ML18152A348
| ML18152A348 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/03/1995 |
| From: | Rankin W, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A349 | List: |
| References | |
| 50-280-95-02, 50-280-95-2, 50-281-95-02, 50-281-95-2, NUDOCS 9502140048 | |
| Download: ML18152A348 (17) | |
See also: IR 05000280/1995002
Text
Report Nos. :
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIEITA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
February 6, 1995
50-280/95-02 and 50-281/95-02
Licensee: Virginia Electric and Power Company
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.:
Inspection Conducted:
January 16-20, 1995
Inspector:
d~Y\\.~tf=
F. N. Wright
Approved ~
~::{Q Rovv-.L
W. H. Rankin, Chief
Scope:
Facilities Radiation Protection Section
Radiological Protection and Emergency Preparedness
Division of Radiation Safety and Safeguards
SUMMARY
2/3j'l5
Date's i gned
f'al.'41 'l,.~
Branch
This routine, announced inspection was conducted in the area of occupational
radiation exposure.
Specific elements of the program examined included:
changes in the radiation protection program;
planning and preparation;
training and qualifications; 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:
The inspection included interviews with licensee personnel, procedure and
record reviews, and observations made during tours of the licensee's
radiological controlled areas. Overall, the licensee's radiation protection
program was effective in keeping occupational exposures within the limits
specified in 10 CFR Part 20, "Standards for Protection Against Radiation."
The inspector spoke favorably of collective dose reductions and the
housekeeping improvements in observed facilities.
Two NRC identified non-
cited violations were identified concerning the use of procedures for
9502140048 950206
ADOCK 05000280
G
generating personnel exposure records:
1) Violation of Technical
Specification 6.4.B requirements for failure to follow procedures for
generating NRC Form 5 for an individual terminating during a personnel
radiation monitoring period (Paragraph 5); and 2) Violation of Technical
Specification 6.4.B requirements for use of a dosimetry records procedure that
was not controlled and approved (Paragraph 5).
__ ____
1.
Persons Contacted
Licensee Employees
REPORT DETAILS
- W. Benthall, Supervisor Licensing
M. Biron, Supervisor Radiological Engineering
- D. Boone, Supervisor Quality Assurance
B. Dorsey, Supervisor Exposure Control
- D. Ericksbti, -superintendent Radiation Protection
- M. Fischer, Health Physics Technician
- B. Garber, Licensing
- D. Maddrey, Health Physics Technician
- D. Miller, Supervisor Health Physics Operations
- D. Noce, Radiological Engineering
M. Olin, Supervisor Health Physics Technical Services
- A. Price, Assistant Station Manager
- R. Saunders, Vice President Nuclear Operations
- T. Steed, ALARA Coordinator
D. Sweany, Training
- B. Thornton, Corporate Health Physics
- N. Urquhart, Supervisor Nuclear Training, Radiological Protection
D. White, Health Physics Shift Supervisor
Other licensee employees contacted during the inspection included
technicians, maintenance personnel and administrative personnel.
Nuclear Regulatory Commission
- M. Branch, Senior Resident Inspector
D. Kern, Resident Inspector
S. Tingen, Resident Inspector
- Attended January 20, 1995 Exit Meeting
Abbreviations used throughout this report are defined in the last
paragraph.
2.
Radiation Protection Program Changes (83750)
The inspector reviewed the licensee's RP program to determine if any
significant changes had occurred since the last inspection was conducted
during the period of August 29 - September 2, 1994, and documented in
-IR 50-280 and 281/94-26.
Changes in organization, personnel,.
facilities, equipment, programs, and procedures, from the previous
inspection, were reviewed to assess their impact on the effective
implementation of the occupational RP program.
The most significant
change involved the decontamination of the "Two Foot" elevation of the
Auxiliary Building.
The project included stripping old paint, some
concrete removal and resurfacing, ground water in-leakage control,
..
2
painting and shielding.
The inspector noted the decontamination and
shielding should result in improved surveillance, fewer personnel
contaminations and lower collective dose for work in the area.
The
person-rem goal for the project was 41.5 person-rem and was completed
with approximately 44 person-rem.
The licensee had cut the number of contract HPs utilized to supplement
the siteHPs during RFOs by 15 percent in 1993 and another 15 percent' in
1994.
