulated accident, had
7
been left in place *around the circumference of the seal ring. It ~as
felt th~t thes~ may have acted as-~nanticipated crud traps and that
elev~ted amounts of contamination may have deposited _there when the
cavity was drainec: follovling refueling.
The sttong backs* also
restricted* the use of mops which were normally used extensively to
decon the area around the reactor cavity seal ring.
This
necessitated a great deal of hand decontamination in that area, which
had not been anticipated.
Following the problems noted with the high contamination and the
subsequent high radiation lev~ls .on the bags of decon rags, the
licensee took several corrective actions.* The bags and rags, as
discussed previously, were surveyed after having been placed in a
Individuals who moved the bags and who
performed the . radiation surveys were required to wear extremity
dosimetry.
The RWP covering the decon activities in the Unit 1 .
. reactor cavity (RWP No. 88-3019) was subsequently revised to require
the use of extremity dosimetry by those performing hand
decontamination.
The licensee also required an HP technician to be
present in the work area on the reactor ~avity floor to provide
increased survei 11 a nee for decon rag and. bag monitoring.
The
licensee also indicated that future outage schedules* would be
modified to allow time for the removal of the strong backs from
around the reactor cavity sea 1 ring and a flush of the area with
water to reduce the contamination levels as much as possible.* A
station deviation was written concerning the event ana the
Radiological Engineering Section of the HP organization was assigned
to investigate the incident further.
The inspector reviewed the data that had been collected during the
fi na 1 survey of the. bags and decon rags from the Unit 1 reactor
cavity.
The person who had surveyed the rags * had handled each bag
and .rag individually and his extremity thermoluminescent dosimeter
(TLD) results were analyzed.
The TLD results indicated that the
exposure to the hands was only about fifty percent greater than that
of the whole body.
The licensee indicated th.at the extremity
dosimetry results of all the decon personnel would be evaluated to
determine if they were receiving excessive exposure to their
extremities.*
Also, licensee representatives had assigned an
extremity dose of 898 millirem to each of the deconners who had been
working under.RWP-88-301~ during the time period that the event had
occurred.
This millirem total was based on the
11worst case
11
assumption that each individual had handled each rag for one minute.
The inspector discussed the initial evaluation of the radiological
conditions of the reactor cavity area prior to decon and the use of
dosimetry for this job with the l_icensee.
Licensee representatives
indicated that the elevated contamination levels in the reactor
cavity and the high radiation level readings on decon rags were not
typical and had not been encountered in the past.
The use of the
WEPA decon system, the presence of the strongbacks around the cavity
8
seal ring and the contamination levels were not assu~ed to present
hazards different from those encountered'in the past.
Therefore,
based on past experience, extremity dosimetry had not been con*sidered
necessary prior tc initiating for the decon *work.
The licensee
acknowledged the fact that failure to issue extremity dosimetry to
the decon personnel was a problem.
They indicated, however, that the
finding should be considered as licensee identifed by the NRC.
The
finding was not viewed as licensee identified because the root cause
of the problem was determined to be failure to evaluate adequa.tely
the radiation hazards present in the Unit 1 reactor cavity which then
led to the licensee
1s failure to provide the appropriate* dosimetry,
and the expectation that the 1 icensee
I s response to previous .
violatio,ns (NRC Reports 50-280, 281/88-10 and 50-280, 281/88-25)
should have prevented this violation.
The criterion for licnesee.
identified in the NRC Enforcement Policy (10 CFR 2) that the
violation could reasonable be expected to have been prevented by the
licerisee
1s corrective action for a previous violation was not met.
Failure of the licensee to evaluate adequately the radiation hazards
present prior and incident to decontaminating the Unit 1 reactor
cavity with elevated contamination levels and conditions whfch had
changed from those encountered historically and which resulted in the
failure to provide extremity dosimetry was identified as an apparent
viol~tion of 10 CFR 20.20l(b) (50~280, 281/88-49-01).
During tours of the fac*ility, the inspector observed the exit of
workers and the movement of material from cont~mination control to
clean areas to determine if proper frisking was performed by the
workers and if proper direct and removable contamination surveys were
performed on materials.
The inspector determined that frisking and
material release surveys were adequate.
