ML20057C342
| ML20057C342 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/10/1993 |
| From: | Boland A, Pharr E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057C333 | List: |
| References | |
| 50-321-93-16, 50-366-93-16, NUDOCS 9309280238 | |
| Download: ML20057C342 (21) | |
See also: IR 05000321/1993016
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET, N.W., SUITE 2900
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ATLANTA, GEORGIA 30323-0199
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SEP 101993
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Report Nos.:
50-321/93-16 and 50-366/93-16
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Licensee: Georgia Power Company
P. O. Box 1295
Birmingham, AL 35201
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Docket Nos.: 50-321, 50-366
License Nos.:
Facility Name: Hatch I and 2
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Inspection Condu tad: August) 9-13 ,1993
Inspectors:
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A. T. Bolan
Date signed
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Accompanied by: M.
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Approved by M
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W. H. Rankin, Chief
Date Signed
Facilities Radiation Protection Section
Radiological Protection and Emergency Preparedness Section
Division of Radiation Safety and Safeguards
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SUMMARY
Scope:
This special, announced inspection was conducted to evaluate the licensee's
efforts for maintaining occupational radiation exposure as low as reasonably
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achievable (ALARA). The assessment included a review of the licensee's
current organization and program for keeping radiation doses ALARA; a review
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of past and current licensee ALARA initiatives; and an evaluation of
management and worker awareness of, involvement in, and support for the ALARA
program.
Results:
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Overall, the inspector found the licensee's program for maintaining worker
exposures ALARA to be functioning adequately. The inspector informed licensee
representatives that the effectiveness of their ALARA program appeared to have
improved sinr: a previous special inspection of the ALARA program conducted
December 10-14, 1990, as documented in Inspection Report (IR) 50-321,366/90-
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Program enhancements appeared to have resulted from a reorganization of
the ALARA group, development and use of historical files, and improved
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communications between the ALARA group, Health Physics (HP), plant work
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9309280238 930910
ADOCK 05000321
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groups, and planners and schedulers. The inspector reviewed audits performed
by the Safety Audit and Engineering Review (SAER) group, incorporation of
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ALARA into training programs, and use of the ALARA Suggestions Program and
Plant ALARA Review Committee (PARC). The inspector noted that each of these
programs appeared to be beneficial in identifying and resolving issues to
reduce personnel exposures. The inspector also reviewed and discussed various
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dose reduction initiatives which the licensee had implemented as well as other
initiatives the licensee was evaluating for future implementation. ALARA
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initiatives and source term reduction programs appeared to be getting
management support at both the plant and corporate levels. The inspector
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noted that overall these initiatives had been successful in maintaining outage
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exposures, as well as cumulative annual exposures as projected. The
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licensee's collective exposure goals appeared to be aggressive, and thereby
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demanded a strong ALARA program. One apparent violation was identified by_ the
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inspector involving the licensee's failure to maintain an access to a posted
Very High Radiation Area locked in accordance with licensee procedure.
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REPORT DETAILS
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1.
Persons Contacted
Licensee Employees
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- G. Barker, Superintendent, Instrument and Calibration (I&C)
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- E. Burkette, Supervisor, Engineering Support
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- C. Coggin, Manager, Training and Emergency Preparedness
- S. Cowan, Foreman, Health Physics (HP)
- J. Davis, Manager, Administration
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- 0. Fraser, Site Supervisor, Safety Audit and Engineering Review (SAER)
- M. Googe, Manager, Outages and Planning
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- J. Hammonds, Supervisor, Regulatory Compliance
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- W. Kirkley, Manager, HP and Chemistry
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- J. Lewis, Manager, Operations
- M. Link, Supervisor, HP.
- M. Moore, Senior HP Technician
- P. Moxley, Nuclear Specialist
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R. Ott, Training Supervisor
- J. Payne, Senior Engineer, Nuclear Safety and Quality Control (NSQC)
- W. Prince, Training Instructor
- D. Smith, Superintendent, HP
- L. Sumner, General Manager
- J. Thompson, Manager, Security
- S. Tipps, Manager,' Nuclear Safety and Compliance
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- A. Wheeler, Supervisor, Plant Engineering
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C. Zander, Senior HP Technician
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Other licensee employees contacted during this inspection included
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engineers, technicians, and administrative personnel.
Nuclear Regulatory Commission
E. Christnot, Resident Inspector
B. Holbrook, Resident Inspector
- L. Wert, Senior Resident Inspector
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- Denotes attendance at August 13, 1993 exit meeting
2.