During the up-coming Unit Two RFO the licensee planned to utilize
approximately 55 senior and 19 junior HPTs, 6 vendor HP Supervisors,
2 ALARA technicians, 12 laundry personnel, 44 decontamination personnel,
and 6 dosimetry specialists.
No further reductions in contract support
personnel were planned for 1995.
No violations or deviations were identified.
3.
Planning and Preparation (83750)
Licensee activities and documents were reviewed to determined the
adequacy of management and staff efforts in planning and prP.paration of
radiation work.
At the time of the inspection, the licensee was preparing for a Unit 2
RFO to begin February 2, 1995, with a completion goal of 64 days.
The
licensee also planned to conduct a RFD on Unit 1 scheduled to begin .
September 1, 1995, for 62 days.
Unit 2 significant work scope included
S/G maintenance, reactor vessel head guide funnel inspection, 10 year
vessel inspection, service water piping inspection, and reactor coolant
pump inspection and maintenance.
The inspector determined that the licensee held post outage critiques to
determine adequacy of radiation protection activities during outages.
During that process a list of items needing action, improvement or
review was assembled and action items assigned and tracked for
completion. A site Outage Integration Team, which included
representatives of the radiation protection staff, held meetings to
discusses up-coming outage plans, objectives and needs.
Approximately
six months prior to the outage the radiation protection staff began
internal outage planning meetings to review scheduled work and make
outage preparation assignments. Typical RFO planning assignments
included:
preparation of RWPs;
development of shielding packages;
development of ALARA evaluations; contractor HP staffing plans;
equipment plans for use of HEPAs, cameras, communications, dosimetry,-
containments, radiological monitoring, decontamination equipment, and
electrical power; and radioactive waste plans.
The inspector determined
that there was adequate management support for planning and implementing
effective radiological control measures for the RFOs.
No violations or deviations were identified.
- 4.
3
Training and Qualifications (83750)
Training was reviewed to determine whether HPTs, contractor HPTs and
radiation workers were receiving appropriate instructions for their work
assignments.
10 CFR 19.12 required that licensees instruct all individuals working or
frequenting any portion of the restricted areas in: health protection
aspects associated with exposure to radioactive material or radiation;
precautions or procedure~ to minimize-exposure; purpose and function of
protection devices employed; applicable provisions of the Commission
Regulations; individuals responsibilities; and availability of radiation
exposure data.
The licensee's initial radiological protection NET training course was
required for.all Virginia Power radiation workers prior to their
radiation work assignments at the station.
In January of 1994, the
licensee implementing changes to the NET retraining program.
The new
training plan required licensee radiation workers to attend a clas~room
NET retraining session every three years.
In the other years, licensee
personnel were required to review the NET Training Manual and certify
their completion of the self-study activities on a "Required Self-Study
Receipt." Contract employee radiation worker retraining requirements
did not change and their participation in a annual retraining class was
required.
The licensee began using CBT for radiological protection NET
on January 1, 1995.
The CBT training took the place of the NET re-
training classroom instruction. The CBT was available to staff _on a.
network for their review.
The CBT included an examination which
generated a set of randomly selected questions.
Following the test the
student could review test results and receive the correct answers for
all missed questions.
The licensee req~ired a proctor be present
whenever students were taking the examination.
The inspector reviewed the continuing training program activities for
site HPTs.
"Health Physics Technician Development Program," Rev. 24,
dated December 30, 1994, served as programs governing administrative
document.
Each fall an Annual Needs Assessment was conducted with each
duty area supervisor to determine continuing training program needs.
The inspector determined that the licensee provided approximately 96
hours per year for continuing HPT training. The inspector noted that
there were separate continuing training programs and schedules for the
HPTs depending upon assigned responsibilities.
The inspector reviewed
the following training plans:
0
HP Operations/HP Count Room/HP Instrumentation Technicians_;
0
Exposure Control/Bioassay/Respiratory Technicians; and
0
Rad Material Control Technicians .
4
The inspector noted that the selected topics appeared appropriate for
the technicians and the time allotted for each subject reasonable.
The inspector attended a portion of "Emergency Planning" class held at
the licensee's training center for HP Operations, HP Counting Room, and
HP Instrument Technicians.
The inspector noted that the course
objectives, content and level of training appeared appropriate.
The
instructor appeared knowledgeable in the material reviewed and presented
to the class.
The inspector reviewed the NET and continuing training documentation and
records for selected HPTs in 1994.
