ML18152A394
| ML18152A394 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/14/1994 |
| From: | Forbes D, Bryan Parker NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A395 | List: |
| References | |
| 50-280-94-05, 50-280-94-5, 50-281-94-05, 50-281-94-5, NUDOCS 9405200330 | |
| Download: ML18152A394 (13) | |
See also: IR 05000280/1994005
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report Nos.:
50-280/94-05 and 50-281/94-05
Licensee:
Virginia Electric and Power Company
Docket Nos.:
50-280, .50-281
License Nos.:
Facility Name:
Surry 1 and 2
Inspection Conducted:
February 14-18 and March 21-25, 1994
Inspectors: fft::/ f.t.
B. ~Parker
~~~~
(2.
Approved By: '--"l_.)..) ~~
~ ~
Scope:
W. H. Rankin, Chief
Facilities Radiation Protection Section
Division of Radiological Protection
and Emergency Preparedness Branch
Division of Radiation.Safety and Safeguards
1 Da e Signed
0'1 /t'l/'1'(
' Date Signed ,
- -/11:j_/9+ .
r Daie S1gned
This routine, announced inspection was conducted in the area of occupational
radiation exposure during outage.
Specific elements of the program examined
included:
organization and management control; audits and appraisals;
training and qualification; external exposure control; internal exposure
control; surveys, monitoring, and control of radioacttve fuaterial;
instrumentation; and maintaining occupational radiation exposure as low ~s
reasonably achievable {ALARA).
Results:
Overall, the licensee's radiation protection program was well 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 and the ALARA program continued to be program
strengths.
One NRC-identified non-cited violation was identified for failure
to properly control contaminated material {Paragraph 7).
9405200330 940415 -
ADOCK 05000280
Q
1.
REPORT DETAILS
Persons Contacted
+J. Abbott, Health Physics {HP) Technician
D. Anderson, Shift Supervisor, HP
- G. Belongia, HP In~tructor, Nuclear Training
- W. Benthall, Supervisor, Licensing
- R. Bilyeu, Engineer, Licensing
+*M. Biron, Supervisor, Radiological Engineering
+D. Boone, Quality Assurance
- J. Butrick, Shift Supervisor, HP
B. Campbell, HP Site Coordinator, Numanco
Z. Edwards, HP Technician
E. Dilandro, HP Technician
B. Dorsey, Supervisor, Exposure Control
J. Hill, Radwaste Facility Coordin~tor, Radwaste
+*D. Erickson, Superintendent, Radiation Protection
A. Fields, Senior Technician, Decontamination
- M. kansler, Station Manager
+*D. Miller, Supervisor, HP Operations
- R. Morgan, Staff Quality Specialist, Quality Assurance
L. Morris, Superintendent, Radwaste
- J. O'Hanlon, Vice-President, Nuclear Operations
+*M. Olin, Supervisor, HP Technical Services
+*J. Price, Assistant Station Manager
L. Ragland, Shift Supervisor, HP
R. Schau, HP Instrument Technician
+S. Scheibe, HP Technician
- E. Smith, Jr., Manager, Quality Assurance
- T. Sowers, Superintendent, Engineering
T. Steed, ALARA Coordinator
.
+*W. Thornton, Director, HP and Chemistry {Corporate)
C. Verelle, HP Technician
J. Wright, HP Technician
Other licensee employees contacted during this inspection included:
craftsmen, engineers, operators, contract personnel, and
administrative personnel.
Nuclear Regulatory Commission
M. Branch, Senior Resident Inspector
- S. Tingen, Resident Inspector
+J. York, Resident Inspector
- Attended Exit Interview conducted on February 18, 1994.
+Attended Exit Interview conducted on March 25, 1994 .
2
2.
Organization and Management Controls (83729)
The inspector reviewed the staffing of the radiation protection (RP)
organization as related to lines of authority and noted no changes
since the previous inspection conducted November 15-19, 1993, and
documented in NRC Inspection Report (IR) 93-25.
The inspector noted
that at the time of the inspection, the licensee maintained an
adequate level of staffing for-the outage with an approximate return
rate of 95 percent utility contract returnees.
At the time of inspection,_ the licensee was approximately mid-way into
a planned 64-day refueling outage on Unit 1.
Along with typical and
routine outage maintenance, the outage also included required IO-year
inservice inspection (ISi) work.
