ML18152A299
| ML18152A299 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/10/1989 |
| From: | Bassett C, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A300 | List: |
| References | |
| 50-280-89-14, 50-281-89-14, NUDOCS 8905250132 | |
| Download: ML18152A299 (15) | |
See also: IR 05000280/1989014
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
MAY 1 0 1989
Report Nos.:* 50-280/89-14 and 50-281/811-14
Licensee:
Virginia Electric and Power Company
Glen Allen, VA
23060
Docket Nos.:
50-280 and 50-281
License Nos.: DPR-32 and DPR-37
Facility Name:
Surry 1 and 2
Inspection Conducted:
April 17-21, 1989
t
v
Inspectqr:
PJ~-~ r> ~-ry'
k-*1* C. H. Ba ett ,;
Approved by:
--i.f.>. 6j
.L,r\\J * P ;
o t, er, hi f
Facilities Radiat on Protection Section
Emergency Preparedness and Radiological Protection
Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope
I ~ {-'\\
i ~ ?i1
oabt Signed
IOMn-l~~n *
Data1 Signed
This routine, unannounced inspection of the licensee's radiation protection
program consisted of a review of items associated with the Performance
Improvement Program (PIP) and followup on various previous enforcement items
concerning: organization and management controls; training and qualifications;
external and internal exposure control; and control of radioactive material and
contamination, surveys, and monitoring.
The inspection also included a review
of an unresolved item (URI).
Results
Management and general employee support of the radiation protection program
appears to be good.
The licensee appears to have established an adequate
program for identifying problems noted in the radiation protection and safety
areas.
The licensee's radiation protection program appears to be functioning
as* necessary to protect the health and safety of the occupational radiation
~orkers.
During the inspection, a possible weakness was noted in the audit
program due to an apparent lack of a master schedule or matrix to ensure that
all areas of the radiation protection program are audited on a periodic
recurring basis.
The licensee has completed various plans and reports, each
containing recommendations or suggestions on ways to improve the radiation
protection program.
The NRC will follow the licensee's actions regarding these
- recommendations as an inspector followup item (IFI).
No weaknesses were noted
8905250132 890510
ADOCK 05000280
Q
in the area of regulatory compliance or in the area of compliance with the
Technical Specification requirements.
-
However, within the areas inspected, the following licensee identified
violations (LIVs) were identified:
Failure to maintain the entrance to a high radiation area locked to
prevent unauthorized entry.
Failure to follow procedures by not following and enforcing the
requirements of a Radiation Work Permit.
Failure to label an incore detector, control the item, or have
procedures to establish accountability for the detector .
REPORT DETAILS
1.
Persons Contacted
- Licensee Employees
.*W. Benthall, Supervisor, Licensing
R. Chase, Shift Supervisor, Health Physics
- W. Cook, Supervisor, Operations, Health Physics
- D. Erickson, Superintendent, Health Physics
- B. Garber, Supervisor, Technical Services, Health Physics
E. Grecheck, Assistant Station Manager, Nuclear Safety and Licensing
D. Hart, Supervisor, Quality Assurance
- M. Kansler, Station Manager
- G. Miller, Licensing Coordinator
L. Morris, Supervisor, Radwaste and Decontamination, Health Physics
A. Royal, Supervisor, Nµclear Training
- F. Thomasson, Supervisor, Corporate Health Physics
- F. Walking, Senior Staff Health Physicist, Corporate
Westinghouse Employee
G. Smith, Acting Supervi~or, Radiologi6al Engineering, Health Physics
Other licensee employees contacted during this inspection included
engineers, security force personnel, technicians, and administrative
personnel.
Nuclear Regul ato_ry C.ommi ssi on
- W. Holland, Senior Resident Inspector
L. Nicholson, Resident Inpsector
J. York, Resident Inspector
- Attended exit interview
2.
Organization and Management Controls - Occupational Exposure, Shipping, *
and Transportation (83750).
a.
Organization
The licensee is required by Technical Specification (TS) 6.1 to
implement the plant organization spetified in TS Figures 6.1-2. The
respons.i bi l iti es, authority, and other management controls are
fu~ther outlined in Chapters 12 and 13 of the Final Safety Analysis
Report (FSAR). Technical Specification 6.1 also specifies the members
of the Station Nuclear Safety and Operating Committee (SNSOC) and
outlines its function and authority.
