ML20215A444
| ML20215A444 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/26/1987 |
| From: | Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215A408 | List: |
| References | |
| 50-338-87-14, 50-339-87-14, NUDOCS 8706160660 | |
| Download: ML20215A444 (11) | |
See also: IR 05000338/1987014
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UNITED STATES
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NUCLEAR REGULATORY COMMisslON
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REGION 11
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ATLANTA, GEORGI A 30323
101 MARIETTA STREET N.W.
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Report Nos.: 50-338/87-14 and 50-339/87-14
Licensee: Virginia Electric and Power Company
Richmond, VA 23261
Docket Nos: 50-338 and 50-339
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Facility Name: North Anna Power Station
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Inspection Conducted: M
11-15, 1987
Inspector:
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B. K. Revsin'
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Date Signed
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Approved by:
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C. M. Hoky, Se$1on Chief .
Date Signed
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Division of Radiation Safety and Safeguards
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SUMMARY
Scope:
Ihis routine, unannounced inspection involved onsite inspection in the
area of radiation protection and included:
organization and management;
external exposure control and assessment; control of radioactive materials;
contamination, surveys and monitoring; solid waste; transportation of
radioactive materials; refueling outage activities, allegation followup and
followup on previous enforcement issues and inspector followup items.
Results:
One violation - failure to maintain radiation exposure records in
accordance with instructions contained on Form NRC-5.
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- E. W. Harrell, Station Manager
- E. R. Smith, Assistant Station Manager
- A. H. Stafford, Superintendent, Health Physics
- D. T. Johnson, Supervisor, Quality Assurance
- G. Hareness, Licensing Coordinator
- W. I. Bartlett, Senior Staff Health Physicist
H. L. Hay, Quality Assurance
T. Peters, Assistant Health Physics (HP) Supervisor
E. Dryer, Senior Staff HP
D. Ross, Senior Staff HP
Other licensee employees contacted included eight technicians, two
security force members, and one office personnel.
Other Organizations
Radiation Protection Services, Numanco, Inc.
Nuclear Regulatory Comission
- J. L. Caldwell, Senior Resident Inspector
- Attended ex1t interview
2.
Exit Interview
The inspection scope and findings were summarized on May 15, 1987, with
those persons indicated in Paragraph 1 above.
One violation, failure to
maintain exposure records in accordance with instructions contained on
Form NRC-5 (Paragraph 5.e), was discussed in detail.
The licensee
acknowledged the inspection findings and stated that they would confer
with NRC management prior to determining whether an exception to the
violation would be taken.
The licensee did not identify as proprietary
any of the materials provided to or reviewed by the inspector during this
inspection.
3.
Licensee Action on Previous Enforcement Matters (92701, 92702)
(Closed) Violation (50-338, 339/86-27-01) Failure to establish calibration
procedures for Alpha Scintillation Counter No. 737.
The inspector
reviewed the licensee's response dated January 19, 1947, and verified that
the corrective actions specified in the response had been implemented.
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(Closed) Unresolved Item (50-338, 339/86-07-02) Density thickness for
whole body dose assessment.
The licensee was informed that this matter
had been escalated to the status of a violation (Paragraph 5.e) and that
the unresolved item was now considered closed.
4.
Organization and Management Controls (83722)
The licensee is required by Technical Specification (TS) 6.2 to implement
the plant organization as shown in Figure 6.2-1.
The responsibility,
authorities, and other management controls were further outlined in
Chapters 12 and 13 of the Final Safety Analysis Report (FSAR).
The inspector reviewed the licensee's staffing level and lines of
authority as they relate to radiation protection and transportation of
radioactive materials, and verified that the licensee had not made
organizational changes which would adversely affect the ability of the
licensee to implement critical elements of its radiation protection
program.
The licensee stated that Health Physics (HP) was authorized 92 positions,
89 of which were filled.
The three vacant positions were senior level,
i.e., Supervisor for Technical Services, and Assistant HP Supervisor
(Radioactive Materials Shipping), and a Shift Supervisor.
Personnel had
been shifted to these positions as acting interim supervisors, and a
search was underway for permanent replacements.
For the ongoing Unit 1 outage,107 junior and senior HP technicians were
onsite.
It was anticipated that eight additional technicians would be
added to bring the total to 115. Also, 64 decontamination personnel were
onsite for the outage.
The inspector discussed with the HP Superintendent the type, methods, and
degree of interaction with the contract personnel.