No violations or deviations were identified.
3.
Audits and Appraisals (83729)
The inspector reviewed the lic~nsee's internal program for-
self-identification of weaknesses as it related to the RP program and
the appropri~teness of corrective actions taken.
The progra~ included
Station Deficiency Reports (SDRs) and Radiation Problem Reports
( RPRs) . * Both systems were utilized by the licensee to document,
investigate, and track items of concern.
The SDR system was a
plant-wide system for identification of concerns, while the RPR was a
lower-tier system utilized mainly by the RP organ.ization to identify a
variety of minor concerns .. The inspector noted, that nine SDRs had
been identified and assigned to the RP group for investigation and
corrective action during 1993, while 92 RPRs were initiated in 1993.
In 1994, four RP-related SDRs and five RPRs had been generated at the
time of inspection.
The inspector reviewed selected RPRs from 1993 and 1994 and noted that
t_he 1 i censee was i dent i fyi ng substantive i terns of concern and was
following through with appropriate corrective actions to prevent
recurrence.
Many of the reviewed RPRs dealt with problem~ associated
with the use of digital alarming dosimeters, (DADs), such as damaged or
dropped DADs or problems with radiofrequency (RF) radiation.
No
significant concerns arose from the review of RPRs .. The inspector
also selected SDRs from 1994 and noted no significant concerns, *with
one exception which is discussed in Paragraph 7 of this report. -
The inspector reviewed Radiological 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.
r~*,
3
. Based on the inspectors review of the various levels of audits and
apprai~als performed by the licensee, the inspector determined the
audit and appraisal program was considered to be adequate in
identifying potential issues.
No violations or deviations were identified.
4.
Training and Qualification (83729)
10 CFR 19.12 requires, in part, that the licensee instruct all
individuals working in or frequenting any portion of a restricted area
in the health protection problems associated with exposure to
radioactive material or radiation; in precauti6nJ or procedures to
minimize exposure; in the purpose and function of protection devices
employed; in the applicable provisions of the Commission regulations;
in the individual's responsibilities; and in the availability of
radiation exposure data.
The inspector reviewed the licensee's program for providing training
to both general plant work~rs and HP technicians.
The inspector was
informed that licensee employees received Nuclear Employee Training
(NET) prior to beginning work activities, and were required to*
complete an abbreviated retraining annually.
As of January 1, 1994,
the licensee implemented new retraining requirements .. Classroom
training and testing changed from annual, for Virginia Power
employees, to once every three years.
Retraining during the interim
two years would consist of an annual self-study of the NET manual with
a signed certification from the employee indicating'that the manual
had been reviewed.
Contract employees~ retraining was unchanged,
remaining as annual classroom training and testing. All testing
required a passing grade of 70 percent.* licensee training
representatives indicated that some mechanism may be established that
would randomly ensure that the self-studies were being accomplished as
designed.
They also indicated that a computer-based NET might also be
developed to facilitate training and make it easier to obtain,
accomplish, and audit.
No concerns were noted.
The inspector also reviewed continuing training to be presented to the
RP staff in 1994 and identified no concerns.
The inspector noted that
the continuing training, as planned, would consist of 92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br />, 44
hours, and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for HP Technicians, HP Specialists, and
Decontamination Technicians, respectively. The inspector noted that
each training session required completion of comprehensive written
examinations with at least 70 percent correct, as well as satisfactory
demonstration of applicable tasks as presented during the training.
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 exposure areas, emergency response,
implementation of the revised computer system, and revised 10 CFR Part
20, specifically to address procedural changes resulting from the
revisions.
Any less-than-satisfactory performance was treated on a
4
case-by-case basis, usually receiving one-on-one retraining and
retesting with different tests.
No violations or deviations were identified.
5.
External Exposure Control (83729)
10 CFR 20.1201 (a) requires each licensee to control the occupational
dose to individual ~dults, except for planned special exposures under
20.1206, to the following dose limits:
(I)
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;
(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 r~ms to the skin or to
any extremity.
10 CFR 20.1501(c)(I) and (2) requires that dosimeters used to comply
with 10 CFR 20.1201 shall be processed and evaluated by a processor
accredited by the National Voluntary Laboratory Accreditation Program
(NVLAP) for the types of radiation being monitored.