Records showed that the technicians
had completed all of the training planned for 1994 and had successfully
demonstrated their knowledge of training objectives for each subject.
Records were maintained in very good order.
In general, the training programs for radiation workers and HPTs
appeared appropriate for the students needs.
No violations or deviations were identified.
5.
External Exposure Control (83750)
This area was reviewed to determined whether personnel dosimetry,
administrative controls, and records and reports of external radiation
exposure met regulatory requirements.
Paragraph 20.1101, "Radiation Prritection Programs," (a) states; "Each
licensee shall develop, document, and implement a radiation protection
program commensurate with the scope and extent of licensed activities.
and sufficient to ensure compliance with the provisions of this part."
TS 6.4.B states procedures for personnel radiation protection shall be
prepared consistent with the requirements of 10 CFR Part 20 and shall be.
approved, maintained and adhered to for all operations involving
personnel radiation exposure.
a.
Personnel Radiation Exposures
10 CFR 20.120l(a) requires each licensee to control the
occupational dose to individual adults, except for planned special
exposures under 10 CFR 20.1206, to the following dose limits:
(1)
An annual limit, which is the more limiting of:
(i)
The total effective dose equivalent being equal to -
5 rems; or
(ii) The sum of the deep-dose equivalent and the committed
dose equivalent to any individual organ or tissue
other than the lens of the eye being equal to 50 rems;
and
b.
5
(2)
The annual limits to the lens of the eye, to the skin, and
to the extremities, which are:
(i)
An eye dose equivalent of 15 rems; and
(ii) A shallow-dose equivalent of 50 rems to the skin of to
any extremity.
The inspector reviewed and discussed with licensee representatives
1994 external exposures for plant and contract personnel.
The
inspector determined that personnel radiation exposures assigned
during the period were within 10 CFR Part 20 limits.
The maximum
doses for an individual radiation worker through December 31, 1994
were:
TEDE, 1,814 mrem;
Skin, 2,395 mrem;
Eye, 1,814 mrem;
and
Extremity, 4,652 mrem.
From a review of record~ and discussions with. licensee
representatives, the inspector noted that worker dose in general
appeared to be under control.
No violations or deviations were identified.
Personnel Radiological Exposure Records
This area was reviewed to verify that the licensee had determined
the prior occupational radiation dose received by radiation
workers and that the dose records for those radiation workers met
the requirements of 20.2104 and were properly maintained.
Section 20.1502 of 10 CFR Part 20, "Standards for Protection
Against Radiation," requires licensee~ to provide radiation
monitoring for all occupationally exposed individuals who might.
receive a dose in excess of 10 percent of the limits in
10 CFR 20.1201, 20.1207, or 20.1208.
10 CFR 20.2104(a) requires licensee's (1) determine the prior
occupational dose in the current monitoring year for all persons
who must be monitored in accordance with 20.1502 and (2) attempt
to obtain the records of cumulative occupational radiation dose
for those individuals.
10 CFR 20.2104(d) requires licensees record the exposure history
of each individual, as required by Paragraph (a) of this section,
on NRC Form 4, or other clear and legible record, including all of
the information required by NRC Form 4.
10 CFR 20.2106(a) requires licensees maintain records of doses
received by all individuals for whom monitoring was required
pursuant to Paragraph 20.1502, and records of planned special
exposures, accidents, and emergency conditions.
6
10 CFR 20.2106(c) requires the licensee maintain the records
specified in Paragraph (a) of this section, on NRC Form 5, in
accordance with the instructions for NRC Form 5, or in clear and
legible records, containing all of the information required by NRC
Form 5.
10 CFR 20.2106(d) requires the licensee make entries of the
records specified in Paragraph (a) of this section at least
annually.
The inspector reviewed licensee procedure HP-1031.010, "Exposure
Control Records And Reports," Rev. 3, Effective September 27,
1994.
Section 6.6 "Termination Records - Monitored Worker," of
HP-1031.010 listed dosimetry staff requirements for radiation
workers ending an assignment and a radiation monitoring period at
the station. The dosimetry staff was to collect the radiation
worker's TLD and conduct an exit WBC.
Following the TLD
processing, step 6.6.1 of the procedure required TLD results be
entered in the PREMS data base or on a current "Occupational
Exposure Record for a Monitoring Period (NRC Form 5).
11
Step 6.6.5
of the procedure required the staff produce and print an
"Occupational Radiation Dose Report (Attachment 6, Form HP-
1031.010-5.1) for the current year.