Duri rig p 1 ant tours, the inspector observed the use of survey
instruments by station and contractor personnel.
The inspector
examined the calibration stickers on radiation protection instruments
in use by various personnel and at various areas throughout the
plant. All instruments examined were within the dates of calibration
as indicated on the calibration stickers. There appeared to be an
adequate supply of instruments which were being maintained properly.
The inspector not~d that, during the decon w~rk in the Unit 1 reactor
cavity, the contract deconners had been issued radiation survey
instruments for entrance into a high radiation area as required by
TS 6.4.B.1.e. During the period when the bags of highly contaminated
waste were generated, one of these survey instruments had failed to
operate properly.
Through discussions with the licensee it was
determined that the deconners were *issued the same type of
instruments issued to anyone or any group entering a high radiation
area.
When questioned about the adequacy of such instruments, the
licensee indicated that this practice was adequate because the
instruments were only to .be used to give an indication of the general
9
dose rates.
Should a ,question have arisen concerning unusual
radiation levels, -either general area or on contact with an-item (a
bag filled with decon rags in this instarite), then the workers should
have notified trP. HP covering the job for further support and a *
better radiation reading.
f.
Maintainin~ Occupational Exposures As Low As Reasonably Achievable
(ALARA)
10 CFR 20.l(c) specifies that licensees should implement programs to
maintain workers' doses ALARA.
Other recommended elements of an*
ALARA program are contained- in Regulatory Guides 8.8-and 8.10.
.
.
The inspector reviewed the* licensee* s program for maintaining
occupational exposures ALARA including changes in the ALARA policy
and procedures, _ALARA considerations for the maintenance and
refueling outage, and establishment of goals and objectives and
effectiveness in meeting those goals.
The inspector reviewed the ALARA packag~s for Unit 2 recirculation
spray heat exchanger replacement.
A total of four heat exchangers
were replaced.
The Unit 1 replacement in early 1988, which also
included a 11 four heat exchangers, required 83 person-rem to
complete.
The* Uriit 2 replacement was projected to require
approximately 46 person-rem.
At the time of the inspection, the
project was 95% complete with 49 person,.;rem expended. * ALARA*
personner stated that lessons learned from Unit 1 significantly
decreased the dose received.
The ALARA package for Unit 2 refuei'ing water storage: tank (RWST)
c;lesludging was also reviewed by the inspector. This job was recently
completed expending 3.23 person-rem.
Unit 1 RWST desludging was in
progress.
The ALARA packages reviewed appeared thorough and
contained sufficient information required to maintain an adequate
history file for those specific jobs.
The inspector observed the morning outage status meetings attended by
upper level management during the week of the inspection.
Current
cumulative plant exposure and its relation to the goal were disGussed
at all meetings attended.
TS 6.4.D requires that radiation control procedures be followed.
HP Procedure HP-5.4.50, Temporary Shielding, dated April 28, 1988,
contains guidance on temporary shielding and provides, i_n attachments
to the procedure, forms to be utilized to give detailed instructions
on shielding placement and attachment.
A copy of Attachment 3 of
HP Procedure HP-5.4.50,
contained
in
Temporary
Shielding
Request 88-55 and completed specifically for shielding the reactor
cavity drain line on the -27 foot elevation of the Unit 1
containment, requires ;~_step 3 that shielding used shall be attached
.
.
10 .
with ties, stainless steel wire, or red tape.
Step 3 also requires
that, if tape is used, it Will not be placed directly on the pipe.
During tours of the Unit 1 containment on December 14, 1988~ the
inspector observed various locations where temporary shielding had
been installed to lower the contact and general area dose rates. The
temporary shielding that had been placed on the reactor cavity drain
line on the -27 foot elevation was noted to have been laid over the
pipe but was not fastened or attached in any manner.
The reactor
cavity drain line, which was approximately two inches in diameter and
approximately four inches ~bove the floor, had hot spots ranging from
.three to twenty R/hr and the shielding had be!=!n placed over those
spots.
The inspector noted that the shielding could be moved easily
and, if moved, would expose the hot-spots and raise the general area
dose rates.
the inspector *notified licensee representativ~s of the sttuation and
reviewed the temporaryshieiding package.
