IR 05000280/1981025

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IE Insp Repts 50-280/81-25 & 50-281/81-25 on 810921-25. Noncompliance Noted:Failure to Follow Required Procedures, Failure to Post High Radiation Area & Failure to Establish Egress Controls from High Radiation Area
ML18139B714
Person / Time
Site: Surry  Dominion icon.png
Issue date: 11/19/1981
From: Hosey C, Jonathon Puckett
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18139B707 List:
References
50-280-81-25, 50-281-81-25, NUDOCS 8202050319
Download: ML18139B714 (8)


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e UNITED STATES e

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos. 50-280/81-25 and 50-281/81-25 Licensee:

Virginia Electric and Power Company P. 0. Box 26666 Richmond, VA 23262 Facility Name:

Surry Nuclear Power Station Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37 SUMMARY Inspection on September 21-25, 1981 Areas Inspected near Surry, VA Division Date Signed

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te Signed This routine, unannounced inspection involved 36.2 inspector-hours on site in the areas of radiation protection, effluent sampling and accountability, dosimetry, and health physics procedure Results Of the 4 areas inspected, no violations or deviations were identified in one area. Three violations of NRC requirements were found in three areas (failure to follow required procedures, failure to post a high radiation area, and failure to establish egress controls from a high radiation area).

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REPORT DETAILS* Persons Contacted Licensee Employees

  • J. L. Wilson, Station Manager
  • F. L. Rentz, QC
  • 0. Johnson, QC
  • S. P. Sarver, HP Supervisor
  • R. F. Saunders, Asst. Station Mg *G. E. Kane, Supt. Operations
  • H.F. Kahnhauser, HP Corporate B. Garber, Health Physicist P. P. Nottingham, Asst. Supv. HP D. Densmore, Asst. Supv. HP Other licensee employees contacted included three construction craftsmen, five technicians, four operators, and nine mechanic *Attended exit interview Exit Interview The inspection scope and findings were summarized on September 25, 1981 with those persons indicated in ~aragraph 1 abov The station manager stated that the violation regarding the padlock on the seal water injection filter room (control not established to permit egress in accordance with 10 CFR 20.203.C.3) was not vali The station manager acknowledged the other two
  • violation.

Licensee Action on Previous Inspection Findings The inspector examined the licensee 1 s corrective actions on the following: (Closed) Infraction (50-280/80-29-16; 50-281/80-33-16) Failure to Follow Procedure (1)

Prior to August 5, 1980, only one daily background count for the whole body counter was being performed contrary to procedure HP3.l-15 Section The licensee revised the Surry Radiation Protection Manual on November 12, 1980 to require a background check once per shift or whenever an increase in background is suspecte The licensee 1 s corrective action appears to be ade-quat (2)

Workers and supervisors were found working in Unit 2 cable vault without a Radiation Work Permit (RWP) contrary to Radiation Protection Manual (RPM) paragraph 2.1. Licensee surveillance and training in the use of RWP 1s has been appropriately upgrade *

(3)

Workers tied back their protective clothing hoods contrary to RPM Section 2.2.C.l,C. Training in the wearing of protective clothing has been stressed in the General Employee Training (GET) class and the monitor at the RWP desk is charged with checking for proper clothing us (4)

A worker was observed to be wearing his dosimetric device other than as required by RPM section 1.3. During this inspection no instance of improper wearing of dosimetry was noted by the inspector and also, the licensee had posted attention getting signs to remind workers of proper us (5)

Five workers were observed by passing a frisking station contrary to RPM section 1.3.1. Although inadequate frisking for contamination was observed during this inspection, no instances of personnel not performing the required self-survey were observe The corrective measures (supplemental training) taken by the licensee appear to be adequat (6)

Contrary to RPM section 1.3.E, a worker was observed to reach across a contaminated area barrier and handle contaminated items without protective clothin No occurrances of this type were observed during this inspectio The corrective action (supple-mental training) taken by the licensee appears adequat (Closed) Infraction (50-280/80~29-21; 50-281/80-33-21) Lead Shielding On Pipe Without A Safety Review A memorandum instructing site personnel to avoid stressing safety-related piping was issued on January 16, 198 During this inspection no instance of improper use of shielding on safety systems was note The licensee's corrective action appears to be adequat (Closed) Infraction (50-280/80-29-22; 50-281/80-33-22) Failure to Maintain Process Vent System The licensee has nearly completed a major upgrade of the entire venti-lation system in the auxiliary buildin The inspector examined the written program for filter replacement currently in use and al so examined records of filter changes and checked the differential pressure on several filters which were in us The licensee's corrective action appears adequat.

Unresolved Items Unresolved items were not identified during this inspection.

