ML18152A374
| ML18152A374 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/08/1988 |
| From: | Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A375 | List: |
| References | |
| 50-280-88-16, 50-281-88-16, NUDOCS 8807120359 | |
| Download: ML18152A374 (13) | |
See also: IR 05000280/1988016
Text
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Report Nos.:
50-280/88-16 and 50-281/88-16
Licensee:
Vir~inia Electric and Power Company
Richmond, VA
23261
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
Inspection Conducted:
May 2-6, 1988
License Nos.: DPR-32 and DPR-37
Inspecto~,1-~,,F~
rlat~ Signed
Accompanying Personnel:
R. B. Shortridge
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Approved by:
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~:._ C. M. H\\osey, Se~tion Chief
Division of Rad~ation Safety and
Date Signed
Safeguards
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the area of the
radiation protection aspects of the Unit 1 outage including:
organization and
management controls; training and qualifications; external exposure control and
dosimetry; internal exposure control and assessment; control of radioactive
materials and contamination, surveys and monitoring; the program to maintain
exposure as low as reasonably achievable (ALARA) and followup on open items and
IE Notices.
Results:
Four violations were identified - 1) failure to provide radiation
monitoring devices for entry into high radiation areas, 2) failure to perform
adequate surveys to evaluate the extent of airborne radioactive material
present, 3) failure to follow radiological procedures and 4) failure to
adequately label containers/items of radioactive material .
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REPORT DETAILS
1.
Persons Contacted
- Licensee Employees
W. Cook, Operations Supervisor, Health Physics
D. Densmore, Assistant Supervisor, Health Physics
C. Early, ALARA Coordinator, Health Physics
C. Foltz, ALARA Coordinator, Health Physics *
B. Garber, Technical Supervisor, Health Physics
- W. Grady, Supervisor, Non-Destructive Examination (NDE)
- E. Grecheck, Assistant Station Manager, Nuclear Safety and Licensing
- A. McNeil, Supervisor, Inservice Inspection and Testing
- G. Miller, Licensing Coordinator
- J. Price, Manager, Quality Assurance
- S. Sarver, Superintendent, Health Physics, Surry
~A. Stafford, Superintendent, Health Physics, North Anna
Other 1 i censee employees contacted included engineers, technicians,
mechanics, security force members, and office personnel.
Nuclear Regulatory Commission
- W. Holland, Senior Resident Inspector
- Attended exit interview
2.
Exit Interview
3.
The inspection scope and findings were summarized on May 6, 1988, with
those persons indicated in Paragraph 1 above.
The inspector described the
areas inspected and discussed in detail the inspection -findings including
four apparent violations:
1) failure to provide radiation monitoring
devices for entry into high radiation areas (Paragraph 4.C), 2) failure to
perform adequate surveys to evaluate the extent of airborne radioactive
material present (Paragraph 4.d), 3) failure to adhere to radiological
control procedures (Paragraph 4.d), and 4) failure to adequately label
containers/items of radioactive material {Paragraph 4.e).
The inspector
also discussed the licensee
1 s program for developing and implementing
revised health physics procedures.
No dissenting comments were received from the licensee. The licensee did
not identify as proprietary any of the materials provided to or reviewed by
the inspector during this inspection .
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
2
4.
Occupational Exposure During £xtended Outages
a.
Organization and Management Controls (83722)-
(1)
Planning and Preparation
The present Health Physics (HP) organization, staffing levels and
1 i nes of authority as related to outage radiation protection
acti vi ti es were discussed with 1 i censee representatives.
-The
organizational responsibility and control of the contractor HP
technicians used during the outage was also discussed.
After
training had been completed and verified, contractor HP technicians
were integrated into the licensee's work force and were assigned jobs
commensurate with their expedence and qualifications.
Licensee
personnel were placed in supervisory roles over the contract foremen
and technicians to assure compliance with established procedures and
quality of work.
A total of 82 contractor health physics technicians
(HP techs) and 65 decontamination personnel (deconners) had been
recruited for the outage.
