ML20245C007
| ML20245C007 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/13/1989 |
| From: | Bassett C, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20245C004 | List: |
| References | |
| 50-338-89-05, 50-338-89-5, 50-339-89-05, 50-339-89-5, NUDOCS 8904260435 | |
| Download: ML20245C007 (19) | |
See also: IR 05000338/1989005
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA ST., N.W.
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ATLANTA, GEORGIA 30323
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- APR i 71989-
Report Nos.: '50-338/89-05 and 50-339/89-05
-Licensee: Virginia Electric and Power Company
Glen Allen, VA 23060
Docket Nos.: 50-338 and 50-339
License Nos.:
Facility Name: North Anna 1 and 2
Inspection Conducted: March 20-24,1989
Inspector: M)t2/td
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C. H. Bas
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D&t Signed
Approved by.
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J. P/ Totter, Chief
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Dht6 Signed
Facilities Radiation Protection Section
Emergency Preparedness and Radiological
Protection Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope
This routine, unannounced inspection of the licensee's radiation protection
program consisted of a review in the areas of:
organization and management
controls; training and qualifications; external and internal exposure control;
control of radioactive material and contamination, surveys, und monitoring; and
the program to maintain doses as low as reasonably achievable (ALARA).
The
inspection also included a review of an unresolved item (URI) and inspector
followup on an allegation and on Information Notices.
Results
Management support of the radiation protection program appears to be adequate
except in the area of controlling entry into high radiation areas.
Except for
this problem, the licensee's radiation protection program appears to be
functioning as necessary to protect the health and safety of the occupational
radiation workers.
During the inspection, an allegation was reviewed concerning
control of contractor health physics technicians. This matter as dealt with by
the licensee prior to the inspection.
No weaknesses were noted in the area of
regulatory compliance but a major, recurring problem, as noted above, was
identified in the area of compliance with the Technical Specification
requirements.
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Within the areas inspected, the following violation was identified:
Failure of personnel to have the required radiation monitoring device or
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to be accompanied by a qualified health physics technician during entry
into high radiation areas (Paragraph 4.b).
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- M. Bowling, Assistant Station Manager, Nuclear Safety and Licensing
E. Dreyer, Supervisor, Technical Services, Health Physics
- R. Driscoll, Manager, Quality Assurance
- R. Enfinger, Assistant Station Manager, Operations and Maintenance
R. Irwin, Supervisor, Operations, Health Physics
T. Johnson, ALARA Coordinator, Health Physics
- G. Kane, Station Manager
- P. Kemp, Supervisor, Licensing
M. Lane, Shift Supervisor, Health Physics
- J. Leberstien, Licensing Specialist, Licensing
S. Montgomery, Senior Instructor, Power Training Services
T. Peters, Assistant Supervisor, Dose Control and Bioassay, Health Physics
- A. Stafford, Superintendent, Health Physics
- W. Thornton, Director, Health Physics and Chemistry, Corporate
F. Wolking, Senior Staff Health Physicist, Corporate
Westinghouse Employee
1. Seybold, Coordinator, Integrated Radiological Services Program
Other licensee employees contacted during this inspection included
engineers, security force personnel, technicians, and administrative
personnel.
Nuclear Regulatory Commission
J. Caldwell, Senior Resident Inspector
- N. Economos, Reactor Inspector, Region 11
L. King, Resident Inspector
- Attended exit interview
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2.
Organization and Management Controls - Occupational Exposure, Shipping,
and Transportation (83750)
a.
Organization
The licensee is required by Technical Specification (TS) 6.2 to
implement the plant organization specified in TS Figures 6.2-1. The
responsibilities, authority and other management controls are further
outlined in Chapters 12 and 13 of the Final Safety Analysis Report
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(FSAR).
TS 6.2 also specifies the members .of the Station. Nuclear
Safety.and Operating Committee (SNS0C).and outlines its function and:
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authority.
Regulatory Guide 8.8 specifies certain functions and.
responsibilities to be assigned to the Radiation Protection Manager
and radiation protection responsibilities to be assigned to line
management.
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The inspector reviewed the licensee's station organizat_ ion, as well
as the responsibilities, authority, and control given to management
as they relate to the site radiation protection program. .'No recent
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changes have been made in station organization .which would adversely
affect the ability of the licensee to implement the critical elements
of. the program.
There appeared to be sufficient management support
to implement essential elements of the program as necessary,
b.
Staffing
TS 6.2 also. specifies the minimum staffing for the plant.
