IR 05000280/1981030
| ML18139B722 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/25/1981 |
| From: | Franklin L, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18139B718 | List: |
| References | |
| 50-280-81-30, 50-281-81-30, NUDOCS 8202050378 | |
| Download: ML18139B722 (9) | |
Text
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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. 50-280/81-30 and 50-281/81-30 Licensee:
Virginia Electric and Power Company Richmond, VA 23261 Facility Name:
Surry Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37 Inspection Virginia Inspector:~~~~~'..-='-,--V---4~~~'.J-------------~
.fov App roved by-,,,: c_it-U6<~~.l.__j~~~'4----c------~------
C M. Hosey, Acing Section Chief echnical Inspection Branch Engineering and Technical Inspection Division SUMMARY Inspection on October 26 - 30, 1981 Areas Inspected D te Signed u/zrfj_J Signed This routine, unannounced inspection involved 32 inspector-hours on site in the areas of radiological protection procedures, training, exposure control, posting, labeling and control, and previously identified item Results Of the five areas inspected, no violations or deviations were identified in four areas; one violation of NRC requirements was found in one area (Improper posting of a radiation area).
8202050378 820126 r--
PDR ADOCK 05000280
- G PDR
- REPORT DETAILS Persons Contacted Licensee Employees
- J. L. Wilson, Station Manager
- R. F. Saunders, Assistant Station Manager
- S. P. *sarver, Health Physics Supervisor P. Nottingham, Assistant Health Physics Supervisor J. Peterson, Operations Coordinator
- D. A. Christian, Superintendent, Technical Services
- D. H. Rickeard, SES
- 0. J. Costello, Staff Assistant 0. Vogtsberger, Nuclear Training Coordinator e
Other licensee employees contacted included four technician NRC Resident Inspector
- 0. J. Burke
- Attended exit interview
- Exit Interview The inspection scope and findings were summarized on October 30, 1981 with those persons indicated in paragraph 1 abov Items discussed included one violation (failure *to post a radiation area) and the status of several previously identified item The Station Manager acknowledged the vio-latio.
Licensee Action on Previous Inspection Findings Closed (50-280/79-18-02) (50-281/79-26-02) Violation - Failure to take adequate survey This violation dealt with surveys not being repre-sentative of activity released each time the subsurface drain system was automatically pumped ou The licensee procedure (Periodic Test Number 38.21) has been revised and samples are now taken dail The inspector reviewed the revised procedure and had no further question Closed (50-280/79-18-04) (50-281/79-26-04) Unresolved Item - Fit test for respirator This item concerned the practice of allowing a respirator fit test by a previous employer to suffice as documented training by the license This practice is no longer employe All personnel subject to respirator usage are now fit tested by the licensee. This procedure is incorporated in the licensee 1 s Respiratory Protection Manual (Procedure RAM-6).
The procedure was reviewed by the inspector and appears adequat *
e 2 Closed (50-281/79-20-0l) Violation -
Failure to follow RW This
.violation concerned the failure of personnel to follow the instructions detailed on a specific radiation work permit (RWP).
The licensee has established minimum guidelines (Procedure HPA-4.14) concerning contain-ment responsibilities for health physics job coverag The inspector reviewed this procedure and had no further question Closed (50-281/79-20-02) Violation - Failure to keep records of effort to obtain dose histories. This violation concerned the practice used to determine previous exposure of personne Revised Procedure HP-3.1.2 now establishes a satisfactory method for obtaining dose histories. The inspector had no further question Closed (50-281/79-20-03) Deviation - Failure to follow ALARA commit-ments. This item was closed in conjunction with 50-281/79-20-02. The inspector had no further question Closed (50-280/79-24-01)
(50-281/79-42-01) Violation -
Failure to follow standing radiation work permit directions. This item is closed in conjunction with 50-281/79-20-0 In addition, a procedure (Admin-istrative Procedure 19.0) for the administration of disciplinary action is in effect for personnel failing to follow instruction The inspector had no further questions.
