ML20151W762
| ML20151W762 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/09/1988 |
| From: | Hosey C, Shortridge R, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20151W728 | List: |
| References | |
| 50-338-88-18, 50-339-88-18, NUDOCS 8808250123 | |
| Download: ML20151W762 (13) | |
See also: IR 05000338/1988018
Text
- _ _ - - _ _ _ _ _ _ _ _ _
- >
.,
.
,,[>R KiTug
'D
NUCLEAR REGULATORY COMMISSION
o
['
REGION it
o
g
,j
101 MARIETTA GTREET, N.W.
- *
- 2
ATL ANTA, GEORGI A 30323
%...../
p
Report Nos.: 50-338/88-18 and 50-339/88-18
Licensee: Virginia Electric and Power Company
Richmond, VA 23261
Docket Nos.: 50-338 and 50-339
License Nos.: HPF-4 and NPF-7
Facility Name: North Anna 1 and 2
Inspection Conducted: June 6-10, 1988
8
("N
Inspectors:
4
F. N. Wrifht'
Date Signed
f& 44A-
t/sler
Shnrtridge
Date Signed
'
.
M
Approved by:
,/ .
C. M. Hosey,' Sectiot Chief
Date Signed
Division of Radiaticn Safety and Safeguards
i
SUMMARY
Scope: -This routine, unannounced inspection involved onsite Mspection in the
area of radiation protection and included: external exposure control and and
dosimetry; internal exposure control and assessment; control of radioactive
materials; contamination, surveys and monitoring; solid waste, transportation
of radioactive materials and training and qualifications.
Results: Based on the results of interviews with licensee management,
supervision, and personnel from different departments; review of records and
pertinent health physics data; inspector surveys sind health physics personnel's
knowledge of functions and responsibilities regarding department operations,
the inspectors found the Radiation Protection to be fuactioning adequately.
However, weaknesses were found in the radiation monitoring program for
equipment leaving the RCA and the release of eouipment for uncontrolled use,
Paragraph 5.a.
Within the areas inspected, the following violations were identified:
Failure to perform adequate radiation surveys for contamination,
-
Paragraph 5.a.
with requirements for entries into a high
Failure of personnel to comply (licensee identified).
-
radiation area, Paragraph 3.b
8808250123 000010
ADOCK 050
8
gDR
- - - - - - - - - - - -
a
.
,_ O *
.
'
,j.
t
,
_
- g
4
.
REPORT CETAILS
,
1.
Persons Contacted
,
Licensee Employees
- M. L. Bowling, Assistant Station Manager, Nuclear-Safety and Licensing
E. W. Dreyer, Supervisor, Healt', Physics
- R. F. Driscoll, Manager, Quality Assurance
- R. O. Enfinger, Assistant hatton Manager, Operations and Maintenance
- D. A. Heacock, Supervisor, Technical Services
R. R. Irwin, Supervisor, Health Physics
- M. R. Kansler, Superintendent, Maintenance
T. Peters, Assistant Supervisor, Health Physics
- J. H.-Leberstien, Engineer, Licensing
- T. L. Porter, Supervisor, Nuclear Licensing
- D. E. Quarz, Associate Engineer
!
- A. H. Stafford, Superintendent, Health Physics
- J. A. Stall, Superintendent, Operations
- F. L. Thomasson, Supervisor, Corporate Health Physics
- W. A. Thornton, Director, Corporate Health Physics and Chemistry
Other licensee employees contacted during this inspection included
engineers, operators, mechanics, security force members, technicians, and
-
administrative personnel.
Nuclear Regulatory Commission
- J. Caldwell, Senior Resident Inspector
L. King, Resident Inspector
- Attended exit interview
2.
Training and Qualification (83723)
The licensee was required by 10 CFR 19 to provide basic radiation
protection training to workers.
Technical Specification (T.S.) 6.4 and
Regulatory Guides 8.13, 8.27, and 8.29 outline topics that should be
included in such training,
t
a.
General Employee Training
The ins 9ector reviewed quality assurance audit N-87-14 for
non-lice.nsed personnel training (and qualification.GET) was administered in a
The audit found
that General Employee Training
-
with station administrative procedure 2.3 for non-licensed personnel.
,
,
No violations or deviations were identified.
l
P
--
-m
,a
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
..