Regulatory Guide 8.8 specifies
certain functions and responsibilities to be assigned to the
Radiation Protection Manager
(RPM)
and radiation protection
responsibilities to be assigned to line management.
2
The inspector reviewed the plant organization with the RPM and members
of the Health Physics (HP) staff to determine the degree of support
received from members of management and from workers in other than HP
organizations as well.
It appeared that the support necessary to
improve the radiation control program and implement the critical
. elements of the program was in place.
The new station HP organization, as discussed in NRC Inspection
Report (IR) Nos. 50-280, 281/88-35 and further discussed in IR
Nos. 50-280, 281/89-02, appeared to be functioning adequately.
In an
effort to further improve the functioning of the HP Radiological
Engineering section, the licensee had transferred one person from the
HP staff, one per*son from the corporate HP staff, and one person from
the ALARA g~oup to the section. The section was being supervised by
a contractor and another contractor was also helping in the capacity
of an engineer.
The section's responsibilities were expanded to
include support for the radioactive waste program (trash monitoring
and segregation), support for the ALARA program, response to a 11
HP-related station Deviation Reports (DRs) and other licensing
commitments, and support for the HP technical and operations sections
so that these groups could focus more fully on their jobs.
b.
Staffing
c.
TS 6.1 also specifies the minimum staffing for the plant.
Chapters 12 and 13 outline further details on staffing as well.
The inspector reviewed the staffing level of the various sections
within the HP organization and discussed the current level with
licensee representatives.
At the time of the inspection, of the 38
authorized HP positions (including shift supervisors, specialists and
technicians), all but two specialist positions were filled. All the
18.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 Nl8. l-1971.
Due to the outage in progress, the licensee had augumented the number
of authorized ANSI technicians by 17 and also was utilizing 15 junior
technicians. The licensee had also acquired the help of 66 contractor
HP .technicians and other personnel who were assisting in
decontamination efforts and onsite laundry facility operation.
Management Controls
The inspector reviewed the licensee I s Radiation Problem Reports
(RPRs) which were written by HP personnel and used to identify and
document safety and radiological problems noted in the plant. It was
noted that nearly 60 RPRs had been written for 1989 to date. Most of
the problems outlined dealt with failure of personnel to comply with
various procedure or radiation work permit (RWP) requirements.
The
i ns*pector verified that adequate corrective acti ans had been
initiated as a result of the findings.
The inspector also reviewed
3
selected DRs written fo~ 1989.
These DRs are further outlined in
Paragraphs 3, 4, and 5.
No violations or deviations were identified.
3.
External Exposure Control and Personnel Dosimetry_- Occupational Exposure,
Shipping and Transportation (83750)
a.
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 tours of the radiati-on control area (RCA), the inspector
observed -personnel wearing the appropriate monitoring devices as
required.
b.
Control of High Radiation Areas
10 CFR 20.203 specifies posting and control requirements for
radiation areas, high radiation areas, airborne radioactive areas,
radioactive material areas, and radioactive material.
TS 6.4.B.1.b requires that the entrance to each radiation area in
which the* intensity of radiation is equal to or greater than
1,000 millirem per hour* (mrem/hr) shall be provided with locked
barricades to prevent unauthorized entry into these areas.
During plant tours, the inspector observed the licensee's posting and
control of radiation, high radiation, airborne radioactivity, and
radioactive material areas.
The *inspector determined that the
posting and controls.for the various RCAs were adequate.
The inspector reviewed station DR, Number Sl-89-229, concerning a
high radiation area that was not controlled as required.
On
January 30, 1989, during* a walkdown of the Fuer Building, an HP
technician was checking the integrity of the high radiation gate on
the 27-foot elevation~
As the technician pulled sharply on the lock
and chain securing the gate, one of the links of the chain failed and
the gate was thus found to be accessible. Another HP technician was
summoned and the gate guarded until a new chain could.be found to
replace the broken one.
The gate was then properly locked.
The licensee's investigation of the event revealed that the area was
being maintained locked due to the presence and operation of ion
exchange (IX) vessels in the basement of the Fuel Building;
On
January 30, 1989, two of the four IX vessels-had readings (at a
distance of 12 inches from the vessels) of 5 - 6 rem per hour.
Two
people had checked out the key to the area and had apparently locked
4
the gate with the padlock and chain without checking the integrity of
.the chain.