10 CFR 20.1502(a) requires each licensee to monitor occupational
~xposure to radiation and supply and require the use of individual
monitoring devices by:
(I).
Adults likely to receive, in one year from sources external to
the body, a dose in excess of 10 percent of the limits in
(2)
Minors and declared pregnant women likely to receive, in one
year for sources external to the body, a dose in excess of
10 percent of any of the applicable limits of 10 CFR 20.1207 or
20.1208; and
(3)
Individuals entering a_high or very high radiation area.
a.
Personnel Dosimetry
During tours of the plant, the* inspector observed personnel
wearing appropriate monitoring devices on the location of the
body as specified by Radiation Work Permits (RWPs).
The
inspector reviewed and discussed the licens~e's dosimetry
5
program with site personnel and determined licensee dosimetry
was being processed under NVLAP certification.
The inspector discuss~d the licensee's system used for tracking
dose as well as other worker information, the Personnel
Radiation Exposure Management System (PREMS), and recent
problems associated with it. The licensee developed PREMS as
part of the change to revised 10 CFR Part 20 and, during the
inspection, problems related to the switchover were somewhat
compounded by the outage and the continuous need and use of the
PREMS system.
The DAD system would not interface with PREMS
and PREMS periodically "crashed" due to memory problems,
forcing the licensee to*control access to and exit from the
radiologically-controlled area (RCA) with the DADs manually.
- Overall, the licensee responded well to the problems and no
significant concerns were noted.
The inspector noted that the licensee used OADs pri_marily for
daily dose tracking, with approximately 1500 active DADs being
kept onsite fcir routine exposure moriitoring.
The problems
associated with DADs, which were captured by the RPR system,
were not significant considering the thousands of entries made
into the RCA.
The inspector was informed that the licensee
expected the DAD dose to be one to five percent higher than the
TLD dose during a typical quarter. Correlation results we~e
especially good when individual quarterly doses less than
- 100 millirem were excluded from the correlation calculation due
to high ~argins of error.
For example, in the third quarter of
1993, total TLD dose was approximately one and a half percent
higher than the total DAD dose for the same period.
However,
when the individual doses less than 100 millirem were not
counted, the DAD dose-exceeded the TLD dose by a few percent as
designed.*
b.
Whole Body Exposure
The inspector discussed the cumulative whole body exposures for
plant and contractor employees.
Licensee representatives
stated and the inspector confirmed by a selected review of
dosimetry records that all whole body exposures assigned since ..
the previous NRC inspection of this area were within
10 CFR Part 20 limits. The inspector reviewed licensee
followup actions to an administrative overexposure which
occurred in June of 1992 as discussed and documented in
Inspection Report 50-280, 281/92-16.
Based on a review of
licensee dosimetry records and discussions with licensee
representatives the inspector determined all exposures received
since this event have been within licensee admini~trative
exposure control limits.
'i
c.
6
Personnel Contamination Control
The inspector discussed Personnel Contamination Events (PCEs)
~ith cognizant licensee personnel and reviewed licensee
procedure HP-6.1.20, "Personnel Contamination Monitoring and
Decontamination," Rev. 2, dated November 6, 1990.
In 1993, the
licensee experienced 99 PCEs, and 152 PCEs had occurred in 1994
as of March*25, 1994.
The inspector reviewed selected PCE
reports and noted that these PCEs were attributable to varying
craft personnel and work events. A number of PCEs had resulted
from clothing coming in contact with low level radioactive
particles (hot particles). The licensee had detected
approximately three "tight" leaking fuel pins which may have
contributed to a number of the hot particle PCEs.
Some of the
PCEs we~e attributable to poor work practices; however, other,
- root causes were identified which were not worker controlled.
A review of the PCEs did not indicate any adverse trends.
The inspector reviewed a January 1994 PCE that involved the
contamination of a worker's finger.
The contamination was not
readily removable.
Initially, th~ licensee thought the
contamination may have been inside the hand, perhaps via a
wound, but subsequent investigation ruled out that possibility.
A wound was never found and multiple attempts were made to
decontaminate the finger, but none were very successful.
Whole
body counts showed no internal intake, and eventually,
156 hours0.00181 days <br />0.0433 hours <br />2.579365e-4 weeks <br />5.9358e-5 months <br /> after the individual -had initially alarmed a
personnel monitor, the contamination was no longer detectable.