.
.
'
2
,
t
b.
Health Physic Site and Contract Technicians
To increase awareness and depth of training, a three hour course on
hot particle monitoring and control was provided to all health
physics technicians. The training included instruction on evaluation
of hot particles, contamination posting and access controls,
radiologically controlled areas and hot particles, contamination
surveys, considerations for radiation work permits, use of controls
for protective clothing, and personnel contamination monitoring and
dose assessments.
In addition, a practical factors training session
was given using radioactive sources of various beta energies to
demonstrate the effects on different instrument types, shielding
material, speed of frisking, and distance of hot particles from the
i
detector.
Also, the problems associated with personnel hot particle
contamination and monitoring a smear from a contaminated hot particle
area were evaluated.
The inspector noted that lesson plans and job
performance measures were changed to reflect the most current hot
particle detection instruction.
In addition to the HP technician specialized training, all station
,'
personnel were given a one hour training session on personnel
contamination and hot particle awareness.
No violations or deviations were identified.
c.
Continuing Training
-The inspector discussed continuing training with licensee
representatives.
As a followup corrective action to a hot particle
skin contamination, the licensee was providing training to laundry
operators on the new automated laundry monitor.
Sixteen laundry
operators were given a three day training course on new contamination
,
limits for protective clothing, precautions associated with
,
laundering and frisking protective clothing, and hot particle
contamination detection.
The training session included a practical
factors session where each student operated the laundry monitor and
used a radioactive source to display the different alarm functions of
,
i
the monitor.
The inspector observed the practical factors
demonstration and noted that the material content of the session and
instruction was satisfactory.
No violations or deviations were identified.
3.
External Occupational Exposure Control and Dosimetry (83724)
a.
Personnel Monitoring
10 CFR 20.202 requires each licensee to suoply appropriate personnel
monitoring equipment to specific individuals and require the use of
'
such equipment. The inspector reviewed the licensee's procedures for
issuance, control and calibration of self reading dosimeters (SR0s).
'
--
_ _ _ _ .
.
.
.
.
3
The inspector verified that the licensee drift tested and response
checked SRDs.
The inspector toured the licensee's calibration
facility where SRDs were response checked.
The inspector verified
that the licensee had sources and detectors (condenser R meters) that
were traceable to the National Bureau of Standards (NBS).
The
inspector reviewed serial numbers and certification papers for the
standards.
The licensee response checks and drift tests two batches
of SRDs which replace each other on a semi annual basis.
The
inspector noted that the licensee utilized one source for response
checks of dosimeters, TLDs, and most instruments.
The SRD response
calibration sheets did not have the source serial numbers recorded.
The inspector discussed the traceability of the response process and
the licensee agreed to document the source serial numbers on the SRD
response documents.
The inspettor also reviewed tl+ licensee's control procedures for
SRDs. The licensee issues SRDs to individuals entering the RCA. The
individual's Radiation Work Permit (RWP) number, SRD identification
number, and SRD reading are tracked by a computer program.
Upon
exiting the RCA and a particular RWP, the licensee surveys the SRD
and records the reading in the computer.
The SRD data is used to
track an individual's exposure - during each ~LD assignment.
The
inspector discussed the licensee's procedure for lost SRDs.
If an
individual loses a SRD, the ind;vidual's TLD is processed.
This is
also done if a SRD is turned in off scale to determine current
personnel exposure.
The inspector determined that SRDs found in the
,
'
RCA or SRDs known to have been dropped or turned in off scale were
surveyed and drift tested.
The inspector discussed the need to
verify that the SRD that may have Seen damaged were response checked
'
prior to reissuance.
Licensee representatives agreed that
potentially dt.Kufed SRDs should receive a response check prior to
issuance to ensure proper operability. The it.:pector stated that SRD
response check criteria would be reviewed during a subsequent
inspection and would be tracked as inspector Followup Item
(IFI) 50-338/88-18-01.
The licensee has a TLD program that has been accredited by NAVLAP and
is approved until October 1,
1988.
Tha licensee had recently
completed the dosimetry testing portion for recertification and the
inspector reviewed the results of the test.
The licensee's TLD
program is certified in categories II, IV, V, VII and the licensee
had passed in all categories on the recertification test.