The licensee stated
that while most jobs were covered by contractor personnel oversight was
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exercised by the inhouse HP group through the HP rovers in containment and
by tours of work areas by HP shift supervisors.
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No violations or deviations were identified.
5.
External Occupational Exposure Control and Personnel Dosimetry (83524)
a.
requires the licensee to determine an
individual's accumulated occupational dose to the whole body on a
Form NRC-4 or its equivalent record prior to permitting an individual
to exceed the limits specified by 10 CFR 20.101(a).
The inspector
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reviewed selected occupational exposure histories for individuals who
exceeded the 10 CFR 20.101(a) values and determined that exposure
histories were being completed and maintained as required.
b.
10 CFR 20.202 requires each licensee to supply appropriate personnel
monitoring equipment to specific individuals and require the use of
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such equipment.
During tours of the plant the inspector observed
workers wearing appropriate personnel monitoring devices.
c.
Technical Specification 6.11 requires the licensee to have written
radiation protection procedures, including the use of radiation work
permits (RWPs).
The inspector reviewed selected RWPs that had been
written and executed for the Unit I refueling outage.
They were:
RWP No. 87-1482, Remove and Store Primary Manways for Steam
Generators (S/G) "A," "B" and "C."
RWP No. 87-1503, Remove and Store Diaphragms, Install Nozzle
Covers, and Install Ventilation on S/G
"A."
RWP No. 87-1504, Remove and Store Diaphragms, Install Nozzle
Covers and install Ventilation on S/G "C."
RWP No. 87-1522, Remove and Store Diaphragms, Install Nozzle
Covers and Install Ventilation on S/G "B."
The inspector verified that adequate radiological controls had been
specified in terms of radiological surveys, dosimetry, protective
clothing and respiratory protective equipment.
d.
10 CFR 20.203 specifies the posting, labeling and control
requirements for radiation areas, high radiation areas, airborne
radioactivity areas and radioactive material.
Additional
requirements for control of high radiation areas are contained in
During tours of the plant, the inspector reviewed the licensee's
posting and control at radiation areas, high radiation areas,
airborne radioactivity areas, contamination areas, radioactive
material areas and the labeling of radioactive material.
The
inspector verified that locked hign radiation areas in the Auxiliary
Building and Unit I containment were maintained locked as required.
e.
10 CFR 20.401(a) requires that each licensee maintain records showing
the radiation exposures of all individuals for whom personnel
monitoring is required and that such records be kept on Form NRC-5 in
accordance with the instructions contained in that form.
Form NRC-5, Item 5, requires that unless the lenses of the eyes are
protected with eye shields having a tissue equivalent density
thickness of at least 700 mg/cm , dose recorded as whole body dose
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should include the dose delivered through a tissue equivalent
absorber having a density thickness of 300 mg/cm2,
During two previous inspections (Report Nos. 50-338, 339/86-07 and
50-338, 339/86-2/), the density thickness at which whole body dose
was assessed when the lenses of the eyes were not shielded with
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700 mg/cm2 of material was addressed.
At the North Anna plant,
personnel are not required to routinely wear eye shields, and in no
case, do any available eye shields provide the required density
thickness of 700 mg/cm2
Due to the physical make-up of the licensee's thermoluminescent
dosimeter (TLD) badge, direct measurement of whole body dose
delivered through an absorber equivalent to a density thickness of
300 mg/cm2 was not possible, and therefore whole body dose was
assessed through a tissue equivalent absorber of 1000 mg/cm2
Consequently, whole body dose delivered between density thicknesses
of 300 and 1000 mg/cm2 was not assessed by the licensee for whole
body exposure pruposes.
10 determine the adequacy of their dosimetry system to assess whole
body dose between 300 and 1000 mg/cm2, (Unresolved Item No. 50-338,
339/86-07-02), the licensee undertook studies to characterize the
radiation field capable of producing doses between the above density
thicknesses.
Even though studies performed by the licensee indicated that the
difference between whole body dose measured at 300 or 1000 mg/cmd was
small, approximately one percent of the beta radiation dose was
missed by measurements through 1000 mg/cm2 of absorber rather than
300 mg/cm2, the licensee reviewed their dosimetry records since the
installation of the dosimetry system approximately 10 years ago. The
licensee concluded that, based on the data thus accumulated
concerning the beta field at the plant, no individual was likely to
have exceeded any regulatory limit. The licensee stated that further
studies were planned to more tully characterize the beta field to
which workers are exposed.
