ML20245C007

Insp Repts 50-338/89-05 & 50-339/89-05 on 890320-24. Violations Noted.Major Areas Inspected:Radiation Protection Program in Areas of Organization & Mgt Controls,Training & Qualifications & Internal Exposure Control

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: IR 05000338/1989005 ML20245C003 ML20245C006 ML20245C007
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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D ..' ~ 1' t- UNITED STATES

, NUCLEAR REGULATORY COMMISSION

o 'e '

REGION 11

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101 MARIETTA ST., N.W.

eo,, ATLANTA, GEORGIA 30323

- 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.: NPF-4 and NPF-7

Facility Name: North Anna 1 and 2

Inspection Conducted: March 20-24,1989

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Inspector:

C. H. Bas

M)t2/td  ? D&t Signed

/c2

Approved by. -

J. P/ Totter, Chief .

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

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:

l 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.

l The inspector reviewed the licensee's station organizat_ ion, as well

as the responsibilities, authority, and control given to management

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as they relate to the site radiation protection program. .'No recent

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. FSAR ,

Chapters 12 and 13 outline further ' details on staffing as well.

The' insp(ector

physics reviewed

HP) sections and the staffingthe

discussed level of the

current station

level with health

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 ,

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 ]

urgently the individuals were needed to help perform job coverage in

the RCA. According to those contractors interviewed, the time spent i

in training varied from eight to eighteen hours. The contractors  !

indicated, however, that the training was adequate and comparable to

I 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

, monitoring equipment to specific individuals and requires the use 'of

I 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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3) 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

the doors to HRAs locked as required by TS 6.12.2. Following a

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review of these events, the Plant Manager issued a memorandum on

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 j

inspector determined that, at North Anna Power Station (NAPS), a

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 i

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 .

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 I

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

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 l

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 1

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

o 89-1252 - Removal, Replacement and Repair of Small Bore Snubber

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

Unit 2 ]

No violations or deviations were identified.

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L '5. Internal Exposure Control and Assessment -

Occupational' Exposure,

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. {

6. Control of Radioactive Material and Contamination, Surveys, and Monitoring

. - Occupational Exposure, Shipping, and Transportation (83750) {

a. Plant Surveys j

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

The recommended elements of an ALARA program

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E radiation exposure ALARA. l

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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,  !

and 8.10, Operating Philosophy for Maintaining Occupational Radiation ]

Exposures ALARA. ]

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

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 ,

13,250 square feet (f tz) within the RCA, excluding the containment

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buildings, as contaminated. This represented about 13 percent (%) of -

the total 105,000 ft2 within the RCA. At the end of 1988, I

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

l 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 I

hours per day; three crews on day shift and three crews on night J

shift. A licensee HP supervisor was placed in charge of each

containment on each shift and the third supervisor on shift was j

in charge of RWP preparation and support. )

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This has appeared to be effective in bringing the work under )

control and in allowing enforcement of the licensee's werk i

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

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accumulated quarterly exposure greater than .1,000 mrem. It was

l . 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.

l. which- was: within the regulatory. limit of 3,000 mrem for

The inspector also ' verified that the

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quarterly exposure.

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 HRAs

(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

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ALARA As Low As Reasonably Achievable

ANSI American National Standards Institute

ARW Advanced Radiation Worker

CFR Code of Federal Regulations i

DR Deviation Report

FSAR Final Safety Analysis Report

ft2 Square feet

GET General Employee Training

HEPA High Efficiency Particulate Air (filter)

HP Health Physics

HRA High Radiation Area

IN Information Notice

IR Inspection Report

LIV Licensee Identified Violation

mrem Millirem

mrem /hr Millirem per hour

NAPS North Anna Power Station

PCs Personal Protective Clothing

PCE Personal Contamination Event

PWR Pressurized Water Reactor

QA Quality Assurance

QMT Quality Maintenance Team

RCA Radiation Control Area

RWP Radiation Work Permit

SNS0C Station Nuclear Safety and Operating Committee

SRD Self-reading Dosimeter

TL9 Thermoluminescent Dosimeter

TS Technical Specification

URI Unresolved Item

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