The
inLpector also determined that the plant participates in a
performance test of the TLD program conducted by the corporate office
twice a year.
The inspector determined that the licensee had also
passed the corporate sponsored TLD test.
No vitiations or deviations were identified.
,
_ __
- _ - - _ _
.__
_ ._
.
. .
._
___
. _ _ _ _ . _ _ _ _ - _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ .
_.
_
_
.__ . _ _ _ . _
_
__
_
-
_ - _
-
. ..;
.
.
'
4
b.
Control of Radiological Areas
10 CFR 2.203 specifies posting, labeling and control requirements for
radiation areas, high radiation areas, airborne radioactivity areas
and radioactive material areas.
T.S. 6.12.1 requires that in lieu of the "control device" or "alann
signal" required by Paragraph 20.203(c)(2) of 10 CFR 20, each high
radiation area in which the intensity of radiation is greater than
100 mrem /hr but less than 1,000 mrem /hr shall be barricaded and
conspicuously posted as a high radiation area and entrance thereto
shall be controlled by requiring issuance of a RWP.
Any individua'.
or group of individuals permitted to enter such areas shall be
provided with or accompanied by one or more of the following:
(1) A radiation monitoring device which continuously indicates the
radiation dose rate in the area.
(2) A radiation monitoring device which continuously integrates the
radiation dose rate in the area and alarms when a preset
integrated dose is received.
Entry into such areas with this
monitoring device may be made after the dose rate level in the
area has been established and personnel have been made
knowledgeable of them.
(3) An individual qualified in radiation protection procedures who
is equipped with a radiation dose rate monitoring device. This
individual shall be responsible for providing positive control
over the activities within the area and shall perform periodic
radiation surveillance at the frequency specified by the
facility Health Physicist (HP) in the RWP.
T.S. 6.12.2 requires the areas having a dose rate in excess of
1,000 mr/hr be locked to prevent unauthorized entry in addition to
the requirements of T.S. 6.12.1.
Inspection Report Nos. 50-338/88-02 and 50-339/88-02 identified an
Unresolved item regarding a number of events of personnel
noncompliance with T.S. 6.~J.
The licensee reported 12 separate
events of personnel entering high radiation areas without required
monitoring devices and/or job coverage by a health physics
technician.
Prior to identificatior, of this item by the NRC, the
licensee, on January 4,1988, required each station department head
to provide a specific department action plan to improve personnel
performance in RWP compliance.
Access to the high radiation areas
were administratively controlled by issuance of an RWP.
The
inspector reviewed the action plans and noted that implementation of
the action plans began in January 1988.
In discussions with health
physics supervision and technicians, the inspector verified that no
recurrence of failure to comply with high radiation area entry
requirements have occurred since implementation of the corrective
k
_ _ - - _ _ - _ _ - _ - _ _ _ _ _ _
.,
.,
.
.
-
.
V
I
5
,
actions.
Failure of perscanel to wear the monitoring devices
'
specified in T.S. 6.12 or to be accompanied by a qualified HP
technician was identified as an apparent violation of T.S. 6.12.
However, it was determined that the violation met this criteria
outlined in the NRC Enforcement Policy,10 CFR 2, Appendix C and
would be considered licensee identified (50-338,339/88-18-05).
During tours of the radwaste and reactor auxiliary building, the
inspector verified that areas were properly posteo.
4.
Internal Exposure Control and Assessment (83725)
a.
Engineering Controls
10 CFR 20.103(b)(1) requires that the licensee use process or other
engineering controls, to the extent practicable, to limit
concentrations of radioactive materials in the air to levels below
those which delimit an airborne radioactivity area as defined in
10.203(d)(1)(ii).
During plant tours, the inspector observed various engineering
controls to limit the concentrations of airborne material.
These
included the use of ventilation systems equipped with high efficiency
filters and containment enclosures.
No violations or deviations were identified,
b.
Respiratory Protection
The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, and
20.403 to control intakes of radioactive material, assess such
intakes, and keep records of and make reports of such intakes.
The inspector verified that the licensee issues respirators for use
after verifying the users training and qualifications for the type of
respirator issued, the date of last annual medical review, the users
respirator fit testing date, and the users total maximum permissible
concentration-hours in the last seven days. The licensee hand washes
each respirator after use and verifies that there is no smearable
radioactive contamination on the respirator and there is also no
fixed radioactive material greater than 0.2 mr/hr.