Organization and Staffing (83728)
During the onsite inspection, the inspector reviewed the licensee's
organization and staffing for the ALARA program. The inspector noted
that during 1992 the Health Physics (HP) group experienced several
organizational changes including assigning the Plant Health Physicist
the overall responsibility of ALARA Coordinator. Th2 Coordinator
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reported directly to the HP Superintendent, with an ALARA Specialist and
a Radiation Work Permit / Maintenance Work Order (RWP/MWO) Specialist
reporting directly to the Coordinator. As ALARA Coordinator, the Plant
Health Physicist was responsible for' long term dose reduction projects
and the Plant ALARA Review Committee ~(PARC). The ALARA Specialist
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responsibilities included the Hot Spot Program, outage planning,
procedure reviews, and cobalt reduction. The RWP/MWO Specialist
responsibilities included interface with various work groups and
planning committees, and MWO and RWP review.
Three HP technician
positions were permanently assigned to assist with ALARA planning,
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including development of historical files, and two technician positions
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were permanently assigned to assist w:th RWP and work coordination. The
inspector noted that the licensee continued to support rotational
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assignments between the HP and ALARA staffs to support those five
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technician positions within the ALARA operations grotg.
The inspector noted that the background knowledge and experience of the
Health Physicist and the Specialists appeared to be appropriate for
their designated responsibilities. All pe* sons within the present
organization, including the technicians, had numerous years of Boiling
Water Reactor (BWR) plant experience.
During discussions with licensee
representatives, the inspector noted that the prescnt organization and
staffing levels appeared to be appropriate to implement the ALARA
program.
The inspector noted several overall program enhancements which had
resulted from the recent reorganization of the ALARA program.
Those
included development and use of historical files for work evolutions and
improved communications between ALARA, HP, and planning personnel, both
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of which had provided for successful preplanning efforts. These
improvements had been beneficial in maintaining routine and outage
exposures approximately as projected.
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No violations or deviations were identified.
3.
Audits and Appraisals (83728)
Section 17.2.18.1, Audits, of the Hatch Unit 2 Final Safety Analysis
Report (FSAR) requires, in part, that audits of HP and radiation
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protection (RP), to include the ALARA program, be performed under the
cognizance of the Safety Review Board (SRB) at least once per 24 months,
unless more frequent audits are necessary due to certain specified
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conditions.
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The inspector discussed with licensee representatives within the Safety
Audit and Engineering Review (SAER) Department the licensee's audit
prrgram as related to meeting FSAR requirements for performing biennial
at>dits of the ALARA program. The inspector was informed that although
biennial audits of the HP program were required, SAER usually performed
an annual HP program audit, which included a formal review of the ALARA
program. The inspector was also informed that the SAER group routinely
evaluated work practices and ALARA techniques, regardless of the
discipline audited.
The inspector reviewed the most recent SAER audit of the HP program, 93-
HP-1, conducted June 8-25, 1993. The inspector noted that although the
audit did not include a formalized review of the ALARA program, due to a
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prior, and recently performed, informal review of the program, the audit
did include a review of the effectiveness of the licensee's program to
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maintain exposures ALARA. Based on their review, the auditors
determined that the HP group was satisfactorily tracking, monitoring,
and recording exposures, and in response was implemanting effective
processes for identifying and thus restricting access of personnel
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approaching exposure limits.
TFe inspector verified that an ALARA
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review had been performed during the previous year's HP audit, 92-HP-1,
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conducted September 14-18, 1992.
During this audit, the recent
reorganization of the ALARA group was reviewed and evaluated for
effectiveness.
Recently assigned responsibilities for the staff members
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and implementation of these were also reviewed for effectiveness.
Overall, the audit determined the reorganization to be a positive
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initiative and improvements which had resulted in the ALARA program had
led to personnel exposure reductions.
The inspector also reviewed various other program inspections conducted
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by the SAER department during 1993. These included 93-SA-1, a special
audit of outage activities, conducted March 17, to April 23, 1993; 93-
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CH-1, an audit of the Plant Chemistry program, conducted February 17, to
March 10,1993; and 93-FH-1, an audit of Special Nuclear Materials (SMN)
control, fuel handling, and refuel floor activities, conducted March 8,
to May 7, 1993. The inspector noted that each of these audits did
include a review of HP and ALARA issues, mainly concentrating on ALARA
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work practices, posting and labeling, and dosimetry use. The inspector
also noted that during 93-CH-1, the auditors identified a finding
regarding several examples of poor radiation work practices and ALARA
techniques.
In accordance with procedural guidelines, the Chemistry
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group had provided a timely response to the audit finding and the
responsible groups were in the process of final review and verification
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of the response.