Step 6.6.6 required:
"For
each report to be given to or forwarded to the terminated worker,
make a copy and p 1 ace in the workers f i 1 e fo 1 der.
11
A copy of t.he
NRC Form 5 was to be placed in the individuals personnel exposure
file and a copy mailed to the radiation workerr
The inspector reviewed the individual personnel exposure files,
for several radiation workers that had completed a work assignment
and a personnel monitoring period at the station in 1994, for the
following documents:
0
- -**
0
0
0
0
0
"Determination of Prior Dose Statement," (Form HP-1031.0ID-
l) ;
"Individual Whole Body Count Record and Evaluation," (Form
HP-1041.010-1);
"Request For Report of Workers Exposure To Radiation," (Form
HP-1031-010-2);
"Cumulative Occupational Exposure History (Equivalent NRC
Form 4)," (Form HP-1031-010-4);
"Occupational Exposure Record For A Monitoring Period (NRC
Form 5),
11 (Form HP-1031-010-5); and
"Occupational Radiation Dose Report," (Form HP-1031.010 5-
1) .
In general, the inspector found records were appropriately filed,
completed as required, and received appropriate reviews.
However,
the inspector did identify some problems with one of the records
7
reviewed.
During the period of September 26, 1994 through
December 21, 1994; a contractor working for the licensee arrived
and departed from the site on three separate occasions and was
monitored for radiation dose in the following three periods:
0
September 26 through October 3, 1994;
0
October 24 through October 28, 1994; and
0
November 21 through December 21, 1994.
The inspector determined that the NRC Form 5 for the September 26,
through October 3, 1994 monitoring period was not in the
individual's personnel exposure file. The inspector reported the
finding to the Dosimetry Supervisor.
The Dosimetry Supervisor
began an investigation concerning the missing document and later
reported that the NRC Form 5 had not been generated.
The
inspector stated that failure to generate the NRC Form 5 for th~
radiation worker and the individual's radiation exposure records
was a violation of licensee's procedural requirements. This NRC
identified violations is not being cited because criteria
specified in Section VII.B of the NRC Enforcement Policy were
satisfied .
NCV 50-280, 281/95-02-01:
Violation of TS 6.4.B requirements for
failure to follow procedures for generating NRC Form 5_ for an
individual_ terminating personnel radiation monitoring period.
In reviewing the licensee's process for generating the NRC Form 5
the inspector determined the following.
The radiation Worker
reported back to the site approximately 21 days following the
_previous assignment.
An Exposure Control Technician, recognizing
the worker had recently been assigned dosimetry at the site,
accessed the PREMS data base and removed the termination date
(October 3, 1994) of the previous monitoring period to reactivate
the individual in the dose tracking system.
The PREMS system
permitted the removal of a monitoring period termination date to
correct an incorrect data entry. The licensee's procedures did
not address the process performed by the technician and was not
the process the licensee wanted to perform.
The licensee wanted
to define and process each monitoring period separately.
Additionally, the inspector noted that the technician had noted
the above actions on a form used to document the generation of the
NRC Form 5s for radiation workers having completed an assignment *
and radiation monitoring period at the site. The inspector
determined that the form "Termination/Transfer Log" and it's use
was not addressed in approved and controlled licensee procedures.
The inspector stated that failure to describe the use of the .form
in written and controlled procedures appeared to be violation TS
procedure requirements. This NRC identified violation is not
being cited because criteria specified in Section VII.B of the NRC
Enforcement Policy were satisfied.
8
NCV 50-280, 281/95-02-02:
Violation of TS 6.4.B requirements for
use of a dosimetry records procedure that was not controlled and
approved.
The licensee responded promptly to the identified violations.
Corrective actions included:
0
Generation and transmittal of the missing NRC Form 5
document to the individual and his exposure files;
0
Exposure Control personnel were instructed on proper
procedures to follow when processing in a radiation worker
that has returried before the termination process for a
previous monitoring period has been completed; and
0
Initiated a procedure revision to HP-1031.010 to describe
proper termination process and use of the
"Termination/Transfer Log" form.
No deviations were identified.
c.
Declared Pregnant Women Records
10 CFR 20.1003 defined a DPW as a woman who has voluntarily
informed her employer, in writing, of her pregnancy and the
estimated date of conception.