The licensee indicated-
that the shielding should be attached to the pipe in som~ manner, as
prescribed, even though the pipe was close to the floor.
During a
tour of the Unit 1 containment of December 15, 1988, the inspector
noted that the shielding had been attached to the pipe*with red tape
but it was also noted that the tape had be~n placed directly on the
pipe.
A~ain the licensee was notified of the shielding* situation.
The licensee then removed the tape from the pipe and attached the
temporary shielding as required by the procedure.
Failu.re to comply with the requirements of the temporary shielding
procedure was identified as an ap*parent violation of TS 6.4.D
(50-280, 281/88-49-02).
g.
Facility Statistics
In 1987, the station
1s cumulative personnel dose was 356 person-rem
per reactor as compared to the Pressurized Water Reactor (PWR)
national average of 369 person-rem/reactor.
As of December 13, 1988,
the cumulative outage dose was approximately 610 person-rem as
compared to the goal of 566. * The station
1s yearly total as of
- December 13, 1988, including both outage and non-outage exposure, was
approximately 728 person-rem/reactor while the annual goal had been
set at 734 person-rem/reactor.
As of December 1, 1988, the .1 i censee had experienced a total of
211 skin and 267 clothing contaminations compared to. a total of
174 skin _and 319 clothing contaminations for 1987.
This is a
downward trend in personnel contaminations when the number of outage
days for the two years are considered.
In 1987, the licensee hid a
total of 115 scheduled and unplanned outage days.
There had been
202 scheduled and-unplanned outage days in 1988, as of December 14,
1988.
11
Licensee representatives indicated that approximately 24,000 cubic
feet (ft3) of solid radioactive waste- had been shipped to waste
collectors or burial sites through December 1, 1988 containing
189 ci..:ries of activity.
During 1987, thE: licensee had shipped
approximately 24,000 ft 3
of solid waste containing about
29,000 curies of activity.
The high curie total for 1987 was
attributed to shipping process resins and activated material which
came from cleaning up the spent fuel pool.
At the _end of 1987, the licensee maintained approximately
22,400 square.feet (ft 2 ) within the Radiation Control Area (RCA),
excluding the containment buildings, as contaminated~
This
represented about 24 percent{%) of the total 92,000 ft 2 within the
RCA.
As of December 1, 1988, approximately 21,350 ft 2 were being
controlled as contaminated area or about 23% of the RCA.
No violations or deviations were identified.
I'
3.
Act1on of Previous Inspection Findings (92701)
a.
(Closed) Inspector Followup Item (IFI) 50-280/87-FRP-10, Followup on *
Licensee's Program for Removing/Defacing Radiation Markings on
Clean/Used Equipment Released for Unrestricted Use.
The inspector discussed this issue with licensee representatives and
reviewed current practices.
Licensee representatives stated that it
is the station's policy not to allow containers with radiation
markings to leave the controlled area.
Clean containers,
specifically 55 gallon drums, which had marki~gs and were released
from the controlled area in the past were crushed thereby destroying
the markings. -
b.
(Closed) IFI 50-280, 281/88-03-01, ALARA Exposure Goals are Based on
Exposure Incurred Per Day Rather than Exposure Associated With the
Specific Task to be Performed.
The inspector reviewed the licensee's response dated September 16,
1988, which stated that department daily exposure goals would not be
substituted for task specific goals.
The inspector also reviewed a
memorandum, dated October 31, 1988, to all supervisors from the
assistant station manager dictating that exposure goals be focused on
task specific exposure instead of exposure per unit time, i.e.
person-rem/day.
Discussions with station ALARA personnel verified
th~t current practice was in agreement with this memo.
c.
(Closed) IFI 50-280, 281/88-03-02, Dose Projections for Some Work
Covered by Radiation Work Permit Are Being Exceeded Without
Management Review of Concurrence.
The inspector reviewed a Station Commitment Assignment/Response forn,
documenting an enhancement system planned for implementation by
- ,
12
March 31~ 1989.
The inspector discussed these software enhancements
with licnesee personnel who stated that an automatic block preventing
RWP sign-in will be activated when 125% of the estim~ted collective
exrcsure for the job is observed for RWPs estimated to require
greater than 500 person-mrem to complete.