(2)
Health Physics Procedures
During the inspection, numerous licensee HP procedures were reviewed.
The inspector noted several i-nstances where there appeared to be
inconsistencies or contradictions in the guidance or requirements in
the procedures.
These items were discussed with licensee
representatives. - The licensee indicated that they were aware of the
apparent inadequacies of the HP procedures and had therefore
established a program to upgrade and improve the procedures.
The
program to upgrade and improve procedures resulted from an outside
review by two different contractors of the Station Health Physics
Program in 1983.
As a result of the contractors' evaluation, the
licensee decided to revise HP procedures to improve the program and
to have a corporate document to describe functions and responsibilities
and define utility radiation protection policies. Therefore in 1984,
the licensee drafted the Radiation Protection Plan (RPP).
In August
of 1984, a transition plan was issued by corporate HP that estabilshed
a schedule for the development and implementation of station procedures
that would reflect the policies and requirements in the RPP.
The
first transition plan called for implementation of 240 procedures,
divided into 9 major groups, by 1985.
The RPP was formally approved
in April of 1985, by the Vice President of Nuclear Operations, and
status report #2 of the transition plan indicated that the scheduled
implementation of procedures would be complete in 1986.
The latest transition plan status report #14 estimated total plan
implementation by 1989.
While many of the procedues have been
developed, only 2 of the 9 major groups of procedures have been
implemented.
The licensee's reasons for delays in full
implementation of the HP procedures were that the approval process
3
required --that both stations, Surry and North Anna, approve the
procedures, the procedures receive Quality Assurance concurrence, and
the station admi ni strati ve procedures require that- *many of the HP
procedure formats be restructured.
The inspector informed the
1 i censee that progress in development and implementation of the
revised HP procedures
would be an open item and would be reviewed
during subsequent inspections (50-280, 281/88-16-01).
b.
Training and Qualifications
Contractor Health Physics Technician Training
The licensee is required by 10 CFR 19.12 to provide radiation
protection training to workers including contractors.
Regulatory
Guides 8.13, 8.27, and 8.29 outline topics that should be included in
such training.
Chapters 12 and 13 of the Final Safety Analysis
Report (FSAR) also contain further commitments regarding training.
The inspector discussed training of contractor health physics
technicians with the licensee's training staff.
Contract health
physics technicians receive approximately one week of training prior
to assignment to in-plant radiological operations.
To successfully
complete the training phase they must score 70 or better on three
tests.
The first test is given on the first day of arrival to
ascertain their kn owl edge of regu 1 a tory requirements.
The test
contains questions regarding Title 10, Code of Federal Regulations,
Part 20, Standards for Protection Against Radiation.
If the
technicians successfully complete the test they attend two days of
General Employee Training (GET) that includes a practical factors
session where they must demonstrate their knowledge of elementary
radiological techniques.
Upon completion of GET, the contract
technicians receive two days of site specific training that includes
instruction on detection and handling hot particles.
The site
specific training is designed to ensure that the technicians, upon
successful completion of the test, are thoroughly familiar with Surry
radiological procedural requi~ments and radiological work practices.
The inspector reviewed selected lesson plans and tests and determined
that the level of difficulty was sufficient to make an adequate
determination of the candidates'
knowledge and ability in
radiological protection commensurate with their duties.
The contract
technicians also must successfully pass 13 job performance measures
to show their proficiency in standard duties that plant health
physics technicians perform.
No violations or deviations were identified.
c.
External Occupational Exposure Control and Dosimetry
(1)
The licensee is required by 10 CFR 20.101, 20.102, 20.2dl(b),
20. 202, 20. 401 and 20. 407 to maintain workers
I doses be 1 ow
specified levels and_ to keep records of the exposure.
4
During tours of the Auxiliary Building and Unit L containment,
the inspector observed the use of thermoluminescent dosimeters
(TLDs) and self-reading dosimeters (SRDs).
Individuals wearing
protective clothing (PCs) routinely placed their TLD in a pocket
on the inside of the PCs; while the SRO was placed in a plastic
bag and worn outside the PCs so that radiation exposure could be
monitored periodically.