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The inspector verified that the SAER group was performing HP audits, to
include a review of the ALARA program, as required by the FSAR. These
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program audits appeared thorough and complete in_their review of the
effectiveness of the ALARA program. The inspector also noted that the
review of ALARA work practices during other program audits was a
positive initiative and should be beneficial in improving the overall
effectiveness of the ALARA program. The inspe:. tor also noted that audit
reports as documented by SAER, to include audit findings and
recommendations, were reviewed by an appropriate level of both plant and
corporate management. An identified audit finding required a 30 day
response from the responsible organization which identified root cause
and corrective actions. This response required a review for approval by
both SAER and the Vice President of the Hatch Project. Once approved,
the identified corrective actions and their effectiveness would be
reviewed for closure by SAER. The inspector informed licensee
representatives that their program for auditing the effectiveness of the
ALARA program was adequate and appeared to be effective in identifying
issues to improve the program.
No violations or deviations were identified.
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4.
Training (83728)
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10 CFR 19.12 requires, in part, that the licensee instruct all-
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individuals working in or frequenting any portion of a restricted area
in the health protection aspects associated with exposure to radioactive
material or radiation; in precautions or procedures to minimize
exposure; in the purpose anc' function of protection devices employed; in
the applicable provisions of the Commission regulations; in the
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individual's responsibilities; and in the availability of radiation
exposure data.
Section C.1.c of Regulatory Guide 8.8 describes the contents of licensee
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training programs with respect to ALARA instruction,
a.
General Employee Training (GET) Program
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Licensee Procedure 73TR-TRN-001-05, General Employee' Training
Programs, Revision (Rev.) 6, dated September 10, 1992, details the
licensee's requirements for initial GET and retraining for all
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personnel working at the plant.
Employees needing unescorted
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access to areas of the plant other than vital areas (i.e.
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protected area on'y) are required to complete instruction on
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security procedures and emergency preparedness. Employees needing
unescorted access to vital areas are required to complete
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instruction on radiation protection principles in addition to
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security and emergency preparedness, and demonstration of
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proficiency in the practical areas of radiological work, including
donning protective clothing and frisking, is required.
Employees
may be exempted from full initial classroom training if they have
been previously trained and allowed unescorted access to
restricted areas at a nuclear facility within the past three
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years.
For both exempted and non-exempted employees successful
completion of a written examination with at least a 70 percent
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score is required. GET training remains current for a period of
one year from the last day of the month in which the ' initial
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training sessions were completed, at which time requalification is
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required.
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The inspector reviewed the current lesson plans and training
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modules in use for GET initial training.
For radiation
protection, the course included approximately seven hours of
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instructional material including modules on health physics
fundamentals, biological effects of radiation, administrative
health physics considerations, exposure control, contamination
control, access control, monitoring, and protective clothing.
Related to the concepts of ALARA, the inspector noted that the
course outlines included appropriate information related to
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workers' and their supervisors' responsibilities in maintaining
exposures as low as achievable, the need for awareness of the
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radiological conditions in the work environments, the concepts of
time-distance-shielding, and the ALARA work review process.
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addition, the presentation encouraged employr.cs to submit
suggestions for improving exposure performance, ALARA suggestions.
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Further, the inspector discussed with licensee representatives and
reviewed selected course documentation for annual GET
requalification.
In requalification training, selected areas of
emphasis are provided on an annual basis, and workers are required
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to successfully complete an examination covering the new material,
as well as material contained in initial GET with a 70 percent
score.
For 1993, special topics included radioactive waste
minimization, high radiation door procedures, and changes
forthcoming with the implementation of the new 10 CFR Part 20.
In
1991, special topics included instruction on ALARA with emphasis
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on the worker's responsibility in minimizing their personal
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exposure.
Review of a sample examination used to determine
proficiency noted that the question content was consistent with
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the course objectives and included specific questions on ALARA
principles. Overall, no concerns were noted with respect to the
content of GET; however, the inspector did discuss with licensee
representatives the need to update the industry events used as
examples throughout course materials. Training personnel stated
that the material was currently under revision and consideration
would be given to including more recent events.
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During the onsite inspection, the inspector reviewed computerized
GET training documentation for selected employees who had worked
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on RWPs 193-0291 and 193-0290 associated witn Kaowool insulation
repair, replacement, and support work.
For the records reviewed,
the inspector determined that all workers had successfully
completed GET training within the last year, as required. No
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concerns were noted.
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Based on the evaluation of selected training procedures,
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examinations, student handouts, and course outlines, the inspector
determined that the licensee's GET program met the provisions of
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10 CFR 10.12, and appropriate ALARA principles were incorporated
to facilitate exposure reduction by workers,
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No violations or deviations were identified.
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b.
Initial Health Physics Training
Licensee Procedure 73TR-TRN-002-OS, Non-licensed Training
Programs, Rev. 5, dated June 1,1991, established the program for
the training and qualification orograms for maintenance, HP,
chemistry, and quality control p?rsonnel .
Fce HP technicians the
initial training program included academic course work and HP
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coverage course instruction, as well as specialized skills
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qualification.
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The inspector reviewed selected aspects of the HP technician
initial training program with respect to the inclusion of ALARA
principles.
