IR 05000280/1979018
| ML18116A151 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/07/1979 |
| From: | Gibson A, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18116A147 | List: |
| References | |
| 50-280-79-18, 50-281-79-26, NUDOCS 7907180695 | |
| Download: ML18116A151 (8) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30303 Report Nos. 50-280/79-18 and 50-281/79-26 Licensee: Virginia Electric and Power Company Richmond, Virginia 23261 Facility Name:
Surry Power Station, Units 1 and 2 Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37 Inspection at Ins!pc or:
q,r,,' near Williamsburg, Virginia App OV"f-', Section Chief, FF&MS Branch SUMMARY Inspection on April 9-13, 197 Areas Inspected Date Signed s:izh?
Date 'srghed This routine unannounced inspection involved 41 inspector-hours onsite in the areas of radiation protection, including posting and control of radio-logical areas, surveys, respiratory protection, radioactive waste management program including solid radioactive waste processing and disposal and radioactive liquid effluent releases, and tours of the plan Results Of the six areas inspected, no apparent items of noncompliance or deviations were identified in three areas; three apparent items of noncompliance were found in three areas (Infraction - failure to follow procedure for test and checks of tents, (281/79-26-01, paragraph 7; Infraction - failure to take adequate surveys of subsurface drain system prior to release of effluent, (280/79-18-02; 281/79-26-02) paragraph 9; Infraction - failure to post a radiation area, (280/79-18-03; 281179-26-03) paragraph 10).
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DETAILS Persons Contacted Licensee Employees.
- J. L. Wilson, Superintendent - Operations R. F. Saunders, Superintendent - Maintenance R. M. Smith, Health Physics Supervisor P. P. Nottingham, Health Physics Coordinator, SGRP T. A. Peebles, Superintendent - Technical Services S. Stevens, Operations Coordinator D. Densmore, Assistant Health Physics Supervisor M. R. Beckham, Assistant Health Physics Supervisor S. Sarver, Corporate Health Physicist Other licensee employees contacted included five construction craftsmen, six technicians, two operators, 2 mechanics, and two office personne NRC Resident Inspector D. J. Burke
- Attended exit intervie Exit Interview The inspection scope and findings were summarized on April 13, 1979 with those persons indicated in Paragraph 1 above. With regard to the sampling of the subsurface drain system, the Acting Station Manager stated that the frequency of sampling and analysis would be changed to dail The Acting Station Manager acknowledged the other items of noncomplianc Licensee Action on Previous Inspection Findings (Open) Noncompliance (280/79-09-02, 281/79-10-02) Posting and/or Barri-cading High Radiation Area On April 11, 1979, the inspector observed that a high radiation area in the Unit 1 "A" steam generator cubicle (-3 feet 6 inches elevation) was not posted and barricaded in accordance with Technical Specification 6.4.B. The high radiation area was only posted and barricaded on two of three accessible sides. The highest radiation levels recorded during a survey performed in the area on April 10, 1979 was 750 mR/hr. This is an additional example of failure to post and barricade a high radiation area reported as noncompliance with Technical Specification 6.4.B.1.a in Region II Report No /79-9 and 50-281/79-10 of March 28, 197 It should be noted
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that the licensee had not formally responded to the item of noncompliance prior to the inspector identifying the additional example of noncomplianc Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations. New unresolved items identified during this inspection are discussed in paragraph.
Respiratory Protection Program By review of records, observations and discussion with licensee representatives, the inspector evaluated the plant's program for air sampling, engineering controls, medical evaluation, issuance controls and quality of breathing ai The* inspector reviewed the respiratory protection equipment used at the station and verified that when credit was taken for the respiratory protection equipment in accordance with 10 CFR 20.103(c)
only NIOSH approved equipment was use The inspector reviewed the results of an analysis of breathing air performed in accordance with Periodic Test 38.29 "Analysis of Breathing Air" and reported to the licensee in a letter dated December 26, 1978. The quality of the service air and the compressed air source appeared to meet the standards for Class E air recommended in NUREG-004 The inspector performed contamination and radiation surveys of respirators in a "ready-for-issue status" and determined that the contamination levels were less than those established for "ready-for-issue" respirators in the Station's Respiratory Protection Manua CFR 20.103(c) requires that respiratory protection equipment be used in accordance with Regulatory Guide 8.1 Regulatory Guide 8.15, Paragraph C.4.c requires the licensee to maintain and implement a respiratory protection program which includes written procedures to ensure the adequate individual fitting of respirator VEPCO's Respiratory Protection Manual, Section RPM-7, Paragraph 2 states that "individuals must have successfully passed a respirator fit test before they are issued a respirator." During a review of respirator issue and fit test records, the inspector noted that fit test records were not available for two visitors who were
.issued respirators on March 30, 1979 for work on Unit 1 steam generator A licensee representative stated that the plant accepted the fit test certification provided by the visitor's employe A review of the clearance letter provided by the visitor's employer revealed that only medical approval to wear a
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- _:_-:._.. ~,--~--Z-c...*------...,...- ****-*-----,-*--*,-- ---..............., ___...__, ____,_ -...... respirator was provide A licensee representative stated that he was sure the visitor had been given a respirator fit test by their employer. The inspector stated that issuance of respirators to individuals prior to the satisfactory completion of a fit test would be in noncompliance with 10 CFR 20.103(c). The inspector further stated that this item would remain unresolved (280/79-18-04; 281/79-26-04) pending receipt of verification that the individuals received respirator fit test from their employe Surveys The inspector selectively reviewed records of radiation, contamination and airborne radioactivity surveys performed in Unit 2 containment in April, 1979 and discussed the survey results with licensee representa-tives The surveys reviewed appeared to be adequate and the frequency and detail of the surveys appeared to be in accordance with plant procedures and radiation work permit The inspector had no further questions concerning survey.