Extremity monitoring or multi-badging
was also used in areas where large dose rate gradients existed
or when individuals were required to work in close proximity to
items with high radiation dose rate.
The placement of such
dosimetry was specified and supervised by Health Physics
personnel and the dosimetry was typically worn in a whirl pack
taped on the outside of the PCs.
The inspector reviewed the computer printout of personnel
exposures generated for the station.
One individual was
noted to have exposure in excess of the station administrative
control level of 750 millirem per quarter and that exposure had
occurred during the first quarter of 1988.
The licensee was
still assessing exposure that occurred during that incident and
further dose assignments will be forthcoming.
The inspector also reviewed selected exposure records of
permanent station, as well as temporary contractor personnel and
verified that a Form NRC-4 or equivalent was properly filed
before an individual was authorized to exceed the 1.25 rem per
quarter limit.
No individuals had received exposures in excess
of the 10 CFR 20.lOl(b) limits during the first quarter of 1988
or to date through the second quarter of 1988.
No violations or deviations were.identified.
(2)
Control of Radiation Areas, Posting and Labeling
10 CFR 20.203 specifies the posting, labeling and control
requirements for radiation areas, high radiation areas, airborne
radioactivity areas and radioactive materials.
During tours of the plant, the inspector reviewed the licensee
1 s
posting and control of radiation areas, high radiation areas,
airborne radi cacti vity areas, contamination areas, and
radioactive materials storage areas.
The inspector performed
independent radiation surveys throughout the facility using NRC
equipment and verified that radiation fields measured were
consistent with area postings.
No violations or deviations were identified.
(3)
High Radiation Area Control
5
Technical Specification 6.4.B.l.e requires that any individual
or group of individuals permitted to enter a high radiation area
(in which the intensity of radiation is greater than 100 mR/hr
but less than 1000 mR/hr) shall be provided with a radiation
monitoring device which continuously indicates the radiation
dose rate in the area.
Health Physics Procedure HP-2.13, Locked High Radiation Area
Access Control, dated April 19, 1984, states in Section 2.1 that
a dose rate meter is required for all entries into high
radiation areas (i.e., greater than 100 mR/hr) and is required
to be turned on continuously while in such areas.
Prior to each entry into Unit 1 containment, the inspector
requested and was issued a radiation monitoring device by the
licensee.
The instrument was used to verify dose rates in
various areas throughout containment and to enter high radiation
areas.
During tours on May 3 and May 4, 1988, the inspector
entered the high radiation area (HRA) on the 18 foot elevation
in the
11C
11 Reactor Coolant Pump (RCP) cubicle and on the -27 foot
elevation which included the entire lower level of containment.
Generally occupied areas in these HRAs had dose rates that varied
from 10-40 mR/hr and work area general dose rates that varied
from 10-600 mR/hr.
On the morning of May 4, 1988, at approximately 10:30 a.m. two
workers were observed entering the -27 foot elevation from the
elevator and crossing the barrier posted as a high radiation
area.
The workers were not carrying a dose. rate meter but
reported to a contract HP technician assigned to that elevation.
When questioned about this practice, the HP technician indicated
that it was standard practice for people entering containment on
the 47 foot elevation to check with HP there and the HP
technician would then call the HP rover on the elevation the
workers were assigned to work on.
The workers were then allowed
to-90 to the -27 foot elevation by way of the elevator or the
stairs and enter the HRA without having a radiation monitoring
device as long as they reported to the HP rover upon initial
entry.
The inspector discussed this practice with the 1 i censee
representatives and was informed that this was not station
policy.
The licensee indicated that every individual or group
was to have a monitoring device in their possession to enter a
HRA.
During the afternoon of May 4, 1988, between approximately
4:00 and 6:00 p.m. two other groups of individuals were observed
entering the HRA on the -27 foot elevation, one group from the
elevator and one group from the st~irway.
No one in either
gr.oup had a dose rate meter but both groups did report to the HP
rover for the -27 foot elevation prior to starting work.