As corrective actions, the licensee performed a walkdown of all high
radiation gates secured with a chain and padlock to ensure that no
other chains with weal< links were in use.
The HP Operations
Supervisor also addressed this issue in the HP Operations Shift Order
Book (which is required to be read by all HP operations personnel).
The Operations personnel, who had orginally checked out the key to
the area, were reprimanded by their supervisor.
Installation of a
.new gate was not considered as a corrective action by the .licensee
since the gate involved in this incident is only.maintained locked as
the need arises.
The long-term corrective. actions contemplated by
the licensee for securing other high radiation areas (as mentioned in
IR Nos 50-280, 281/89-02) would not solve the problem. That solution
involved submitting work requests to replace all the old gates with
new gates having butlt-in locking mechanisms.
Failure of the licensee to comply with the requirements to maintain
the entrances to high radiation areas locked to prevent unauthorized
entry was identified as an apparent violation of TS 6.4.B.
However,
pursuant to 10 CFR 2, Appendix C.V.G~ this issue was considered to be
a licensee identified violation (LIV) and a Notice of Violation (NOV)
was not issued due to the violation being (1) licensee identified,
(2) of severity level IV or V, (3) not reportable, (4) corrected, and
(5) not expected to have been preventable by corrective action for a
previous violation (50-280, 281/89-14-01).
4.
Internal Exposure Control and Assessment - Occupational Exposure,
Shipping, and Transportation (83750)
a.
Engineering Controls
10 CFR 20.103(b) requires. the licensee to use process* or other
engineering controls, to the extent practical, to limit concentrations
of radioactive material in air to levels below those specified in
10 CFR Part 20, Appendix B, Table 1, Column 1.
During tours of the ~CA, the inspector observed the use of process
control and engineering controls to limit airborne radioactive
concentrations in the plant. The inspector also discuss~d the use of
engineering controls .with members of the Radiological Engineering
sectio~.-
It was noted that the Radiological Engineering section was
placing emphasis on the use of process and/or engineering controls
instead of respirators whenever a work package was submitted for
review which required the use of respiratory protection.
.. ~
..
.
5
b.
Respiratory Protection
TS 6.4.D r~quires that radiation control procedures be followed.
Health Physics Procedure HP-5.3.20, "Initiating~ Using, Extending,
and Terminating an RWP,
11 dated August 15, 1988, requires in
step 4.3.2.a that radiation workers comply with the requirements,
instructions, and precautions of the RWP and any ALARA requirements
specified.
The inspector reviewed a station DR, Number Sl-89-0251, regarding
ingestion of radioactive material.
On January 10, 1989, two contract
- mechanics.were leaving the RCA through the Personnel Decontamination
Area (PDA) usintj the whole body personnel monttors (PCM-lAs).
When
the monitors alarmed, the individuals were surveyed with a frisker
and count rates of approximately 100 counts per minute {cpm) were
detected.
The individuals were decontaminated using cleansing cream
and a rag and the count rate decreased to below 100 cpm, although
some activity was still detectable by the.personnel monitor and when
using a frisker.
Later that same day, the individuals again alarmed
the PCM-lAs and an attempt was again made to decontaminate them.
The
HP shift supervisor became aware of ~he situation and the individuals
were requested to get whole body counts {WBCs).
The WBCs revealed
that the mechanics had ingested radioactive material.
The licensee's investigation into the incident showed that, the day
before, on January 9, 1989, the two contract mechanics had entered
the
118
11 loop room in the Unit 1 containment to work on a valve.
The
RWP used required that they use respitators fo~ the work but the
contract HP technician covering the job informed them that they did
,not need respiratory protection.
During the subsequent repair work,
the individuals apparently ingested small* amounts of Cobalt-60
(Co-60).
One worker ingested approximately 0.186 microcuries {uCi)
of activity while the other ingested approximately 0.076 uCi of
activity.
The contract HP technician later indicated that he thought
that the RWP stated that the use of respirators was not specifically
required but could be used
11as per HP direction.
11
He had covered
similar work on other valves during the outage, had taken air samples
during the work, and had never found any airborne radioactivity on
any of the samples.
He therefore felt that respirators would not be
necessary due to past experience.
The 1 icensee took several measures to correct this problem.
The
contract HP technician's employment at the station was terminated as
disciplinary action.
