ML18152B094
| ML18152B094 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Surry |
| Issue date: | 08/11/1988 |
| From: | Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152B092 | List: |
| References | |
| 50-280-88-03, 50-280-88-3, 50-281-88-03, 50-281-88-3, NUDOCS 8808240274 | |
| Download: ML18152B094 (19) | |
See also: IR 05000280/1988003
Text
,
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION 11
101 MARIETTA. STREET, N.W.
ATLANTA, GEORGIA 30323
AUG 171988
ENCLOSURE 3
Report Nos.:
50-280/88-03, 50-281/88-03
Licensee:
Virginia Electric and Power Company
Richmond, VA
23261
Docket Nos.:
50-280, 50-281
Facility Name:
Surry
Licens~ Nos.:
Inspection Conducted:
April 4-8, 1988
~*,
\\
\\
Team Leader: (,/\\Iv) ~
.
R. E. Wed in t~
Date Signed
Team Members:
C. Hinson, NRR
R. Shortridge
F. Wright
Accompanying Personnel:
C. Hosey
J., Wjgginton, NRR
Approved by:
Date Signed
Safeguards
SUMMARY
Scope:
This was a special, announced assessment in the area ~f licensee's
program to maintain occupational exposures as low as reasonably achievable
(ALARA).
Results:
The licensee now has in place the elements of a successful ALARA
program.
Continued support and involvement of management is required if the
program is to be effective. However, several weaknesses were identified in the
ALARA program that should be addressed to ensure that collective annual
personnel radiation dose is reduced to industry norms.
These weaknesses were
in the areas of:
Exposure goal formulation, Paragraph 4.c.
Radiation work permit hold program, ALARA procedures and job history
files, Paragraph 4.d.
Number of containment power entries, Paragraph 5.c.
ALARA Action Plan implementation schedule, Paragraph 4.f.
Timely revision of ALARA procedures, Paragraph 4 .
Within the area~ inspected, no violations or deviations were identified.
- .
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- T. Banks, Health Physics (Corporate)
- D. Benson, Station Manager
- H. Collar, Supervision, Quality Assurance
- C. Folz, Station ALARA Coordinator
- E. Grecheck, Assistant Station Manager
- G. Kane, Station Manager (North Anna)
- G. Miller, Licensing Coordinator
- H. Miller, Assistant Station Manager - Operations and Maintenance
- G. Pannell, Director of Safety Engineering (Corporate)
- S. Sarver, Superintendent, Health Physics
- A. Stafford, Superintendent, Health Physics (North Anna)
- E. Swindell, Supervisor Chemistry
- J. Wilson, Manager, Nuclear Operations Support (Corporate)
Other licensee employees contacted included engineers, technicians,
maintenance and office personnel.
Nuclear Regulatory Commission
- L. Nicholson, Resident Inspector
- Attended exit interview
2.
Exit Interview (30703)
The inspection scope and findings were summarized on April 8, 1988, with
those persons indicated in Paragraph 1. The inspector described the areas
inspected and discussed in detail the inspection findings (see
Paragraph 9).
The licensee acknowledged the inspection findings and took
no exceptions.
The licensee did not identify as proprietary any of the
material provided to or reviewed by the inspector during the inspection.
3.
Background (83528/83728)
Historically, collective personnel radiation exposure at Surry Power
Station has been among the highest for pressurized water reactors (PWRs)
in the industry over the period from 1974 through 1986.
The average
collective dose for all PWRs over this period is 492 person-rems per year
per reactor.
Five PWRs have cumulative average doses which exceed this
PWR cumulative average exposure by 50 percent or more.
Surry had the
highest cumulative average of this group with 1255 person-rem per year per
reactor.
In 1983, a document generated in the Corporate ALARA Group
attempted to assess the reasons for high personnel radiation doses.
While
much of the dose was attributed to the degradation of the steam generators
..
2
and their subsequent remova 1 and replacement, it was noted in the
evaluation that Surry was stil 1 experiencing higher than anticipated
exposures which were also attributed to the following factors:
a.
Since radioactive corrosion products were continually being generated
and accumulated within the primary systems, the dose rates of the
components increased with age.
However, it was noted that 8 of 32
PWRs in the US were older than Surry, with some of the stations
experiencing similar major maintenance problems, yet their primary
system source terms were not as high.
b.
Fuel failure had contributed appreciably to dose rates at the
station.