Failure to assess whole body dose through a tissue equivalent
absorber ot 300 mg/cm2 or to shield the lenses of the eyes with
material having a desity thickness of at least 700 mg/cm2 was
identified as an apparent violation of 10 CFR 20.401(a) (50-338,
339/87-14-01).
f.
10 CFR 20.101(a) states 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 from radioactive material and other sources of
radiation a total occupational dose in excess of 75 rems for the skin
of the whole body or 18.75 rems for the extremities.
The inspector was informed that during the ongoing Unit 1 refueling
outage four instances of microscopic, " hot" particles had been found
on personnel.
Three of the particles were identitied as pure
cobalt-60 while the fourth particle contained a variety of fission
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products.
The licensee postulated that this latter particle was
ceramic in nature with fission products imbedded within it.
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Dose calculations performed by the licensee for these cases were
reviewed by the inspector and were found to be 2.214,.0.874 and
1.671 rem to the skin of the whole body for the cobalt-60 particles.
For the mixed fission product particle, a dose of 0.477 rem to the
extremities was assigned.
The licensee stated that training on
detection and isolation of these " hot" particles had been performed.
Numerous other instances of personnel contamination had been
identified by the licensee.
In these cases, the contamination was
uniformly distributed over a larger area when found on the worker's
skin. Many of the contamination events were due to activity found on
shoes and clothing.
From January I to May 10, 1987, 347 personnel
contamination events had been documented.
During 1986, 122/
personnel contaminations had occurred, and as a consequence, for
1987, a goal of no more than two per day (730 per year) had been
established.
The licensee stated that realization of that goal
seemed unlikely since the plant was only four weeks into the Unit I
refueling outage which would be followed by a Unit 2 refueling
outage.
Nevertheless, the licensee stated that every effort was
being undertaken to minimize the number of these events.
6.
Internal Exposure Control and Assessment (83725)
a.
10 CFR 20.103 establishes the limits for exposure of individuals to
concentrations of radioactive materials in air in restricted areas.
This section also requires that suitable measurements of
concentrations of radioactive materials in air be performed to detect
and evaluate the airborne radioactivity in restricted areas.
The inspector reviewed the results of air samples taken in support of
steam generator work covered by the RWPs described in Paragraph S.c
air samples had been evaluated for alpha, beta and gamma activity.
Observation of the Maximum Permissible Concentration (MPC) hour
assignments for selected individuals performing S/G activities
revealed that all exposures were well under the 40 MPC hour control
measure,
b.
TS 6.11 states that procedures for personnel radiation protection
shall 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.
HP Procedure 8.0.50, Section 4.4.7 states that during each month, at
least 10 routine air samples inside the Radiation Control Area (RCA)
shall be counted for long-lived gross alpha radioactivity.
The inspector reviewed the results of Quality Assurance (QA) Audit
No. N-87-04, Health Physics Dose Control and Administration,
March 1987.
Une finding of this audit concerned air sampling,
failure to analyze routine air samples for long-lived gross alpha
radioactivity.
During discussions with licensee representatives the
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inspector learned that during the last fuel cycle for Unit 1,
leakages from two fuel bundles had been confirmed by fuel sipping.
The licensee stated that new procedures for alpha air sampling had
recently been implemented and that awareness of new procedural
requirements by the HP staff was sometimes incomplete.
The licensee was informed that failure to assess long-lived gross
alpha activity of air samples would normally be considered a
violation of the requirements of TS 6.11.
However, the NRC
Enforcement Policy delineated in 10 CFR 2, Appendix C,1986, states
that a Notice of violation will generally not be issued for
violations identified by the licensee provided that the licensee
identification meets the criteria specified by 10 CFR 2.
The
inspector stated that this violation met the required criteria and ~
consequently would be considered licensee identified. The licensee's
corrective action wilI be reviewed during future inspections (50-338,
339/87-14-02).
c.
10 CFR 20.103(b) requires the licensee to use process or other
engineering controls, to the extent practicable, to limit
concentrations of radioactive material in air to levels below that
specified in 10 CFR Part 20, Appendix B, Table I, Column 1 or limit
concentrations, when averaged over the number of hours in any week
during which individuals are in the area, to less than 25 percent of
the specified concentrations.
The use of process controls and engineering controls to limit
airborne radioactivity concentrations in the plant was discussed with
licensee representatives and the use of sucn equipment was observed
during tours of the plant.
No violations or deviations were identified.
7.
Control of Radioactive Materials and Contamination, burveys and Monitoring
(83526)
a.
10 CFR 201(b), 20.401 and 20.403 require the licensee to perform
surveys and to maintain records of such surveys as necessary to show
compliance with regulatory limits.