For jobs estimated to
require less than 500 person-mrem to complete, a block will be
activated when the RWP exceeds 500 preson-mrem collective dose.
To
deactivate the block, an RWP ree~aluation meeting must be held.
d.
(Closed) IFI 50-280, 281/88-03-03.
There i*s Little or No Management_
Involvement in the Decision Process for Entries Into the_ Containment
. Builidng When the Plant is at Power.
.
.
The licensee
1 s response, referenced above, specified certain
procedure revisions to correct this finding.* The inspector reviewed
Administrative Procedure 38,
11Guidelines, Procedures and Limitations
for Containment* Entry,
11 dated September 16, 1988.
This procedure
stated *that permission to enter subatmospheric containment may be
given only by the SNSOC.
Licensee representatives stated that other
procedures require that only the Station Manager or Assistant Station
Manag~r may be chairman of the SNOSC.
e.
(Closed) IFI 50-280, 281/88-03-04, The licensee*s ALARA Action Plan
Does
Not
Include Formal
Milestones for Implementing the
Recommendations.
The licensee
1s _ response, referenced above, stated that the ALARA
Action Plan was. reviewed with milestones formalized and confirmed by
the Corporate ALARA Coordinating Committee (ACC). The inspector
reviewed
an
ACC
Recommendations
Follow-up document dated
September 28, 1988, and verified that it contained milestones and.
implementation dates.
f.
(Closed) IFI 50-280, 281/88-03-05, The Licensee
1 s ALARA Program
- Procedures Have Not Been Revised to Conform to the Corporate
Radiation Protection Plan.
- *
Licensee _representatives stated that re~ised procedures which
conformed with the corporate radiation protection plan were completed
and -implemented on April 28, 1988.
g.
(Closed) IFI 50-280, 281/88-FRP-18:
Consultant Review of Station
Activities Planning and Management.
A consultant had performed a review of the activities planning and
management at the station.
The consultant review indicated several
areas where improvement was needed.
The inspector reviewed the
licensee
1s action plan that had been established to address the
various areas needing improvement.
The proposed actions included
.development of a program for self-identification of problems, a
review of supervisory/management responsibilities during outages, a
".
13
review of the outage planning process,- and development *of a source
term radiation plan including long term decontamination efforts. The
- proposals appeared to be adequate.
Because action plan contained numerous new scheduled completion dates
for the improvements proposed. an IFI will be established to follow
the development and implem~ntation of these improvements (50-280 1
281/88-49-03).
4.
Followup on Information Notices {92717)
The inspector determined tha~ the following Information Notices (IN) had
been received by the licensee, reviewed for applicability,* distributed to
- appropriate personnel, and that action, as required/appropriate, was taken
- -t~~lc'
- or scheduled.
IN 88-32: Prompt Reporting to NRC of Significant Inciijents Involving
Radioactive Material
. IN 88-62: Recent Findings Concerning Implementation of Quality
Assurance Programs by Suppliers of Transport Packages
IN 88-63: High Radiation Hazards From Irradiated Incore Detect~rs and
Cables
5.
Exit Interview
The inspection scope and findings were summarized on December 16, 1988,
with those persons indicated in Paragraph 1. * The inspector described the
areas inspected and discussed in detail the inspection findings listed
below:
The concern about relying too heavily on historical data and past
experience without making an adequate evaluation of the current situation
and conditions was reviewed with the licensee.
The licensee indicated
that the finding concerning the failure to provide extremity dosimetry to
the decon personnel should be considered as licensee identified.
The
licensee did not identify as proprietary any of the material provided to
or reviewed by the inspector during the inspection.
Item Number
50-280, 281/88-49-01
50-280, 281/88-49-02
Description and Reference
Violation - Failure to adequately evaluate the
extent of radiation hazards present prior to and
during decon operations in Unit 1 reactor cavity
(Paragraph 2.e.{2)).
Violation - Failure to follow procedure for
securing temporary shielding to piping
(Paragraph 2.f.(4)).
..
50-280, 281/88-49-03
- .~ ...
14
IF! - Followup on the licensee's actions to
improve the activities planning and management at
the station {Paragraph 3.h).
Licensee management was informed that the items discussed in Paragraph 3
were considered closed.