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Chapters 12 and 13 outline further ' details on staffing as well.
The' insp(ector reviewed the staffing level of the station health
physics
HP) sections and discussed the current level with licensee
representatives.
At the time of the inspection, of the 58 HP
positions authorized for the site (including shift supervisors,
specialists and technicians), 49 were filled. The shortages were in
the specialist and technician positions.
Of the 38 authorized
technician positions at the station,11 were filled with personnel
who were qualified to the requirements outlined by the American
National Standards Institute (ANSI) Standard ANS 3.1-(12/79 Draft)
and they were being assisted by 20 junior technicians.
Due to the
dual unit outage in progress, the licensee also had retained the help
of 89 contractor HP technicians and approximately 70 personnel who
were assisting in decontamination efforts and onsite laundry facility
operation.
c.
Management Controls
The inspector reviewed the licensee's Radiation Problem Reports which
were used to identify and document safety and radiological problems
noted by HP personnel in the plant.
It was noted that nearly
40 reports had been written for 1989 to date.
Most of the problems
outlined dealt with the failure of personnel to comply with various
procedure or radiation work permit (RWP) requirements. The inspector
verified that adequate corrective actions had been initiated as a
result of the findings. The inspector also reviewed selected station
Deviation Reports (DRs) written for 1989.
Most dealt with
operational problems but two detailed the entry by unauthorized
individuals into high radiation areas (HRAs).
These DRs are
discussed further in Paragraph 4.b.
No violations or deviations were identified.
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3.
Training and Qualifications - Occupational Exposure, Shipping, and
Transportation (83750)
a.
General Employee Training (GET)
The licensee is required by 10 CFR 19.12 to provide radiation
protection training to workers.
Regulatory Guides 8.13, 8.27, and
8.29 outline topics that should be included in such training.
The inspector verified, through review of selected training modules
for. personnel allowed access to the radiation control area (RCA),
that proper training had been given to those individuals prior to RCA
entry.
Also, through discussions with training personnel, the
inspector determined that the training given covered such topics as
requirements for entry into HRAs, hot particle contamination control,
and proper placement and wearing of self-reading dosimeters (SRDs).
The inspector also determined that a good line of communication
existed between operational HP and GET training personnel.
This
allowed instructors to quickly address any possible poor work
practices identified in the field through improvements in training,
b.
Contractor Health Physics Training
The inspector reviewed the licensee's program for training contractor
HP technicians prior to allowing them to perform job coverage in the
RCA.
The program, developad by contract HP technicians currently
working in the ALARA group, is composed of six modules that cover the
various aspects of the licensee's HP program, as well as certain
administrative matters.
The training normally is given during
eighteen hours of classroom instruction by those contractor
individuals designated to function in the capacity of supervisors
during the contract period.
The inspector reviewed the modules and
verified that the course appeared to cover the essential elements of
HP and included site specific training on hot particle contamination
control, job coverage for certain potentially high exposure jobs,
survey techniques, and dosimetry requirements.
Other training was
also given the contract HP technicians including GET, if necessary,
and respiratory protection training and fit testing.
Following
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training, a test was given to verify that each individual had
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adequate experience and as academically qualified to function as an
HP technician.
Through interviews with contract HP technicians, the inspector
determined that the time spent in training varied directly with how
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urgently the individuals were needed to help perform job coverage in
the RCA.
According to those contractors interviewed, the time spent
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in training varied from eight to eighteen hours.
The contractors
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indicated, however, that the training was adequate and comparable to
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training received elsewhere.
No violations or deviations were identified.
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4.
External; Exposure Control and Personnel Dosimetry ~- Occupational Exposure,
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Shipping and Transportation (83750)
a.
. Personnel Dosimetry
10 CFR 20.202 requires each licensee-to supply appropriate _ personnel
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monitoring equipment to specific individuals and requires the use 'of
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such equipment.
Due lto a relative increase in the number. of personnel contamination
events (PCEs) during- the outage, the licensee had begun to require
the use of paper coveralls over the regular cloth protective clothing
(PCs).
This was done' in an effort to reduce the number. of PCEs.
During plant tours, the inspector observed.that workers were wearing
the required paper coveralls.
However, it was also noted that the
paper coveralls ~ were worn over the- plastic bag contairing the
individual's SRD which was normally worn attached to a loop on the-
outside of the cloth PCs.
In discussions with the licensee, the
inspector. indicated that such a practice seemed to preclude or at
least inhibit the workers from checking the SRDs frequently in order
to keep their exposures as low as reasonably achievable (ALARA). The
licensee indicated that they would evaluate the practice and correct
it as needed.