An example given in the evaluation stated that 6 months
after the Unit 1 refueling in 1981, the Xe-133 activity levels and
dose equivalent I-131 were about 50 to 80 times higher than that of
Unit 2
1s primary coolant.
Unit l's Volume Control Tank (VCT) read
100,000 mrem/hr on contact while Unit 2
1s VCT read 2,000 mrem/hr.
General area readings around the tanks were 50,000 and 450 mrem/hr
respectively.
Unit l's charging pump cubicles had contact dose rates
of 450 to 3,000 mrem/hr while Unit 2
1 s read 150 to 200 mrem/hr.
c.
Standing Work Permits (SWPs) were employed to allow individuals to
enter radiation areas for routine and repetitive work while Radiation
Work Permits (RWPs) were utilized for specific job assignments in
radiation areas.
A significant amount of all dose at Surry,
41 percent, was incurred using SWPs.
Since SWPs did not undergo
ALARA review and were not specific regarding ALARA instructions to
the worker, the corporate report concluded that the ALARA program was
being circumvented when SWPs were used instead of RWPs.
d.
The boric acid flats and associated tanks showed a marked increase in
dose rates indirectly due to Unit 1. primary coolant activities
(failed fuel).
Radiation levels ranged from 150 to 700 mrem/hr on
the top of the boric acid storage tanks to 800 to 2,000 mrem/hr on
the bottom with a general area reading of 600 mrem/hr.
Since the
boric acid flats were a high maintenance area (139 RWPs/SWPs were
i~sued for repairs in the area with 88 man-rem incurred in 1982), it
was recommended that an aggressive program to clean up and remove the
high activity in this area be scheduled for the next outage.
In January 1983, Virginia Electric and Power formally implemented their
ALARA Program.
Procedures were developed pertaining to ALARA
considerations for design change packages to ensure that proper ALARA
considerations were employed in applicable design change modifications.
In the fourth quarter of 1983, a report listing ALARA current concerns was
completed by corporate health physics.
Major areas of concern were:
insufficient attendance at ALARA committee meetings, improper checkoff of
temporary shi el ding and approved ALARA suggesti ans were not being
implemented in a timely manner.
Through interviews with workers,
Year
1974-
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
4.
3
corporate health physics concluded that the general feeling among workers
was that the ALARA program took a low precedence to production.
The 1987 collective radiation dose at Surry was 356 person-rein per
reactor, which was three percent below the national average for
pressurized water reactors of 368 person-rem per reactor.
Whi 1 e this
represents a considerable reduction in collective dose from 1986, it
should be noted that Surry went through 1987, without a refueling or major
maintenance outage.
Dose projection for 1988, indicated that the
collective dose at Surry will again be significantly above the industry
norm.
Table 1 shows a comparison of Surry Collective Annual Dose with that of
average PWR Collective Annual Dose.
TABLE 1
Comparison of Surry Annual Collective Dose with Average
Collective Dose from Commercial Pressurized Water Reactors
1974 - 1987
PWR Average Dose eer Reactor (rem)
Surri Dose eer Reactor (rem)
331
441
318
824
460
1,582
396
1,153
429
917
516
1,918
578
1,792
652
2,122
578
745
592
1., 610
552
1,123
416
907
397
1,178
368
327
Program To Maintain Radiation Exposures ALARA ( 83528/83728)
The inspector reviewed the following licensee ALARA procedures:
SAM-1, Station ALARA Committee, December 7, 1984
SAM-2, ALARA Procedures, November 7, 1986
SAM-3, ALARA Suggestion Program, December 7, 1984
SAM-5, Determination of Station ALARA Objectives and Goals,
October 3, 1984
SAM-6, Design Changes, October 3, 1984
..
4
SAM-7, ALARA Suggestion Awards Program, December 7, 1987
SAM-8.1, Procedure for Temporary Lead Shielding, Request,
Installation, Removal and Accountability, December 8, 1986
The inspector ~oted that in some instances the procedures did not fully
reflect the current activities of the ALARA Section.
The inspector also
noted that the station had not revised the ALARA procedures to conform
with the corporate radiation protection pl an.
Similar procedures were
implemented at North Anna in April 1987.
Licensee representatives stated
they were in the process of upgrading their procedures to conform to the
corporate radiation protection pl an and expected to have improved
procedures in place by the end of July 1988.
a.