The HP operations staff was informed of the
incident and notified that failure to follow RWP requirements would
result in strict diciplinary action. A revision to the HP procedure
governing actions to be taken at the PDA following alarm of the
PCM-lAs subsequent to decontamination efforts was al so initiated.
The change required the technician covering the PDA exit to notify
the HP shift supervisor in instances when an individual continues to
6
alarm the PCM-lA following decontamination attempts. If the activity
is less than 100 cpm using a frisker but the PCM-lA still shows a
positive indication, the HP shift. supervisor must then give
authorization to release the individual from the PDA.
The inspectof reviewed the licensee's data and calculations of the
Maximum Permissible Concentration-hours (MPC-hrs) for each mechanic.
One worker was assigned
22.7
MPC-hrs exposure and the other was
assigned 6.44 MPC-hrs.
These calculated exposures appeared to be
adequate based on the WBC results and the time factor involved (the
WBCs were taken 26.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> following the time of the probable
ingestion).
Failure to follow and enforce the requirements of the RWP was
identified as an apparent violation of TS 6.4.D.
However, pursuant
to 10 CFR 2, Appendix C.V.G, this issue was considered as an LIV and
no NOV was issued (50-280, 281/89-14-02).
5.
Control of Radioactive Material and Contamination, Surveys, and
Monitoring~ Occupational Exposure, Shipping, and Transportation (83750)
a.
- Pl ant Surveys
10 tFR 20~201(b) requires each licensee to make or cause to be made
such surveys as (1) may be necessary for the licensee to comply with
the regulations in this part and (2) are reasonable under the
circumstances to evaluate the extent of radiation hazards that may be
present.
The licensee is required by 10 CFR 20.401 and 20.403 to maintain
records of such surveys necessary to show compliance with .regulatory
limits.
Survey methods and instrumentation are outlined in
Chapter 12 of the FSAR.
During plant tours, the inspector reviewed radiation level and
. contamination survey results posted outside various area and
cubicles.
The inspector* verified these radiation levels using NRC
instrumentation.
The inspector also reviewed selected records of
- radiation and contamination surveys performed during the inspection.
b:
Personnel and Material Release Surveys
During tours of the facility, the inspector observed the exit of
workers and the movement of material from contamination 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.
7
c.
Instrumentation
During plant 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 cal i bra ti on stickers.-
There appeared to be an
adequate supply of instruments which were being maintained properly.
d.
Control of Special Nuclear Material
10 CFR. 20.203(f)(l) requires that each container of licensed material
shall bear a durable, clearly visible label identifying the
radioactive contents.
10 CFR 20.207 requires that licensed materials stored in an
unrestricted area shall be secured ~ram unauthorized removal from the
place of storage.*
10 CFR 70.51(c) requires that the licensee establish, maintain, and
follow written material control and accounting procedures which are
sufficient to enable the licensee to account for the special nuclear
material (SNM) in his possession under license.
The inspector reviewed a station DR, Number Sl-80-570, which outlined
the discovery of an incore detector assembly in the licensee's
training center.
On March 6, 1989, an operator receiving training at
- the*station training center noted the incore detector assembly in the
training area.
The detector was not labeled, locked in a storage
area, and no procedure could be located that specified the control
and accountability required for such material.
Following an investigation of the event, the licensee determined that
the incore detector assembly had been checked out from the warehouse
following an incident involving an incore detector in March of 1988.
The detector assembly had been used in a mockup of a Unit 2 detector
drive unit.
This mockup was used during. the investigation that
followed the incore detector incident.
It has been used since as a
training aid during General Employee Training {GET) and other classes
which discussed the previous incident and ways to avoid such
problems.
As corrective actions, the licensee had the fission detector portion
of the detector assembly cut off.
The detector was then replaced
with an imitation which had been fabricated to look-like the actual
item.
The fissiori detector, al-0ng ~ith other detector assemblies
which had been located in the warehouse, was moved to an area that
was locked with a padlock and key controlled by HP.
A procedure was
developed to provide control and accountability for the detectors and
other SNM as well.
The procedure, SUADM-0-28, "Physical Inventory of
8
Special Nuclear Material (SNM) Detectors and Other SNM Sources,
11
appeared to be adequate.
Failure of the licensee to label the incore detector assembly,
control it as required, or have procedures to establish
accountability for the detector was identified as an apparent
violation of 10 CFR 20.203(f)(l), 20.207, and 70.51(c).