No violations or deviations were identified,
b.
Control of High Radiation Areas
10 CFR 20.203 specifies posting and control requirements for
radiation areas, HRAs, airborne radioactivity areas, radioactive
material areas, and radioactive material.
TS' 6.12.1 requires that in lieu of the . " control device" 3r " alarm
signal" required by Paragraph 20.203(c)(2) of 10 CFR 20, each HRA in
which the intensity of radiation is greater than 100 mrem /hr but less
than 1,000 mrem /hr shall be barricaded and conspicuously costed as .i
HRA and entrance thereto shall be controlled by requiring issuance of
an RWP.
Any individual 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 arens with this
monitoring device may be made after the dose rate level in these
areas have been established and personnel have been made
knowledgeable of them.
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An ind,vidual 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 in the RWP.
TS 6.12.2 requires that areas having a dose rate in excess of
1,000 mrem /hr be locked to prevent unauthorized entry in addition to
the requirements of TS 6.12.1.
(1) Historical Perspective
The inspector reviewed the licensee's performance in the area of
control of HRAs as reflected in previous NRC Inspection Reports
(irs) and in memoranda issued by the licensee on this subject.
IR No. 50-338/87-25 and 50-339/87-27 discussed an event in which
a HRA was left unlocked.
On August 2,1937, at 6:00 p.m., a
spot reading 10 R/hr was found on a blanked flange following
resin transfer that occurred on July 30, 1987.
The licensee
determined that the area had been left unlocked during the
period between the transfer and the discovery of the HRA.
A
review of exposure results of personnel who had access to the
area indicated that no one received inadvertent exposure as a
result of the event.
The event was determined to be a licensee
identified violation (LIV) for failure to maintain an HRA locked
as required.
IR No. 50-338, 339/88-02 opened an Unresolved Item
(URI 88-02-04) concerning 12 instances of unauthorized entries
into HRAs during 1987.
Each event dealt with entry by
individuals into an HRA without HP coverage or the required
survey meter.
In January of 1988, following a review of these
events, the Station Manager issued a memorandum to the head of
each department requesting a plan from each department to
address strict RWP compliance.
It was indicated that compliance
with RWPs would solve the problem with HRA entries since entry
into any HRA is governed by an RWP.
IR No. 50-338, 339/88-18
closed out URI 88-02-04 following a review of the plans
submitted by the department managers. The report also identified
the instances of entry into HRAs without a survey meter or HP
coverage as 12 examples of an LIV for failure to comply with the
requirements of TS 6.12.
IR No. 50-338, 339/88-27 reviewed two events involving discovery
of unlocked HRA (greater than 1,000 mrem /hr) access doors.
On
August 21, 1988, the door to the "A" gas stripper area was found
unlocked and on August 23, 1988, an HRA door in the
decontamination building basement was discovered unlocked. The
licensee indicated that a review had been conducted and that no
one received an inadvertent exposure as a result of the unlocked
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doors.
The licensee was given an LIV for failure to maintain
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the doors to HRAs locked as required by TS 6.12.2.
Following a
review of these events, the Plant Manager issued a memorandum on
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September 2,
1988, requiring a minimum of two qualified
individuals to maintain continuous communication in locked HRAs
and both individuals to independently verify that the door or
gate to the area was c'losed and locked upon exiting the area.
Each HRA door / gate was to be fitted with a unique key lock and
the keys controlled by HP.
Engineering was to evaluate the
installation of automatic door closure devices, if appropriate.
IR No. 50-338, 339/88-33 opened a URI concerning an individual
who " jimmied" the door to an HRA and entered without a meter or
HP coverage.
This event occurred on November 26,1988, and is
discussed in the following paragraph as Incident #2.
(2) Recent HRA Entry Incidents
Four incidents, each documented in a DR written by the licensee,
have occurred since August 1988, dealing with unauthorized entry
into HRAs. The three latest incidents were reviewed by a member-
of the HP staff and an investigative report was written
detailing the events of each incident. The details of these DRs
and investigative reports were reviewed by the inspector.
INCIDENT #1- On August 25, 1988, a Quality Assurance (QA)
inspector escorted a work crew into the Unit 1 Auxilary Building
piping penetration area, a posted HRA. General area dose rates
were from 10-20 mrem /hr.
Neither he nor anyone on the crew had
a survey meter and no HP coverage was provided.