Course Module HP-100, ALARA Philosophy, provided
instruction on the implementation of the plant ALARA program as
well ALARA concepts related to technician responsibilities.
Topics included:
the pre-job review process minimization of
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unnecessary work; work hold points; required tools list; special
tool requirements; pre-job briefings; and incorporation of lessons
learned from previous similar job evolutions.
In addition, Module
HP-210, Health Physics Coverage, provided specific instructions
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related to the technicians responsibilities in providing job
coverage activities including the authority to stop work, the cost
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value of a person-rem, and shielding concepts and calculations.
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Based on the review of this area, the inspector determined
appropriate inclusion of ALARA principles in initial HP technician
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training.
Although not procedurally included as part of the required
training program, the licensee had also established a detailed,
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one-week course specifically designed for ALARA technicians. Tnis
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course, Module HP-260, had been provided to ALARA technicians in
the past; however, licensee personnel stated that the training
would in the future become part of the required training and
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qualification program.
In addition, by the end of August 1993,
the licensee stated that all current ALARA technicians and
specialists would have completed the' training.
Review of the
course material by the inspector determined that the material
included general information such as exposure contiels, use of
glove bags and shielding, hot spots, conduct of ALARA reviews,
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outage planning activities, and an in-depth review of the ALARA
computer system.
Review of test material given for a previous
course determined that the questions provided comprehensive
coverage of the lecture material as well as tested capability of
calculational skills applicable to ALARA. Overall, the inspector
found this course to be a good initiative and s strength to the
overall ALARA program.
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In addition,-for those personnel who participated on the PARC, a
special eight-hour course covering the duties, responsibilities,
interfaces, and activities of the PARC was provided. Review of
the related documentation and student handout noted that the
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course included a more in-depth treatment of ALARA principles
appropriate to the management oversight and review / approval role
of the committee.
In addition to general exposure control
fundamentals and ALARA program elements, the material included
information on the formulation of ALARA goals and job dose
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estimates, cost benefit analyses, and post job reviews. Overall,
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the course content appeared to support a greater understanding of
ALARA principles by PARC participants, and was considered a
strength to the overall program.
No violations or deviations were identified.
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c.
Continuing Training Programs
Licensee Procedure 73TR-TRN-002-OS, Non-licensed Training
Programs, Rev. 5, dated June 1, 1992, outlines the. program for
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continuing training for the various plant disciplines. - The intent
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of continuing training is to improve the knowledge level and
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skills of previously qualified personnel.
For maintenance and HP
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personnel, continuing training consists of approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
and 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> per year, respectively.
Failure to complete
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continuing training within the established time limit results in
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the loss of qualification in the duty areas affected by the -
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training materials.
The inspector reviewed selected aspects of the continuing training
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programs provided to HP, mechanical maintenance, electrical, and
engineering personnel.
In general, the inspector determined that
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the training provided over the past several years had periodically
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included HP topics tailored to the specific work function being
trained as well as specific ALARA topics such as ALARA program
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requirements, ALARA suggestions, and how to use, establish, and
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fabricate glove bags (mock-up). However, the inspector noted that
although onsite engineers received some training in the use of the
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company design guide, the initial training nor continuing programs
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for these personnel included any specific tra.ning on ALARA design
considerations such as stellite reduction, valve orientation, pipe
runs, and maintenance activities potentially affecting exposures.
The inspector noted that emphasis in this area could'be
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particularly effective given the recent increased.onsite
engineering responsibilities implemented for minor design changes.
Licensee representatives stated that they would evaluate the need
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for potential improvements in this area.
No violations or deviations were identified,
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d.
Worker Awareness
During the onsite inspection, the inspector discussed overall HP
and ALARA programs with various plant personnel including
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technicians, supervisors, and management personnel.
From these
discussions, the inspector determined that workers were
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knowledgeable of general ALARA principles, management directives
in this area, and their individual responsibilities in minimizing
personnel exposure.
No violations or deviations were identified.
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5.
ALARA Program Awareness, Support, and Incentives (83728)
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During discussions'with the licensee, the inspector was informed of the
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high level of management support, both plant and corporate, the ALARA
program was currently receiving. This support was evidenced by the
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licensee budgeting funds for plant participation in the Plant Model
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Chemistry Program, chemical decontamination of the recirculat' on system
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during the 1994 Unit One outage, chemical' injection programs, cobalt'
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reduction programs, spent fuel pool (SFP) cleanup projects, and the
program to eliminate high radiation areas (HRAs) throughout the plant.
Additionally, the HP group had recently purchased remote monitoring
equipment and additional shielding. These initiatives are further
discussed in Paragraph 6 of this IR. The inspector also discussed with
licensee representatives methods for the plant populous to express their
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concerns and ideas for improving the plant ALARA program.
