ML18152B095
| ML18152B095 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna, 05000000 |
| Issue date: | 08/11/1988 |
| From: | Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152B092 | List: |
| References | |
| 50-280-88-03-01, 50-280-88-3-1, 50-281-88-03, 50-281-88-3, 50-338-88-03, 50-338-88-3, 50-339-88-03, 50-339-88-3, NUDOCS 8808240275 | |
| Download: ML18152B095 (5) | |
See also: IR 05000280/1988003
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
AUG 1 7 1988
ENCLOSURE 4
Report Nos.:
50-338/88-03, 50-339/88-03, 50-280/88-03 and 50-281/88-03
Licensee:
Virginia Electric and Power Company
P. 0. Box 26666
Richmond, VA
23261
Docket Nos.:
50-338, 50-339
50-280, 50-281
License Nos.:
Facility Name:
Virginia Electric and Power Company
Corporate Offices
Inspection Conducted:
March 14-18 and April 4-8, 1988
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Inspector:
Jy,/~, 'lCJ]I~'\\
F. N. Wr, g t ,
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Approved by: (~_/'i,v;
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C. M. Hdse,secti~n Chief
Division of Radiation Safety and Safeguards
SUMMARY
Date' Signed
c1:ltt4n
' i gned
Scope:
This was a special, announced assessment of the licensee
1s corporate
staff in the area of the licensee
1s program to maintain occupational exposures
as low as reasonably achievable (ALARA).
Results:
No violations or deviations were identified .
1.
Persons Contacted
Licensee Employees
- Report Details
- T. Banks, Corporate Health Physicist
W. Cameron, Director Health Physics
C. Snow, Supervisor Nuclear Fuel Operations
W. Stewart, Senior Vice President
- J. Wilson, Manager, Nuclear Operations Support
Nuclear Regulatory Commission
J. Caldwell, Senior Resident Inspector, North Anna
L. King, Resident Inspector, North Anna
- L. Nicholson, Resident Inspector, Surry
- Attended exit interview
2.
ALARA Policy and Procedures (83528/83728)
The Virginia Power Nuclear Operations Department Standards (NODS) Manual
provides the corporate ALARA policy in the Radiological Protection Policy
Statement (NODS-HP-02).
The responsibilities and requirements for
implementing the Radiation Protection Plan are also included in Standard
No. NODS-HPl.
The Radiation Protection Plan describes the utilities*
ALARA Program in Chapter V, Section 4.
The utilities* ALARA program formally began in 1983.
The program was
documented in a corporate ALARA manual and implemented at Surry and North
Anna through site specific ALARA manuals.
Evaluations of the utilities*
radiation protection program by outside contractors in 1983 resulted in
the development of a comprehensive radiation protection program document
to address corporate policy and requirements.
The resulting document was
titled Virginia Power Nuclear Operations Radiation Protection Plan and was
officially approved in 1985, along with an implementation plan.
The
implementation plan established schedules for implementing the various
segments of the Radiation Protection Plan (RPP).
The utility hired a
contractor to develop the various implementing procedures and the
implementation pl an was continuously revised and updated based on the
contractor's progress.
At the time of the inspection all areas of the RPP
were projected to be completed in 1989.
North Anna implemented the ALARA
section of the RPP April 15, 1987.
Surry had not yet implemented the RPP
implementing procedures and was still operating under the old ALARA
manual.
Licensee representatives at Surry pointed out that the procedures
developed by the contractor and implemented at North Anna had to be
reformatted to meet station procedure format requirements and that this
had caused some delay in implementation, also the Surry station procedures
2
required additional review by the stations Quality Assurance group.
Surry
representatives planned to implement the new RPP ALARA procedures in April
1988.
.
3.
Corporate ALARA Staff (83528/83728)
The utilitie
1s corporate ALARA staff reported directly to the Director of
Health Physics.
The Vice President - Nuclear Operations was responsible
for providing direction and resources for the utilitie
1s ALARA and
radiation protection programs.
The Manager Nuclear Operations Support
acted on beha1f of the Vice President to administer the Virginia Power
Radiation Protection Program and assumed primary responsibility for
implementation of the radiation protection plan.
The Director of Health
Physics interfaced with corporate and station management in the
implementation of the radiation protection plan and was responsible for
ensuring the program met applicable regulatory requirements.
The
inspector interviewed the Vice President -
Nuclear Operations, the
Director of Health Physics, and a Health Physicist assigned corporate
ALARA responsibilities to determine the corporate managements knowledge
and involvement in the utilities
1 ALARA program.
The inspector determined
that the Vice President of Nuclear Operations discussed ALARA goals in
daily conferences held with corporate and station managers via telephone
and that the corporate management and staff were very knowledgeable of the
ALARA program and considered ALARA principles and objectives an important
job responsibility.