Organization
(1) Staff
The licensee ALARA organization consisted of a permanent staff
of an ALARA coordinator (supervisory level), a licensee health
physics technician and two contractor technicians.
The
inspector reviewed the staff members
experience and
qualification~ and determined that they fully met the technician
qualification requirements of ANSI 3.1 and had extensive applied
hea 1th physics experience.
A maintenance mechanic was a 1 so
assigned to the section to help plan mechanical maintenance
tasks.
(2)
Review Committee
The licensee had established a. Station ALARA Committee
consisting of the Assistant Station Manager as Chairman,
Maintenance Superintendent, HP Superintendent, Station ALARA
Coordinator and Department ALARA Coordinators from Maintenance,
Operations, Technical Services, Engineering and Construction,
and Training.
The Committee routinely meets on a monthly basis
to review the station's performance toward dose goals, ALARA
suggestions, preplanned jobs with collective doses greater than
10 person-rem and post-job reviews of jobs with doses greater
than 25 person-rem.
The inspector reviewed the minutes of the Station ALARA
Committee meetings held during the period January 1986 through
December 1987.
The inspector discussed with licensee
representatives the omission from the minutes of the meetings of
documentation of discussions regarding exceeding dose goals and
job dose estimates in terms of lessons learned and remedial
actions.
Licensee repr~sentatives stated that such topics were
discussed in their meetings and acknowledged that the minutes
could be enhanced by including identification of root causes for
exceeding dose estimates and recommended preventative actions
taken in the meeting minutes.
..
b.
c.
5
Work Reviews *
The inspector reviewed Licensee Procedure SAM-2, ALARA Procedures,
November 7, 1986.
The licensee procedure required pre-job reviews by
the ALARA staff for work in which the dose estimate exceeded one
person-rem.
A Station ALARA Committee review was required for work
estimated to exceed 10 person-rem and work estimated to exceed
50 person-rem was forwarded to the Corporate ALARA Coordinating
Committee fo*r review.
In determining if a job met the guidelines for
each level of review, radiation work permits (RWPs) authorizing work
contributing_ to a specific task, such as steam generator sludge
lancing, were considered collectively rather than individually to
ensure that appropriate reviews were not overlooked.
The inspector
reviewed selected*pre-job rev1ews performed during 1987, and verified
that appropriate dose control techniques and lessons learned from
prior similar work were considered during the reviews.
During 1987,
72 percent of the station's dose was received from work that had been
preplanned, which was significantly less than the 86 percent achieved
at the licensee
1s North Anna facility.
Part of the reason for this
differerice can be attributed to a more liberal use of standing RWPs
at Surry rather than charging dose against RWPs specific to the work
being performed.
Post-job ALARA reviews were performed by the ALARA Coordinator for
work with actual collective dose great~r than one person-rem and
which exceeded the estimated exposure by 25 percent.
The Station
ALARA Committee also performed post-job reviews for work requiring
greater than 25 person-rem and formal reports were written following
each outage.
The inspector reviewed documentation of selected
post-job reviews that had been performed during 1987 and 1986 outage
reports.
The inspector verified that reasons for exceeding dose
estimates or lessons learned, as appropriate, were specified on the
reviews.
ALARA Dose Goals
The inspector reviewed Licensee Procedure SAM-5, Determination of
Station ALARA Objectives and Goals, October 3, 1984.
The procedure
described the process used by the licensee to establish department
exposure goals.
The goa 1 s were based on the average dose received
during the current and two preceding years in terms of average dose
for an outage and nonoutage day.
The station annual dose goal was
formulated in a similar manner.
For 1988, the station's dose goal
was 11.795 person-rem for an outage day and 1.245 person-rem for a
nonoutage day.
The licensee projected there would be 96 outage and
270 nonoutage days in 1988 for a total goal of 1,468 person-rem.
As
of April 5, 1988, the station's actual dose was 77.405 person-rem,
which was 64.5 percent of the licensee's projection to that date of
118.275 person-rem .
6
The inspector discussed the management of daily dose* goals with
licensee representatives.
Generally, department managers managed
conformance with the daily dose goal by deferring work until they had
sufficient dose saved to allow performance of the work or, if the
work could not be deferred, as in the case of forced outages, the
excess over the projection, an attempt was made to reduce work on
succeeding days.
The inspector observed that meeting the daily dose
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
the current performance toward the daily dose goal and the estimates
for the upcoming outage which were well below the dose predicted by
the historical average.