They entered
without a meter or HP coverage because the QA inspector had
observed an irdividual inside the HRA with a meter and assumed
that the person was an HP technician who could provide the
needed coverage.
The person inside the barrier was not an HP
technician but an advanced radiation worker providing his own
work coverage.
After the QA inspector and work crew were
escorted out of the HRA, a read out of each of their
thermoluminescent dosimeters (TLDs) indicated that no one
received any dose as a result of the unauthorized HRA entry.
In discussing this incident with licensee representatives, the
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inspector determined that, at North Anna Power Station (NAPS), a
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person who has been through GET and received Advanced Radiation
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Worker (ARW) training can provide his own coverage for work in
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an HRA with dose rates less than 1,000 mrem /hr. Also, it is an
established work practice that, when a crew is sent into an HRA,
no HP coverage is required if the crew members are all qualified
as advanced radiation workers and are Quality Maintenance Team
(QMT) members.
One of the crew must check out a survey meter
and provide coverage for the job.
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The licensee took several steps as corrective action following
the event.
The QA inspector and the other individuals involved
were given management direction and specific training to insure
this inappropriate action would not recur. A recommendation was
also made to require HP technicians to wear colored hoods or arm
bands to distinguish them from the other workers.
(The use of
arm bands by HP techs was observed by the inspector during the
inspection.)
INCIDENT #2 - On November 26, 1988, an unlicensed operator
needed access to the Waste Solids Area, a posted, locked HRA, to
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collect daily samp' es and shiftly readings.
In order to get the
job done more quickly, the individual pried the locked HRA door
open with his pockit knife and entered the area. He was an ARW
and, as such, was qualified to use a radiation survey meter.
However, he had neither a key to unlock the door nor obtained a
meter from HP and had not made arrangements for HP coverage.
After entering the HRA, he worked in an area with dose rates
from 5-10 mrem /hr for about five minutes when two HP technicians
found him. He reportedly did not enter other areas of the Waste
Solids Area with dose rates from 150-700 mrem /hr. The operator
was escorted out of the area and required to turned in his SRD.
The individual's SRD reading for the entry was 0 mrem and his
TLD read 60 mrem for the quarter.
The licensee calculated 175
mrem as the maximum exposure he would have received assuming the
" worst case" (i.e., if he had been in an area with a dose rate
of 700 mrem /hr for 15 minutes).
No internal uptake was found
following an annual whole body count on November 28, 1988.
The licensee initiated various corrective actions following this
incident.
A plate was attached to the door / lock interface to
preclude unauthorized entry.
A more secure door and lock were
also ordered for the area.
The operator was given a " decision
day" (day off without pay to decide whether or not he would
follow the rules) and assigned to give presentations during
General Employee Retraining regarding the importance of adhering
to TS requirements and HP procedures when entering HRAs.
A
memorandum from the Station Manager was sent to all station
personnel emphasizing the need to adhere to HRA controls and
Tech Spec requirements.
The operator subsequently resigned for
other, unrelated reasons.
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INCIDENT #3 - On January 16, 1989, two contractor engineers went
to the NAPS site to perform inspections in the piping
penetration area of the Auxiliary Building. They did not report
to their representative onsite but went to the RCA entrance.
They contacted HP and were reportedly briefed on the
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requirements for entry into the area including the PC and HRA
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requirements.
They then dressed out, entered the RCA, and went
to the Unit 2 piping penetration area of the Auxiliary Building
on the 244 foot elevation. They entered the HRA without a meter
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or HP coverage and worked in the area for approximately one and
a half hours.
Tne engineers reportedly worked in ' areas with
dose rates from 5-10 mrem /hr.
There was one hot spot in the
area reading 200 mrem /hr at contact and 70 mrem /hr at one foot.
(The maximum dose rates in the penetration area are on the
charging and return lines and can reach 100-150 mrem /hr at one
foot during changing operations.
No such operations were
ongoing at the time of this incident.)
An operator, upon making his rounds, found the engineers in the
area and asked one engineer where his meter was located.
The
engineer stated that the other person had the meter and the
operator left.
Later the operator came back through the area,
observed that they did not have a meter, and asked them to leave
and report to the HP office.
The engineers' SR0s and TLDs were read and the TLD doses were
assigned as their official doses for the entry:
10 mrem for one
engineer and 9 mrem for the other. Results of whole body counts
of the individuals indicated no internal uptake.
Also, no
personal contamination was detected.
Upon further investigation of this event, it was determined that
the engineers had received GET at the licensee's Surry facility.