6
Failure to provide each .indjvidual or groups of individuals
permitted to enter a high radiation area with a radiation
monitoring device was identified as an apparent violation of
Technical Specification 6.4.B.1.e (50-280, 281/88-16-02).
d.
Internal Exposure Control and Assessment
(1)
Engineering Controls
10 CFR 20.103(b)(l) requires that the licensee use process or
other engineering controls to the extent practicable to limit
concentrations of radioactive materials in the air to levels
below those which delimit an airborne radioactivity as defined
in 20.103(d)(l)(ii).
The Surry Respiratory Protection Manual Policy Letter requires
that, to meet the primary objective of limiting the inhalation
of airborne radioactivity, station management must ensure that
available engineering controls are being utilized to the fullest
extent possible.
During tours of the Fuel Handling Building, the use of
engineering controls in the form of two large tents constructed
to facilitate work on two reactor coolant pumps was observed.
The tents were equipped with ventilation ducting and associated
high efficiency particulate air (HEPA) filters to limit spread
of contamination and reduce airborne radi cacti vity.
However,
the use of engineering controls in other areas of the station,
including Unit 1 containment, with general area contamination
levels from 5,000 to 200,000 disintegrations per minute per
100 square centimeters (dpm/100 cm2 ), was not as apparent and
the extensive use of respiratory protection was noted inside
containment.
The inspector observed many jobs which involved
welding, grinding or drilling on what was reported to be "clean"
areas or items by the HP techs covering the work.
The workers,
however, were still required to wear respiratory protection.
Reasons given for using respirators during work on "clean" items
or in clean areas included: 1) the workers "liked" to wear
respirators, 2) the HP techs required them because the workers
were using -contaminated equipment, i.e., drills, grinders and so
forth, and 3) the workers felt that wearing a respirator would
help prevent a skin contamination event.
In discussions with the licensee, the use of engineering
controls and
respiratory protection, as well
as
the
contamination levels inside Unit 1 containment, was addressed.
The licensee indicated that engineering controls in the form of
decontamination of work areas had been used prior to allowing
jobs to be worked.
It was also noted that, although the use of
respirators in areas or on systems that were
11 clean
11 was a very
conservative practice, it was preferable to not requiring it.
7
The inspector noted that there was possibly a more basic problem
of high general area contamination levels which would lead to
this conservatism, even after local, work area decontamination
had been performed.
Licensee representatives indicated that
they were cognizant of that possibility and were considering an
extensive decontamination of the entire Unit 1 containment to
reduce contamination levels, as well as help prevent or limit
the number of personnel contamination events.
No violations or deviations were identified ..
(2)
Air Sampling
The licensee is required by 10 CFR 20.20l(b) to make or cause to
be made such surveys as (1) may be necessary to comply with the
regulations and (2) are reasonable under the circumstances to
evaluate the extent of radiation hazards that may be present.
10 CFR 20.103 establishes the limits for exposure of indivi~uals
to concentrations of radioactive materials in air in restricted
areas.
Section 20.103 also requires that suitable measurements
of concentrations of radioactive material in air be performed to
detect and evaluate the airborne radioactivity in restricted
areas and that appropriate bioassays be performed to detect and
assess individual intakes of radioactivity.
Health Physics Procedure HP-3.3.2, .Health Physics Survey -
Airborne Radioactivity, dated November 20, 1984, requires in
Section 3.1.4 that all air samples taken to assess airborne
hazards to personnel be* collected as near the anticipated
breathing zones as possible.
Health Physics Procedure HP-3.7.2, Health Physics Survey -
Station, dated November 5, 1985, requires in Section 3.4.2 that
general area grab samples be representative of the worker
1 s
breathing zone.
During tours of the Unit 1 Containment on May 3, 1988, the
inspector observed HP techs taking air samples in support of
various jobs in progress.
In three instances, it was noted
that, the air sample being taken was not representative of the
workers breathing zone.
An air sample taken in the area of the
"A
11 Recirculation Spray Heat Exchanger on the -27 foot elevation
in support of flapping operations on the inlet pipe under
Radiation Work Permit (RWP) 88-1298, was taken in an area
approximately 15 feet from the worker, at knee level.