In addition to having no relationship to the
work actually performed, these goals were also apparently not
challenging.
Historically, high collective dose at Surry would lead
to the generating of artifically high dose goals when the dose per
day method is used.
Formulation of task specific goals would also
permit the personnel who actually received the dose to contribute
tow a rd accomp 1 is hnient of the goa 1 and would pro vi de a better
perspective for managers on the status of the station
1s collective
dose.
The inspector also questioned why the licensee would accept a
goa 1 of 1. 245 person-rem for a nonoutage day which was 3. 5 times
higher than the O. 355 person-rem per nonoutage day goa 1 at North
Anna.
Although source terms at the two facilities are not the same,
the differences would not be large enough to account for differences
in daily dose averages.
Licensee repfesentatives stated that they
would evaluate this difference in daily goals.
d.
Job Histories
The inspector discussed with licensee representatives historical job
dose data that was available for review when preplanning radiological
work.
The PREMS computer data base permitted generation of a listing
of all RWPs and associated summary dose data for all work performed
on a given system or location since 1982.
The RWP listing was cross
referenced to the ALARA review control number for the job.
This
control number could be used to access a hard copy file of all of the
documents associated with that RWP, such as, the RWP request, the RWP
and forms used to document the dose estimate, pre-job review and
post-job review.
The inspector reviewed selected PREMS data listings and hard copy job
history files for radiological work performed during 1986 and 1987.
The inspector noted that data retrieval and comparison was more
difficult than it had.been using the same system at North Anna.
The
problem appeared to involve the consistency with which RWP dose data
was charged against the same
11mark number
11 in PREMS from year to
year.
(A mark number was a numerical code established by the
licensee to designate a particular maintenance evolution or piece of
equipment.)
Licensee representatives stated that hard copy files
would have to be retrieved and reviewed to make sure similar data was
e.
f.
7
being compared.
Licensee personnel at North Anna were able to obtain
comparison data directly from the computer.
Licensee representatives
stated that they would review the system in place at North Anna to
determine if there were any differences in encoding procedures which
would aid their data retrieval.
Hold Program
The licensee
1s ALARA staff generated a daily computer printout
showing the exposure status of each RWP.
A flag appeared on the
printout for RWPs when the ac~ual dose had reached the dose estimate.
When the actual exposure reached 125% of the estimate, a flag and
message was printed which stated that a hold was required to be
placed on the job until the dose estimate could be reevaluated.
The
inspector reviewed the daily RWP dose status report for the week of
April 4, 1988.
Only one RWP, 88-1-0702, Unit 2 Containment
Instrumentation, was flagged.
The flag indicated that a hold on the
RWP was possible because 1.223 person-rem had been charged to the RWP
and 1. 007 person-rem had been projected.
Licensee representatives
stated that holds could be placed on an RWP from the ALARA office by
making an entry on the computer screen for the RWP.
Such reviews
were typically performed each work day morning so that a RWP could
incur doses in excess of the projection for some period of time until
it was identified the next work day.
During review of job history
files, the inspector identified that RWP 1514 had an dose estimate of
4.50 person-rem and on March 16, 1987, the dose had been
5.22 person-rem.
There was no documentation to show if a hold had
ever been applied or the timeliness with which it had been applied.
Licensee representatives stated that they had no means of
demonstrating that holds had been placed on RWPs.
Licensee
representatives stated that they would evaluate means of enhancing
their program in this area.
Personnel were logged onto RWPs at the
controlled area entrance by health physics personnel using a computer
terminal which accessed the licensee
1 s exposure data base (PREMS).
Licensee representatives stated it may be possible to provide an
automatic lock to prevent personnel logging in on RWPs that were in
excess of the estimate.
This would provide real time control and
would preclude charging doses significantly above that estimated
against RWPs without a subsequent review.
Licensee Initiative to Enhance Program
The station began compiling a photo library of plant components in
1984, to aid in job planning and future dose radiation efforts. The
station has also begun replacing the photo library with the VIMS.
In an effort to increase ALARA awareness, television monitors (video
bulletin boards) are used to display collective dose and other ALARA
related messages .
8
In 1987, the licensee
1s Corporate ALARA group completed an ALARA
Action Pl an and Source Term Redu'cti on Study.
This study specified
initiatives to reduce collective doses.