The requirements for entry into an HRA at Surry are somewhat
different than those at NAPS. At Surry, anyone who has received
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GET is allowed to check out a survey meter and provide his own
job coverage in an HRA with dose rates less than 1,000 mrem /hr.
At NAPS, only those who have received the ARW training can check
out a meter and provide their own coverage.
Although the
engineers, at one point during their briefing with HP, indicated
that they were trained to use a survey meter, they did not check
one out at the instrument issue window.
The engineers were restricted from all further work at either of
the licensee's nuclear power facilities as a measure to correct
the problem with failure to comply with established HRA entry
requirements. The engineering contractor was instructed to have
their other employees report to the onsite project manager when
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arriving on site, prior to performing any work.
INCIDENT #4 - On March 15, 1989, members of a contractor rigging
crew were trying to move a snubber rigid restraint through the
Unit 2 containment personnel hatch.
They could not use the
equipment hatch due to the refueling that was in progress.
Although no fuel was being moved at the time of the event, high
radiation caused by fuel movement was the reason that a HRA
barrier had been established beside the personnel hatch. During
efforts to move the snubber restraint, several crew members
briefly backed into the HRA near the personnel hatch without a
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meter or HP coverage. The crew members were in the area for
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approximately< one minute.
During this evolution, one crew
member also moved the HRA barrier out of the way for a period to
allow.better access to the snubber restraint.
He then stepped
into the HRA for a few moments.
Reportedly, an HP Supervisor observed this operation and told-
the crew members to step out of the HRA.
They did not
immediately respond but finally moved as the restraint was
repositioned.
No overexposure, personal contaminations or
injuries occurred.
The crew's official . quarterly dose ranged
from 36 to 510 mrem as determined from reading their TLDs.
Due to this HRA entry problem and other examples of lack of
adherence to good HP and ALARA practices (i.e. rising numbers of
personnel contaminations, poor work control by contractor HP
technicians, and workers being too focused on. completion of the
job without regard for safety concerns), much of the work in-
Units 1 and 2 was stopped for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Each crew was given a-
presentation on the importance of following all radiological and:
safety rules and on being responsive to HP directions.- Each
contractor supervisor was also required to respond injwriting to
the Station Manager detailing what actions had been taken to
ensure proper adherence to RWP and station requirements.
Following a review of these incidents, the licensee was informed that
the four incidents involving failure of personnel to have a radiation
monitoring device as specified or to be accompanied by a qualified HP
technician during entry into HRAs were identified as four examples of
an apparent violation of TS 6.12.1 (50-338, 339/89-05-01)
c.
Radiation Work Permits
The inspector observed selected outage-related work being performed
using radiation control requirements dictated by RWPs. The inspec;or
reviewed the appropriate RWPs and determined that the HP monitoring,
PC, dosimetry, and respiratory protection requirements established :y
the RWPs appeared to be adequate. The RWPs reviewed included:
89-1251 - Removal of Large Bore Snubbers from Steam Generator
Cubicles in Unit 2
89-1252 - Removal, Replacement and Repair of Small Bore Snubber
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in Unit 2
89-1448 - Eddy Current Testing in Unit 2
)
89-1616 - Replace Valves 2-RH-5, -13, and -23 on the RHR Flat in
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Unit 2
No violations or deviations were identified.
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'5.
Internal Exposure Control and Assessment
Occupational' Exposure,
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Shipping, and Transportation (83750)
a.
Engineering Controls
10 CFR 20.103(b) requires the licensee to use process or other
engineering controls to the extent practical to limit concentrations
of radioactive material in air to levels below those specified in-
10 CFR Part 20, Appendix B, Table 1 Column 1.
During tours of the Auxiliary Building and Units 1 and 2
Containments, the inspector observed the.use of process controls and
- engineering ' controls to limit airborne radioactivity in the plant.
The licensee used tent enclosures and vendor supplied sealed chambers
to decontaminate various tools and items of equipment and to perform
maintenance on contaminated items.
These tents.and chambers were
kept under negative pressure by means of high efficiency particulate
air (HEPA) filtration systems.
Some filtered ventilation also was
provided by using several lengths of ducting to draw air from highly.
contaminated work areas in places ~ such as the pump cubicles in. the
containment buildings.
The air was subsequently drawn into the
permanent filtered containment ventilation system through the
temporary ducting.
b.
Respiratory Protection
10 CFR 20.103(c) requires that, when respiratory protection equipment
is.used to limit the inhalation of airborne radioactive material, the
licensee train, medically qualify, and fit test the individual user
of such equipment..