However,
pursuant to 10 CFR 2, Appendix C.V.G, this issue was considered ~n
LIV and no NOV was issued (50-280, 281-89-14-03).
6.
Audits - Occupational Exposure, Shipping, and Transporatioi (83750)
The inspector discussed the audit and surveillance efforts related .to the
~adiation protection program with licensee representatives. The inspector
reviewed the following audits:
- Process Control Program/ODCM, S87-J7, conducted in June and July 1987.
- Nuclear Training ADM 02-04-10, S88-02, conducted October 17 - 28, 1988.
- Health Physics and Radiological Environmental Monitoring, S88-19,
conducted April 18 - May 9, 1988.
-* Process Control Program, S89-11, conducted January 16 - 20, 1989.
- Radiation Protection Program, S89-19, conducted April 10 - 28, 1989
(in progress at the time of the inspection).
The scope, depth, findings, and evaluatio~ of th~ corrective ictions taken
in respon~e to the findings were reviewed and appeared adequate.
Through discussions with licensee representatives and review of the
audits, the inspector noted that the station
1s auditing methodology had
changed.
Prior to 1988, the licensee, as a company, had performed audits
at each reactor site and at the corporate -Offices on different schedules.
Subsequent to 1988, a program of
11 concurrent
11 * auditing was initiated.
Using this program, each power plant and the corporate office performs
audits of the same general area (i.e. HP, Maintenance, Operations, etc.),
simultaneously.
This allows each audit group to share current findings
and provides the opportunity for each audit group to look for similar
problems at their respective location.
The inspector also noted that more emphasis was being placed by the
audito~s on evaluating the responses to the audit findings, as well as the
. correcti~e actions taken. This was being done to ensure that the response
and corrective actions were adequate and would prevent recurrence. Also,
findings were not being closed out simply based on development of a new
procedure or some similar approach of correcting the problem identified.
The findings were being held open pending evaluation by the auditors of
the actual implementation and effectiveness of the corrective action.
.. : .. .- .. ****
- "-ff""*'**~.'.*~*-**"****"' .:h *.:.*'--*'*..-.. * ... *-* ** ;_.:,
- *** .:
.9
During discussions with licensee repr~sentatives, the subject of a master
audit schedule or matrix was reviewed.
Such a matrix is generally used to
ensure that all aspects of the program being audited are reviewed. 6n a.
periodic recurring basis.
The licensee indicated that no such majter plan.
existed at the station for the execution of Quality Assurance (QA) audits.
Other licensee representatives indic~ted that a master plan did exist for
the corporate audits .. The inspector indicated that, if no such plan
existed, this was a possible program weakness that should be corrected *
. The licensee acknowledged this and indicated that they would investigate
the matter.
No.violations or deviations were identified.
7.
Licensee Reports/Plans Concerning Improvements to the Radiation
Protection Program (RPP) (92706)
The inspector reviewed recent plans developed by the licensee to i~prove
the RPP at the station.
Recent reports and assessments concerning the
station RPP were also reviewed.
These reports/plans were:
0
0
C,
0
"Source Term Reduction Plan," developed by the Corporate HP Staff and
dated October 20, 1988 ..
"Radiation Protection Program 1988 Annual Assessment Report,"
prepared by the Corporate HP staff and dated March 10, 1989.
11 Leak and Containment Area Tracking Report," prepared the HP
Radwaste/Decon Supervisor and dated April 3, 1989.
"HP Delegation Evaluation of the Japanese Atomic Power Company's
Tsuruga Nuclear Power Station," compiled by the North Anna RPM and
dated April 5, 1989.
"An Assessment of the Radiological Controls Program At the Surry*
Power Station," prepared by the Corporate Radiological Assessor and
dated April 6, 1989.
All of these reports and plans contained various reconvnendations and/or
suggestions to improve the* RPP at the station.
Because the licensee had
not had the time or opportunity to respond to each of these reconmenda-
tions prior to the inspection, it had not been decided course of action
the licensee would take to implement or reject them.
The licensee was
informed that their actions concerning these recommendations would be
tracked by the NRC as an Inspector Foll owup Item (IFI) (50-280,
281/89-14-04).
10
8.
Action of Previouw Inspection Findings (92701, 92702)
a.
(Closed) Violation (VI0).50-280, 281/87;..35-01:
Failure to Follow
Contaminated Material Control Procedur~.