The Final Safety Analysis Report
(FSAR) of Units 1 and 2, Chapter 12, outlines survey methods and
instrumentation while each Unit's TS 6.11 requires adherence to
written procedures for all operations involving personnel radiation
exposure.
During plant tours, the inspector examined radiation levels and
contamination survey results posted at the entrance to the RCA. The
inspector also reviewed tne results of selected surveys taken in
support of the steam generator work in Unit 1.
Selected RWPs
controlling general, as well as specific radiological activities were
also reviewed.
The inspector observed the use of survey instruments
by plant staff and examined calibration stickers on radiation
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H,dection instruments 3in use by licensee personnel.
Instrument use
appeared to be adequate and all instrunents examhd hou Leen
calibrated.
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b.
10 CFR 20.203(f) states that, except as provided by 20.203(f)(3),
each container of licensed material shall bear a durable, clearly
visible label identifying the radioactive contents and shall bear the
radiation caution symbol and the words " Caution" or " Danger,
Radioactive Material," and shall provide sufficient information to
permit individuals using or handling the containers, or working in
the vicinity thereof, to take ' precautions to avoid or minimize
exposures.
Durir.g tours of the plant and the adjoining protected area, the
inspector checked containers of radioactive material for proper
, labeling.
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No violations or deviations were identified.
8.
Transportation (86721)
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10 CFR 71.5 requires that each licensee who transports licensed material
eutside !% ;or.ff w Of hi algt ar other place of use, or who deliver::
htcased Wet.arial f.o a c&lrtiUI for transport, shall comply with the
applicable requirements of the regulations app (ropriate to the mode ofD0T) in 49 C
transport of the Department of Transportation
through 189.
The inspector reviewed selected records of radicaci.ive waste shipments and
non-exempt radioactive materials shipments performed during 1987 and
verified that the requirements of 49 CFR Parts 170 through 189 had been
met for those shipments.
No violations or deviations were identified.
9.
Solid Waste (84722)
10 CFR 20.311 requires that the licensee maintain a tracking system iur
radioactive waste shipments to verify that shipments have been received
without undue delay by the intended recipient. The inspector reviewed the
tracking log maintained by the licensee ar.d select.ea copies of returned
receipt acknowledgements in the shipping files for shipments performed in
1987.
10 CFR 61.56 specifies the waste characteristics and stability
requirements for low level radioactive waste.
Through discussions with
licensee representatives and review of selected records, the inspector
determined that waste stability, when required, was achieved by use of
pproved containers or by solidification. Solidification was performed by
a vendor and included formation and testing of a demonstration product
prior to each batch processing.
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10 CFR 20.311 requires a licensee who transfers radioactive waste to a
land disposal facility to prepare all wastes so that it is classified
according to 10 CFR 61.56.
10 CFR 61.55(a)(8) states that the concentration of a radionuclide may be
determined by indirect methods such as the use of scaling factors which
relate the inferred concentration of one radionuclide to another that is
measured if there is reasonable assurance that the indirect methods can be
correlated with actual measurements.
lhe inspector verified that concentrations of selected radionuclides which
were inferred by use of scaling factors could be correlated with actual
measurements, i.e., within a factor of 10.
No violations or deviations were identified.
10. Plant Statistics
a.
Radioactive Waste Shipments
The inspector reviewed the radioactive waste shipment log and
determined that during 1986, 41 shipments were made constituting
1G,041 cubic feet containing 607 curies.
As of May 14, 1987, seven
shipments had been made consisting of 2,565 cubic feet containing
seven curies.
Tne licensee stated that no backlog of waste was
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a.41ntaliied cnstle, partially due to lack of storage facilities.
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b.
Centaminated Areas
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In determining square footage t
the plant maintained under
contamination controls, the licensee included all areas excepting
Units 1 and 2 containment.
At the beginning of January 1987,
14,965 square feet were maintained as contaminated.
This had
decreased to 13,7/3 square feet at the end of March 1987, but with
refueling outage activities, contaminated areas - had increased to
20,29/ square feet, or approximately 17 percent of the plant area.
c.
Collective Dose
During 1986, 722 man-ren (361 per unit) were expended during
performance of work at the site.
For 1987, a goal of 1,123 (562 per
unit) man-rem had been established.
The licensee stated that they
were optimistic about achieving)that goal.As of April 30, 1987 (two
weeks into the refueling outage 141 man-rem had been expended.
No violations or deviations were identified.