The use of respiratory protection was observed and discussed with -
licensee representatives.
It was noted that, on occasion,
respiratory protection is issued to individuals as a precaution
against facial contamination and not necessarily due to airborne
radioactivity or high levels of surface contamination. This practice
was not widespread, however, due 'in part to the efforts expended
during the outage in progress to decontaminate the containments.
No violations or deviations were identified.
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6.
Control of Radioactive Material and Contamination, Surveys, and Monitoring
. - Occupational Exposure, Shipping, and Transportation (83750)
{
a.
Plant Surveys
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The licensee is required by 10 CFR 20.401 and 20.403 to maintain
records of such surveys necessary to show compliance with regulatory
limits.
Survey methods and instrumentation are outlined in
Chapter 12 of the FSAR.
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During plant tours, the inspector reviewed radiation level and
contamination survey results posted outside various areas and
cubicles.
The. inspector. verified these . radiation levels using NRC
instrumentation.
The inspector also reviewed selected records of-
radiation.and contamination surveys performed by the licensee during
.the inspection and discussed the survey results with licensee -
representatives,
b.
Radiation Detection and Survey Instrumentation
The inspector reviewed the licensee's use of . portable ' radiation
detection instruments for routine radiation protection activities.
During plant tours, the . inspector verified that all instruments.
observed in use had been calibrated within the prescribed time period
and also observed that the selection and use of instruments was
appropriate for the radiation protection activity involved.
c.
Personnel and Material Release Surveys
During tours of the facility, the inspector observed the exit of.
workers and the movement of material from contamination control to
clean areas to determine if proper frisking was performed by the
workers and if proper direct and removable contamination surveys were
performed on materials.
The inspector determined that personal
frisking was adequate but some examples of poor material survey
practices were noted.
The inspector observed contractor HP
technicians performing contamination surveys using cotton glove
liners as the smear medium. The items checked for contamination were
adequately surveyed but the technique was not appropriate.
In
. discussing this with licensee representatives, they indicated that
this was not an accepted practice and that this would be stopped. No
further examples of this survey " technique"'were observed following
the discussion.
No violations or deviations were identified.
7.
Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA)
- Occupational Exposure, Shipping, and Transportation (83750)
10 CFR 20.1(c) states that persons engaged'in activities under licenses
issued by the NRC should make every reasonable effort to maintain
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radiation exposure ALARA.
The recommended elements of an ALARA program
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are contained in Regulatory Guides 8.8, Information Relevant to Ensuring
that Occupational Radiation Exposure at Nuclear Stations will be ALARA,
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and 8.10, Operating Philosophy for Maintaining Occupational Radiation
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Exposures ALARA.
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a.
Goals and Objectives
The inspector discussed the ALARA program with licensee
representatives.
The site ALARA group develops the goals for the
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station based on corporate, station management and department input.
Once established and agreed upon, each department head is held
responsible for achieving the goal.
This is done by management
objective in performance plans.
Contractors are also given goals
with respect to ALARA.
The goals are then coupled with monetary
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incentives to increase the likelihood of achieving the goals,
b.
ALARA Suggestion Program
ALARA suggestions are encouraged and solicited from all plant
workers.
To reinforce this effort, T-shirts are given to all those
who submit a suggestion for consideration. As further incentive, the
licensee has initiated the practice of awarding a $150 cash prize on
a quarterly basis to the individual submitting the best ALARA
suggestion that is adopted for action.
c.
High Exposure Jobs
The inspector reviewed the exposure data to date of various jobs with
the potential for high accumulated exposure and discussed these jobs
with the site ALARA coordinator.
The pre-job reviews, dose
estimations, pre-job briefings and subsequent job review and exposure
tracking for selected work in Unit 1 and Unit 2 containments were
also reviewed. All but one of the jobs reviewed were well within the
exposures projected for the jabs. The one job which had exceeded the
projection was the sludge lancing work being performed in Unit 2.
It was expected to require a total of approximately 5 person-rem for
completion instead of the original estimate of 3.8 person-rem.
All
the licensee reviews appeared to be adequate and the pre-job
briefings were being performed as required.
No excessive exposure
for any job was noted and it appeared that the exposures for all jobs
were being tracked on a timely basis.
No violations or deviations were identified.
8.
Action on Previous Inspection Findings (92701)
(Closed) URI 50-338, 339/88-33-06:
Unauthorized Entry into a Locked High
Radiation Area.