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5, Licensee Action on Previous Inspector Identified Items (Closed) IFI (50-280/80-29-0l; 50-281/80-33-01) More Effective Utiliza-tion of Key Health Physics Personne There has been no formal change in the organization of the Health Physics Department, though the HP Supervisor stated that some were contemplate Informal change has come about as a result of the assignment of a new H.P. Superviso Health Physicists are not given supervisory responsibilities and are therefore free to exercise their technical duties and talents full (Closed) IFI (50-280/80-29-02; 50-281/80-33-02) Establish A Required Reading File for Updated HP Procedures. See 5.d. belo (Closed) I FI ( 50-280/80-29-03; 50-281/80-33-03) Fully Implement the qualification Record System. See item 5.d belo (Closed) IFI (50-280/80-29-04; 50-281/80-33-04) Implement HP Retraining Progra Coincident with the January 1, 1981 implementation of the HP retraining program, accurate records have been maintained by the licensee of this trainin Twenty-four sessions have been held since January The inspector examined the training outline and found it comprehensive including theory, current events, and related topic (Closed) IFI (50-280/80-29-05; 50-281/80-33-05) Full Implementation of Five Day Training Course in the First Month on Sit A licensee training representative stated that classes had now returned to a normal 12-14 person size and that an effort is made to meet the first month training goal. Almost all new employees are trained within the first two month The licensee feels that a strict requirement for training would detract from the benefits gained by allowing scheduling flexibilit The inspector was satisfied that the licensee is per-forming adequately in this are (Closed) IFI (50-280/80-29-06; 50-281/80-33-06) Intercomparison of TLD Badge and Reader Responses With North Ann Licensee procedure CHP-1 11 Confirmatory Measurements of TLD 11 was imple-mented in 1980 and experience has led the licensee to utilize the University of Michigan to perform the associated testing for both of VEPCO's facilities. The inspector had no further question (Closed) IFI (50-280/80-29-08; 50-281/80-33-08) Excessive Downtime for TLD Reade This problem has disappeared with the passing of the Steam Generator repair projec The project's reader is available to the licensee and will ultimately be a full-time backu *

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IFI (50-281/80-33-09; 50-280/80-29-09) Computerization of Dosimetry Record The licensee has begun to feed data to a new dose control computer

  • system installed in April, 198 It is expected to be fully opera-tional by January, 198 This will be examined during an inspection after that dat (Closed) IFI (50-280/80-29-10; 50-281/80-33-10) Shop Monitoring of Dos The new computer system described above will correct this proble This item is closed for administrative purposes and will be examined under item 5.h., abov (Closed) IFI (50-280/80-29-11; 50-281/80-33-11) Incorporation of All Items Listed in Respirator Trainin k.

The licensee is now including in the respiratory training program all items listed in the facility respiratory protection manual and NU REG 004 (Closed) IFI (50-280/80-29-12; 50-281/80-33-12) Reestablish Compara-bility of Medical Test The inspector randomly selected five contractor personnel and quest-ioned them concerning the type of medical screening t8eY had received in order to be certified medically qualified to wear respiratory protective device Their descriptions matched that of a licensee representative:

i.e., an M.D. certifies by examination individual qualification for both plant and contractor personne The inspector had no further question (Closed) IFI (50-280/80-29-14; 50-281/80-33-14) Tagging Respirators at Emergency Station The inspector checked five emergency station respirators and found all to be properly bagged and tagge The inspector had no further question (Closed) IFI (50-280/80-29-15; 50-281/80-33-15) Certification of Oxygen Enriched SCBA Unit This concern derrives from the failure to re-certify bottles of oxygen enriched air after filling via a transfer pump from certified grade D quality bottle The inspector determined that such testing is not required because the transfer pump is of the diaphragm type and contam-ination of the pumped fluid is not possible.

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5 (Closed) IFI (50-280/80-29-18; 50-281/80-33-18) *Vendor Spike Program Verification The urinalysis vendor is audited by VEPCO corporate quality assuranc It has been determined by VEPCO that further program verification is not warrante (Open) IFI (50-280/80-29-20; 50-281/80-33-20) Establishment of a Formal ALARA Progra A licensee representative stated that an ALARA program manual is still under review by VEPC This item will remain open until licensee action is complet.