10 CFR 20.1208(a) required that the
dose to the embryo/fetus not exceed 500 mrem during the entire
pregnancy due to the occupational exposure of a DPW.
10 CFR 20.2106(e) required each licensee to maintain the records
of dose to an embryo/fetus with the records of the DPW.
The
declaration of pregnancy shall also be kept on file, but may be
maintained separately from the dose records.
The licensee's DPW policy was clearly described in VPAP-2101.
The
definition of a DPW was provided in Section 4.0, "Definitions" and
the licensee's dose limits for a DPW were specified in*
Section 6.3.2 which agreed with the limits of 10 CFR 20.1208(a)
and (d).
VPAP-2101 clearly stated that the choice to declare or
not to declare pregnancy was strictly voluntary, a DPW may choose
any of the options and could withdraw her declaration at any time.
HP-1031.020, Administrative Dose Control, Rev. 0, dated
December 7, 1993, reflected the DPW program requirements of VPAP-
2101.
.
In the previous inspection, the inspector requested a list of
individuals that had declared DPW and attempted to review the
individual's personnel exposure records, maintained by the Records
Department, to determine that "Voluntary Declaration of Pregnancy"
documents were maintained as required by 10 CFR 20.2106(e).
The
inspector was unable to find most of the required DPW documents in
the individual's exposure record files.
The finding was reported
9
to licensee management and the licensee was able to present the
applicable documents for the inspector's review the following day.
Licensee representatives reported that the records had been sent
to Records Department but had not been filed in the exposure files
when they were requested by the inspector.
The inspector reported
a review of the disposition of personnel dosimetry records would
be made in a future inspection as IFI 50-280, 281/94-26-03.
The inspector reviewed the dosimetry files for all radiation
workers that had DPW status in 1994.
The inspector found all DPW
documentation in the reviewed files, as required by licensee
procedures, and stated that the IFI would be closed.
No violations or deviations were identified.
6.
Internal Exposure Control (83750)
10 CFR 20.1502(b) requires each licensee to monitor the occupational
intake of radioactive material by and assess the committed effective
dose equivalent to:
(1)
Adults likely to receive, in one year, an intake in excess of
10 percent of the applicable Annual Limit of Intake. in Table 1,
Columns 1 and 2 of Appendix B to 10 CFR 20.1001-20.2401; and
(2)
Minors and declared pregnant women likely to receive, ,none year,
a committed effective dose equivalent in excess of 0.05 rem.
10 CFR 20.1204(a) states that for the purposes of assessing dose used to
determine compliapce with occupational dose equivalent limits, each
licensee shall, when required under 10 CFR 20.1502, take suitable and
timely measurements of:
(1)
Concentrations of radioactive materials in air in work areas; or
(2)
Quantities of radionuclides in the body; or
(3)
Quantities of radionuclides excreted from the body; or
(4)
Combinations of these measurements.
10 CFR 20.llOl(b) required that the licensee use, to the extent
practicable, procedures and engineering controls based upon sound
radiation protection principles to achieve occupational doses and doses
to members of the public that are ALARA.
Through discussions with licensee representatives, the inspector
determined that the licensee had continued to reduced the use of
respirators in various activities in recent years.
Licensee
representatives reported that the reduction in use of respirators had
resulted in some personnel contaminations. A summary of the respirator
use, annual site dose and number of PCEs are showed below.
The figures
10
show increases in the number of personnel contaminations with the
reductions in respirator usage from 1993 through 1994.
The licensee
reported that there were a total of 151 special WBCs requested by HP
staff during 1994 which was up significantly from the 3 made in 1993.
However, most of these WBCs were precautionary with the highest internal
dose reported by the licensee for 1994 being 11 mrem.
Year
Dose
No. Resp.
Skin Clothing Actual
Goal
1992
538
10,461
56
66
122
160
1993
387
2,276
72
27
99
115
1994
378
343
125
74
199
0
1995
2*
0
0
0
0
0
- Time of inspection
No violations or deviations were identified.
7.
Control of Radioactive Materials and Contamination, Surveys, and
Monitoring (83750)
This program are was reviewed to determine whether survey and monitoring
activities were performed as required and control of radioactive
materials and contamination met requirements.
10 CFR 20.150l(a) 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 .and (2) are reasonable under the circumstances to evaluate
the extent of radioactive hazards that may be present.
10 CFR Part 20, Subpart J - Precautionary Procedures, describes posting
requirements for radiation, high radiation, very high radiation,
airborne radioactivity areas and radioactive material use and storage
areas.
