ML20245H182
| ML20245H182 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 04/19/1989 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| Shared Package | |
| ML20245H184 | List: |
| References | |
| NUDOCS 8905030336 | |
| Download: ML20245H182 (4) | |
See also: IR 05000395/1989005
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Docket No. 50-395
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License No. NPF-12
South Carolina Electric & Gas Company
ATTN: Mr. O. S. Bradham
Vice President, Nuclear Operations
P. O. Box 88
Jenkinsville, SC 29065
Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NO. 50-395/89-05
This refers to the Nuclear Regulatory Commission (NRC) special team assessment
conducted by E. D. Testa and team on February 27 - March 3,1989.
The
inspection included a review of activities authorized for your Summer facility.
At the conclusion of the inspection, the findings were discussed with those
members of your staff identified in the enclosed inspection report.
The assessment was conducted to evaluate the effectiveness of actions you have
taken or are taking to reduce collective dose at your Summer facility.
This
inspection was conducted because of the above average collective radiation dose
at your Summer facility during refueling and maintenance outages for 1987 and
1988.
The assessment also evaluated the actions you have taken or are current-
ly taking to reduce collective doses during refueling and maintenance outages.
The assessment consisted of examination of selected procedures and representa-
tive records, interviews with personnel, and observation of activities in
progress.
Particular attention was directed to assessing management awareness
of, involvement in, and support of your facility's program to keep radiation
doses as low as reasonably achievable (ALARA).
Within the scope of the assessment, no violations or deviations were
identified.
A number of notable strengths were identified in your programs to
contol worker's doses, these are described in Enclosure 1 and are discussed in
detail in the enclosed report.
In addition, several weaknesses were identified
during the assessment that have reduced the effectiveness of your program to
keep radiation exposures ALARA, and thus merit your attention. The weaknesses
are also described in Enclosure 1 to this letter.
Since resolution of these
issues is also of interest to the NRC, you are requested to submit to this
office, within 30 days of the date of this letter, your written assessment of
each of the weaknesses, including actions that you have taken or plan to take
to improve these areas and the dates when actions will be completed.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2
Title 10, Code of Federal Regulations, a copy of this letter and its enclosures
will be placed in the NRC Public Document Room.
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The responses directed by this letter and its enclosures are not subject to the
clearance procedures of the Office of Management and Budget as required by the
Paperwork Reduction Act of 1980, Pub. L. No.96-511.
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8905030336 890419
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ADOCK 05000395
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South Carolina Electric & Gas Company
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Should you have any questions concerning this letter, please contact us.
Sincerely,
J. Philip Stohr, Director
Division of Radiation Safety
and Safeguards
Enclosures:
1.
Executive Summary
2.
NRC Inspection Report
cc w/encls:
J. L. Skolds, General Manager
Nuclear Plant Operations
A. R. Koon Jr. , Manager
Nuclear Licensing
J. B. Knotts, Jr.
Bishop Cook, Purcell & Reynolds
W. A. Williams, Jr. , Technical
Assistant, Nuclear Operations -
Santee Cooper
R. E. Rainear. Executive Vice
President, South Carolina Public
Service Authority
State of South Carolina
bec w/encls:
NRC Resident Inspector
J. J. Hayes, Project Manager, NRR
Document Control Desk
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ENCLOSURE 1
Executive Summary
Between 1984 and 1986, the annual collective radiation dose for the V. C.
Summer facility averaged 232 person-rem which was below the national average of
453 person-rem for pressurized water reactors (PWRs) during the same time span,
in 1987 and 1988 however, the annual collective dose average increased to 535
person-rem while the national average for PWR's decreased to 359 person-rem.
The increase in' annual collective dose during this period was attributed to
increased reactor coolant activity due to fission and activation product build
up in piping from failed fuel, increased steam generator maintenance, and valve
repair.
In some .high traffic areas adjacent to the residual heat removal
system piping, the dose rates have increased by a factor of up to 20.
While
collective doses for 1987 and 1988 are representative for plants experiencing
steam generator and failed fuel problems, it is not typical of a plant with six
years of operation to have these problems.
During the period February 27 - March 3,1989, a special team assessment was
conducted to evaluate the licensee's programs. for maintaining occupational
radiation dose ALARA.
The assessment included a review of the causes for the
high radiation dose; an evaluation of the licensee's current organization and
programs for keeping radiation dose ALARA; a review of initiatives the licensee
has taken or is taking to control the collective radiation dose; and an
assessment of licensee management's awareness of, involvement in, and support
of the program for keeping doses ALARA.
The assessment team found a high level of plant and corporate management
awareness of and support for the dose reduction program. -Fuel defects have
caused increases in out-of-core radiation levels which can contribute to
increased collective dose.
Increased innovative dose management techniques for
steam generator maintenance and repair, and valve maintenance, are being
considered by the licensee to reverse the recent trend in collective dose.
Strengths and weaknesses identified during the assessment are summarized as
follows:
Strengths
Completion of many inspection and maintenance tasks with lower than
industry average collective dose for each task.
General worker and management knowledge of ALARA concepts and awareness of
their responsibility to keep doses ALARA.
Inclusion of dose goal performance as part of each persons' annual
performance review.
Excellent plant-wide contamination control.
Annual continuing training of Health Physics personnel.
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Use of Radiation Safety Bulletins, Summer Report, Program and Content
Criteria, and Safety Meetings to keep personnel aware of ALARA activities
and plant dose information.
Weaknesses
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Slowness in completion of evaluation of dose reduction initiatives (for
example, reactor vessel head shield, system chemical decontamination,
cobalt reduction, and RTD bypass replacement)
Infrequent use of still photographs, video tapes and mock-ups for valve
and pump maintenance training.
Less than full implementation cf adopted Electric Power Research Institute
chemistry guidelines for Secondary Water Chemistry for Sulfate and Cation
conductivity.
Lack of followup on AllRA action items by the ALARA Review Committee.
Minimal use of the ALARA suggestion program.
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