The inspector reviewed the event outlined in URI 88-33-06 involving entry
by an operator into an HRA. The operator " jimmied" the HRA door lock and
entered the area without a survey meter or HP coverage. The incident was
identified as an example of an apparent violation of TS 6.12.1 for failure
of the person entering a HRA to have a radiation monitoring device or to
be accompanied by a qualified HP technician.
The incident is further
detailed in Paragraph 4.b.
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9.
Followup on Information Notices (92717)
The inspector determined that the following Information Notices (ins) had
been received by the licensee. reviewed for. applicability, distributed to
the appropriate personnel and that action, as appropriate, had been taken
or was scheduled.-
IN 88-79: Misuse of Flashing Lights for High Radiation Area Control
IN 88-101: Shipment of Contaminated Equipment Between Nuclear Power
Stations
10. Facility Statistics
a.
Annual Personnel Dose
In 1987, the station's cumulative personnel dose was 760 person-rem
per reactor as compared to the Pressurized Water Reactor (PWR)
national average of 369 person-rem per reactor.
In 1988, the dose
goal was set at 65 person-rem per reactor due to the lack of any
anticipated outages. The actual cumulative dose received in 1988 was
59 person-rem per reactor.
In 1989,- the site goal was set at
293 person-rem per reactor. As-of March 23, 1989, 247 person-rem had
been expended. A goal for the current outage had been established at
228 person-rem and, as of March 23, 1989, 226 person-rem had been
used.
b.
Personnel Contamination Events (PCEs)
The licensee experienced 61 skin and 197 personnel clothing
contaminations for a total of 258 PCEs'in 1988, compared to'611 skin
and 920 clothing contaminations for a total 1,531 PCEs for 1987.
This is an obvious downward trend in personnel contaminations and
reflects the efforts made by the licensee to reduce the number of
PCEs. As of March 23,_1989, the licensee had experienced 48 skin and
89 clothing contaminations or a total of 137 PCEs.
c.
Area Contamination Control
At the end of 1987, the licensee maintained approximately
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13,250 square feet (f tz) within the RCA, excluding the containment
buildings, as contaminated. This represented about 13 percent (%) of
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the total 105,000 ft2 within the RCA.
At the end of 1988,
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approximately 9,850 fte were being controlled as contaminated area or
about 9 % of the RCA.
As of March 23, 1989, the licensee was
maintaining approximately 17,750 f tz as contaminated area.
This
figure had increased due to the outage in progress and also included
temporary work areas, such as those established for the painting
contractors.
No violations or deviations were identified.
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11.
Followup on Allegations (99014)
a.
Statement of Concern
Allegation No. RII-89-A-0019.
It was alleged that there wert serious
problens with the radiation protection program and the ALARA program
at NAPS. The following specific allegations were made:
(1) A contractor HP technician was fired because the individual
raised safety concerns while working at NAPS.
(2) The licensee had seriously underestimated the exposure for a
specific job involving snubber removal / replacement work in the
Unit 2 containment.
(3) The ALARA program was inadequate.
(4) The organization and control of the HP activities wac poor and
there was no direction given to the technicians.
(5) Many people are receiving an excessive amount of exposure due to
the high radiation levels associated with the sr.ubber
removal / replacement work.
b.
Discussion
The inspector discussed these concerns with licensee representatives
and the HP contractor representatives.
The inspector reviewed the
work request, the pre-job review, the exposure estimate, the RWP, the
additional ALARA requirements, and all the surveys and other records
generated and associated with the snubber removal / replacement work.
The inspector also reviewed the adequacy of the ALARA program, the
organization and control of HP technicians and the exposure records
of personnel involved in the snubber work.
The inspector found the
following:
(1)
In discussions with the onsite contractor HP coordinator, it was
determined that the contractor HP technician had been fired due
to insubordination.
The technician had failed to complete
assignments given and would not comply with the directions of
the contract HP shift supervisor.
The technician had raised
" safety" concerns but these were used a means to avoid unwanted
work assignments.
And, although the technician had failed to
come to work and had failed to call in to inform the supervisor
of
the
situation,
the reason for termination was
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insubordination. The onsite contractor HP coordinator had spent
approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in conversation and counselling with the
individual but the individual would not agree to conform to the
rules established for contractors and would not accept the
authority of the assigned supervisor.
The alleger had been
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advised earlier of his 10 CFR 19.20 rights to engage in protected
activity.
(2) The inspector reviewed all the documents associated with the
snubber removal / replacement in the ALARA file and in the HP
file.