The action items have
personnel assigned as responsible for completion.
However-, target
dates for completion have not been established to ensure the timely
completion of the actions items, nor have milestones been established
to track progress in completing the action items~
5.
Performance (83528/83728)
a.
Exposure Performance on Repetitive Work
The inspector discussed with licensee representatives their ability
to apply lessons learned from previous jobs in order to reduce dose.
Using the licensee
1 s PREMS computer and job histry files, dose data
from two repetitive tasks during refueling outages were obtained.
Job:
Remove and Reinstall Reactor Head Studs
Year
Person-Rem
Man-Hours
1984
29.060
815
1986
22.691
1,121
Job:
I nsta 11 Reactor Head 11011 Rings
Year
Person-Rem
Man-Hours
1984
5.334
171
1986
2.556
77
The inspector discussed this data with licensee representatives and
reasons for the dose reductions.
Licensee representatives cautioned*
that in reviewing the data one should be aware that the man-hour data
from PREMS was the total amount of time between a worker's entry and
exit from the controlled area which may be considerably longer than
the time actually spent in a radiation area at the job site.
The
i r:ispector al so reviewed dose estimates for contractor work to be
performed during the upcoming refueling outage and compared the data
to historical data for similar work.
In all cases, the dose goals
were significantly lower than the historical experience for the work.
The licensee's goal when performing exposure estimates was to always
establish controls and dose reduction techniques so that work would
be performed for less dose than it had been previously.
b.
The inspector reviewed NUREG/CR-4254, Occupational Dose Reduction and
ALARA at Nuclear Power Pl ants:
Study on High-Dose Jobs, Radwaste
Handling, and ALARA Incentives, April 1985, with licensee ALARA
personnel.
NUREG/CR-4254 contains data on doses experienced
throughout the industry for typical high dose jobs.
The inspector
9
compared the licensee
1s exposure history for several of those jobs
described in the NUREG as indicated in the following table:
Job
S/G Tube
Plugging
Reactor
Disassembly,
Assembly and
Fuel Sipping
S/G Manway
Remove/Replace
S/G Sludge
Lancing and
Inspections
!SI and
Remove/Replace
Insulation
Inspection
RHR Repair
and
Maintenance
Licensee Exposure
Unit
85
86
U-1
U-1
U-2
U-1
U-2
U-1
U-2
U-1
U-2
U-1
U-2
U-1
U-2
U-1
U-2
10.423
57.404
69.899
45.747
19.268
9.293
8.013
10.432
20.467
11.330
67.235
48.792
34.120
17.948
237.017
11.790
10. 784
19.174
6.023
37.355
44.587
11.460
Avg
47
57
11
11
64
110
3
30
The inspector determined that for most of the jobs reviewed, the
licensee
1s exposure performance compared favorable with the industry
averages indicated in NUREG/CR-4254 (1974-1984 data).
c.
Containment Entries with the Reactor at Power
The inspector reviewed with licensee representatives the containment
entries made since 1983, with the reactor at power.
The number of
entries and exposure received each year were as follows:
10
Year
No. of Entries
Total Person Rem
1983
167
not available (NA)
1984
138
NA
1985
119
NA
1986
176
20.457
1987
175
16.395
The licensee has a subatmospheric containment and personnel making
entries with the reactor at power are required to wear self-contained
breathing apparatuses (SCBAs).
The inspector reviewed the
Containment Entry Check Sheets for the entries performed in 1987.
The forms gave the reasons for entry and indicated the approvals.
Many of the entries were to perform surveillances and to respond to
operating conditions such as to investigate unidentified reactor
coolant leakage.
The inspector also observed that these entries may
be viewed by the licensee as normal routine occurrences that are not
as critically assessed as they might be.
Entries were made on a
standing RWP and shift personnel could authorize the entry.
Six of
the containment access authorization sheets did not have the reason
for the entry portion of the form completed, yet they had been signed
by the shift supervisor to approve the entry.
Licensee
representatives acknowledged the inspector's comments.
Source Term Reduction
a.
The inspector reviewed radiation survey records for the licensee's
HRAs.
The licensee controlled 8 HRAs with dose rates between 100 and
1,000 mi 11 i rem/hour and 14 HRAs with dose rates greater than
1,000 millirem/hour.
The number of HRAs controlled by the licensee
did not appear to be excessive.
b.
Chemistry Control
c.