This violation dealt with discovery of contaminated. items inside of a
storage cabinet located in an uncontaminated area.
The finding was
not closed originally due to a similar finding that was noted during
a subsequent inspection.
The licensee was then requested to take
further action to correct this problem.
In response to VIO 50-280,
281/88-35-02 (the similar finding), dated December 9, 1988, the
licensee* indicated that containers of radioactive material located in
uncontaminated areas were surveyed and no unbagged i terns or 1 oose
surface contamination was detected.
Another action taken was to
secure all radioactive material storage containers with locks
controlled by HP.
Instructions were posted on the storage containers
to notify individuals that HP would be required to provide access to
the containers.
Training was also provided during GET to review and
emphasize the procedural requirements for proper handling and storage
of radioactive materials.
The inspector reviewed the licensee's
actions and, during tours of the RCA, verified that radioactive
material storage containers/cabinets were locked and the instructions
posted on the outside.* Lesson plans for GET instruction were also
reviewed and found to be adequate.
b .. (Closed) VIO 50-280, 281/88-35-01:
Failure to Operate Supplied Air
Hoods _Within Certified Pressure Ranges for Length of Hose Used and
to Use Air Supply Hose Not Certified for the Respirator.
During an inspection, an inspector found that the licensee was using
an air supply pressure for supplied air hoods below that which was
required and certified for the length of hose being used.
It was
also noted that air supply hoses in use were not approved on the
respirator certification form for those respirators being used.
In a
response to the prob 1 em, dated November 9, 1988, the 1 i censee
indicated that they had removed the equipment from service and had
- replaced the uncertified air supply hoses.
They had also
recalibrated the equipment, inspected the remainfog units at the
station to ensure no" other problems existed, and changed the
- procedure governing the use of the respiratory equipment so the
problem would not recur.
The inspector verified that these
corrective actions had been performed and reviewed the procedure.
The procedure appeared to be adequate.
c.
(Closed) VIO 50-280, 281/88-35-02:
Failure to Comply with Procedures
for Controlling Contaminated Material.
The inspector verified that the licensee had taken the corrective
actions stated in their response dated December 9, 1988.
This item
is discussed more fully in Paragraph 8.a above.
11
d:
(Closed) VIO 50-280, 281/88-42-01:
Failure to Follow Radiation
Control Procedures when Exiting the Site Using the Portal Monitors.
Licensee personnel had been noted exiting the site through alarming
or non-functional portal monitors.
In a response dated November 29,
1988, the licensee indicated that a security officer would be posted
at the exits to prevent personnel from exiting following a portal
monitor alarm. Also, audible and visual alarms were in*stalled inside
the enclosed security booths at the exits to alert security to the
problem.
The old electrical components.of the portal monitors were
replaced.
The licensee determined that, under certain conditions,
the old components* were* giving spurious alarms.
As a further
precaution against personnel exiting *through a portal monitor that
was not functioning, the licensee installed a chain on each monitor ..
The chain was in~talled at such a height that, when placed ac~oss the
exit portal, a person would have* difficulty not noticing it or trying
to exit underneath it. The inspector reviewed the licensee actions
and verified that they had been taken as indicated in the response.
e.
(Closed) VIO 50-280, 281/88-49-01:
Failure to Make an Adequate
. Evaluation of the Radiation Hazards Present During Decontamination
of the Unit 1 Reactor Cavity.
Decontamination efforts in the Unit 1 reactor cavity had produced
.rags ieading several rem per hour.
This had not been adequately
evaluated prior to the work .. In a response to the violation dated
February 27, 1989, the. licensee indic~ted that sevetal actions to
correct this problem had been initiated. . A new multiple/special
dosimetry procedure, HP-5 .1. 22,
11Dosimetry Requirements For Work
Under A RWP,
11
was written to provide added guidance for HP
technicians in determining when extra dosimetry was needed.
The
licensee and contractor HP technicians were given training on the new
procedure.
HP shift supervisors were also fequired to complete a
form,
11 RWP Special Instruction Sheet,
11 which required them to be more
involved in the RWP writing process and aware of the circumstances of
each.
HP technicians were also given reinstruction on developing
RWPs based current job assessments and current survey results as well
as past history.
The inspector reviewed the licensee's actions and
verified that they had been completed.