Ano~her
air sample taken in the Pressurizer Cubicle on the 18 foot
elevation to s~pport grinding operations under RWP 88-1306, was
taken at the airborne radioactivity barrier approximately 10
feet from the workers and was taken as the job was terminated.
Another air sample was taken in an area near the grinnel valves
e.
8
on the .-27 foot elevation under RWP 88-1441, and approximately
seven feet away from the workers replacing valve diaphragms.
Failure to evaluate adequately the radiation. hazards that may
have been present was identified as an apparent violation of
10 CFR 20.20l(b) (50-280,281/88-16-03).
(3)
Area Posting
Technical Specification 6.4.D requires that radiation control
procedures be followed.
Health
Physics
Procedure H.P.3.7.1,
Radiological
Area
Designation, Posting and Control, dated November 5, 1985,
requires in Section 4.2.8.3.C that areas be posted
11 Respiratory
Protection Required for Entry
11 when respirators are required by
Health Physics and/or by the Radiation Work Permit.
While observing jobs in progress inside Unit 1 containment on
May 3, 1988, the inspector observed workers on the 47 foot
elevation of Unit 1 containment removing highly contaminated
scaffolding (greater than 100,000 dpm/100cm 2 ) from a storage van
container while wearing respiratory protection.
The workers
were inside an area posted
11Respiratory Protection Required for
Entry,
11 and were transferring the scaffolding to workers on the
-27 foot elevation.
The workers on the lower level were also
wearing respiratory protection but the area was not barricaded or
posted as respiratory protection required and people not in
respirators passed near by or through the area during the
operation.
During work on the Recirculation Spray Heat Exchanger on the
-27 foot elevation on May 3, 1988, the inspector observed an
individual lapping the contaminated inlet pipe of the heat
exchanger with pre-work contamination levels of 5,000 to
200,000 dpm/100 cm2 *
The individual was required to wear a
respirator but the area was not barricaded or posted
11 Respiratory
Protec ti on Required for Entry.
11
The HP tech covering the work
indicated that the lapping work was being done on a
decontaminated area of the pipe but did not indicate the reason
for the lack of a barrier or posting.
Failure to post areas
where respiratory protection was required to be worn with the
precautionary sign indicating
11 Respiratory Protection Required
for Entry
11 was identified as an apparent violation of Technical
Specification 6.4 (50-280,281/88-16-04).
Control of Radioactive Material and Contamination, Surveys, and
Monitoring
The licensee is required by 10 CFR 20.201(b), 20.401, 20.403 to
perform surveys and to maintain records of such surveys necessary tci
..
9
show compliance with regulatory 1 imi ts.
Survey methods and
instrumentation are outlined in the FSAR, Chapter 12.
(1)
Contamination Surveys
While touring the facility, the inspector observed workers
exiting the radiation control area (RCA) and the movement of
material from the RCA to clean areas to determine if ad*equate
surveys were being performed by workers and if adequate direct
and smearable contamination surveys were performed on materials.
All personnel and material surveys appeared to be adequate.
The
inspector also reviewed records of personnel contamination
events for the current outage.
During the first week of the
outage the number of personnel contaminations was from two to
nine per day.
As the work scope increased and more personnel
became involved in the outage, the number of contamination
events rose to a maximum of 21 in one day.
In an effort to
reduce the number of personne 1 contami nati ans,. the 1 i censee
stopped all work briefly to assess the problem.
A major
decontamination effort was initiated in the work areas and
workers were required to wear paper coveralls and extra_paper
booties in addition to their regular protective clothing. These
measures reduced the number of contamination events to the
number experienced prior to the work scope increase.
(2)
Survey Results
During plant tours, the inspector examined radiation level and
con~amination survey results posted outside selected areas and
rooms.
The inspector performed independent radiation 1 evel
surveys of selected areas using NRC equipment and compared them
with 1 i censee survey results.
The inspector a 1 so examined
licensee radiation protection instrumentation and verified that
the calibration stickers were current.