(1)
Reactor Coolant pH Control
The licensee was attempting to obtain permission from the vendor
to implement the Reactor Coolant pH Control Program discussed
for North Anna in Enclosure 2 of this report (Paragraph 6.b(l)).
Implementation of the pH control program will be subject to
approval of the licensee's fuel vendor.
No completion date was
available.
Fuel Integrity
The licensee has implemented a fuel integrity monitoring and
chemistry measurement evaluation program which includes allowable
levels of dose equivalent I-131 (DEI) in the Primary Coolant System.
The DEI is monitored on a daily basis, under equilibrium and
11
transient conditions, with respect to the technical specification
limits of one microcurie per milliter (1 uCi/ml).
This was
accomplished through the use of a computer code, which plotted the
daily iodine -isotopic concentrations in the primary coolant system,
based on measurements performed by station chemists, and calculated
the DEI.
Si nee 1983 the licensee has discovered numerous fuel failures.
Licensee Event Report (LER) No.83-014 indicated that failures of
fuel rods due to debris induced fretting were detected in March 1983;
revisions to that LER were submitted to the NRC in 1984 and 1985.
It
was noted in the LER revision submitted on May 7, 1985, that the
results of sipping, single rod leak detection system (i.e., the Brown
Boveri Reactor ultrasonic test), and visual observations indicated
that 52 of the cycle 6 fuel assemblies were leaking. There appeared
to be a total of 86 defective fuel rods.
Of the 52 assemblies,
approximately 20 contained debris, which appeared to be small pieces
of metallic shavings.
Additional failures were evident during
Surry 1, cycle 7 (May 30, 1983 to September 26, 1984) and Surry 1,
cycle 8 (December 26, 1984 to May 10, 1986).
Wet sipping and
ultrasonic testing indicated 8 failed fuel assemblies in cycle 7 and
10 failed fuel assemblies in cycle 8.
Fuel cycle 9, which began in
July 1986, and was still in use at the time of the evaluation was
believed to contain 2 or 3 fuel failures based on reactor coolant
analysis.
The licensee had not experienced fuel failure in Unit 2.
The licensee plans to continue ultrasonic testing following cycle 9.
The cycle 6, 7, and 8 fuel assemblies that were found to be leaking
were replaced. All of the fuel assemblies that were determined to be
defective were later reconstituted by replacement of individual fuel
pins.
The licensee's corporate radiochemistry group evaluates fuel
performance on a monthly basis to determine if a specific fuel cycle
has leaking fuel rods.
The licensee's procedure specifies various
actions and requirements as a function of predicted number of failed
fuel rods.
The licensee's procedures also require examination of all
fuel assemblies replaced into the core following the detection of one
failed fuel rod.
d.
Ambient Radiation Levels in Auxiliary Building
During tours of the facility, the inspector performed radiation
surveys in the Auxiliary Building.
The ambient radiation level in
main passageways appeared to be generally less than 1 millirem/hour.
The radiation levels in the facility appeared to be lower than those
reviewed at the licensee
I s North Anna facility.
The licensee
I s
program of flushing systems, installing shielding and cleaning
contaminated areas had apparently been effective in reducing ambient
radiation levels .
12
e.
Other Dose Reduction Initiatives
The ALARA Coordinating Committee again reviewed indepth exposure
related information in late 1984.
They observed that dose rates on
selected components were consistently higher at Surry than other
As a result of the observation, a request for an
engineering study was submitted to Engineering and Construction
pertaining to performing an ~in system
11 chemical decontamination.
A study pertaining to reduction of containment airborne radioiodine
1 eve 1 s after unit shutdown was performed.
Results indicated that
rec i rcu 1 at i ng containment air through containment cha rcoa 1 filter
banks would assist in reducing iodine levels below 25 percent maximum
permissible concentration.
Late in 1984, a large bank of iodine
filters were placed in front of Unit 1, Band C recirculation fan
inlet plenums to reduce iodine airborne levels and the amount of time
personnel were required to wear respiratory equipment after unit
shutdown.
In early 1985, major modifications were performed on both units to
reduce or eliminate the removal/reinstallation of large bore
Historically, maintenance work on the large bore snubbers
have cost an average of 100 person-rem per unit each time the task is
performed.
Permanent reactor head shields were i nsta 11 ed and resulted in a
significant dose rate reduction of up to 50 percent at the reactor
vessel head stud plane.
