ML18152A895
| ML18152A895 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/19/1988 |
| From: | Hinson C Office of Nuclear Reactor Regulation |
| To: | Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8804280022 | |
| Download: ML18152A895 (10) | |
See also: IR 05000280/1988003
Text
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MEMORANDUM FOR:
FROM:
SUBJECT:
e
UNITED STATES
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NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
APR 1 ~ 1988
Roy E. Weddington, Health Physicist
tmergency Preparedness and Radiological Protection
Division of Radiation Safety and Safeguards
Region II
Charles s. Hinson, Health Physicist
Radiation Protection Branch
Division of Radiation Protection
Office of Nuclear Reactor Regulation
SURRY 1, 2 - NRR INPUT INTO INSPECTION
REPORT 50-280, 281/88-03
Branch
During the week of April 4-8, 1988, Charles Hinson lNRR), Roy Weddington lRII},
Fred Wright (RII), and Roger Shortridge (RII} conducted a special team inspec-
tion ot the ALARA Program at Surry 1 and 2.
Enclosed is a draft of NRR's
inspection findings to be incorporated into the inspection report. The inspec-
tion report will contain the findings from both this Surry ALARA inspection and
a similar ALARA inspection conducted at North Anna 1 and 2 and VEPCO corporate
headquarters during the week of March 14-18, 1988.
If you have any questions concerning this report, please *contact Charles Hinson
at (301) 492-3148.
Enclosure:
Draft Inspection Findings
CONTACT:
Charles S.
492-3'148
Charles s. Hinson, Health Physicist
Radiation Protection Branch
Division of Radiation Protection
Office of Nuclear Reactor Regulation
...
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4.
SURRY 1, 2
DRAFT INSPECTION FINDINGS
(50-280, 281/88-03)
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ENCLOSURE
c.
ALARA Exposure Goals
The inspector discussed management of daily exposure goals with
several of the licensee managers and supervisors.
For the most part,
department managers managed conformance with the daily exposure goal
by deferring work until they had enough exposure saved to allow
performance of the work or, it the .work could not be deferred, as in
the case of forced outages, the excess over the projection was
attempted to be made up for on succeeding days.
The inspector
observed that meeting the daily exposure goal does not necessarily
ensure that the exposure received is ALARA since it does not take
into account the tasks that are performed each day, which may be
highly variable. Supporting this observation was information gath-
ered from interviews with first-line supervisors and workers which
indicated they were generally unfamiliar with their department
1 s
exposure goal or exposure goals for their routine activities.
Formulation of task specific goals would permit the personnel who
actually received the exposure to contribute toward accomplishment of
the goal and would provide a better perspective for managers and
health physics personnel on the ALARA status of the station
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exposure.
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7.
Interviews
a.
Employee Interviews
Licensee employees were interviewed to assess their knowledge,
involvement, and perspective ot the utility's ALARA Program.
An
ALARA Questionnaire was prepared prior to the ALARA Program Apprais-
al.
The questionnaires were utilized during each interview to ensure
each employee's ALARA awareness and involvement were evaluated
uniformly.
The employee questionnaire was prepared to evaluate the employee's
knowledge of ALARA goals, concepts, policy and procedure documents,
individual responsibilities, personal exposure, and personal exposure
limits; the employees involvement in special ALARA training, communi-
cation with co-workers and supervision, and participation in the
ALARA suggestion program; and the employees perspective on how to
improve the ALARA Program, wnat events or conditions have caused
increased personnel exposures, and what events or conditions had
helped reduce personnel exposures.
Employees
All employees interviewed entered the radiological controlled areas
on a daily to weekly basis depending on plant conditions.
Employees
entered hign *radiation areas, however, on a less frequent basis
(daily to once every several months).
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Knowledge of ALARA Program
Each of the employees interviewed was familiar with the basic ALARA
concepts taught in the General Employee Training {GET) program and
knew'that they had a basic responsibility for implementing the
utility's ALARA Program by performing tasks in a manner consistent
with the utility's ALARA policy.