The inspector also verified
that the RWP Special Instruction Sheet was being completed as
required, reviewed the new procedure, HP-5 .1. 22, and found it to be
adequate.
f..
(Closed) VIO 50.;.280; 281/BB~fi~oi':
Failure to Follow the Procedure
for Attaching Temporary Shielding to Piping.
During a previous inspection, problems had been noted with lead
shielding that was improperly attached to piping.
In the licensee's
response dated February 27, 1989, the licensee indicated that the
shielding had been removed and installed properly. The licensee also
commited to perform a QA review of all the temporary shielding
g.
12
packages that were still in use at that time.
Of 25 shielded
components inspected, 19 discrepancies or variations from the
installation instructions wer-e identified.
The licensee determined
that one of several, or a combination of errors likely contributed to
the unacceptable shielding condition.
The Station Manager issued a
memorandum to all employees recounting the problems found and
reemphasizing the need for installing shielding properly and
performing all jobs correctly the first time.
(Closed)
Unresolved Item (U~I) 50-280, 281/89-02-01:
Failure to
Adequately Evaluate the Radiation Hazards Pre~ent Prior and Incident
to Welding Work in the Unit 1 Conoseal Area.
This URI was opened as a result of the inspector
I s review of a
licensej station DR.
The DR had ideritified an inadequate evaluation
of a job resulting in the failure to use special or multiple
dosimetry.
The inspector left the i tern as a URI pending the
licensee's response to a previous violation (50-280, 281/88-49-01)
for the same type of a problem.
The licensee's response to that
violation had been determined to be acceptable (see Paragraph 8.e),
and, therefore, this violation is closed based on that response dated
February 27, 1989.
9.
Facility Statistics
a.
Annual and Outage Personnel Dose
In 1987, the station's cumulative personnel dose was 356 person-rem
per reactor as compared to the Pressurized Water Reactor (PWR)
nat i ona 1 average of 369 person-rem/reactor.
The station
I s 1988
-yearly total, 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 April 20, 1989, the licensee
had expended a total of 172 person-rem per reactor.
The 1989 goal,
which had been set prior to the extended outage in progress, was
251 person-rem/reactor. The 1 i censee indicated that they would
probably exceed their goal for 1989 due to the unanticipated outage
of both units.
(1)
Personnel Contamination Events (PCEs)
During 1988, the licensee had experienced a total of 226 skin
and 275 clothing contaminations compared to a total of 174 skin
and 319 clothing contaminations for 1987.
As of April 20, 1989,
the number of PCEs stood at 31 skin and 30 clothing
contaminations.
(2)
Solid Radioactive Waste
Licensee
representatives
indicated
that
approximately
25,000 cubic feet {ft 3 ) of solid radioactive waste had been
13
shipped to waste collectors or burial sites during 1988
containing 193 curies of attivity. During 1989, as of April 20,
the licensee had. ship~ed approximately 7,250 ft 3 of solid waste
containing about 500 curies of activity.
(3)
Area Contamination Control
At the end of 1987, the 1 icensee maintained approximately
22,400 square feet (ft 2 ) within th.e 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, 31, 1988, approximately 20,630 ft 2 were being
controlled as contaminated area or about 23% of the RCA.
As of
April 20, 1989, the square footage of contaminated area had been
reduced to 18,595 or about 20% of the RCA.
This represents an
acceptable reduction when considering that the station is still
in the midst of a dual unit outage.
No violations o~ deviations were identified.
10.
Exit Interview
The inspection scope and findings were summarized on April 21, 1989, with
those persons indicated in Paragraph 1 above.
The inspector described the
areas inspected and discussed in detail the inspection findings listed
below.
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, 281/89-14-01
50-280, 281/89-14-02
50-280, 281/89-14-03
50-280, 281/89-14-04
Description and Reference
LIV~ Failure to maintain the entrance to a
high radiation area locked to prevent
unauthorized entry (Paragraph 3.b).
LIV - Failure to follow procedure by not
following and enforcing the requirements of
an RWP (Paragraph 4.b).
LIV - Failure to label an incore dete~tor,
control it, or have procedures to establish
accountability
for
the
detector
(Paragraph 5.d).
I FI - Foll owup on the 1 i censee' s acti ans in
response to various recommendations made in
1 i censee pl ans/reports .to improve the RPP at
the station (Paragraph 7).
Licensee management was informed that the items discussed in Paragraph 8
were considered closed.