Closed (50-281/79-26-01) Violation - Failure to follow procedures for testing tents. This entire Procedure (HP-SGRP-10) was cancelled due to the completjon of the steam generator replacement wor However, tents are still in use for other wor A licensee representative stated that this procedure will be included in the Health Physics Manua Closed (50-280/79-32-03) (50-79-50-03) Unresolved -
RWP system effec-tiveness. This item is closed in conjunction with 50-281/79-20-01 and 50-280/79-24-01. After review of procedures HPA-4.14 and Administra-tive Procedure 19.0, the inspector had no further question Closed (50-280/79-49-0l) (50-281/79-69-0l) Unresolved - Beta dose rate surveys. At the time this item was opened the licensee did not perform beta dose rate survey This item has been resolved by licensee Procedure HP 3.3.1, Part 4.4 which provides for the beta dose rate survey This procedure was reviewed by the inspector and appears adequate. The inspector had no further question Closed (50-280/79-49-02) (50-281/79-69-02) Unresolved - Assessment of workers exposur The inspector reviewed the assessment performed by the license Dose calculation methods were conservative and appeared adequate. The inspector had no further questions.
3 Closed (50-280/80-16-0l) (50-281/80-17-0l) Violation - Radwaste ship~
ment with truck surface radiation levels in excess of DOT limits. The licensee has instituted a training program for health physics personnel dealing exclusively with radwaste handling, surveying containers, preparation of shipping papers, et The inspector reviewed the course content and reviewed records of classes presented on May 2 0, 19 81, May 2 7, 19 81, June 2 4, 19 81, June 3 0, 19 81, and July 21, 198 Of the five classes reviewed, attendees included eighteen health physics technicians and one assistant health physics superviso This is mandatory training for health physics technicians and supervisors. This training appears adequat The inspector had no further question Closed (50-280/80-16-02) (50-281/80-17-02) Violation -
Inadequate survey of radwaste shipment vehicl This item is closed in con-junction with 50-280/80-16-01 and 50-281/80-17-0 Closed (50-280/79-09-04) (50-281/79-10-04) Unresolved item -
Locking high radiation area in containmen This item concerned the inability of a guard,. posted at the entrance to containment, to exercise control over high radiation areas inside of the containment buildin Entries to containment are now covered by licensee Procedure HPA-4.14, and require continuous coverage by health physics personnel. This proce-dure was reviewed by the inspector and appears adequat The inspector had no further question * Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tion One new unresolved item identified during this inspection is discussed in the following paragrap The old drumming station, located in the auxiliary building 27 1 level, is now utilized as a radwaste sorting are Bags of radioactive waste are brought to this area previously marked as containing no more than 5000 0/M/100cm2 activit These bags are cut open and reclaimable material is remove The remaining contents are eventually compacte Air sampling is not continuous in this area and no respiratory protec-tion is employed by the person sorting this wast The air flow is from the sort area to a 11 cl ean 11 area of the auxiliary buildin The inspector stated that this work has the potential of being in violation of 10 CFR 20.103 and 10 CFR 20.201(b).
The inspector requested the licensee review this work procedure (280/281/81-30-02). Licensee Action on Previous Inspector Identified Items Closed (50-280/78-02-06) (50-281/78-02-06)
IFI -
Respirator room procedure The inspector toured the areas for the cleaning, issuance, and inspections of respirators. In addition, a tour was made of both
. *.
e
areas used for fit testin A general rev1s1on was made to the licensee Respiratory Protection Manual during June and July 1978. This manual was reviewed by the inspector and appears adequate with minor exceptions which are noted in paragr,i'ph 10 of this repor The inspector had no further question Closed (50-280/78-17-06) (50-281/78-27-06) IFI -
E-bar determinatio Licensee Technical Specification 3.1.0 was revised February 10, 198 This revision specifies nuclides with greater than 15-minute half-lives will be included in the E-bar determinatio Iodines are not included in this determinatio Licensee Chemistry Procedure 41 was revised April 17, 1980, to meet the technical specification chang These procedures were reviewed and appear adequat The inspector had no further question Closed (50-280/79-FI-04) IFI -
Followup of IE Bulletin Number 79-19; Packaging of Low Level Radioactive Wast The licensee responded to this Bulletin, by letter, September 27, 197 This response was reviewed by the inspector and appears adequat This item is closed in conjunction with 50-:-280/80-16-0 The inspector had no further question d.