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The inspector discussed and reviewed the PARC, to include its
responsibilities and activities, with cognizant licensee
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representatives. The inspector noted that the PARC aeetings were
normally chaired by the HP/ Chemistry Manager or the MP Superintendent.
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The Committee was comprised of personnel from key station departments,
including HP-Operations, ALARA, Instruments and Calibration (I&C),
Maintenance, Operations, Quality Control and Engineering,- and Outages
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and Planning. The inspector also noted that the Assistant General
Manager-Plant Operations routinely attended the meetings, as well. The.
PARC usually met at least once every month, although the Committee was
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only required to meet on a quarterly basis.
During review of selected
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1992 and 1993 meeting minutes, the inspector noted that the PARC
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reviewed major jobs, outage and non-outage, and expected exposures,
including Radiation Work Permits (RWP) for jobs with projected exposures
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greater than 10 person-rem, outage preparations, HRA access controls,
plant exposures, dose goals, ALARA Suggestions, radiation deficiencies,
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and design change requests (DCR). The inspector also noted that the
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PARC reviewed and approved dose goals for both outage and non-outage
activities, to include the goal for each work group. The inspector was
informed that these goals were set by the ALARA group following
department input and review of scheduled work evolutions and historical
dose data.
The inspector also reviewed the licensee's ALARA Suggestion program.
The inspector noticed numerous ALARA Suggestion Boxes throughout the
facility, for submittal of employee ALARA suggestions. The inspector
further noted that these boxes were appropriately and conveniently
located in areas where they could be utilized by all facility employees.
The inspector also. observed ALARA signs throughout the plant which would
aid in increasing worker awareness and enhancing interest in the ALARA
program. The inspector reviewed selected ALARA Suggestions submitted
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since 1992 and noted an increase in suggestions during outages or
immediately following. The inspector also noted that the majority of
these suggestions were submitted by HP personnel.
Suggestions were
reviewed by the PARC and either approved or disapproved. Those approved
were assigned to an individual for further review and/or implementation,
with their status tracked until closure. Additionally, during
discussions with licensee representatives, the inspector was informed
that the licensee was presently reviewing various options for an
incentive program for approved suggestions.
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During discussions with plant personnel and supervisors, the inspector
noted that personnel appeared to be aware of the importance of a strong
ALARA program and indicated that management support for ALARA seemingly
had increased over recent years. The inspector also noted that the PARC
and ALARA Suggestion program both appeared to be active and
appropriately identifying and resolving issues beneficial in reducing
plant dose rates and personnel exposures.
No violations or deviations were identified.
6.
Radiological Work Control (83728)
The inspector reviewed selected aspects of the licensee's work control
program including RWP development and integration of ALARA into the
design change process and maintenance work order processes.
a.
Radiation Work Permits (RWPs)
Licensee Procedure 62RP-RAD-006-0S, RWP Processing, Rev. 4, dated
September 1,1992, establishes the licensee's requirements for
generation, routing, approval, and termination of RWPs. The
licensee utilizes a general RWP for inspection, HP survey,
chemistry sampling, and operating functions while specific RWPs
are required for specific jobs or work functic.1s.
Specific RWPs
are further characterized as routine, normal operations job
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specific, or outage job specific depending on the nature of the
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work and anticipated radiological conditions.
Discussions with licensee representatives revealed that ALARA
personnel were responsible for generating RWPs and formulating
person-rem estimates as well as recommending additional protective
requirements, as deemed necessary.
Final approval of the RWP and
associated requirements is the responsibility of the HP foreman.
A detailed ALARA review is required for all jobs in areas with
dose rates greater than 100 mrem /hqur and which are expected to
receive greater than 1 man-rem of exposure as well as all jobs
with smearable contamination levels greater than
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The inspector reviewed selected RWPs associated with the 1993
Unit 1 outage as well as selected RWPs associated with the on-
going Kaowool insulation work for appropriateness of the radiation
protection requirements based on work scope, location, and
conditions.
For those RWPs reviewed, the inspector noted that
radiological concerns were appropriately addressed in that
adequate protective clothing, respiratory protection, and
dosimetry were required. ALARA reviews and p a-job briefings were
also performed, as required.
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The inspector was further informed that the licensee had developed
a historical file program to be used for pre-job planning and RWP
development. Development of historical files was initiated so as
to aid the ALARA group in documenting information such as problems
encountered hot spots, suggestions for improvements, and methods
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which were effective during specific work evolutions.
The intent
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of the program was to update the files as new information became
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available.
Currently, the licensee is exploring methods to better
manage the information including optical scanning and use of the
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local area network. The inrpector noted that optimization of this
information should facilitate the use by personnel in the job
planning process.
The inspector informed licensee representatives that their program
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for RWP implementation adequately addressed radiological
protection concerns and provided for proper control measures.
