ML18152A336
| ML18152A336 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/16/1993 |
| From: | Bryan Parker, Pharr E, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A337 | List: |
| References | |
| 50-280-93-25, 50-281-93-25, NUDOCS 9401040181 | |
| Download: ML18152A336 (14) | |
See also: IR 05000280/1993025
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
.
. DtC 1 5 1993
Report Nos:: * 50-280/93-25 and 50-281/93-25
Licensee: Virginia Electric and Power Company
Glen Allen, VA
23060
Docket Nos.:
50~280, 50-281
License Nos.:
Inspection Cond~ed: November 15-19, 1993
Inspectors: 4~ a
e__ J...
. . .
. *. B~iL *.
LIUh~rr ./ /
n
.*
..
Approved by:~~~ Vw"II :6\\.. \\tC ~
W. H. Rankin, Chief
Scope:.
Facilities Radiation Protection Section
Radiological Protection. and Emergency Preparedness
Division of Radiation Safety and Safeguards
SUMMARY
tz/J~/9$
Date'Sighed
Branch
This ~outine, announced inspection was conducted in the area of occupational
radiation exposure.* Specific elements of the program examined included:
organiz.ation and management control; audits and appraisals; training and
qualification; external exposure control; internal exposure control; surveys,
monitoring, and control of radioactive material; and maintaining occupational
radiation exposure as low as*reasonably achievable (ALARA)~
Results:
One NRC-identified non-cited violation (NCV) was identified regarding the*
licensee's failure to supply a complete dose history to an individual upon
request in accordance with 10 CFR I9.13(c). Overall, the licensee's radiation
protection program was we 11 * supported by both* corporate and station management
and was functioning effectively to protect the health and safety of plant
personnel and the general public. Control of contamination, housekeeping, and
the ALARA program were considered program strengths.
9401040181 931215
ADOCK 050002BO
.G
REPORT D.ETAILS
1.
Persons Contacted
D. Anderson, Shift Supervisor; Health Physics
W. aenthall, Supervisor, Licensing
- R. Bilyeu, Engineer, Licensing
- M. Biron, Supervisor, Radiological Engineering
W. Cook, Staff Engineer
B. Dorsey; Supervisor, Exposure Control
- D. Erickson, Superintendent, Radiation Protection
- 0; Hart, Supervisor, Quality Assurance
- R. Hayes, Supervisor, Quality Assurance
- M. Kan~ler, Station Manager
- J. McCarthy, Superintendent, Operations.
D. Miller, Supervisor, Health Physics Operations
L. Morris, Superintendent, Radwaste
- M. Olin, Supervisor, H.P. Technical Services
- J. Prite, Assistant Station Manager; Licensing
~- Saunders, Assistant Vice President, Nuclear Operations
T. Steed, ALARA Coordinator
E. Smith,.Jr., Manager; Quality Assurance
- F. Thomasson, Supervisor, Corporate Health Physics
Other licensee employees contacted during this inspection included:
craftsmen, engineers, operators, contract personnel, and
administrative personnel.
Nucle_ar Regulatory Commission
- M. Branch, Senior Resident Ins~ector
- Attended Exit Interview conducted on November 19, 1993.
2.
Organization and Management tontrols (83750)
The inspector reviewed the staffing of the radiation protection (RP)
organization as related to lines of authority and noted that changes
. had been made s i nee t~e previous inspection conducted March 29 -
April 2, 1993, and d6cumented in NRC Inspection Report (IR) 93-09.
According to licensee repre~entatives, organizational chahges were
made mainly foi personnel development reasons and to better piepare
for proposed staff reduction measures.
The inspector verified that
the changes did not adversely affect the licensee's ability tri
maintain control of the RP program and the licerisee indicated that the
proposed staff reductions would most likely be accomplished within the
recommended timeframes through normal attrition. The inspector noted
2
that at the time of the inspection the licen~ee maintained an adequate
level of staffing; however, the inspector reemphasized to the licensee
the need to ensure that safety was not jeopardjzed if staffing levels
d~op as anticipated.
No violations or deviations were identified.
3.
Audits and Appraisals (83750)
- Technical Specification (TS-) 6.1.C.2.h.4 requires that audits of
facility activities be performed under the cognizance of the
Management Safety Review-Committee (MSRC) encompassing the performance
of activiti~s required by the Operational Quality Assurance Program to
.meet the criteria of Appendix B, 10 CFR Part 50, at least once per
24 months.