Closed (50-280/79-09-07) (50-281/79-10-07) IFI - Use of Isoamyl-acetate for respirator fit test This item concerned the exposure of personnel, awaiting fit tests, to the odor of Isoamyl-acetate prior to the fit test. The licensee purchased a fitting booth employing sodium chloride and this unit, at present, is used exclusivel The old unit which employed I soamyl -acetate is in a standby condition for use during emergencies onl It is located in a different building and engi-neering controls have been installed to remove the odor in the waiting area. The inspector had no further question Closed (50-281/79-15-01) IFI - Special and/or extremity dosimetry. The inspector reviewed procedure changes in the licensee 1 s Health Physics Manual and in Procedures HP-3.1.3 and HP-3. These procedures appear adequate. The inspector had no further question Closed (50-280/79-16-02)
(50-281/79-24-02)
IFI -
Preparation of shipping paper This item is closed in conjunction with 50-280/
80-16-01 and 50-281/80-17-0 Closed (50-280/79-16-03) (50-281/79-24-03) IFI - Review of radioactive material storag The inspector toured this area and determined that separate storage of oil is now in effect. It was noted that while a sma 11 number of packages stored had deteriorated wrapping, these packages were confined to an area of extremely low level waste and that this is not tolerated in most area The inspector had no further questions.
- * Closed (50-280/79-18-05 (50-281/79-26-05) IFI -
Testing of vacuum cleaner The licensee has institited a routine practice of visually inspecting vacuum cleaners for damage, and air sampling is performed continuously while vacuum cleaners are in us The inspector had no further question Closed (50-280/79-18-06) (50-281/79-26-06) IFI - Control of yellow polyethylene bottles. This area of concern is a discontinued practice and the steam generator replacement Health Physics Manual is no longer in effect. The inspector had no further question Closed (50-280/79-18-07) (50-281/79-26-07) IFI - Reduction of radwast The licensee has introduced this subject into training given to all employee In addition, the inspectors noted signs at various areas reminding employees of the importance of radwaste reductio The inspector had no further question Closed (50-280/79-49-03)
(50-281/79-69-03)
IFI -
Calculations of activity in resin liner The incorporation of radwaste procedures into one procedure was accomplished August 1, 1979. This procedure has been revised several times to keep pace with regulatory requirements
~nd contains an acceptable method of determining curie content for 60 cubic foot resin liners. The inspector had no further questions.
Radiological Protection Procedures The inspector reviewed selected procedures that have been revised since the last inspectio Procedures reviewed included licensee Procedure HP-3. titled 11 Personnel Dosimetry -
Dosimeter Issue and Dose Determination 11,
Procedure HP-3.3.l titled 11 Health Physics Survey-Station 1i, Procedure HP-3.1.2 titled 11 Personnel Dosimetry - Personnel Dosimetry Control, Records, and Reports 11, Procedure HP-3.2.9 titled 11 Packaging and Shipment of Solid Radioactive Waste 11, Procedure HPA-4.14 titled 11 Number 1 and 2 Containment Responsibilities 11, and Procedure titled 11 Violation of Radiation Protection Manual 11 *
These procedures appear adequate and the inspector had no further question.
Training Technician trainees enter a training program that runs for four year The program is broken down to six-month steps and a trainee must pass an examination after each step in order to qualify and continue in the progra The inspector reviewed the course outline and individual qualification sheets. The course appears adequat In addition to the above,* bi-monthly training is given to health physicists, assistant health physics supervisors, and health physics technician This training is mandator Memorandums are sent to supervisors for individuals missing a training session and the
e
individual must make up this particular sessio The course outlines are varied and a number of sessions have been devoted to reactor systems and operatio The bi-monthly training was initiated on January 1, 198 The inspector examined training records *for the period January 1, 1981 to August 198 The inspector had no furthe question A 11 licensee employees must complete a one-day general employee training cours This training course is basic and includes theory, radiation dose limits, radiation protection, dosimetry, control of contamination, emergency procedures, legal aspects, security, et Upon completion of the basic course, employees are required to complete an additional 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of training in respiratory protection, contain-ment entry procedures, first aid, quality control, emergency proce-dures, fire protection, etc. The inspector examined the course content of these varied training subjects and they appear to be adequat The inspector had no further question.
Exposure Contra l The inspector reviewed the exposure control system in use at this tim The system is a manual system and employs the use of a dose record card for each employe Entry to the radiation control area (RCA) is maintained by the use of a contra l point manned by a heal th physics technicia Radiation work permits are posted at this control point and are numbere Any entry to the RCA must be made on a specific RWP and a dosimeter is requir.e Workers making an entry must obtain a dosimeter from a health physics clerk and state the RWP numbe The clerk notes the individual 1s entry on that person 1 s dose car This card states training records, available exposure, et Upon exiting the RCA the dosimeter must be returned by the worker and the dose card is updated at that tim In this manner an up to the minute dose history is maintained for workers and RWP A computerized system has been installed by the licensee and is nearly ready for us The basic system will remain, however, records availability will be improved and the system will be much faste Selected exposure records were reviewed by the inspector to determine compliance with 10 CFR 20.. lOl(b).