A modified quick change blank flange was installed on the fuel
transfer tube that was postulated to -reduce person-rem associated
with removal/replacement of the flange by 90 percent of the normal
5 person-rem.
Modifications were made to safety injection valves to allow testing
to be performed without disassembly and installation of bottom
mounted thermocouples.
The* 1 i censee
I s chemically decontaminated a portion of the gas
stripper/boron recovery system.
A dose reduction factor of 3.5 was
achieved by this chemical decontamination effort. The insulation on
the system was also replaced which further reduced the area dose
rates.
Replacement of fuel with inconel grids using fuel with zircaloy grids
was scheduled to begin during the 1988 refueling outages.
Both
Units 1 and 2 were scheduled to receive a one third core complement
of the new fuel in 1988, and a total core compliment after the third
refueling outage for each unit.
Expected dose savings is estimated
to be 40 person-rem each year upon complete replacement.
No extra
dose would be required for implementation.
13
In 1987, corporate ALARA personnel performed a technical evaluation
of techniques for general plant radiation field strength reduction.
The report addressed how source terms were produced and 1 i sted
methods to reduce the activity already incorporated in the piping and
components.
In addition another evaluation was in progress on
methods to reduce personnel doses at Surry and North Anna.
As a
result of both evaluations an ALARA action plan was developed with
recommendations and personnel assignments for completion of the
actions.
7.
Interviews (83528/83728)
a.
Employee Interviews
Licensee employees were interviewed to assess their knowledge,
involvement, and perspective of the utility's ALARA Program.
An
ALARA questionnaire was prepared prior to the inspection and was
utilized during each interview to ensure each employee's ALARA
awareness and involvement was evaluated uniformly.
The employee questionnaire was prepared to evaluate the employee
1s
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, what events or conditions have caused
increased personnel exposures, and what events or conditions had
helped reduce personnel exposures.
The licensee
1s employees were interviewed to assess their knowledge,
involvement and perspective of the utilities ALARA program as
described in the North Anna report (Paragraph 7.a).
(1)
Employees
(2)
All employees interviewed entered the radiological controlled
areas on a daily to weekly basis depending on plant conditions.
Employees entered high radiation areas, however, on a less
frequent basis (daily to once every several months).
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 res pons i bil ity for
implementing the utility
1 s ALARA Program by performing tasks in
a manner consistent with the utility
1 s ALARA policy.
Each of
the employees interviewed had a 1 so either taken or were
scheduled to take the Quality Maintenance Training (QMT)
14
program.
All of the employees interviewed knew their current
radiation exposure and their quarterly exposure 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 staff.
(3)
ALARA Program Involvement
All of the employees 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 Hea 1th Physics staff but less
frequent contact with the ALARA staff.
A few of the employees
interviewed had participated in the formal ALARA suggestion
program.
Other employees reported that they had discussed ALARA
suggestions with their co-workers but had not used the formal
ALARA suggestion program.
(4)
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/ sys tern, a comprehensive set of
photographs of different views of the component and its
surroundings, a required tool checklist, a list of component
parts (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 perform the job,
thereby eliminating multiple RCA entri*es 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 performed by a single worker, continued
cleanup of contaminated areas in the auxiliary building, better
coordination between the operations and maintenance departments
to ensure that area dose rates are minimized prior to scheduling
b.
15
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 signs,
movement of protective clothing 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
interaction with
HP and
ALARA staffs, and management
1 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 departments
when scheduling jobs resulting in adverse conditions and higher
radiation fields .
Management Interviews
The licensee management employees were interviewed to assess their
knowledge, involvement and perspective of the utilities ALARA program
as described in the North Anna report (Paragraph 7.a).
(1)
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.
(2)
Knowledge of ALARA Program
Each of the individuals interviewed was familiar with the basic
ALARA concepts taught in the 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
1s ALARA policy.
All of the individuals interviewed
ranked their ALARA 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 managers and supervisors
interviewed knew what their department
1 s ALARA objectives were.
However, 1 ess than half of the managers and supervisors
16
interviewed knew their department
1s yearly dose goal.
Even
fewer could identify their department's daily dose goal.
This
large percentage of supervisory personnel who were unaware of
their department's dose goals is another indication that goals
specific to the work to be performed needs to be established so
that mid-level and first line supervisors can contribute toward
the accomplishment of the exposure goal and where necessary be
held accountable for poor performance in attaining dose goals
and for corrective actions necessary to prevent recurrence.