-
The inspector reviewed Radiologjcal Protection Audit 93-08 conducted
by the Quality Assurance (QA) department during the period July 7 -
August 5, 1993.
The audit encompassed a variety of areas within the
RP program and utilized both performance and compliance based auditing.
techniques. - The most significant finding identified by the auditors
was apparent inattention to detail due to a number of minor
. administrative errors. The inspector noted the audit to be
comprehensive with substantive findings, recommendations; and
- comments.
The inspector also reviewed the licens~e's most re~ent QA assessment
of RP completed in October 1993.
This assessment was performance-
based utilizing checklists and a rating system to assess a number of
RP areas. The rating system ranged from 1.00 for ,fully acceptable"
to 4.00 for "unacceptable," and the overall ~ating from the assessment
averaged out to be 1.17. This was up slightly from a similar
assessme'nt performed in January 1991 that gave an overall rating of
1.30. Within the most recent assessment, the lowest r~ted category
was Dosimetry Processing and Control at 1.83.
No specific
subcategori~s within any of the categories assessed received a rating
of greater than 2.5.
Additionally, the inspector reviewed the licensee's internal program
for se 1 f-i dent i fi cation of weaknesses re 1 ated to the _RP program and
the appropriateness of corrective actions taken. Specifically, the
inspector r~viewed 1993 Deficiency Reports (DRs) related to the RP
function and Radiation Problem Reports (RPRs) initiated during 1993~
Both systems were utilized by the licensee to document, investigate,
and track items of concern.
The inspector was informed that the DR
system was a plant-wide system for identification of concerns, while
the RPRs were utilized mainly by the RP organization to id.entify
applicable concerns.
The inspector noted that nine DRs ~ad been
identified and assigned to the RP group for investigation and
.
corrective action during the period January 1 - September 30, 1993,
while approximately 90 RPRs ha~ been injtiated through October 10,
1993.
The inspector reviewed selected DRs and RPRs from this period
3
and noted.that the licensee was identifying substantive items of.
concern and was appropriately following through with corrective
action~ to prevent recurrence.
The inspector also noted that each
reporting system received an appropriate level of management oversight
for.their applicable threshold level. The inspect~r noted that the
threshold for DR and RPR initiation appeared appropriate, in that more
safety significant issues were assigned to and tracked for closure
through the DR system. The.licensee's efforts in these self-
identificatiori program~ appeared appropriate, with no adverse
performance trends being noted.
Overall, the licensee had effectiv~ auditing and assessment functions
actively reviewing the RP program. *
No viol~tions or deviatioris were id~ntified.
4.
Training and Qualification (83750)
10 CFR 19.12 requires, in part, that the licensee instruct all*
individuals working in or frequenting any portioris of a restricted
area in the health protection ~spects associated with ex~osure to
radioactive material or radiation; .in precautions or procedures to
minimize exposure; in the purpo~e and function of protection devices
employed; in the applicable provisions of the Commission reguhtions;
in the individual's responsibilities; and in the availability of
- radiation exposure data.
During the onsite inspection, the inspector reviewEd the licensee's
program for prqviding training to both general plant workers and
Health Physics (HP) technicians~ The inspector was infor~ed that
licensee employees received Nuclear Employee Training (NET) prior to
beginning work activities, and were required to complete an
abbreviated retraining annually.
The inspector noted.that topics *
presented iri NET included industrial *safety, the emergency plan, plant
security, workers' rights, basic radiation theory and the biological
effects of radiation exposure, Radiation Work Permit (RWP) compliance,
and access control, to.include the proper use of Digital Alarming
Dosimeters (DADs) .. Additionally, the inspector noted that *NET also
included a basic introduction to revised 10 CFR Part 20 terminology,
exposure limits, and.philosophy changes, with emphasis on respirator
reduction and reasons for this reduction.
- . The inspector also discussed with licensee representatives and
reviewed the training program for HP technicians. The inspector noted
that the initial HP Technician Development Program was prefaced by
17 weeks of general foundational-level training which included topics
related to communications, mathematics, classical physics, chemistry,
electricity, and nuclear physics. This training program was designed*
to provide appropriate academic backgrounds for technicians entering
the Development Program.