During the onsite inspection, the inspector toured selected areas of the
Auxiliary Building, Instrument Calibration Facility, Fuel Handling *
Building, and yard storage areas. The inspector noted:
0
Portable radiation detectors, air samplers, and friskers and
contamination monitors had up-to-date calibration stickers and had
been source-checked as required;
Containers, materials, and areas were properly labeled, posted,
and/or safeguarded in accordance with radiation hazards present;
and
,.
11
0
Posting and control of radiation areas, high radiation areas,
contamination areas, and radioactive material areas were adequate.
All signs were conspicuous, legible and no problems were observed
with radiological postings.
No concerns with control of radioactive material or contamination
controls were identified.
No violations or deviations were identified.
8.
- Program for Maintaining Exposures As Low As Reasonably Achievable
(83750)
.
This program area was reviewed to determine the involvement of ALARA
program.
Areas reviewed included organization support, goals and
objectives, radiation source reduction, worker awareness and
involvement, ALARA plans, and ALARA results in the implementation of the
licensee's ALARA program.
10 CFR 20.llOl(b) requires that each licensee use, to the extent
practicable, procedures and engineering controls based upon sound
radiation protection principles to achieve occupational doses and doses
to members of the public that are ALARA.
The site's collective dose goal for 1994 was set at 642.0 person-rem.
The licensee had completed a Unit 1 RFO and two S/G cleaning outages in
1994.
A summary of licensee dose (person-rem) per outage and recent
years is shown below.
The licensee has generally met collective and
outage dose goals and has compared well with similar facilities in 1993
and 1994.
The 1993 collective dose average for PWRs was 194 person-
rem/unit.
At the time of the inspection the licensee's 1995 collective
dose was 1.7 person-rem below projected 4.5 person-rem for tha'tperio~.
Collective Personnel Exposure (Person-Rem)
Year Outage
Actual
Target
Outage Dates
Collective Goal
1992
Ul-RFO
479.0
477 .0
2/29/92-5/3/92
538.0
654.3
1993
U2-RFO
305.9
466.7
3/6/93-5/5/93
386.7
395.0
1994
Ul-RFO
232.8
311. 7
1/22/94-3/26/94
378.0
642.0
U2-S/G
28.8
20.0
6/4/94-6/25/94
Ul-S/G
28.9
21.5
ll/28/94-12/25/94
1995
U2-RFO
199.6
2/2/95-64 days
460.3
Ul-RFO
190.7
9/1/95-62 days
The original goal for 1994 was 642 person-rem which was set for two
RFOs.
The licensee lowered the goal to 325 person-rem in July of 199A
with the movement of the Unit 2 RFO into 1995.
Had the licensee just
subtracted the estimated Unit 2 RFO dose, the revised goal for 1994
- ,
12
would have exceeded 400 person-rem.
However, the licensee made the goal
more challenging at 325 person-rem.
The licensee was able to complete
the Unit 1 RFO with 233 person-rem significantly below the target of
312 person-rem.
In October the 1994 annual dose goal was revised again
with the addition of secondary S/G cleaning outages and raised to
365 person-rem as a "Stretch Target." Re-work on a reactor coolant pump
and additional work with the chemical cleanup of the S/Gs contributed to
dose in excess of the 365 person-rem target.
The inspector determined
that the licensee was attempting to make realistic goals that were
challenging with the removal and addition of significant work during the
period.
The inspector discussed initiatives, for both immediate and long term
dose savings, that recently had been completed or were planned for
implementation.
The licensee was evaluating and utilizing technological improvements in
remote radiation monitoring equipment, dosimetry, visual monitoring and
communication equipment to better control and assess radiological
conditions and lower personnel exposures.
During the inspection, the
inspector discussed the use of the equipment in previous outages and the
plans for the upcoming Unit 2 RFO.
The licensee had improved the Video
Information Management System to permit overlays with radiation
information such as dose rates an appropriate RWP for area shown .
The ALARA staff consist of a ALARA Coordinator and four technicians
during non-outage periods with two additional ALARA contract technici"ans
during outages.
In addition, another 8-10 personnel were provided
during outages to support shielding activities. The inspector
determined that each of the ~ite's departments had an assigned
individual with some ALARA c"clo"rdinating duties. These personnel
received some ALARA training and had contributed to various ALARA
activities including: maintenance (maintenance representative); hotspot
flushing (operations representative); and shielding (engineering
representative).
