IR 05000280/1979032
| ML18130A628 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/29/1979 |
| From: | Ewald S, Jenkins G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18130A624 | List: |
| References | |
| 50-280-79-32, 50-281-79-50, NUDOCS 7909200238 | |
| Download: ML18130A628 (4) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos. 50-280/79-32 and 50-281/79-50 Licensee:
Virginia Electric and Power Company Richmond, Virginia 23261 Facility Name:
Surry Power Station Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37 Inspection at SUMMARY Inspection on June 11-13, 197 Areas Inspected Virginia ifate Signed
~l?i/?cz Date Sfgned This routine unannounced inspection involved 22 inspector-hours onsite in the area of radiation protection including respiratory protection, Radiation Work Permits, and facility tour Results Of the three areas inspected, no apparent items of noncompliance or deviations were identified in one area; two apparent items of noncompliance were found in two areas (Infraction - failure to provide survey instrument to workers in a High Radiation Area -paragraph 6; Deficiency - Failure to log correct RWP numbers when issuing respirators - paragraph 5).
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DETAILS 1. _ Persons Contacted Licensee Employees
- W. L. Stewart, Station Manager
- T. A. Peebles, Superintendent, Technical Services
- R. K. Smith, Health Physics Supervisor P. P. Nottingham, IV, SGRP Assistant Supervisor, Health Physics H.F. McCallum, Assistant Supervisor, Health Physics S. Sarver, System Health Physicist NRC Resident Inspector
- D. J. Burke
- Attended exit interview Exit Interview The inspection scope and findings were summarized on June 13, 1979 with those persons indicated in Paragraph 1 abov Items discussed included two items of noncompliance and an unresolved item relative to the RWP syste With regard to the RWP system, licensee representatives stated a thorough review of the system and its effectiveness would be pursued and the system revised as necessar.
Licensee Action on Previous Inspection Findings Not inspecte.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviation New unresolved items identified during this inspection are discussed in paragraph.
Respiratory Protection CFR 20.103(c) requires the licensee use respiratory protection equipment as stipulated in Regulatory Guide 8.15, "Acceptable Programs for Respiratory Protection." Regulatory Guide 8.15 outlines the technical, procedural, and administrative controls necessary for an acceptable program. The facility Respiratory Protection Hanual (RPM) constitutes the licenseds program for implementating these requirement The inspector reviewed changes to the RPH up through July 1978 and had no question RPM Section 8.5 and 9.8 require monthly inspections of
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-2-full face respirators and SCBAs, respectively. These inspections are controlled by Periodic Test P. T. 38. 27. The inspector ex~ined P. T. 38. 27 records and RPM forms 9.1 (SCBA) documenting monthly inspections for 1979 and had no questions. The inspector also reviewed tests results of P.T.-38.29, "Service Air and Breathing Air Sampling." This test is performed semi-annually to assure quality of air used with respiratory protection equipment meets required standards. The inspector reviewed analyses performed in July and December 1979 by an independent contractor and had no question RPM 7.2 lists the requirements for issuing respirators. A worker is required to have had physical examination within the last 12 months and have passed the respirator fit test. These records must be on file at dose control for a worker to get authorization to draw a respirato The inspector selected twelve names at random from the respirator issue log and verified appropriate documentation of fit test and physicals was in the individual's file The inspector reviewed data recorded in the respirator issue log as required by RPM 7.2.5 and noted a large number of apparent errors in RWP number An examination of seventy-nine entries, for respirators issued the week of June 4-11, 1979, revealed thirty-five entries where the RWP was not correc Several of the problems involved listing a work area not covered by the RWP but most of the errors (33 of 35) involved logging the number of a terminated RWP. The inspector stated that failure to record accurate RWP data, as stipulated in RPM 7.2.5, was in noncom-pliance with 10 CFR 20.103(c).
(280/79-32-02, 281/79-50-02) The inspector's concerns relative to the RWP system are discussed in paragraph.
Facility Tours The inspector toured the auxiliary building on June 12 and questioned a group of workers in the basement of the auxiliary building as to their RWP. The workers stated the RWP they were working under was N.
No copy of this RWP was poste A review of RWP records and further discussions with licensee representatives revealed the RWP N was a SGRP controlled permit and did not explicitly apply to the extension of work to the auxiliary buildin The inspector reviewed RWPs generated from the plant (non-SGRP) and found RWP No. 353 had been written to cover the wor A health physics technician returned to the work location and verified a copy of RWP No. 353 was poste The inspector had no further questions relative to RWP procedure implementation but expressed concern that the workers were apparently unaware of the applicable RW These concerns are discussed further in paragraph The inspector toured Unit 1 containment on June 13 with an Assistant Supervisor, Health Physics and questioned several groups of workers as to RWPs authorizing their wor The inspector talked with eight workers, two of whom were performing a periodic test to assure the sump was dry. These workers indicated they did not need a special RWP
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-3-as the Standing RWP (SRWP) was appropriate for their job. In discussions with the remaining six workers, who were performing inspections of baseplates and anchor bolts, they indicated their work was also covered by the SRWP for general containment entries. The inspector discussed the work with three individuals and surveyed the area near one baseplate the workers were in the process of examining. General area radiation levels were 200 mrem/hr. The entrance to the cubicle where the baseplate is located was posted as a high radiation area. The inspector questioned the workers as to their knowledge of the radiation levels and whether they had a survey meter. The workers did not have a survey meter and apparently had no specific knowledge of the radiation levels in their work area. The inspector examined the active RWPs and noted RWP No. 514 had been written June 8 to specifically cover the baseplate inspection effor Technical Specification 6.4.B.1.c states any individual or group of individuals permitted to enter a high radiation area shall be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area. The inspector stated that failure to provide the workers discussed above with a survey meter while working in a high radiation area (200 mrem/hr) was in noncompliance with Technical Specification 6.4.B.1.C (280/79-32-01; 281/79-50-01).
The inspector also expressed that the workers performing base plate inspec-tions were apparently unaware of the special RWP for the job. These concerns are discussed further in paragraph.
Radiation Work Permits Several items revealed during the inspection and previous inspections, raised questions and concerns relative to the effectiveness of the facility RWP syste Technical Specification 6.4.B.1.g requires work in high radiation areas be controlled with a RWP system. Health Physics procedures implement this requirement and are intended to control, from a radiological safety perspective, all work in the restricted control area or any other area where a radiological hazard may exist. The inspector expressed concern at the instances where workers were not fully aware of applicable RWPs and the problem of expired RWPs being logged to issue respirators. The inspector stated the RWP system, as being used, apparently does not provide the degree of control impHed by the RWP procedure The inspector discussed bis concerns with Management representatives and acknowledged co111Dents relating to problems with implementing the procedures as written rather than the system itself. The inspector c0D111ented that if the RWP system was not providing the desired degree of control, for whatever reason, then changes in procedures for implemen-ting the system or the system itself should be investigated. Management representatives acknowledged the inspector's couments and concerns and stated a review of RWP controls would be initiated. The inspector stated the RWP system effectiveness would be unresolved (280/79-32-03; 281/79-50-03)
pending further review by the licensee and by the inspector during future inspections.