Each of the employees interviewed
ha.ct also either taken or were scheduled to take the Quality Mainte-
r.ance Training (QMTJ program.
All of the employees interviewed knew
what their current radiation exposure was and their quarterly expo-
sure limit. The employees had a poor understanding of where the
ALARA requirements originated or what corporate or plant documents -
described the ALARA Program objectives. Most of the employees
interviewed knew what their department's daily dose goals were,
although half of these employees did not know what their department
yearly dose goals were.
However, the employees did know that they
could find out their section's dose goals from the ALARA staft.
ALARA Program Involvement
All of the employee interviewed had received or were scheduled to
take advanced ALARA training as part of the QMT program.
A majority
of those interviewed had received some informational ALARA training
on jobs requiring ALARA pre-job planning and on-the-job training.
The employees reported frequent discussions of ALARA objectives on
major jobs during outages with co-workers and supervisors. The
employees also reported good communications with the Health Physics
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staff but less frequent contact with the ALARA staff. A few of the
employees interviewed had participated in the Formal ALARP. Suggestion
Program.
Other employees reported that they had discussed ALARA
suggestions with their co-workers but had not used the formal ALARA
suggestion program.
Perspective
Several employees had suggestions on how the ALARA Program could be
improved.
One employee said that it would be very beneficial to
have, for each component/system, a comprehensive set of photographs
of different views of the component and its surroundings, a required
tool checklist, a list of component part {i.e., bolts, flanges,
pipes, etc.) dimensions, and a listing of plant components/equipment
that differ (by way of model number, design changes, etc.) from
similar components/equipment commonly used in the plant.
For jobs in
the RCA, such information would help to minimize time spent in.
radiation zones by familiarizing the worker with the component/area
prior to entering the RCA and providing the worker with all of the
proper tools required to perfonn the job, thereby eliminating multi-
ple RCA entries to procure extra tools. Such information would also
minimize the number of tools carried into a potentially contaminated
area by specifying only those tools which are necessary to perform
the job. Other suggestions included elimination of the buddy-system
for jobs in radiation areas which could be perfonned by a single
worker, continued cleanup of contaminated areas in the auxiliary
building, better coordination between the operations and maintenance
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departments to ensure that area dose rates are minimized prior to
scheduling work in these areas, and installation of sample sinks in
the auxiliary building valve pit and liquid waste pit room.
Only the
last suggestion had been submitted to the ALARA suggestion program.
Most of. the employees had opinions on things that had contributed to
decreases and increases in personnel exposures.* Employees believed
that the following actions had contributed to exposure reductions:
cleanup of the boric acid flats and the auxiliary building basement,
better housekeeping practices to stop the spread of contamination,
increased use of signage, movement of PC dressout areas to lower dose
rate areas, the advanced health physics training received in the QMT
program, use of the VIMS and remote video cameras, increased interac-
tion with HP and ALARA staffs, and management's commitment to ALARA.
Employees believed that the following actions had contributed to
increases in personnel exposures:
use of too many people in the RCA,
use of contractor personnel who are inexperienced and not familiar
with the plant layout, high dose rates around the reactor coolant
pumps and reactor head areas, operating with failed fuel in the past,
and poor coordination between the operations and maintenance depart-
ments when scheduling,jobs resulting in adverse conditions and higher
radiation fields.
b.
Management Interviews
Licensee managers and supervisors were interviewed to assess their
knowledge of the utility's ALARA Program.
An ALARA Questionnaire for
managers and supervisors was prepared prior to the ALARA Program
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Appraisal.
The questionnaire was utilized during each interview to
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ensure each manager's and supervisor's ALARA awareness and involve-
ment were evaluated uniformly.