Radiation Work Permit Use and Procedura 1 Comp 1 i ance the inspector toured the radiation controlled area with a licensee representative on September 21, 198 During the tour, the inspector noted the improvement in housekeeping in the areas outside and generally exposed to the element Though this area has room for further improvement, the 1 i censee has made progress in cleaning up these areas after the cessation of steam generator related work. In the refurb building, the inspector noticed a worker removing tools from the freon hydrolaze unit. A search for the radiation work permit (RWP) for this task revealed that the RWP was not visible due to being taped to the side of a shelf which faced the wal Review of the RWP (RWP-1318) revealed that it required a full-face respirator be worn when putting tools in, or taking them out, of the freon hydrolaze decontamination uni The above constitute failure to follow proce-dures required by facility technical specification 6.4.D in that the Health Physics Manual (HPM) Section 1.3.5.B states that a standing RWP or Special RWP will have listed the protective measures taken and will be fo 11 owed. Effluent Sampling On September 23, 1981 the inspector accompanied a licensee technician during the routine change of the vent-vent sample media and observed the acquisition of a routine Tritium sampl HPM section 3. requires the vent-vent tritium sample be obtained by attaching a flow meter and impinger to a bypass downstream of the sampling pum The inspector noted that this procedure was incapable of obtaining a representative sample of the tritium concentration in the vent-ven The technician did not follow the approved procedur Neither did the technique used by the technician obtain a representative sampl This is a violation of Technical Specification 6.4.D (280/281/80-25-0l).

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6 Personnel Radioactive Contamination Surveys The inspector observed numerous licensee and contractor workers perform self-survey 1 s (frisk) to d~tect personnel contaminatio A general alertness on the part of the H.P. staff helped detect inadequate frisking in most cases where it was observed by the inspecto How-ever, on September 24, 1981, the inspector observed an individual perform self-decontamination without notifying health physic Health Physics Manual section 1.3.1.G.2 requires individiuals to survey themselves, when leaving potentially contaminated areas. Also, section 1.3.1.G requires individuals who detect personnel contamination to immediately notify Subsequent surveys of the i ndi vi dual performed at the inspector I s request after he left the frisking station/portal monitor revealed this indiv~dual had inadequately frisked and was still contaminate Failure to notify Health Physics.and failure to properly frisk are a violation of Technical Specification 6.4.D (50-281/81-25-0l). Posting of Required Warning Signs, Locks and Barricades

  • During a plant tour on September 21, 1981, the inspector noted that there were no areas outside of the auxiliary building which were not properly poste This was attributed by a licensee representative to the *good practice of daily (or more frequent) tours,of these areas performed by HP supervisory personne One sign was found to have fallen to the ground and was difficult to read, but this was an iso-1 ated aberrant occurrance and is not i ndi cat i ve of a programmatic proble The inspector toured the auxiliary building on September 22, 1981 in the company of a licensee representativ During this tour the inspector measured, and the licensee representative confirmed, that dose rates of 200 millirem per hour (whole body) were present in the vicinity of the process vent filters in the auxiliary buildin The affected area was not posted as required by 10 CFR 20.203(c). This is a violation (280/281/81-25-02). During the auxiliary building tour the inspector observed that the door to the Unit 1 seal water filter room was locked closed with a chain and padloc The licensee subsequently stated that thumb-latch equipped locks were normally provided to permit an individual to leave a locked high radiation area, but the door in question had experienced a lock failure and a replacement lock had been on order for about three months.

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The inspector stated that Technical Specification (T.S.) 6.4. required locks on doors permitting access to areas greater than 1000 millirem per hour and also required administrative controls be estab-lished for issue of keys to enter such area This Technical Specifi-cation provision is in lieu of the more restrictive requirements of 10 CFR 20.203(c)(2)ii However, the provisions of 10 CFR 20.203(c)(3)

still appl This paragraph states that the controls established for locked high radiation areas shall be established in such a way that no individual will be prevented from leaving a high radiation are Although the administrative control (procedure) established for key issue at Surry pl ant requires the use of the "buddy system, 11 the procedure was designed for thumb-latch operated locks and it fails to contemplate the use of padlock Individuals entering a locked area, unless they intend to maintain the door open and under constant survei 11 ance to prevent unauthorized entry, should lock the door behind themselve With thumblatch locks, egress is assured and no key is necessar A padlock, however, would require the use of a key in order for individuals to exi Protective clothing requirements typically mandate two or more pairs of gloves be worn in such areas and the loss of a padlock key is possible.

The use of the "buddy system" could satisfy the requirement for unre-stricted egress, but only if it is specifically required in the applied administrative controls that the function of the 11 buddyl' is to maintain the exit capability by 1) keeping the door open and u~der surveillance while the room is occupied - in accordance with 10 CFR 20.203(c)(4); 2)

staying outside the room within communication distance and having in his possession a spare key to open the doo Neither of these prac-tices is currently required by the licensee's administrative contro The inspector stated that failure to establish controls for locked high radiation area such that individuals are not prevented from leaving the area is a violation of 10 CFR 20.203(c)(3) (280/281/81-25-03).