After successfully completing the written
examinations with.at least 80 percent correct for each foundational
. tratning topic, the employees were then admitted to the Development
- -
4
Program.
The inspector reviewed the Technician Development Program
and noted that it was a th~ee year program, divided into seven six-
month steps.
Each step included classroom trajning, independe~t -
study, and on-the-job training. The inspector also noted that each
step contained task performance evaluations, which qualified the
technician to perform independent tasks. The inspector reviewed the
seven step curriculums and noted that training topics and performance
evaluations included items related to basic HP theory, radiological
- surveys, airborne radioactivity control,_ instrumentation, respiratory .
protection, routine and special HP coverage, count room operations,.
environmental monitoring, plant systems, dosimetry, radioactive
materhl and contamination control, RWPs, and ALARA program.
The
.. inspector noted that in addition to completing performance evaluations
the technicians were also required to successfully complete written
examinations following each step.
The inspector also reviewed continuing training presented to the HP
technician staff since January 1, 1993.
The inspector noted that the
licensee's annual continuing training program consisted of a minimum
of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
The inspector was informed that the licensee had
scheduled approxi~ately 104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> of continuing training for the
technicians during 1993.
The inspector also noted that each training
~ession required completicin of a comprehensive written examination
with at* least 70 percent correct, as well as satisfactory
demonstration of applicable tas~s as presented during the training
week.
The inspector reviewed training outlines and noted that the
material included review of industry events, lessons learned from
prior outages, job coverage in high risk exposufe areas, emergency
response, implementation of the ievised computer system, and revised
10 CFR Part 20, specifically to address procedural changes resulting
from the revisions. The inspector was informed that HP and training
personnel met annually to d~termine training needs for the upcoming
traini.ng year and to review specified tasks to determine the need* for
retraining and requalification to the task, due to task and/or program
revisions or deficient field performance.
- -
.
'
'
The inspector reviewed trainirig records for selected HP technicians
and noted successful completion of NET, initial technician training~
to include both foundational-level training and the Oevelopment.
Program training, continuing training, and appropriate qualification
to applicable tasks. Overall, the inspector found the ~adiation
protection training provided to both general employees and HP
technicians to be thorough and well prepared and appropriate for
informing plant workers as required by 10 CFR 19*.12.
No violations or deviations*were identified .
5
..
5.
-External Exposure Control (83750)
a._
Program Implementation
10 CFR 20.101 requires that no licensee pos~ess, use, or
_
transfer licensed material in such a manner as to cause any*
individual in a restricted area to receive in ~ny period of one
- calendar quarter a total oc~upational dose in excess of
1.25 rem to the whole body, head and trunk, active blood
forming organs, lens of the eyes, or gonads; 18. 75 rem to the -
hands, forearms, feet and ankles; and 7.5 rem to the skin of
the whole body.
10 CFR 20.202(c) requires, in part, that dosimeters be
processed and evaluated by a dosimetry processor holding
current accreditation from the National Voluntary Laboratory
Accreditation Program (NVLAP) for the types of radiation for
which the individual is monitored.
During the onsite inspection, the inspector discussed the
dosimetry program with cognizant licensee representatives.
The
inspector noted that the licensee continued to use the
Panasonic UD-802 thermoluminescent dosimetry *(TLD) system.
Each dosimeter utflized four TLD chips, two lithium borate and
two calcium sulfate phosphois.
Based ori differing filter
media; correction factors; and response ratios, the licensee's
algorithm determined the type of radiation detected by the TLD
and subsequently determi~ed the dose equivalent at specified
tisstie depths.
The inspectof was informed that the licensee's
algorithm calculated dose equivalents at seven millig~ams per
square centimeter (mg/cm2) for skin dose, 300 mg/cm2 for lens of
the eye dose, and 1000 mg/cm2 for deep dose.
The inspector was
also informed that the minimum TLD sensitivity for each element
response was 10 mi 11 i rem (mrem).
The inspector al so note_d that
the licensee was NVLAP accredited in all eight dosimetry
categories for use of the TLD system.
-
The inspector also noted that the licens~e used DADs primarily
for daily dose tracking, with approximately 1400 active DADs
being kept o_ns i te *for routine exposure monitoring.
The
inspector noted that the number of problems associated with
DADs, which were captured by the RPR system, was very low
considering the thousands of entries made into the
Radiologically Controlled Area (RCA).