NRC-4 forms were on record for all individual files examined. The inspector had no further question.
Posting, Labeling, and Control The inspector toured portions of the RCA on three separate occasions during the inspectio During these tours the inspector noted one violation of 10 CFR 20.203(b).
The inspector also noted three instances of failure to store radioactive waste properl (1)
Approximately six 55-gallon drums containing radioactive waste oil were stored in a zone marked 11 Radioactive Materials Area 1 Upon examination of these drums, it was determined that one drum was
- reading 40 mrem/hr at contact and 10 mrem/hr at 18 inche This area was improperly zoned and should have been posted as a radia-tion area. This is a violation of 10 CFR 20.203(b) 280/281/81-30-01).
10 CFR 20.202(b)(2) states that a Radiation Area is any area, accessible to personnel, in which there exists radiation, originating in whole or in part within licensed material, at such levels that a major portion of the body could receive in any one hour a dose in excess of 5 millirem, or in any 5 conse~utive days a dose in excess of 100 millirem (2)
On two occasions radioactive waste was left in the RCA yard area, wrapped and marked, but not contained within a zoned area posted as a*
11 Radioactive Materials Area 11 *
One entire concrete storage pad contained several 55-gallon drums of radwaste, plus several packages, wrapped and tagged as rad-waste. The storage pad was not posted as a 11 Radioactive Materials Area 11 *
In both examples noted above, the area background radiation levels were approximately 0.7 mrem/hr and it did not appear that these items exceeded 10 CFR 20, Appendix C quantitie Licensee repre-sentatives were however informed that storage areas for radio-active material should be poste Other areas within the RCA including the auxiliary.building were toured and although no violations or deviations were identified, one practice employed by the licensee appeared questionabl The old drumming station located in the auxiliary building 27 1 level, is now ut1lized as a radwaste sorting are Bags of radioactive waste are brought to this area and are previously marked as containing no more than 5000 d/m/100cm 2 activity. These bags are cut open and reclaimable material is remove The remaining contents are then thrown into a box for eventual compaction. Air sampling is not continuous in this area and no respiratory protection is employed by the person sorting this wast The air flow is from the sort area to a 11clean 11 area of the auxiliary buildin The inspector requested the licensee review this work procedure (280/281/81-30-02).
1 Respiratory Program The inspector evaluated the licensee 1 s respiratory protection program as it pertained to air sampling, use of engineering controls, and incorporation of the requirements of 10 CFR 20.103 and recommendations of both Regulatory Gui de 8.15 and NUREG-0.04 The 1 i cen see I s Respiratory Protection Manua 1 was reviewed by the inspector and appears adequate, with minor exceptions, which are noted below. Air sample data for the period August 1981 *to October 1981 was reviewed and appears adequate.
The inspector noted that supplied air belt regulators are used by the license The licensee was asked if records are maintained for certifi-cation of these regulator The inspector was informed that these records are not maintaine NUREG-0041 10.1.2.2 states 11 supplied air regulators shall be visually inspected for damage, attached to an appropriate air supply, and tested for proper functio If a factory-trained repair tech-nician and factory approved test equipment are available, it is advisable to test the regulator functio Otherwise, the regulator is to be returned to the factory at least every 3 years for repa.ir and* inspection.
A licensee representative said he felt that these regulators were properly disposed of within three years of purchase but had no way of determining that this was true in every cas The inspector stated that the licensee should devise a method of assuring that this was done or that the regulators be certified as required (280/281/81-30-03).
The inspector reviewed records maintained on supplied air manifold These records do not provide accountability nor do they contain any record of filter change NUREG-0041 9.2(a) states 11 components of respiratory protec-tive devices must be changed on a replacement schedule as required by conditions of us In no case may replacement time exceed the time recom-mended by the manufacturer.
The inspector stated that the licensee should follow the manufacturer's recommendations regarding these manifolds and take appropriate action to ensure that air manifolds are properly maintained (280/281/81-30-04).