(3)
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 department had a dedicated individual to serve on
the ALARA Committee, which met on a monthly basis or as
appropriate.
The ALARA Committee members represented their
departments in discussions of ALARA objectives or major jobs
during outages.
Two of the managers interviewed had
participated in the formal ALARA suggestion program and several
said they knew of department employees who had submitted
suggestions within the past year.
(4)
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 personnel with plant jobs, ensuring
that procedures for working on components are revised when the
components are replaced by different components or undergo
design changes, and establishment of semiannual meetings 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
1s 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 shi el ding such as the reactor vessel head
shield, use of the VIMS during pre-job planning, use of the
monthly Predictive Maintenance Severity Summary 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
17
basement, and other contaminated areas, use of remote equipment,
use of better pumps and valves (resulting in less leakage), and
more frequent meetings between the ALARA group and pl ant
department personnel.
Individual managers and 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 workers 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 interviewed said that
their staffs were now more experienced and better trained
because of the QMT program that the 1 i censee adopteq 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
person-rem goals for future work inside radiological controlled
areas.
8.
Training (83528/83728)
Advanced Radiation Worker Training was provided to craft personnel at
Surry to increase worker knowledge of radiological protection; as well as,
other areas and to decrease the dependence of the craft person on support
personnel.
Quality maintenance Teams (QMT) consisted of 5 or 6 workers of different
disciplines, such as, electrical and mechanical maintenance, and
instrumentation and control personnel.
Each QMT received 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of
classroom instruction in radiation detection and measurement, radiological
surveys, airborne radioactivity sampling and protection; and radiological
work practices.
In each of the four subject areas a student was required
to satisfactorily complete a laboratory for that subject. The laboratory
consisted of practical application of the material learned in the
classroom.
This training was preceded by 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of basic general
employee training (GET) which satisfied the annual GET requalification
requirement.
-
Upon completion of the classroom, laboratory, and requalification training
a worker was required to perform tasks covered during cl ass room and
laboratory training under simulated conditions in a radiologically
controlled area.
The worker's performance was monitored by a qualified
health physics technician and satisfactory completion of the assigned
tasks was indicated on a job performed measure (JPM) form.
The JPM served
as the student's qualification record.
In early 1987, in response to a historically large number of personnel
contamination events during outages, the Surry training department
provided 60 minutes of instruction in radiological awareness for the
upcoming refueling outage.
The training session was provided for
)*
-*
18
900 Virginia Power and contractor personnel and focused on dose reduction,
ALARA concepts and good radiological work practices.
In addition, health
physics contractor personnel received training in hot particle detection
and respiratory protection equipment issue, and observation of egress from
contaminated areas.
9.
Conclusions (83528/83728)
The inspection revealed that the licensee appears to have the elements in
place to have an effective dose reduction program, however, it's too early
to determine the effectiveness of the recent initiatives.
In the past,
management support and involvement in the ALARA program, conflicting
operational priorities and unforeseen work items, have contributed to less
than total success for the ALARA program.
Licensee management support and
involvement evidenced during this assessment must continue if the _
licensee's collective radiation dose is going to be reduced to the
industry norm.
The following significant issues were identified during
the inspection and should be addressed by the licensee to increase the
effectiveness of their ALARA program.
a.
Dose goal formulation - goals are not based on tasks but rather on an
average dose per day, daily goals are 3.5 times higher at Surry
compared to North Anna (Paragraph 4.c) (50-280/281/88-03-0l) .
b.
RWP hold program - entries are made on RWPs after the hold point is
reached without evaluation and enhanced controls to ensure holds are
applied as documentation of holds is not formalized (Paragraph 4.e),
method of encoding exposure data in PR EMS does not facilitate
retrieval and comparison (Paragraph 4.d)(50-280/281/88-03-02).
c.
Review reasons for containment power entries to determine if the
number
of
such
entries can
be
reduced
(Paragraph 5.c)
(50-280/281/88-03-03).
d.
ALARA Action Plan does not include a formal schedule with milestones
for
implementing
the
recommendations
(Paragraph 4.f)
(50-280/281/88-03-04).
e.
ALARA Program procedures have not been revised in a timely manner to
conform to licensee's corporate radiation protection plan
(Paragraph 4) (50-280/281/88-03-05).
No violations or deviations were identified .