The licensee's ALARA program appeared to have appropriate management
support and was effective in maintaining personnel exposures ALARA.
No
concerns with the licensee's ALARA program were identified.
No violations or deviations were identified.
9.
Action on Previous Inspection Findings (92701 and 92702)
a.
(CLOSED) VIO 50-280, 281/94-26-01:
Failure to follow TS required
procedures.
During the previous inspection of radiation protection activities,
the inspector reviewed the licensee's procedures for access
Three examples of failure to follow
procedures were identified. Specifically:
..
10.
-- --- - -
13
~
Failure-of six radiation workers to follow procedures and
utilize the appropriate RWP for access into a posted and
controlled VHRA (First Example);
~
Failure to follow radiation control procedures requiring
SNSOC approval for three RWPs utilized to control work in
the Incore Sump Room, a posted and controlled VHRA (Second
Example); and
~
Failure to issue keys to a posted and controlled VHRA in
accordance with licensee procedure HP-1032.061 (Third
Example).
The inspector reviewed the licensee's corrective actions described
in the licensee's response to the violations dated December 2,
1994, and verified that the corrective actions had been completed
and were implemented.
Specifically:
0
0
0
0
The outdated VHRA key control logs found by the inspector
were removed and replaced with the required log from
procedure HP-1032.061;
HP-1032.061 was revised (Rev. 1, Effective October 27, 1994)
- to include controls for initial entry and work in the Incore
Sump Room;
Procedures were revised to clearly define SNSOC requirements
for entries into posted VHRAs; and
HP Shift supervisors were required to review the procedural
requirements for VHRA access controls with their personnel.
The inspector reported the item would be closed.
b.
(CLOSED) IFI 50-280, 281/94-26-03:
Review licensee's procedures
and program for personnel exposure record maintenance.
The
inspector reviewed selected personnel exposure records for all
DPWs in 1994 and found all records satisfactory. The inspector
also reviewed records for numerous individuals completing a
radiation monitoring period in 1994 and generally found the
records complete.
Two NCVs concerning personnel exposure record
procedures were identified and discussed in Paragraph 5 of this
report.
The inspector reported the item would be closed.
Exit Meeting
The inspection scope and findings were summarized on January 20, 1995,
with those persons indicated in Paragraph 1.
The inspector described
the areas inspected and discussed in detail the inspection results
listed below.
Dissenting comments were not received from the licensee.
Proprietary information is not contained in this report .
~---
I.YQg_
Item Number
14
Status
Closed
Description and Reference
Failure to follow procedures,
three examples (Paragraph 9).
50-280, 281/94-26-01
IFI
50-280, 281/94-26-03
Closed
Review licensee processing and
document control of personnel
dosimetry records
(Paragraph 9).
- NCV
50-280, 281/95-02-01
Closed
Violation of TS 6.4.B
requirements for failure to
follow procedures for
generating NRC Form 5 for an
individual terminating
personnel radiation monitoring
period (Paragraph 5).
50-280, 281/95-02-02
Closed
Violation of TS 6.4.B
requirements for use of a
dosimetry records procedure_
that was not controlled and
approved (Paragraph 5).
11.
Index of Abbreviations Used in this Report
CFR
HPT
IFI
IR
mrad
mrem
NET
NRC
PREMS
REV
RFD
S/G
SNSOC
As Low As Reasonably Achievable
Computer Based Training
Code of Federal Regulations
Declared Pregnant Woman
High Efficiency Particulate Air-filter
Health Physics Technician
Inspector Followup Item
Inspection Report
Milli-Radiation Absorbed Dose
Milli-Roentgen Equivalent Man
Non-Cited Violation
Nuclear Employee Training
Nuclear Regulatory Commission
Personal Contamination Event
Personnel Radiation Exposure Management System
Planned Special Exposure
Pressurized Water Reactor
Radiation Control Area
Revision
Re-Fueling Outage
Radiation Protection
Resistive Temperature Detector
Radiation Work Permit
Station Nuclear Safety and Operating Committee
15
Total Effective Dose Equivalent
Thermoluminescent Dosimeter
TS
Technical Specifications
Ul
Unit I
U2
Unit 2
Very High Radiation Area
Violation
VPAP
Virginia Power Administrative Procedure
Whole Body Counting