( 3)
10 CFR 20. 203 ( f) ( 1) requires that each container of 1 i censed
material shall bear durable, clearly visible label identifying
the radioactive contents.
(2) States that a label shall bear
the radiation caution symbol and the words "CAUTION, RADIOACTIVE
MATERIAL" and that it shall provide sufficient information (such
as radiation levels) to permit individuals handling or using the
containers, or working in the vi ci ni ty thereof, to take
precautions to avoid or minimize exposures.
Health Physics Procedure HP-2.3, Contaminated Equipment and
Component Control, dated February 2, 1987, requires in
Section B.3 that all unattended radioactive material within the
Restricted Controlled Area shall have as a minimum, the words
11 CAUTION, RADIOACTIVE MATERIAL" accompanied by a radiation
symbol and the highest dose rate mR/hr affixed in a readily
visible location.
10
During tours of the yard area surrounding the reactor, auxiliary
and fuel handling buildings, the inspector observed the posting
and control of radiation and radioactive material areas and the
labeling of radioactive material stored in these areas.
In one
large radioactive material area the licensee had stored numerous
B-25 metal boxes containing radioactive material, typically
waste.
It was noted that several of the B*25 boxes had been
recently filled with waste from the current outage as indicated
by writing on red duct tape on the boxes and, at least two of
the B-25 metal boxes had been stored in the area during day
shift, on May 3, 1988.
The inspector noted that these two
boxes, one of which had a radiation level of 48 millirem per
hour (mr/hr) at contact and 5 mr/hr at 18 inches, had no label
bearing the radiation caution symbol nor the words,
11CAUTION,
RADIOACTIVE MATERIAL.
11
It was further noted that the writing on
the red duct tape affixed to the boxes bore the current date,
indicated that radioactive waste was contained therein and that
the contamination levels were less than 1000 disintegrations per
minute per 100 square centimeters ( 1000 dpm/100cm 2 ) on the
exterior but there were no radiation levels given.
When the
licensee was notified, the boxes were immediately surveyed and
proper labeling was applied to each box along with the radiation
levels.
The inspector also noted a Containment Airlock, refurbished
reactor coolant pump, and three other B-25 boxes that did
not have radiation levels indicated on the labels.
The items
were located within posted radioactive material areas.
The
airlock was located near the Unit 1 containment equipment hatch.
The refurbished RCP was located on a flatbed, low-boy trailer
near the east roll-up door of the Fuel Handling Building and the
three B-25 boxes were located near the main entrance/exit to the
yard area from the Personnel Decontamination Area (PDA).
The
boxes and the other two items had labels *affixed on the exterior
surface which bore the radiation caution symbol and the proper
precautionary words but none of the labels indicated radiation
levels.
Failure to provide sufficient information on a label in a
clearly visible location in order to identify the radioactive
contents of containers/items was identified as an apparent
violation of 10 CFR 20.203(f) (50-280,281/88-16-05).
f.
Program for Maintaining Exposures As Low As Reasonably Achievable
(ALARA)
10 CFR 20.l(c) states that persons engaged in activities under
licenses issued by the NRC should make every reasonable effort to
maintain radiation exposure ALARA.
The recomll)ended elements of an
ALARA program are contained in Regulatory Guide 8.8, Information
Relevant to Ensuring that Occupational Radiati-0n Exposure at Nuclear
11
Stations will be ALARA, and 8.10 Operating Philosophy for Maintaining
Occupational Radiation Exposures ALARA.
The
inspector discussed the
Program with licensee
representatives.
The collective radiation exposure goal for 1988,
which included two scheduled refueling outages, was 1,421 man-rem.
The refueling outage goal for Unit 1 (11.795 man-rem per day for 55
days) was 648.725 man-rem.
However, during the inspection, the
schedule was increased to 62 days and the man-rem goal per outage day
projection was adjusted to 9.4.13.
On May 5, 1988, day 25 of the
outage, the average daily collective exposure expended was 6. 291
man-rem and the performance was 66 percent of the projected
collective exposure.