The licensee investigated the event and concluded that the
radioactive material consisted of a highly-soluble salt-like
compound containing cesium and iodine isotopes and was readily
absorbed by the skin of the hand.
Two different dose
calculations were performed and both calculated skin doses in
the 600-700 millirem range.
Internal dose was estimated to be
less than 0.1 millirem from absorption.
Based on the findings,
the li~ense~ assigned the individual an extremity dose of
703 millirem.
The inspector's review of the issue identified
no significant concerns.
No violations or deviations were identified.
6.
Internal Exposure Control (83729)
10 CFR 20.1204(a)(3) requires, in part, that the licensee, as
appropriata, 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.
7
The inspector reviewed selected licensee procedures which provided
gu_i dance as to when to perform speci a 1 bi oassays, for bi oassay
evaluation, and for subsequent calculation of internal exposures.
The
inspector noted that special bioassays were required to be performed
for facial PCEs or detection of positive nasal swabs.
For th~ PCE
cases reviewed, special whole body analyses were conducted in
accordance with procedural requirements, and all calculated intakes
were less than 10 percent of annual limits of intake {Alls).
Discussion with licensee representatives indicated that Derived Air
Concentration-hours (DAC-hrs) were tracked on an individual basis, and
if 40 DAC-hrs were reached during the year, then an evaluation would
be conducted and dose assignment made.
Internal dose assignment was
also made if a whole body count was "positive." As of
February 17, 1994, the maximum individual internal dose tracked by the
licensee was 2.5 millirem.
The licensee had experienced an increase in the number of low level
positive uptakes from the 1993 Unit 2 outage as a result of respirator-
reduction efforts to reduce the overall dose.
The inspector discussed
with cognizant licensee representatives the engineering controls used
to minimize respirator usage and thereby minimize Total Effective Dose
Equivalent {TEDE) for workers.
The 1994 Unit I outage provided
greater challenges in the area of contamination control than did the
past Unit 2 outage due to the required removal of contaminated
insulation in Unit I to support the IO-year ISI work and the fact that
the overall source term in Unit I was higher than Unit 2.
No concerns
were noted.
No violations or deviations were identified.
7.
Surveys, Monitoring and Control of Contamination and Radioactive
Material (83729)
10 CFR 20.150l(a) requires each licensee to make or cause to be made
such surveys as (l)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.*
The li~ensee continued to effectively control contamination at the
source.* At the end of *1993, the licensee maintained approximately
500 ft
2 of the RCA as contaminated.
The licensee's 1994 goal was to
eliminate contaminated square footage to at least 250 ft 2 *
During the
inspection, contaminated square footage during the outage was in the
4500 ft 2 range, which was typical.
.
The inspector noted during.tours of the plant that very few catch
containments were needed as a means of controlling contamination.
At
the time of inspection, only six containments were in use for active
leaks and a few others were in use for housekeeping and potential *1eak
purposes. Also during tour~, the licensee demonstrated the alarm on
the laundry monitor used to identify protective clothing that was not
8
thoroug~ly decontaminated during the launderihg process.
Alarms prompted the laundry workers to pull the piece of clothing for
relaundering, and if relaundering did not work, the clothing was
either stored to allow the contamination to decay away or it was
- discarded as radioactive waste.
The inspector also no.ted 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.
The inspector verified that incore detectors were "tagged out" in the
control room to prevent movement of the highly irradiated components
while personnel conducted outage activities in and around the incore
detector room.
Licensee Procedure HP-8.U.40, "Contamination Surveys," dated
August 15, 1988, specifies, in Step 4.6.1, that for items surveyed for
unrestricted use, the unrestricted release criteria is (1) loose
surface contamination less than 1,000 disintegrations per minute per
100 square centimeters (dpm/100 cm 2 ) beta-gamma activity and less than
20 dpm/100 cm 2 alpha, and (2) total contamination on any item (fixed
plus removable) less than 5,000*dpm/100 cm 2 *
The inspector discussed
survey documentation and supervisory reviews of surveys with selected
HPs and HP supervisors regarding the maintenance and controls for
survey records.
The inspector reviewed selected surveys and discussed
survey results with cognizant licensee personnel.
As discussed in Paragraph 3, review of SDRs revealed one concern
related to control of contaminated material. Station Deviation
No. 94-0391 was initiated on February 14, 1994, following notification
from a vendor that some contaminated material had been inadvertently
removed from the RCA by them on February 7, 1994.