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No violations or deviations were identified.
b.
Design Changes and Maintenance Work Orders
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Licensee Procedure 60AC-HPX-009-05, ALARA Program, Rev. 8, dated
October 10, 1992, details the licensee's process for ALARA review
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of DCRs. This process inludes initial review of the DCR by the
engineer responsible to determine if an ALARA review is required
based on specific criteria established by the procedure.
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threshold for an ALARA review is met, ALARA personnel conduct an
evaluation of the DCR package with consideration of the following
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areas: radiation shields and design layout, process
instrumentation and control, control of airborne radioactive
contaminents, crud control, decontamination, accessibility, and
human factors. Although not procedurally required, ALARA
personnel informed the inspector that ALARA was now routinely
participating in DCR status meetings conducted at various stages
during the DCR development process. According to the licensee,
such participation early on has facilitated communications and
ALARA input, and has minimized the need for substantive ALARA
.
recommendations at the end of or late in the design process.
Licensee representatives stated that recently the onsite
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engineering group had been assigned greater responsibility for
implementing minor design changes. The inspector noted that the
current ALARA procedures do not address ALARA review of these
types of changes; however, licensee personnel stated that
currently they were being treated similar to DCRs.
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The inspector also discussed with ALARA personnel the planning and
coordination with other plant departments regarding routine
maintenance and work activities. The inspector noted that ALARA
personnel attended daily meetings conducted with the planning
staff to determine the upcoming work as well as the need for RWP
development or other HP support. Attendance at one of these
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meetings by the inspector found it to be infm. native and a
valuable tool for increased HP awareness and input to planned
maintenance activities.
Overall, based on the inspector's review of this area, procedural
controls and HP involvement in plant modifications and maintenance
activities appeared appropriate.
No concerns were noted.
No violations or deviations were identified.
7.
Exposure Goals (83728)
As discussed in Paragraph 5 above, annual and outage dose goals, as well
as individual work group goals, are set by the ALARA group. The ALARA
group bases these goals on anticipated work scope and historical dose
data. The inspector reviewed the licensee's projected goals and actual
cumulative exposures since 1991 and noted a positive trend in
maintaining exposures ALARA. The inspector noted the licensee's annual
cumulative exposure during 1991, 1992, and 1993, to date, was
approximately 1160, 550, and 560 person-rem, respectively. After 1991,
the licensee's three year dose average was 1095 person-rem, which was
higher than the median of 1035 person-rem for BWRs. The inspector was
informed that during 1991 the licensee completed twc refueling' outages
and began actual Hydrogen Water Chemistry (HWC), w nh no zine injection.
Licensee representatives also indicated that dose reduction was a top
priority- following 1991. During 1992 and 1993, the licensee completed
one routine refueling outage each year.
Additionally, the licensee was
aggressively pursuing and implementing dose reduction programs. The
1992 goal was 1035 person-rem and licensee representatives indicated
that ALARA initiatives greatly contributed to the licensee successfully
meeting their goal.
The licensee's 1993 goal was 630 person-rem.
Due
to non-scheduled work, including a forced outage, the licensee's year-
to-date dose, of 560 person-rem, was above projection.
However, the
licensee indicated that the 630 person-rem goal was achievable.
For
1994, the licensee has two refueling outages scheduled and anticipates
establishing another aggressive annual goal.
The inspector informed licensee representatives that their
aggressiveness in reducing personnel exposures by establishing and
meeting their aggressive dose goals was an area in which it appeared
that the ALARA program had improved.
The inspector noted that these
aggressive goals appeared to be appropriate for the anticipated work
scope and was a positive initiative.
No violations or deviations were identified.
8.
ALARA Initiatives and Source Term Reduction Program (83728)
The inspector discussed the licensee's efforts, both long- and short-
term, to reduce plant dose rates and personnel exposures.
Licensee
representatives ndicated that since 1991 several initiatives have been
beneficial to the therall effectiveness of the ALARA program and have
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!
been possible contributing factors to the declining plant cumulative
exposure. These initiatives included staff reorganization which
permanently established an ALARA and RWP/MWO coordination group;
successful preplanning efforts by these groups; and successful
communication and coordination between outage management, HP, and the
work groups.
In addition, the use of closed-circuit cameras and DADS
were effective in providing for remote HP surveillance, thereby
!
!
maintaining HP exposures ALARA. These cameras are also now being used
extensively by Operations so as to prevent or to minimize their entries
,
into HPas.
Extensive use of shielding, permanent arJ temporary, and
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improved coordination between engineering and HP for review and
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implementation of shielding packages has also been beneficial in
maintaining exposures ALARA.
The inspector also-reviewed and discussed the Plant Model Chemistry
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Program, in which the licensee is an industry leader. The inspector
noted that the program was divided into six working groups, each with
its own charter.