The inspector was
informed that the licen~ee typically expected the DAD dose to
be one to five p~rcent higher than the TLD dose.
The inspector
noted that since 1991 the 1 icensee had steadily impro_ved their
DAD to TLD ratio so that the year-to-date total for 1993 should
fall within the one to five percent range with the DAD dose
slightly exceed frig the TLD re_cord dose.
6
During discuisions with licensee representative~, the inspector
was informed that the Panasonic TLD was capable of and
accredited for measuring beta and neutron exposure.
However,
th~ inspector noted that beta doses due to personnel
contaminations and noble gas exposure were calculated using
other methodologies.
The inspector reviewed personnel
contamination reports for the period January 1 -
.
October 30, 1993, and noted a hot particle event which required
calculation of skin dose.
The inspector noted that the
resultant exposure was significantly less than the
75 microcurie-hour _(uCi-hr) enforcement threshold, and final
exposure assigned to the worker was 2.836 rem to the skin.
The
inspector ~lso reviewed 1993 exposure fecords for selected
individuals which had been associated with. entries into the
containment building at ~ower. * The inspector verified that *the
licensee was implementing appropriate radiological
surveillances and methodologies so as to ca~culate and record
individual skin doses due to noble gas exposures and whole body
doses due to neutrrin exposures.
During discussfons with
licensee representatives, the inspector was informed that
during recent years the radioactivity*levels due to noble gases
had not met the threshold to require determination of
applicable skin doses.
The inspector was also informed that
since April 1~ 1993, the licensee had made the determinatitin to
assign neutron doses based on individual. TLD results rather
than calculations, unless there was (1) a large variance
between the two~ and (2) there* was reason to believe the
calculated dose was more representative or was much-more*
conservative.
The inspector noted that the licensee had
recently purchased neutron bubble dosimetry to verify their TLD
results and had an almost one-to-one rati~ between the bubble
dosimetef and the TLD results, with the calculated neutron
exposures exceeding these results by approximately 65 percent ..
The inspector did not note any concerns regarding the
licensee's technical methods for performing the associated
exposure assessments, and personnel exposures were
appropriately updated to th*e individual exposure history files.
The inspector verified that for those records re~iewed all
external doses were within regulatory limit~.
The inspector reviewed 1993 exposure records for selected
individuals and noted that the maximum quarterly cumulative
doses were 195 mrem to the whole body, due to gamma and neutron
exposure, and 2.959 rem to the skin of the whole body, in part
due to the 2.836 rem hot particle dose to the individual's
knee.
The inspector also reviewed third quarter DAD results
and noted that approximately 95 percent of the DAD doses were
less than 100 mrem, with only two doses exceeding 500 mrem of
which 666 mrem was the maximum.
During tours of the RCA, the
inspector noted that the DADs were calibrated semiannually, as
required; and that personnel were wearing DADs and TLDs
properly.
7
During plant tours; the inspector noted that high radiation
areas (HRAs) were locked as required and other entry controls
were in place as necessary.- In addition, HRA keys were
adequately controlled by RP and no major problems were noted.
No violations or deviations were identified
b.
Licensee-Required Reports
10 CFR 20.408(b) and 10 CFR 20.409(b) require that the licensee
make a report to the Commission, and notify the individual
involv~d of the radiation expo~ure of each individual who has
terminated employment. -The report is to be furnished within
30 days after the individual's exposure is. determined by the
licensee or 90 days aft~r the date of termination of employment
or work assignment, whichever is earlier.
10 CFR 19.13(c) requires that, at the request of a worker
formally engaged in licensed activities controlled by the
licensee, the licensee furnish to the_worker a report of the
worker's exposure to radiation or radioactive ~aterial for each
, year the worker was required to be monitored. This report is
to be furnished within 30 days from the time the request is
ma-de, or within 30 ~ays*after the individual's exposure is.
determined by the licensee, whi~hever is later.
T~e inspector ~e~iewed exposure re~ords for selected personnel
which_had*terminated work activities at the licensee's facility
since January 1, 1993, to include vendor petsonnel employed
duri'ng the Spring o*utage.
The inspector verified th.at a 11
those selected had been issued a termination letter within-the
applicable time period.
Tbe inspector noted that the
licensee's program was effective in providing for timely
issuance of termination letters.