The contaminated
material consisted of an acoustical sensor and its respective mount
used to evaluate safety injection cold leg ~nd accumulator ~heck
valves during the Unit 1 refueling oufage. The vendor had brought in
and used five of the sensors to do the testing, but mounts for the
sensors had been permanently mounted on the piping*during a past
outage and left for future use to avoid further.direct contact of the
equipment with the piping.
During this outage, however, when the
testing was completed, one of the sensors was removed from the piping
with the mount still attached.
For an unknown reason, the vendor
technician did not realize that one of the five sensors still had its
mount attached.
The vendor technician exited the RCA at the personnel
decontamination area (PDA), whole body frisked, and presented the
sensors to a HP technician for monitoring in the licensee's small
article monitor (SAM).
Not being intimately familiar with the
equipment, the HP technician also did not*realize one of the sensors
had a mount attached and placed the articles in the monitor for
surveying.
The monitor gave a "clear" signal and the articles were
removed.
The vendor technician exited the PDA with the articles, and
packaged and shipped them back to the vendor's office in Philadelphia,
Upon returning to the office and opening the package,
the vendor realized that one of the sensors still had a mount
attached.
The vendor thought the mount might be contaminated since it
9
had been in direct contact with the p1p1ng for a some period of time
and decided.to check it for contamination.
The mount was unscrewed
from the sensor and surveyed with a hand-held survey instrument.
The
vendor noted an increased count rate on the fnstrument and contacted
- the licensee on February* 14, 1994.
The licensee immediately
dispatched a HP technician to.the vendor's office in Philadelphia to
conduct surveys and retrieve the material.
The HP technician returned
to the site with the material on February 15, 1994, and, after further
analysis, found- that the screw threads of both the sensor (male end)
and the mount (female end) were slightly contaminated. Total
contamination of the sensor mount was determined to be
10,000 dpm/100 cm 2 , 4,000 dpm/100 cm2 of which was removable.
-The sensor end had total contamination of 2,000 dpm/100 cm 2 , with
1,000 dpm/100 cm2 removable .. The other four sensors were found to be
free of contamination.
The licensee re~enacted the monitoring of the equipment in the SAM and
found that the SAM would only alarm when the mount was unscrewed and-
separated from the sensor. This indicated that the mount provided
enough shielding to prevent the SAM from detecting the low.levels of
contamination on the screw threads of the equipment when the item was
originally removed from the RCA ..
The inspector informed the licensee that the release of items above
the unrestri~ted release criteria set forth in HP-8.0.40 constituted a
violation of the procedure.
However, based on the licensee's prompt
response and corrective actions, and the unusual circumstances
surrounding the isolated event, the criteria specified in
Section VII.B of the enforcement policy were met and the violation was
not cited (NCV 94-05-01).
Overall, the licensee's program to control and eliminate contamination
was considered a program strength.
One non-cited violation was identified.
8.
Instrumentation (83729)
During tours of the RCA, the inspector noted that all portable
radiation and contamination monitoring instruments observed, including
DADs, had calibration labels affixed to the initruments designating
the instruments to be currently calibrated. The inspector interviewed
cognizant licensee personnel involved in the calibration process and
reviewed selected calibration records.
During tours of the facflity
the inspector observed instrument storage and maintenance areas to be
well maintained and observed selected personnel performing instrument
pre-operational checks as required prior to signing the instrument
check-out log book.
The inspector discussed calibration frequencies
and methods used by the licensee to retrieve instruments due for
10
calibration to minimize the risk of an instrument being used which
could be out of calibration.
No violations or deviations were identified.
9.
Operational and Administrative Controls (83729)
a.
Radiation Work Permits (RWPs)
-
The inspector reviewed selected routine and special RWPs for
adequacy of the radiation protection requirements based on work
scope, location, and conditions.
For the RWPs reviewed, the
inspector noted that appropriate protective clothing,
respiratory protection, and dosimetry were required. During
tours of the plant, the inspector observed the adherence of
plant workers to the RWP requirements and discussed the RWP
requirements with selected plant workers.
The inspector found the licensee's program for RWP
implementation to adequately address radiological protection
c6ncerns, and to provide for proper control measures~
b.