Plant Tour During the period of the inspection, the inspector toured various areas of the station to observe radiological controls, work practices, housekeeping, et The inspector noted during tours of Unit 2 containment that vacuum cleaners were used to clean radioactively contaminated and potentially contaminated area The vacuum cleaners in use had an internal high efficiency particu-late filter; however, a number of the cleaners in use had external damage to the outer case to such an extent that the integrity of the seals was questionabl A licensee representative stated that the station did not periodically test the vacuum cleaner's filter system to verify that the filtering system was functioning properl The inspector commented that some testing program should be established to ensure the surface contamination is not made an airborne source or redeposited as the results of a faulty vacuum cleane A licensee representative stated the use of vacuum cleaners would be reviewed and testing would be considere The inspector identified this as an open item (280/79-18-05; 281/79-26-0S). On April 9, 1979, the inspector noted in Unit 2 containment a number of 5 gallon and 15 gallon yellow polyethylene bottles used to collect potentially radioactive wate In most instances, the bottles were partially full of wate In some cases, the bottles were not cappe In other cases, one opening was capped, and the other contained a filtered fill adapte The bottles were not tied off to prevent them from being accidently knocked over and the contents spille The inspector commented that the bottles
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-4-should be capped when not installed and that installed bottles should be tied off or secured to prevent accidental spillag The inspector also commented that the Steam Generator Replacement Project (SGRP) Health Physics Manual should be revised to include procedures for the installation, removal and handling of polyethy-lene bottles used to collect radioactive liquid A licensee representative acknowledged the inspector's comments and stated that the use of polyethylene bottles would be reviewe The inspector identified this as an open item (280/79-18-06; 281/79-26-06). The inspector observed the removal of slag and the decon of a piece of reactor coolant system pipe (RCS) in the basement of Unit 2 containmen During this operation, the inspector noted the following poor radiological control practices: (1)
A worker exited the tent used for slag removal and walked approximately twenty-five to thirty feet to an intercom station without removal of his outer set of shoe cover The Health Physics Technician covering the job stated the contaminat~on levels in the tent were approximately 50,000 dpm/100 cm
, while the levels in the walkways cptside the
"contaminated area" were less than 2000 dpm/100 cm (2)
A worker was observed with the trunk of his body leaning up against a piece of RCS pipe while installing the pipe decon equipment in the end of the p~pe. The radiation levels on contact with the end of the pipe were 2000 mR/h The worker could have worked from the side of the pipe when the dose rates were approximately 150 mR/hr. During a discussion with the health physics technician covering the job, he acknowledged that the worker should have positioned himself to minimize his exposure. Both examples were discussed with a licensee representativ The licensee representative stated that health physics technicians would be reminded that they were responsible for helping the worker keep his exposure ALA.R The inspector noted that the personnel frisker at the exit point for Unit 1 containment was inoperative on April 10, 197 The faulty instrument was immediately changed out after Health Physics was notifie,
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\\~I The inspector observe,tpoor housekeeping around the control point at the exit from the (rot machine shop. Overflowing bags of used anti-contamination clothing and trash marked "contaminated material" were located outside/
1~he building. The area was promptly cleaned up when housekeeping, lin the area was brought to the attention of a licensee representativ "'**----~----*
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e-s-Amendment 46 to Unit 2' s operating license issued January 24, 1979, establishes as a condition of license number DPR-37, that the Health Physics Program and Procedures which have been established for the Steam Generator Replacement Program (SGRP) shall be implemente The Health Physics Manual for the SGRP, Procedure HP-SGRP-10, Paragraph B.2.d requires that test and checks of tents be performed by health physics and an acceptance or "stop" sticker affixed to the tent. During a tour of Unit 2 containment on April 11, 1979, the inspector noted that acceptance or "stop" stickers were not affixed to the tent used for removal of slag from RCS piping prior to decon of the pipe nor to the tent used for cutting up miscellaneous pipin Both tents are located in the basement of containment (-18 foot elevation). When questioned concerning the inspection of the tents, a licensee representative stated that the tents had not been inspected as required by the health physics manua Completed copies of Form HP-SGRP-10.1,
"Tent Test Check-off Sheet" for the tents were not on file with other tents test check-off record The inspector stated that failure to inspect the tents and affix the appropriate label was in noncompliance (281/79-26-01) with amendment 46 to Operating License DPR-3 The tents were inspected and acceptance labels affixed prior to the inspector leaving the sit.