4.
Corporate ALARA Staff Activities (83528/83728)
The inspector reviewed the activities of the corporate ALARA staff through
interviews and reviews of quarterly ALARA reports, minutes of the ALARA
Coordinating Committee meetings, special evaluations, corporate memoranda,
and special reports issued since the formal ALARA program began in 1983.
The Quarterly ALARA reports and the minutes of the ALARA Coordinating
Committee meetings documented numerous proposals, industry techniques, and
ongoing evaluations aimed at reducing the utilities* exposures.
Two
examples of corporate documents are discussed below.
Virginia Power ALARA Action Plan issued June 1987, proposed. numerous dose
reduction activities for consideration, reemphasized the need for full
time ALARA Coordinators, and emphasized department goals.
Over two dozen
dose reduction activities were proposed in the plan.
Technical Evaluation of Techniques for General Plant Radiation Field
Strength Reduction, issued June 1987, described various techniques for
reducing the source term and recommendations for reducing the existing
radioactivity within the plants.
Source term controls included primary
chemistry control, use of zircaloy fuel grids, replacing valves with
materials having low cobalt concentrations and housekeeping practices
aimed at reducing the amount of foreign material taken into the primar~
systems.
Techniques for source term reduction included chemical
3
decontamination, replacement of highly contaminated insulation and removal
or shielding of unused components were also discussed.
In June 1987, the Corporate Health Physics staff presented a list of
recommendations to the ALARA Coordinating Committee meeting to enhance the
ALARA program, reduce the radiation exposure source term at the sites, and
to reduce the radwaste generated and shipped.
There were 37 items
included in the action plan and source term reduction recommendations and
14 items included in the radwaste reduction recommendations.
Assignments
were made and documented for each item on the two list, however, the task
did not have progress benchmarks or comp.l eti on schedules assigned.
Licensee representatives agreed to consider the establishment of
completion schedules for the ALARA task. The establishment of completion
schedules for ALARA tasks was discussed at the exit meeting and will be
reviewed
further during
a future inspection (50-338/88-03-05,
50-339/88-03-05, 50-280/88-03-04, 50-281/88-03-04).
The inspector determined that the Corporate ALARA staff had been
instrumental in developing a manual of good work practices for the sites.
The work practices provided dose reduction guidelines and techniques to be
applied to various task such as eddy current testing; reactor head removal
and replacement; and snubber inspections, maintenance and testing.
The inspector determined that the Corporate ALARA staff was aware of
current ALARA activities in the industry and was involved in communicating
and sharing ALARA information with other utilities.
The Corporate ALARA
staff organized a Region II ALARA Coordinators meeting to discuss dose
saving concepts being applied at Region II facilities.
The meeting was
attended by 21 representatives from 11 utilities.
Members of Corporate
ALARA staff had also visited several utilities since 1983, to learn new.
techniques and examine dose reduction activities being considered at Surry
or North Anna.
Members of the Corporate ALARA staff were currently
representing Virginia Power on an ad hoc committee with other industry
representatives
investigating methods for full
primary system
decontamination.
5.
Conclusions (83528/83728)
The inspector determined that Corporate Management had a strong awareness
involved in the 1 i censee
I s ALARA program and had made significant
contributions to the ALARA program; and that the licensee's ALARA policy
was documented and incorporated into the licensee's radiation protection
program.
However, the inspector noted that it was difficult to assess the
progress of the utilities' numerous ALARA objectives since milestones and
schedules had not been assigned to facilitate tracking of ALARA program
improvements.
The progress of improving the ALARA programs has been slow
in some cases, such as implementation of the Radiation Protection Plan.
Many of the Corporate programs for ALARA program improvements have been
made through memorandums that have been made as recommendations and not
di rec ti ves from Corporate management.
Some of the ALARA program
.....
,\\, I'
4
improvements were not implemented at all, such as performance of the
hydrogen peroxide shock with the reactor solid at North Anna (North Anna
report Paragraph 6.b.(3)).
Establishment of milestones and scheduled
completion dates is necessary for management to monitor the progress on
reducing radiation dose at Virginia Power nuclear stations.
6.
Exit Interview
The assessment scope and findings were summarized on April 8, 1988, with
the persons indicated in Paragraph 1.
The inspector described the areas
inspected and discussed in detail the assessment findings (see
Paragraph 6).
The licensee acknowledged the assessment 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 assessment.