The original estimate for the job had been set at
105.6 person-rem. However, the estimate had been reduced by 12%
due to a management / corporate goal to establish a challenging
yet realistic goal.
In reviewing the exposure data received to
date, the inspector determined that, with the job approximately
75% complete, 59 of the 93 person-rem estimated for the job had
been expended.
Licensee representatives indicated that the
remaining work would be similar to that already done and they
expected to use niuch less than the revised exposure estimate.
(3) The inspector reviewed the ALARA program including the required
pre- and post-job reviews, the exposure estimation method, and
the review and tracking performed while jobs are in progress.
The program appeared adequate and all aspects and requirements
pertaining to the snubber job had been or were being completed.
Further explanation of the areas and items reviewed can be found
in Paragraph 7.
(4) The inspector reviewed the organization and control of the
contractor HP technicians.
Through discussions with the
licensee, it was determined that, prior to March 16, 1989, the
organization and control of the contractor HP technicians had
not been completely adequate. On certain shifts, the contractor
HP personnel had been lef t in charge to enforce the station and
HP organization's standards and policies.
This had resulted in
inadequate control of work and in poor maintenance of other
aspects of control as cleanliness in the work areas.
As a
result, PCEs and other problem indicators had arisen, including
problems with responsiveness to HP directions. As a result, the
majority of all the outage work had been stopped for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
period on March 16 and direction given to bring the radiological
aspects of the work under control. The licensee's HP operations
work force, which consisted of six crews with a supervisor over
each crew, was placed on shifts of six days per week for 12
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hours per day; three crews on day shift and three crews on night
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shift.
A licensee HP supervisor was placed in charge of each
containment on each shift and the third supervisor on shift was
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in charge of RWP preparation and support.
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This has appeared to be effective in bringing the work under
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control and in allowing enforcement of the licensee's werk
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practices and standards. This approach has allowed the licensee
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HP supervisors and technicians to be in a position to coach and
help the contractors as the need arises.
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(5) The inspector reviewed the personnel .' records of.-selected.
individuals and the dose. records of all individuals with a total
accumulated quarterly exposure greater than .1,000 mrem.
It was
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. noted -that the -individuals with the highest expo::ure for the
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quarter were not ones working on the snubber job. Of all- those
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reviewed,, the; highest exposure received. had' been 1,739 mrem.
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which- was: within the regulatory. limit of 3,000 mrem for
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quarterly exposure.
The inspector also ' verified that the
exposure extension forms had been completed as required by-
procedure as 'needed and NRC Forms 4 were on file for those
individuals.
c.
Finding.
There were no serious problems identified with the radiation
protection program or with the ALARA program except- as ' previously
outlined in this paragraph and in Paragraph 4 regarding control of
HRAs.
d.-
Conclusion
The allegation was partially substantiated in that there had. been
poor control and organization of HP activities.
This, however,.
appears to have been rectified with the assignment of licensee HP
crews to each shift.
The other aspects of the allegation were not
substantiated.
No violations or deviations were identified.
12. Exit Interview
The inspection scope and findings were summarized on March 23, 1989, with
those persons indicated in Paragraph I above. The inspector described the
areas inspected and discussed in detail the inspection findings listed
below.
The licensee did not identify as proprietary any of the material
provided to or reviewed by the inspector during the inspection.
Item Number
Description and Reference
50-338, 3391/89-02-01
Violation - Failure of personnel to have a
radiation monitoring device as specified or
to be accompanied by a qualified HP
technician
during
entry
into
(Paragraph 4.b).
Licensee management was informed that the item discussed in Paragraph 8
was considered closed.
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13. Acronyms and Abbreviations
f
1
As Low As Reasonably Achievable
ANSI
American National Standards Institute
ARW
Advanced Radiation Worker
CFR
Code of Federal Regulations
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DR
Deviation Report
Final Safety Analysis Report
ft2
Square feet
General Employee Training
High Efficiency Particulate Air (filter)
Health Physics
IN
Information Notice
IR
Inspection Report
LIV
Licensee Identified Violation
mrem
Millirem
mrem /hr
Millirem per hour
North Anna Power Station
PCs
Personal Protective Clothing
Personal Contamination Event
Pressurized Water Reactor
Quality Assurance
QMT
Quality Maintenance Team
Radiation Control Area
Radiation Work Permit
SNS0C
Station Nuclear Safety and Operating Committee
Self-reading Dosimeter
TL9
Thermoluminescent Dosimeter
TS
Technical Specification
Unresolved Item
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