Solid Radioactive Waste By review of records, observations and discussions with licensee representatives, the inspector reviewed the plant's solid radioactive waste processing and disposal progra During tours of the plant, the inspector observed the following examples of the unnecessary generation of solid radioactive waste: Large quantities of wood are used in Unit 2 containment for shoring, scaffolding, flooring for working platforms, etc.,
rather than using metal which could be easily decontaminated and released for unrestricted use. After use, the wood products are being cut up and disposed of as solid radioactive wast Numerous bags of waste containing cardboard boxes and packing materials that were brought into Unit 2 containment. The outer cartons and packing should be removed from components prior to entering the restricted are A number of pallets of lead sheets were brought into containment and never use This excess material will either have to be disposed of, cleared for unrestricted use or stored as radioactive materia Material and equipment for the SGRP should have been brought into containment only when there was a specific nee ' "
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- . Disposable anti-contamination clothing was used to maintain clean-liness in the hot machine shop, before any work on radioactive material was begun. This clothing was disposed of as radioactive wast The inspector commented that the SGRP is going to generate a large volume of radioactive waste and the licensee should take positive action to minimize the amount of material used in contami-nated areas which cannot be readily decontaminated and reused or disposed of as non-radioactive wast A licensee management representative stated that the licensee would review generation of solid radioactive waste and will eliminate the unnecessary introduction of material such as wood, paper, plastic, etc.,
which cannot be released for unrestricted us The inspector identified this as an open item (280/79-18-07; 281/79-26-07). Posting and Control The inspector reviewed the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contamination areas, radioactive material areas, and the labelling of radioactive material during tours of the plan CFR 20.203(b) states, _in part, that each radiation area shall be conspicously posted with a sign or signs bearing the caution sysmbol and the words "Caution - Radiation Area".
10 CFR 20.202 (b)(2) states that "Radiation area means any area, accessible to personnel, in which there exist radiation. * * at such levels that a major portion of the body could receive in any one hour a dose in excess of 5 millirem.**. " On April 12, 1979, the inspector observed a piece of reactor coolant system piping outside the Unit 2 equipment hatc Radiation. levels in accessible areas near the pipe ranged from 10 - 20 mR/h The area was not pos.ted as a radiation area. Later the inspector observed that the area had a barrier around it and was posted as a "Caution Radioactive Material Area". The area was properly posted as a radiation area after the inspector discussed the posting with an licensee repre-sentativ The inspector stated that failure to post the area around the RCS pipe as a radiation area was in noncompliance (280/79-18-03; 281/79-26-03) with 10 CFR 20.203(b).
1 Liquid Effluent Releases from Subsurface Drain System This item was originally discussed in Region II Report 280/79-16 and 281/79-24 and concerns the release of liquid effluents from the subsur-face drain system. The inspector reviewed the sampling and accountability records for radioactivity released from the subsurface drain syste By discussions with licensee representatives it was determined that
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-7-the subsurface drain system is normally pumped out automatically to the discharge canal when a preset level in the sump is reached. Until recently, if the drain system pumps were inoperative, a temporary system was used which discharged the water to a storm drain outside the decon building. This is believed to be the source of contamination in the drain which was discussed in Region II Report 280/79-16 and 281/79-2 When the temporary system was used for maintaining water level in the subsurface drain system, the operators initiated a release permit for each release and health physics sampled and analyzed the water prior to the releas However, when the automatic system is operational, releases are estimated based on run times for the pump, design flow of the pump and the results of a weekly analysis of the water by health physic The inspector reviewed the weekly sample results reported in Periodic Test 38.21, "Chemistry Sampling - Subsur-face Drains" for 197 The ry>0rted concentrations ranged from 11no detectable acttvity" to 4 x 10-microcuries per milliliter for Cobalt-60 and to 6 x 10-microcuries per milliliter for Cesium-137. A licensee representative stated that the subsurface drain system pump was actuated almost daily to keep the system pumped down. The source of radioactivity in the subsurface drain system is believed to be from seepage from safeguards valve pit. Water seeps into the safeguard valve pit and out as the water level in the subsurface drain system rises and fall Past attempts to waterproof the valve pit have been unsuccessfu Contamination levels in th2 safeguard valve pit for Unit 2 were as high as 326,000 dpm/100 cm on surveys performed in March and April, 197 CFR 20.201(b) states, in part, that each licensee shall make or cause to be made such surveys as may ~e necessary for him to comply with the regulations in this part. Between January 1, 1979 and April 4, 1979, radioactive liquid effluents from the subsurface drain system were automatically pumped to the discharge canal by way of the station's storm drain syste The widely varying radioactivity concentrations in the weekly samples indicate that they are not representative of the concentrations released each time the drain system is automatically pumped out. The inspector stated that failure to perform radioactivity analysis at frequencies adequate to ensure that 10 CFR 20 limits are not exceeded was in noncompliance (280/79-18-02; 281/79-26-02) with 10 CFR 20.201(b).
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