Notices to Workers
10 CFR 19.ll{a) and {b) require, in part, that the licensee
po~t current copies of 10 CFR Part 19, Part 20,* the license,
license conditions, documents incorporated into the license,
license amendments and operating procedures, or that a licensee
post a notice describing these documents and where they be
examined.*
10 CFR 19.ll{d) requires that a licensee post form NRC-3,
Notice to Employees.
Sufficient copies of the required forms
are to be posted to permit licensee workers to observe them on
the way to or from licensee activity locations.
During the inspection, the inspector verified that NRC Form-3
was posted properly at plant locations permitting adequate
worker access.
In addition, notices were posted referencing
the location where the license, procedures*, and supporting
documents could be reviewed.
The inspector interviewed
selected licensee and contractor personnel and verified
personnel were familiar with the requirements of
_10 CFR-19.ll{d) .
. No violations or deviations were identified.
i
11
10.
Program to Maintain Occupational As Low As Reasonably Achievable
(ALARA) (83729)
10 CFR 20.llOl(b) *requires that the licensee shall 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 As Low As Reasonably
Achievabl~ (ALARA).
The licensee's total collective*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.
The licensee's total collective dose for 1993 came in
under the goal at 392 person-rem despite some Unit 2 forced outage
steam generator work performed at 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 10-year
ISi work.
At the-time of inspection, the licensee's collective dose
was approximately 230 person-rem, significantly below the anticipated
level of 310 person-rem for that point in the year.
The inspector reviewed a number of dose reduction initiatives employed
by the licensee, including better scheduling of scaffolding,
refinements to shutdown chemistry, and enhancements of camera use,
such as using RF cameras in containment. Also, the licensee continued
to identify effective uses of shielding, including water shields,
temporary lead blankets and bricks, and permanent shielding on
operating systems.
The inspector reviewed the lower inte~nals lift job that was condutted
on January 13, 1994, and involved high dose rates around the reactor
cavity. The job ~as performed under RWP 94-2-2050.
Do~e rates were
anticipated to be as high as 1-10 R/hour general area during the lift
- with contact readings possibly reaching 150-1,000 R/hour.
Teledose *
DADs (used in lieu of direct surveys) indicated, however, that the
highest reading recorded was only 364 R/hour.
Overall, the job
expended approximately 2.7 person-rem, and exceeded the plann~d dose
by approximately one person-rem. This was due to an error in placing
the internals on its stand, requiring it to be relifted and replaced.
However, the ALARA planning of the job was considered satisfactory and
the controls utilized during the job to limit dose were excellent. A
post-job debriefing provided a number of suggestions for improvement
in executing the job, and those were placed into the historical data
files for future reference by the licensee.
Respirator reduction continued to effectively reduce overall worker
dose.
In 1993, the licensee utilized approximately five-fold less
respirators than in 1992, and the 1994 goal of 500 respirators used
would be another approximately five-fold decrease over 1993 use.
No
significant increase in internal exposures was noted and engineering
"
.
12
controls wer-e utilized to complement the reduction 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 violations or deviations were identified.
11.
Review of Previously Identified Inspection Findings (92702)
(Closed) VIO 50-280, 281/93-0g-Ol:
Failure to (1) provide positive
control over an open locked high radiation area (LHRA) ~nd, (2) allow
an individual uninhibited egress from a high radiation area.
The inspector reviewed the licensee's corrective actions to the above
violation.
The corrective actions included using the event in worker
training for lessons learned, changing the posting procedure to
include the word "locked" on postings where necessary, and upgrading
LHRA doors outside of containment such that they self-close/lock and
have keyless egress.
In addition, a procedural chan~e was made such
that LHRA doors that do not have the aforementioned upgrades (i.e.
containment LHRA doors) must have continuous HP coverage while open
and unlocked, and advanced radiation workers are no longer issued LHRA
keys.
The inspector verified the inclusion of the event into training, the
door upgrades, and the procedural changes.
No problems were noted and
this item is considered closed.
12.
Exit Meeting
The 'inspector met with licensee representatives denoted in Paragraph 1
at the conclusion of inspection activities on February 18 and
March 25, 1994.
The inspector summarized the scope of the inspection
findings including 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, 281/94-05-01
Description and Reference
NRC-identified non-cited violation
for failure to properly control
contaminated material -
(Paragraph 7).