The inspector
determined that persons authorized to repair respirator equipment,
such as air regulators, were trained and qualified.
The inspector
'
toured the respirator issuance and repair areas and determined that
respirators needing repair were separated from those stored for
issue.
The licensee does not have a separate plant breathing air system for
use with supplied air respirators.
The licensee has used supplied
air hoods with breathing air supplied by a vendor on site from a
compressor and air tube trailer, for work on steam generators.
The
-
. - _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _
.
. ..
.
.
6
vendors procedures for the setup and operation of the breathing air
system require that the breathing air meet Grade D breathing air and
conform with the Coirpressed Gas Association Specification G-7.1 for
Type 1, Class D gaseous air. The vendors procedure describes how the
diesel air compressor and backup tube trailer are operated.
The
procedure also requires that the supplied air system be monitored at
all times while the system is in use; however, the detection of
carbon monoxide entering the air s'ystem is the only air quality
parameter addressed in the procedure.
The inspector reviewed a memorandum dated March 21, 1988, from the
Director of Corporate Health Physics to the licensee's purchasing
organization.
The memorandum requested the certification records of
breathing air quality be supplied whenever a comprt sor for breathing
air or breathing air in cylinders were supplied to the station.
Since the licensee's vendor did not have the breathing air
certification onsite, the inspector was unable to verify that the air
used for supplied air hoods met the requirements for Grade D
breathing 41r.
A review of breathing air quality certifications to
be supnl4ed by the vendor, will be examined in subsequent inspections
and is tracked as IFI 50-338/88-18-02.
The inspector verified that
the pressure gauges utilized on air distribution systems for
breathing air were calibrated and treated as measuring and test
equipment.
No violations or deviations were identified,
c.
Irternal Assessment
The inspector reviewed licensee procedure Whole Body Counter
Calibration-Bed /ND6620, dated October 1,
1985.
The inspector
reviewed the latest calibration records. The inspector verified that
the whole body counter had been properly calibrated in accordance
with licensee procedures and reviewed the licensee's source data.
The inspector determined that two individuals had been exposed to
more than 2 MPC-hours in one day but that no individual had been
exposed to 10 MPC-hours in any seven (7) days.
No violations or deviations were identified.
5.
Control of Radioactive Materials and Contamination; Surveys and Monitoring
.
(83726)
a.
Surveys
During plant tours, the inspector examined radiation levels outside
selected rooms and cubicles in the auxiliary building. The inspector
performed independent radiation level surveys and compared the
results with licensee survey results.
The inspector's survey
readings were comparable to the licensee survey results.
_ _ _ _ _ _ _ _ _ _ _ _ _ _
_.
..
.
.
7
10 CFR 20.201(b) requires each licensee to make or cause to be made
such surveys as:
(1) may be necessary for the licensee to comply
with the regulations in 10 CFR Part 20; and (2) are reasonable under
the circumstances to evaluate the extent of radiation hazards that
may be present.
.
T.S. 6.8.1 requires written procedures to be established, implemented,
and maintained covering the activities reconnended in Appendix A of
Regulatory Guide 1.33, Revision 2,
February 1978.
Regulatory
Guide 1.33, Appendix A of 1978, requires written procedures for
contamination control.
Licensee procedure HP.8.0.40, Contamination Surveys, requires that
loose surface contamination on items to be released for unrestricted
'
use be less than 1,000 dpm beta gamma activity and less than 20 dpm
alpha measured on a dry smear wiped over 100 centimeters square (cm )
r
of a respective portion of the item's surface.
The procedure also
requires that total contamination on any item (fixed plus removable
contamination ) be less than 5,000 dpm/100 cm2 and that the highest
radiation level shall not exceed 100 counts per minute above
background measured with a thin window GM detector (HP-210 or
equivalentdetectorprobe).
The information below was developed through review of records and
discussions with licensee representatives.
-
On September 28, 1987, the licensee surveyed items / boxes of tools and
cutting equipment for release and shipment to the equipment's owner.
No survey record for the equipment could be produced by the licensee.