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11. Allegation Followup (99014)
RII-87-1-0064
The alleger stated that he was hired through NUMANC0 which placed him on
the job at the North Anna facility. He stated that he was working as a HP
technician for the outage in Unit 1 and that he was terminated from his
employment at North Anna on May 5, 1987, as a result of being found asleep
on the job. The alleger stated that at the time of termination he was the
responsible HP for a Westinghouse crew performing eddy current testing on
the S/G.
The alleger stated that his primary concern was that HP
technicians were being overworked and that they were working an average of
18 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> per day.
He stated that he had been asleep for
approximately 10 minutes when a Shift Supervisor found him.
He stated
that no one intended to take any action against him for sleeping because
they realized the stress the HP technicians were working under. He stated
when the Plant Manager found out he had been asleep on the job, the Plant
Manger insisted that he be terminated in accordance with policy.
Discussion
In discussions with the licensee it was stated that working hours at the
site were controlled by Administrative Procedure 20.3, Hours of Work,
September 5, 1985, Section 4.1.b specifies that HP technicians are covered
by the procedure and Section 5.1.b stated that individuals will not be
permitted to work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period.
Section 6.1
specified that an exception to overtime limitations may be granted on a
temporary basis.
The inspector reviewed with licensee representatives the circumstances
associated with the above incident.
Radiological Problem Report
No.87-116 stated that at approximately 0715 hours0.00828 days <br />0.199 hours <br />0.00118 weeks <br />2.720575e-4 months <br /> on May 5, 1987, a North
Anna HP technician lying in a fully horizontal position with his eyes
closed at the block area between A and B cubicle on the 261 foot elevation
in containment.
The Shift Supervisor asked the contractor to leave
containment and requested that his access to the RCA be suspended pending
an investigation.
lhe HP Operations Supervisor reviewed the circumstances
and recommended an indefinite suspension for the contract HP for being
inattentive while on duty.
Evaluation of the incident by the HP
Superintendent resulted in the conclusion that the behavior exhibited by
the contract HP was unacceptable for continued support of North Anna Power
Station.
NUMANC0 was informed that the individual's access to the plant
would be permanently restricted. The HP Superintendent explained that any
action taken by NUMANCO concerning this individual's employment status was
under the purview of NUMANC0 only and that the only control Virginia Power
Company exercised in the matter was that of plant access which in this
case was revoked in accordance with plant policy as promulgated in a
memoranda from the Station Manager to all employees on April 20, 1987. The
memorandum stated that "any VEPC0 or contractor employee found asleep on
duty shall be imediately placed on indefinite suspension and will be
subject to termination for the first offense."
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The HP Superintendent explained that during outage, normal working hours
for HP contract technicians was 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per seven days including shift
turnover time.
The licensee had not been able to secure as many contract
HP technicians for the start of outage as budgeted and consequently had
applied for an exemption to the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per seven days as permitted by
Administrative Procedure 20.3.
On April 20, 1987, the Station Manager
approved a request from the HP Superintendent to permit contract HP
technicians to work 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day, seven days a week for the first week
of outage. On May 1, 1987, an extension was signed by the Station Manager
to permit repetition of the 84 hour9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> work week for a second week.
Subsequent to this work hours returned to a normal 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per seven
days.
The inspector reviewed time sheets for selected contract HP technicians
(including the alleger) and verified that in general 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts were
being worked by these individuals.
Shift turnover sometines extended the
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift from 15 minutes to an hour. This practice was permitted by
Administrative Procedure 20.3.
The inspector also determined that on
May 4, 1987, the day prior to the sleeping event, the alleger had worked a
10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> shift.
The HP Superintendent stated that the licensee's HP
technicians were aware that relief from the work schedule was available
upon request.
However, he was less confident that the contract
technicians were as knowledgeable.
The licensee also stated that they
were prohibited from working an individual more than 16 hcurs in any
24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, or more that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.
Finding
The allegation was not substantiated in that a review of time sheets did
not indicate that HP technicians were routinely working 18 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> per
day. Virginia Power Company did restrict the alleger's access to the site
in accordance with published Station policy.
12.
Inspector Followup Items (92701)
(Closed) Inspector Followup Item (50-338, 339/86-27-02) Corrective actions
in response to Audit No. N-86-14 findings regarding the Process Control
Program (PCP).
The inspector verified that corrective actions had been
implemented as specified on Quality Assurance (QA) Audit Finding and
Followup Forms, ADM-18.0, August 28, 1986, dated January 6,
1987,
February 4,1987, February 27, 1987, and April 1,1987.
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