The inspector a 1 so reviewed 1 i censee records to verify that, as.
upon request, individuals were receiving accurate and timely.
reports of their radiation exposure while involved in licensed
activities at the 1 icensee' s facility. The inspector noted one
case in which an individual had made such a request and the
licensee had faileg to provide the individual his radiation
exposure in its entitety. During review of the incident, the *
inspector noted that individual exposures monitored by the
licensee during the period 1986 to present w~re recorded in
personnel files, while records dating prior to 1986 were stored
on microfiche.
For the particular* individual of concern, the
inspector noted that the licensee failed to provide complete.
and accurate exposure records, since the licensee's report to
the individual did not include his exposure history for the
period.from April 1979 to September 1981.
The inspector
8
informed licensee representatives*that the failure to provide a
complete and accurate exposure history" to a former worker upon
request was a violation of the requirements specified in
Du~ing discussions with licensee representatives, the inspector -
noted that what appeared to have happened in this particular
instance Was that the individual composing the former worker's
exposure* history failed to survey microfiched records, on which
. the individual's records prior to 1986 were stored.
Duritig
interviews with dosimetry personnel responsible for composing
such exposure histories, the inspector noted that all were
aware of the need to review both filed and micrqfiched exposure
records so as to provide individuals ~ith complete and accurat~
expos~re histories. The insp~ctor reviewed other workers' -
requests for exposure histories, and noted that complete
exposure histories were provided as required.
The inspector*
noted that the licensee's failure to provide accurate exposure
reports in accordance with 10 CFR 19.13(c), as discussed above,
appeared to be an isolated incident due to administrative
oversight. The licensee committed to review the incident and
the procedure for providing reports to foriner Workers to
determine if there was a more generic concern and to determine
if their procedure could be enhanced, or formalized written
guidance be provided so as to prevent future administrative
oversights.
Based on the limited safety significance and the
.licensee's commitment to further review the issue and determine
actions to prevent recurrence, the inspector informed licensee*
representatives that this NRG-identified violation would be
considered non-cited since the criteria specified in*
Section VII.B of the Enforcement Policy were met (NCV 50-
280~ 281/93-25-01).
One NCV for the failure to provide a complete and accur~te
exposure hi story to *a former worker upon request was
i dent i fi ed.
c.
Resin Transfer Observations
Durin~ the inspection, the inspector observed as the licensee
transferred spent resins from Unit 1 resin beds in the
Auxiliary Building .to the Decontamination Building for
dewatering and processing for disposal.
The inspector noted
that RP personnel maintained effective control during the
actual transfer evolution by restricting access to the basement
lev.el of the Auxiliary Building where transient high radiation
- levels could occur as the resins flowed through the_pipework.
The inspector also noted the licensee's good use of
9
communications and video monitoring during the. transfers
(see Paragr~ph 8). The inspector noted no problems with the
actual transfer, although the evolution_ was temporarily stopped
by the Control Room due to an unanticipated drop in the Volume.
Control Tank (VCT) level during the resin transfer.
Following the successful transfer of resin, continuous air
monitors (CAMs) located in the Auxiliary *and Decontamination
Buildings began alarming, ~ausing some temporary evacuation,of
the affected areas until the problem was assessed by RP. The
licens~e responded quickly to the alarms and found that copious
amounts of gas containing the short-lived particulat~s cesium-
138 and rubidium-88 (average half-life approximately
.
17 minutes) were released into the Auxiliary Building sometime
during and/or immediately following the res*;n transfer. This
indicated that primary coolant h~d somehow become involved
during the slurrying of the resin and was venting inside the
plant at some point.*
After investigation, it was determined that the VCT level drop
noted above occurred when a valve located on a bypass line
between the VCT and the resin slurry line (Valve l-CH~21)
failed to isolate* the VCT and "leaked by;" The bypass line
that leaked had a higher pressure- than the pressure created
when Valves I~CH-23 and l-CH-57 cin the resin transfer system
were opened to start the appropriate slurry; therefore, instead
of slurry water being pulled from the Primary Grade (PG) tank
(demineralized water) as desired, primary coolant was pulled
from the VCT.
In the Decontamination Building, the slurried
resin immediately began dewatering and the water was pumped
back to the Auxiliary Building to the Low-Level Waste Tanks for
holding.
These tanks vent directly to the floor drains.