The equipment was transferred by the licensee to the owner's
warehouse in Fredericksburg, Virginia. A box of equipment containing
Flange Facing Tools was subsequently shipped by the equipment owner
to Farley Nuclear Plant via the owner's warehouse in Atlanta,
Georgia, on October 12, 1987.
The tools, a Flange Facer Arm, Drive
Motor Assembly, and a Hand Lathe Stop were backup tools for turbine
.
generator work at Farley and were never used.
On October 18, 1987,
[
the equipment was surveyed for shipment at Farley and loose surface
l
contamination up to 2,317 dpm/100 cm2 and up to 25,000 dpm/ scan of
'
fixed contamination was found.
On October 20, 1987, the owner's
warehouse in Atlanta was surveyed by the State of Georgia and found
,
free of contamination.
On October 22, 1987, the equipment owner had
>
a survey performed at the Fredericksburg, Virginia warehouse and
found 3 of 17 boxes of equipment shipped from North Anna contaminated
r removable and 5,000 dpm fixed
with up to 2,390 dpm/100 cm
contamination.
The three boxes of equipment were shipped as
radioactive, low specific activity, to North Anna for further
evaluation and possible decontamination.
The office and warehouse
l
areas were also surveyed and detennined to be free of contamination.
'
Upon notification of the event by Farley plant personnel, the
[
licensee requested Farley Nuclear Plant to ship the subject box of
1
contaminated tools back for further evaluation and possible
t
-
t
-
.
.
.
.
8
decontamination.
The licensee listed possible causes for the
incident:
(1) a thorough enough survey was not performed or the
have been a contributing factor, or (2)g location (250-300
relatively high background at the friskin
cpm) may
the equipment was not
surveyed at all due to a misunderstanding during a turnover of
technicians surveying equipment for unrestricted release.
If the
survey was performed, no written documentation of the survey was
maintained, nor was it required by the licensee's procedures.
Failure to adequately survey material being released for unrestricted
use, was identified as an apparent violation of 10 CFR 20.201(b) and
T.S.6.8.1(50-338/88-18-03,50-339/88-18-03).
b.
Area and Personnel Contamination
The inspector reviewed the records for personnel contaminations in
1987, and for the first half of 1988.
The licensee had
1,531 personnel contamination events in 1987, and 151 for the first
half of 1988. The licensee radiologically controlled 105,400 ft.2 of
area that included the reactor auxiliary building, fuel, safeguards,
decontamination waste solids and clarifier buildings. The total area
contaminated as of June 1988, was 13.348 ft2 or 12.7%.
The inspector noted on tours of the area that the majority of
friskers were in areas with background readings of 200 to 400 counts
per minute (cpm).
As an example, both the RM-14 friskers at the
truck bay and at the auxiliary building control point had backgrounds
greater than 200 cpm.
The inspector discussed with licensee
management the problem of assessing contamination levels with the
,
high background and the increased probability of low levels of
contamination being released from the site.
The licensee stated
,
,
that the high background on RM-14 friskers would be reevaluated. The
i
inspector notified the licensee that this would be reviewed during
subsequent inspections and would be tracked as IFl 50-338/88-18-04
i
l
The inspector also discussed recent changes to the contamination
'
control program in that the licensee now requires shoe covers to be
worn when entering clean areas of the reactor auxiliary building.
This has the potential for reducing personnel contamination events
but increases the amount of laundry waste to be processed and does
not address the fundamental problem of not maintaining areas of the
plant free of loose surface contamination to the maximum extent
'
l
possible.
To minimize hot particle personnel contaminations and increase
personnel contamination awareness, the licensee has addressed the
!
issue of hot particle contamination with all workers at the station.
Health physics technicians have been given training in detection and
I
handling of hot particles and special areas have been identified
l
throughout the plant as potential hot particle areas. Radiation Work
Pemits require that paper suits be worn over normal protective
l
clothing to minimize the transfer of hot particles when protective
i
i
. _ _ - _ _ _
.. .
.
.
9
clothing is laundered.
Also, protective clothing reading greater
than 50,000 dpm after laundering are discarded.
c.
Postings, Labels and Controls
The inspector reviewed discrepancy report no.88-220 regarding three
rotometers (mechanical tut equipment used to measure air flow)
stored outside of radiologically controlled areas. On M Feb 7, 1988,
health physics discovered contamination on a rotometer'to be cleared
from the radiologically controlled area.