Each working group is comprised of at least one
representative from the site, corporate, and General Electric. The main
focal points of the program are cobalt source term reduction, radwaste
resin reduction, exposure reduction, HWC improvement so as to prevent
crack growth in primary system components, iron source term reduction,
and service water treatment, all by way of optimum water chemistry.
Along with this program to improve water chemistry, the licensee has
successfully utilized chemical decontaminations on recirculation and
Reactor Water Cleanup (RWCU) systems to reduce system dose rates during
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previous outages. The licensee plans another chemical decontamination
of the Recirculation System during the 1994 Unit One outage. The
licensee has also implemented programs for replacing stellite valve and
control rod components with low cobalt materials.
,
The inspector informed licensee representatives that their efforts in
reducing source term and reducing personnel exposure to radiation appear
to have been successful initiatives and continued implementation should
be beneficial to the licensee's program to maintain personnel exposures
No violations or deviations were identified.
9.
External Exposure Controls (83728)
10 CFR 20.101 requires that no licensee shall possess, use, or transfer
licensed material in such a manner as to cause any individual in a
restricted area to receive in any period of one calendar quarter, a
total occupational dose in excess of 1.25 rems to the whole body, head
and trunk, active blood forming organs, lens of the eyes, or gonads;
18.75 rems to the hands and forearms, feet and ankles; and 7.5 rems to
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the skin of the whole body.
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Technical Specification (TS) 6.11 requires that procedures for personnel
{
radiation protection be prepared consistent with the requirements of
10 CFR Part 20 and shall be approved, maintained, and adhered to for all
operations involving personnel radiation exposure.
'
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During tours of the plant with HP personnel on August 9, 1993, the
inspector observed the presence of a temporary step ladder adjacent to
)
the exterior wall of the Unit I transversing incore probe (TIP) room.
,
At the time, licensee personnel were unsure as to the reason for the
temporary ladder; however, they stated that insulation work had been
underway in the area.
Upon further review, the inspector also observed
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the presence of a permanently installed ladder located in an opening on
the roof of the TIP room which provided access from the roof area into
the TIP room.
Although the normal access door to the TIP room was
locked and conspicuously posted as " Grave Danger - Very High Radiation
>
Area," the permanent ladder on the roof was not locked to prevent
unauthorized access.
Based on these observations, the inspector
,
informed the licensee that the permanently installed ladder located on
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the roof provided an alternate access to the TIP Room, and the presence
!
of the temporary step ladder in the area facilitated possible personnel
,
access to the roof opening and the unlocked ladder.
Upon identification
of the concern by the inspector, the licensee removed the permanent
ladder on the evening of August 9,1993, and the temporary ladder was
taken down, but remained in the area.
,
Although the licensee has not yet implemented the new 10 CFR Part 20,
which clearly defines the regulatory position associated with Very High
,
Radiation Areas, the licensee has procedurally defined a Very High
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Radiation Area and has incorporated specific administrative ~ and physical
!
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controls applicable to such areas in Procedure 60AC-HPX-004-OS,
Radiation and Contamination Control, Rev.11, dated July 7,1992.
Specifically, Step 8.1.4.1 defines a Very High Radiation Area as an area
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which could be made accessible to an individual in which potential
radiological conditions could increase very rapidly resulting in an
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individual receiving an acute overexposure, exceeding administrative
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and/or federal exposure limits.
Further Step 8.1.4.2 of this procedure
states that Very High Radiation Areas shall be locked and conspicuously
!
posted with a sign unique to the type area.
,
Based on the above, the inspector informed licensee representatives that
.
,
the failure to lock an access point to the Unit 1 TIP room, a posted
!
Very High Radiation Area, was a violation of TS 6.11 for the failure to
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follow Procedure 60AC-HPX-004-05 (VIO 50-321, 366/93-16-01).
Licensee management personnel informed the inspector that they did not
believe that they were in violation of regulatory requirements.
The
'.
basis for the licensee's contention was the licensee's belief that
extraordinary measures were required to access the TIP room roof, that
,
the main access door was locked, and that no work had been performed in
!
the area without HP coverage.
In response to these items, the inspector
!
,
noted that in accordance with the licensee's procedural requirements,
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the ladder provided accessibility to a very high radiation area which
was not maintained locked, regardless of the status of the main access
door or HP coverage during specific job evolutions.
The inspector discussed with licensee personnel the circumstances
surrounding the presence of the permanent ladder as well as the
temporary ladder. The licensee stated that prior to the locked high
radiation door upgrade progra'n completed in December 1992, the permanent
ladder was outside of the locked primary access point; however, during
the upgrade, the new doors were relocated and installed placing the
permanent ladder inside the locked area. At the tin.a, discussions were
held within the licensee's organization regarding removing the ladder as
well as enclosing the hole on the roof; however, any action had been
deferred.