Consequently; gases from the primary coolant slurry were
emitted-into the Auxiliary Building through the floor drains
and dispersed throughotit the building from the basement level
and upward.
CAMs in the Auxiliary auilding began alarming and
the Control Room received a vent/vent alarm.
As a result of
the vent/vent alarm, the Control Room placea the
_ Decontamination Building on filtered exhaust, which in* turn
_ created a negative pressure within that building.
Subsequently, CAM alarms began in the Decontamination Building
as $Orne of the gases were apparently pulled from the Auxiliary
Building through the pipe cha.se and into the Decontamination
Building.
No personnel_ contaminations resulted from the gas event;
however, one individual that had been working in the
Decontamination Building during the resin transfer and
subsequent gas event was unable to clear the personnel
contamination monitor upon exiting. The individual was
detained until the short-lived radioactive gases trapped mainly
- '
10
in his clothes and hair decayed away, and was released after
approximately one hour.
No problems were noted with the
licensee's methods or procedures, as well as the licensee's
evaluation of the event.
- * *
No violations or deviations were identified.
6.
Internal Exposure Control (83750}
10 CFR 20.103(a)(l) states that no licensee shall possess, use, or
transfer licensed material in iuch a manner as to permit any
individual in a restrict_ed area to inhale a quantity of radioactive
material in any period of one calendar qu~rter greater than the
qu_antity which would _result from i nhal ati on for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for
13 weeks at uniform concentrations of radioactive material in air
specified in 10 CFR Part 20, Appendix B, Table 1, Column 1.
10 CFR 20.103(a)(3) requires, in part, that the licensee, *as
appropriate, use measurements of radioactivity in the body,*
measurements of radioactivity excreted from the body, or any
combination of such measurements as may be necessary for timely
detection and assessment of individual intakes of radioactivity by
exposed individuals ..
.
'
-
'
. The inspector reviewed the licensee's program for assigning and
tracking Maximum Permissible Concentration'.'"hour (MPC-hr) exposures
based on airborne radioactivity measurements.
The inspector was *
informed that internal exposure assignments were calculated prim*arily
based on general area air sampling or on the more recent use of lapel
samplers.
During discussions with licensee representatives and review
of records from the period January 1 - October 15, 1993, the inspector
noted that the threshold for calculating exposures, 25 percent of the
MPC, was rarely exceeded.
The inspector also noted that during the
.*resin transfer incident, as discussed *in Paragraph 5.c, the maiimum
air sample result was 47 percent of the applicable MPC.
The inspector
verified that the exposure of the individual discussed in Paragraph
5.c who was unable to immediately clear the contamination monitor was
based on the air sample result and was properly calculated,
documented, and tracked.
The individual's internal exposure from the
event was very low, evaluated to be less than one-MPC-hour.
The inspector also reviewed selected licensee *procedures which
provided gui.dance as to when to perform special bioassays, for
bioassaY evaluation, and for subsequent calculation of internal
exposures.
The inspector noted that special bioassays were required
to be performed for facial contamiriation events exceeding
- .
1000 disintegrations per minute (dpm) or detection of positive nasal
swabs. ,As of November 17, 1993, the licensee had experienced 99
personnel contamination events (PCEs) in 1993 .. The inspector reviewed
selected PCE reports and noted that approximately one-fifth of the
PCEs were facial contaminations.
Most of these were attributable to
worker error and did not indicate any adverse trends.
For the cases
11
reviewed, special whole body analyses were conducted in ~cccirdance
with procedural requifements, and all calculated uptakes were less
than five percent of a maxi~um permissible organ burden (MPOB). * Since
the whole body count results did not exceed the licensee's threshol~
of five percent of the MPOB, equating to 25 percent of the MPC,
calculations of an MPC-hr assignment were not required.
Based on the above, the inspector concluded that the licensee was
appropriately moriito~ing and documenting int~rnal expo~ures, with none
reviewed exceeding the 40 MPC-hr control limit reqLliring an additional
evaluation.
No violations or deviations were identified.
7.
Surveys, Monitoring and Control of Radioactive Materi_al (83750)
The licensee continued* to effectively control contamination at the
source.
The 1 i censee' s ~oa 1 for 1993 wa_s to maintain 98. 5 percent
(135,000 square feet (ft)) of the RCA. as clean and free of *
.
contamination above 1,000 disintegrations per minute per 100 square
centimeters (1,000 dpm/100 cm2).