The manager's and supervisor's
questionnaire was prepared to evaluate the manager's or supervisor's
knowledge of ALARA goals, concepts, policy and procedure documents,
individual responsibilities, personal exposure, and personal exposure
limits; tne manager 1 s or supervisor's involvement in special ALAHA
training, communication with co-workers and supervision, and partici-
pation in the ALARA suggestion program; and the managers or supervi-
sor's perspective on how to improve the ALARA Program, what events or
conditions have caused increased personnel exposures, and what events
or conditions have helped reduce personnel radiation exposures.
Managers and Supervisors
All individuals interviewed entered the radiological controlled areas
on a daily to weekly basis during plant outages and less frequently
during non-outage conditions. Most individuals interviewed toured
the work areas of their employees at least on a daily basis.
Knowledge of ALARA Program
Each of the individuals interviewed was familiar witn the basic ALARA
concepts taught in the GET program and knew that they had a basic
responsibility for implementing the util ity
1 s ALARA Program by
performing tasks in a manner consistent with the utility's ALARA
policy. All of the individuals interviewed ranked their ALARA
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responsibilities first, or first with safety, among their management
objectives.
The managers and supervisors had a good understanding of
where the ALARA requirements originated and what corporate and plant
documents described the ALARA Program objectives. All of the manag-
ers and supervisors interviewed knew what their department's ALARA
objectives were.
However, less than half of the managers and super-
visors interviewed knew what their department's yearly dose goal was.
Even fewer could identity their department's daily dose goal. This
large percentage of managerial personnel who afe unaware of their
department
1s dose goals is an indication that not enough emphasis is
being placed on the plant dose goals at the first line supervisory
level positions and below.
ALARA Program Involvement
The majority of,_ the managers and supervisors interviewed had received
advanced ALARA training as part of the QMT program.
This was in
addition to the ALARA training given in the GET course.
Each depart-
ment has a dedicated individual to serve on the ALARA Committee,
which meets on a monthly basis or as appropriate.
The ALARA Commit-
te_e members represent their departments in discussions of ALARA
objectives or major jobs during outages.
Two of the managers inter-
viewed had participated in the Formal ALARA Suggestion Program and
several said they knew of department employees who had submitted
suggestions within the past year. *
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Perspective
All managers and supervisors interviewed had suggestions on how the
ALARA program could be improved.
The suggestions included better
planning of work to ensure appropriate equipment and tools were
readily available, an increase in the awareness of the ALARA concept
at all plant personnel levels, more involvement of first-line person-
nel with plant jobs, ensuring that procedures for working on compo-
nents are revised when the components are replaced by different
components or undergo design changes, and establishment ot semiannual
meeting between HP department personnel and other departments to
discuss the performance of each department with respect to the annual
dose goals (and also a comparison of Surry's dose goals with those of
other utilities).
The majority of managers and supervisors had opinions on things that
had contributed to decreases and increases in personnel exposures.
Individual managers and supervisors interviewed believed that the
following actions had contributed to exposure reductions:
increased
management awareness of and commitment to ALARA, permanent shielding
such as the reactor vessel head shield, use of the VIMS during
pre-job planning, use of the monthly Predictive Maintenance Severity
Surrmary report to identify potential equipment problems {i.e., excess
vibrations, high temperature, low oil level) before the equipment
breaks down, cleanup of the boric acid flats, auxiliary building
basement, and other contaminated areas, use of remote equipment, use
of better pumps and valves {resulting in less leakage), and more
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frequent meetings between the ALARA group and plant department
personnel.
Individual managers arid supervisors interviewed believed
that the following actions had contributed to increases in personnel
exposures:
high area dose rates due to several years of operation
with failed fuel, use of excessive number of worker~ in the RCA
during outages, and a poor management attitude towards ALARA in the
past which resulted in annual individual worker doses above the
national average.
Several of the managers and supervisors inter-
viewed said that their statts were now more experienced and better
trained because of the QMT program that the licensee adopted during
1985.
Most of the mechanical and electrical personnel have attended
this QMT program and the licensee intends to have all personnel
complete this program as soon as possible. Completion of the QMT
program should enhance and reduce the licensee's man-rem goals for
future work inside radiological controlled areas.