The person witn the
4
rotometer informed health physics that while in the RCA the item
could not have become contaminated since it was never used or left
his hand.
Upon surveying the storage location of other rotometers,
health physics found from 1,000 dpm to 260,000 dpm fixed
'
contamination on two other rotometers. The rotometers were stored in
a cabinet in the technical support center, a clean area outside of
the radiologically controlled area of the plant.
The licensee was
unable to determine how the contaminated rotometers were removed from
the radiologically controlled area.
Failure to properly survey and control the contaminated rotometers
was identified as a second example of an apparent violation of
10CFR20.201(b)andT.S. 6.8.1 (50-338/88-18-03, 50-339/88-18-03).
,
The inspector surveyed selected areas outside of the radiologicaMy
controlled area with a RM-14/HP-210 frisker and did not locate any
contaminated material.
6.
SolidWaste(84722)
10 CFR 20,311(d)(1) requires that any generating licensee who transfers
radioactive waste to a land disposal facility prepare all waste so that
the waste is classified according to 10 CFR 61.55 and meets the waste
'
characteristics requirements in 10 CFR 61.56.
The inspector reviewed radioactive waste classification documentation for
selected radioactive waste shipments and determined that the waste had
been properly classified and met the waste characteristics requirements of
The inspector discussed with licensee representatives radioactive waste
volume reduction. The licensee provides green and yellow waste containers
in the auxiliary building for sorting of potentially clean and
contaminated waste at its point or origin.
Potentially clean waste was
removed from the green containers in the radiologically controlled area
and placed in the volume reduction and radwaste segregating facility. Tho
potentially clean waste was surveyed on a belt driven automatic monitor.
If the waste was clean it was placed in a bag monitor and released to the
county burial site upon meeting the survey release requirements.
Yellow
trash was placed in 55 gallon drums and compacted for shipment to a vendor
with super compactor capabilities.
,
- - - - - _ - - - - _ - _ - - - - - -
- - - . - - - - - - -
--
- - - - - -
- - - - - - - . - - - -
- - - - - - - - - - - - - - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
..
.
'
.
10
The licensee has recently approved the construction of a new radioactive
waste processing facility and plans are for the facility to be operational
in 1990.
No violations or deviations were identified.
7.
Transportation of Radioactive Material (86721)
Review of Radioactive Material Shipping Records
10 CFR 71.5 requires that licensees who transport licensed material
outside the confines of its plant or other place of use, or who deliver
licensed material to a carrier for transport to comply with the applicable
requirements of the regulations appropriate to the mode of transport of
the Department of Transportation (D0T) in 49 CFR Parts 170 through 189.
The inspector reviewed the records of selected shipments of radioactive
material performed in 1987.
The shipping manifest examined were prepared
consistent with 49 CFR 170-189 requirements and the radiation and
contamination survey results were within the limits specified for the mode
of transport and shipment classification.
No violations or deviations were identified.
8.
Licensee Actions on Previously Identified Inspection Findings (92701,
92702)
a.
(Closed) Violation 50-338/339/87-14-01: Failure to assess whole body
dose through a tissue equivalent absorber of 300 milligram per square
centimeter (mg/cm2) or to shield the lens of the eyes with material
having a density thickness of at least 700 mg/cm2 as required on
The inspector verified that the corrective actions in the licensee's
responte letter to the NRC dated June 29, 1988, had been implemented.
The licensee took direct measurements of the source term in the steam
generator Unit 1, on August 30, 1987, with modified TLDs.
The
measurements formed the basis of a lens-of-the-eye correction factor
which was incorporated in the personnel dosimeter algorithm.
The
inspector determined that the licensee has a procedure to evaluate
the dose delivered to lens of the eye.
The same procedure will be
used to adjust the algorithm when the steam generators for Unit 2 are
opened.
Health Physics Procedure 3.1.2.1, Whole Body Beta Dose
Response of Thermoluminescent Dosimeter Badge, was developed and
implemented to determine if adjustments to the algorithm are
necessary each time the steam generators are opened in the future,
b.
(Closed) Violation 50-338,339/87-30-01:
Failure to maintain
quarterly occupational exposures to individuals in restricted areas
to less than 7.5 rem to the skin of the whole body.