As of November 17, 1993, only ..
1.04 percent (1,425 ft 2 ) of the RCA was contaminated and the licensee
expected-to end the year with even less contaminated area.
The inspector noted during tours of the plant-that very few catch*
- containments were n~eded as a means of controlling contamination:
As
of November 17, 1993, only 19 containments were in us.e throughout the
plant. Control of contamination and housekeeping in general were
noted to be excellent by the inspector and conveyed to the 1 icensee as
strengths to the overall program.
No violations or de~iations were identified.
8.
Program to Maintain Occupational As Low As Reasonably Achievable
(ALARA) (83750)
10 CFR 20.l(c) states that persons engaged in activities under
licenses issued by NRC* should make every reasonable effort to maintain
radiation exposures as low as reasonably achievable .. The recommended
elements of an ALARA program are contained in Regulatory Guide 8.8,
Information Relevant to Ensuri~g That Occupational Radiation ExpQsure
at Nuclear Power Stations will be ALARA, _and Regulatory GuideS.10,
Operating Philosophy for Maintaining Occupational Exposures ALARA.
The licensee's total collectiv~ dose goal for 1993 was originally
595 person-rem; however, due to the overall success of the Unit 2
outage early in the year, the licensee revised the goal to 395 person-
rem. Currently, the licensee's ~ollective dose for the*year wa~ ~n
actual 381 person-rem compared to a projected 382 person-rem for that
12
point in ~he schedule.
Licensee representatives indicated th~t the
goal might be sli~htly exceeded due to some forced outage steam
generator work being perform~d in Unit 2 near the end of the year ..
The licensee's 1994 goal was set at 642 person-rem.
This accounted
for two outages during the year, both of which will include IO-year
in-service inspection (ISi) work.
- *
The-inspector reviewed a number of dose reduction initiatives employed
by the licensee. These included a video camera and radiation detector
setup at the* resin slurry line viewport to allow remote visual and
detector readout verification that slurries were properly flowing and
flushing.
The licensee continued tri actively pursue methods for
eliminating source term including hotspot flushing and early
boration/shutdown chemistry.
As of November 17, 1993, the licensee*
was tracking 48 hotspots, only 10 rif which actually met the lic~nsee's
hotspot definition of 1000 milliRoentgen per hour (mR/hr) or greater
on contact and fives times general area. Hotspots were tratked in a
monthly report and flu~hed whenever possible.
The resin transfer
discussed in Paragraph 5.c was performed in order to provide fresh
beds so bette~ "delithiation" can occur, in an effort to improve the
results of early boration and shutdown chemistry~
Jhe licensee continued to identify effective uses of shielding,
. including water shields, temporary lead blankets and bricks, and
permanent shielding on operating systems.
Distance. was also used to
effectively reduce exposure.
For example, a scaffold was built around
. a 20 R/hr hotspot (contact, 2 R/hr at one foot) in the Unit 2 residual
heat remov~l (RHR) system to keep workers out of high radiation fields
during forced outage steam generator work.
During normal outages, the
piping and hotspot were shielded, but in this case it wa~ more ALARA
to build a barrier to restrict access to it.*
Respirator reduction continued to effectivEllY reduce overall worker
dose.
In 1992, the licensee utilized 10,520 respirators, wher~as, as
of October 31, 1993, only 2,958 had been used in 1993.
No significant
incr~ase in internal exposures was noted ijnd ehgineering controls were
utilized to complement the r~duction in respirator usage.
The inspector noted that the ALARA program continued to be a strength
to the licensee's overall program. Strong management support and
heavy worker involvement contributed to the continued successes in the
area of ALARA ..
No vi o ht i ans or devi at i ans wer_e_ i dent i fi ed.
9.
- Exit Meeting
Jhe inspector met with licensee representatives denoted in Paragraph 1
at the conclusion of the inspection rin November 19, 1993.
The
inspector summarized the scope of the inspection findings including
13
the NCV listed below.
The licensee did not identify any documents or
processes as being proprietary, and no dissenting comments were
received from the licensee.
Item Number
50-280, 281/93-25-01
Status*
Open
Description and Reference
NCV - Failure to provide a
complete and accurate
exposure history to a
former worker upon request
(Paragr~ph 5.b).