The inspector noted that Unit 2 had a similar opening in the
roof of the TIP room. The opening was posted with stantions denoting
" Grave Danger - Very High Radiation Area"; however, no permanent ladder
was installed to provide an access point.
No concerns were noted with
the configuration of the Unit 2 TIP room.
During the onsite inspection the following areas were noted by the
,
inspector and discussed with the licensee:
The licensee stated that the plant employed a "Six Foot Policy"
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which required HP to survey the area prior to access by personnel.
However, the inspector noted that such an administrative policy
does not preclude access.
The top of the permanent ladder was posted a " Grave Danger - Very
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High Radiation Area" and was barricaded using radiation tape;
however, such controls do not preclude the requirement for. locking
the ladder.
Through discussions with HP personnel, the inspector determined
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that the temporary ladder observed adjacent to the TIP room on
August 9, 1993, was used by a HP technician and an engineer on
>
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August 5,1993, to perform a walkdown of the area for upcoming
insulation work. Although the temporary ladder was taken down, it
,
remained in the area throughouc the onsite inspection. The
inspector noted that the licensee did not have a formal ladder
control program.
The aforementioned walkdown of the roof area was conducted under
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RWP 193-0291, TSI/Kaowool Repair, Replacement and Support Work,
,
and documentation confirmed the required pre-job briefing was
conducted. Although the RWP did not require HP coverage, the
technician stated that he accompanied the engineer during the
entire walkdown while performing coverage surveys.
No surveys
were documented associated with this walkdown.
The insulation work to be conducted on the roof of the TIP room
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,
had not yet begun at the time of the inspection; however, a pre-
job briefing for the workers had been conducted and the RWP
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15
applicable to the work (RWP 193-0291) written. The RWP specified
intermittent HP coverage and not continuous HP coverage. The pre-
job briefing records did not document any special instructions
regarding the presence of the ladder on the TIP room roof. The
documentation did specify that continuous HP coverage would be
provided for work in the steam chase; however, no mention was made
of equivalent coverage on the TIP room roof. The technician
stated that the presence of the permanent ladder was discussed in
the pre-job briefing and workers were instructed not to use it;
however, this was not documented.
Review of 1993 records indicated that only two specific RWPs hcd
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been written to cover work on the Unit 1 TIP room roof. These
were RWP 193-1216, Electrical Inspection and Repairs to Electric
Connection and Support Work, and RWP 193-1245, f.emove Insulation
and Buff Pipe Weld and In-service Inspection.
Both of the RWPs
were conducted during the outage at which time the TIPS were
tagged out-of-service. However, discussions with one of the
health physics technicians indicated that work had been performed
on the Unit 1 TIP room roof some months previously, possibly in
the December 1992 or January 1993 timeframe. The individual
stated that for this particular evolution cont inuous line-of-sight
coverage was provided; however, specific documentation of the work
(RWP, log entries, or surveys) was not available for review. The
technician as well as a HP foreman stated that such work on the
TIP room roof would have been performeL Jnder a general RWP which
would not have required continuous HP coverage.
They further
stated that although most work conducted in the area was of short
duration resulting in a technician being in the area throughout
the job; they did not feel obligated to provide continuous
coverage because it was not required, and that at times in the
past work had been done without their constant coverage.
In
general, licensee documentation did not support that work in this
area has or would require continuous HP coverage.
In accordance with Procedure 3450-C51-001-05, TIP System
Operation, Rev. 2, dated May 5,1993, the licensee maintains the
TIP system in " operate" mode, unless the system has been cleared
or the key to the normal access door has been checked out. When
the access control key is checked out, the TIPS are placed into
the " inoperative" mode, and the key required to subsequently
operate the probes is issued to the holder of the door access key.
Thus, while the room is accessed through the primary access door,
the TIPS cannot be operated. However, with the permanent ladder
in place, access was possible during periods of TIP operation.
One apparent violation regarding the licensee's failure to comply with
procedural requirements for maintaining a posted Very High Radiation
Area locked to prevent access was identified.
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10.
Exit Meeting
The inspector met with licensee representatives as denoted in
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Paragraph 1 at the conclusion of the inspection on August 13, 1993. The
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inspector summarized the scope and findings of the inspection,. including
the apparent violation. The licensee informed the inspector that they
were in disagreement with the basis of the apparent violation.
The
inspector acknowledged the licensee's comments and informed them that
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the subject violation would be discussed and reviewed with both regional
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and headquarters management. Additionally, the licensee did not
identify any documents or processes reviewed by the inspector as
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proprietary.
Item Number
Descriotion and Reference
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50-321, -366/93-16-01
VIO - Failure to comply with
procedural requirements for locking
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an access point which provided entry
,
into a posted Very High Radiation
Area (Paragraph 9).
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