The inspector
_ _ _ _ _ _ _ _ _ _ _ _ -
.
. .
.
.
11
verified that the licensee corrective actions in response letter to
the NRC, dated November 25, 1987, had been implemented.
To minimize
,
the potential for hot particle skin contaminations, the licensee
reduced the contamination limits for clothing after laundering,
installed an automatic laundry monitor, provided hot particle
awareness training to all site personnel and specific training for
health physics technicians and laundry personnel, developed a
radiological work practice for hot particle work, and developed a
cleanliness control procedure for work in open systems to contain and
minimize the spread of hot particles,
c.
(Closed) Violation 50-338,339/87-30-02:
Failure to adhere to
protective clothing requirements specified on RWP No. 87-2312.
The
inspector verified that the corrective actions specified in the
licensee's letter to the NRC dated November 25, 1987, had been
implemented. The inspector determined that a series of meetings were
held with all station personnel regarding RWP compliance and hot
particle and contamination awareness.
Health physics personnel are
required to meet the same protective clothing requirements as are the
workers.
If clothing requirements are different for the health
physics technician the requirements will be specified on the RWP.
d.
(Closed) Violation 50-338/339/87-30-03:
Failure to perfom adequate
personal surveys.
The inspector verified that the corrective actions
specified in licensee's letter dated November 25, 1987, had been
implemented.
The inspector reviewed procedures and determined that
health physics procedure 6.1.40, Attachment 5 was amended to require
that all personnel, upon exiting a contaminated area, were to perform
a whole body frisk at the nearest frisker and proceed directly to the
PCM-1B monitors at the control point exit of the radiologically
controlled area.
Each step-off pad has a sign posted stating to
proceed directly to the final frisk point after performing a frisk at
the nearest frisker,
e.
(Closed) Unresolved Item 50-338,339/88-02-04:
Discrepancy reports
regarding improper control and unauthorized personnel entry to high
radiation areas.
See Paragraph 3.b.
f.
(Closed) 87-FRP-01:
Followup on Licensee's Pregram for
Removing / Defacing Radiation Markings on Clean / Unused Equipment
Released for Unrestricted Use.
The inspector discussed the
licensee's policy for disposal of 55 gallon drums.
The inspector
determined that the licensee does throw away damaged drums and sells
'i
some to employees.
However, the licensee representatives stated that
drums that were yellow in color were compacted when damaged and never
released for general public use.
9.
IE Information Notice ('EN) (92717)
The inspector determir.ed that the following Information Notices had been
received by the licensee, reviewed for applicability, distributed to
<
. .
.
.
l
12
appropriate personnel and that action, as appropriate, was taken or
scheduled.
IEN 87-31, Blocking, Bracing and Securing of Radioactive Materials
Packages in Transportation
IEN 87-37, Control of Hot Particle Contamination at Nuclear Plants
10. Exit Interview
The inspection scope and results were sumarized on June 10, 1988, with
those persons indicated in Paragraph 1.
The inspector described the areas
inspected and discussed in detail the inspection results listed below.
Proprietary infonnation is not contained in this report,
item Number
Description and Reference
338/88-18-01
IFI - Review SRD response / calibration records to
ensure that potentially damaged SRDs are response
checked prior to reissuance.
338/88-18-02
IFI - Review breathing air quality certifications for
vendor supplied air.
338,339/88-18-03
Violation - Failure to adequately survey material
being released for unrestricted use.
338/88-18-04
IFI - Review high background on RM-14 friskers.
338,339/88-18-05
Licensee Identified Violation - High radiation area
controls
Licensee management was informed that the items discussed in Paragraph 8
were considered closed.
During a telephone conversation on July 18, 1988, between R. B. Shortridge
of the NRC, and A. H. Stafford of Virginia Electric and Power Company, the
licensee was informed that the failure to properly survey and control
contaminated rotometer would be a second example of violation
10 CFR 20.201(b) and T.S. 6.8.2(50-338,339/88-18-03).
,
During a telephone conversation on August 5, 1988, between R.
B.
Shortridge of the NRC, and A. H. Stafford and M. L. Bowling, Virginia
Electric and Power Company, the licensee was informed that the apparent
violation for failure to adequate control access to high radiation areas
would be considered licensee identified.
L
.