Outage activities have been divided into: 1) replacement of four
recirculation spray heat exchangers, 2) eddy current testing of 900
steam generator tubes and 3) normal refueling activities.
A
significant number of outage tasks were to be performed by a major
nuclear steam system supplier as part of an integrated servicing
program for the uti 1 ity.
To reduce exposure to the maximum extent
possible both the vendor and licensee pe----rformed ALARA Reviews on jobs
greater than one man-rem using the same historical data, when
available.
The licensee then placed a reduction factor of 15
percent on the tasks to represent their committed annual exposure
reduction.
This number and the man-rem resulting from the vendor
ALARA reviews were compared and the lowest estimate was chosen.
The
projected man-rem for collective exposure for the job was factored
into the service contract as an incentive for exposure reduction
performance.
As an example, five major tasks were reviewed for
exposure reduction:
refueling operations, primary steam generator
work, secondary steam generator work, reactor coolant pump work, and
miscellaneous work tours.
The vendor estimated 109.887 man-rem for
the tasks.
The licensee estimated 63. 428 man-rem which was the
man-rem projection placed in the contract.
In mid-April of this year NRC region and headquarters based personnel
performed an assessment of Surry
1s ALARA program.
One result of the
assessment was a finding concerning Surry's primary method of
managing exposure by goals.
Prior to this outage Surry
1s Department
managers relied on a collective exposure goal based on a daily
average man-rem acquired in previous outages to manage personnel
radiation exposure.
The daily exposure for outage or non-outage days
was based on the average exposure from preceding years divided by the
number of scheduled outage and non-outage days for that year.
Previously the daily man-rem goal had been exceeded so frequently
that the goal became an ineffective management tool.
Starting with
this outage a daily health physics status report was implemented.
The report gives the status of jobs relative to the projected man-rem
provided by job-specific ALARA reviews.
Prob 1 ems and methods to
achieve ALARA for the job are discussed by management and supervision
12
at the plan of the day meeting.
The method-of manag~ng exposure by
specific job in lieu of by daily goal appears to have increased the
awareness and participation of station management and supervision in
exposure reduction.
During the inspection, the inspector observed the unloading and
staging of contaminated scaffolding to support outage operations.
A
storage van with highly contaminated scaffolding was unloaded at the
equipment hatch and the scaffolding was then transferred by crane to
the -27 foot elevation for decontamination.
Initial decontamination
of the scaffolding was performed in a high radiation area.
Based on
comments by the inspector, decontamination was secured and later
performed in a radiation area of 30 to 40 mR/hr.
This operation was
discussed with health physics and pointed out to station management
as a poor radiological work practice and not ALARA.
The licensee
acknowledged this as a poor practice and indicated that better
planning would have prevented it.
No violations or deviations were identified.
5.
Licensee Actions On Previously Identified Inspection Findings (92701)
(Closed) Inspector Followup item (IFI) 280/87-35-04, Review License
Procedures for Dropped, Offscale and Lost Self-Reading Dosimeters
The inspector verified that a procedure had been written and implemented
covering SRDs that had been dropped, were offscale or had been lost. The
procedure was implemented April 30, 1988.
6.
Followup On IE Information Notice (92717)
The inspector determined that the following Information Notices had been
received by the licensee, reviewed for applicability, distributed to
appropriate personnel and that action, as appropriate, was taken or
scheduled.
IEN 87-19:
Perforation and Cracking of Rod Cluster Control Assemblies
(Specifically for all Westinghouse PWRs)
IEN 87-28:
Air Systems Problems at U.S. Light Water Reactors
IEN 87-31:
Blocking, Bracing and Securing of Radioactive Materials
Packages in Transportation
IEN 87-39:
Control of Hot Particle Contamination at Nuclear Power Plans
IEN 87-44:
Thimble Tube Thinning in Westinghouse Reactors (For PWRs with
Westinghouse nuclear steam supply system (NSSS))
IEN 87-46:
Undetected Loss of Reactor Coolant (For all PWRs)
IEN 88-08:
Chemical Reactions with Radioactive Waste Solidification
Agents