IR 05000280/1987003

Insp Repts 50-280/87-03 & 50-281/87-03 on 870209-13. Violations Noted:Failure to Adhere to Radiation Control Procedures,To Comply W/Low Level Radwaste Disposal Facility Agreement State License Conditions & W/Dot Regulations

ML20205Q220
Person / Time
Site:	Surry
Issue date:	03/20/1987
From:	Bassett C, Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205Q116	List: IR 05000280/1987003 ML20205Q112 ML20205Q148
References
50-280-87-03, 50-280-87-3, 50-281-87-03, 50-281-87-3, IEB-78-08, IEB-78-8, IEIN-86-103, IEIN-86-107, IEIN-87-003, IEIN-87-3, NUDOCS 8704030467
Download: ML20205Q220 (16)

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4 42 0, UNITED STATES . i

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o NUCLEAR REGULATORY COMMISSION '

[" o REGION il l

3 j 101 MARIETTA STREET, '

• ATLANTA, GEORGI A 30323

..... MAR 2 41987 Report Nos. 50-280/87-03 and 50-281/87-03 Licensee: Virginia' Electric a'nd Power Company Richmond, VA 23261 Docket Nos.: 50-280 and 50-281 License Nos.: DPR-32 and DPR-37 l

Facility Name: Surry 1 and 2 '

Inspection Conducted: February 9-13, 1987 f

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Inspector: /btM Y W .Date Signed R. E.IWeddingto# ,

bW C. H. Bassett

.3/20/$7 Date Y1gned

Accompanying Personnel: G.' B. Kuzo

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H. C. Bermudez ,

Approved by: - CW *

3h h7 C. M. tosey, Section Chie .

Date Signed Division of Radiation Safety and Safeguards

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SUMMARY Scope: This was a routine, unannounced inspection jn the areas of previous enforcement matters, external exposure control, control of radioactive material, solid wastes, transportation, spent fuel and low level radioactive waste storage facilities and inspector followup of onsite events, IE Bulletins ;

and Notices and allegation Results: Three violations were identified: (1) failure to adhere to radiation control procedures, (2) failure to comply with a low level radioactive waste disposal facility's Agreement State's license conditions, and (3) failure to comply with Department of Transportation regulations for transporting radioactive materia '

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REPORT DETAILS Persons Contacted Licensee Employees

• R. F. Saunders, Station Manager

• H. L. Miller, Assistant Station Manager

• N. E. Clark, Manager, Quality Assurance

• S. P. Sarver, Superintendent, Health Physics

• L. L. Morris, Supervisor, Health Physics

• P. F. Blount, Assistant Supervisor, Health Physics D. Densmore, Assistant Supervisor, Health Physics M. R. Beckham, Assistant Supervisor, Health Physics H. Anglin, Assistant Supervisor, Health Physics R. Morgan, Audit Coordinator Quality Assurance

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J. Artigas, Acting Supervisor, Quality Assurance R. C. Early, ALARA Technician, Health Physics

• D. A. Garber, Health Physicist

• T. Bartlett, Senior Health Physicist, Corporate Staff

• D. Craft, Licensing Coordinator Other licensee employees contacted included technicians, operators, security, and office personne Nuclear Regulatory Commission

• E. Holland, Senior Resident Inspector

• L. E. Nicholson, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on February 13, 1987, with those persons indicated in Paragraph 1 above. The following items were discussed in detail: (1) three apparent violations, one involving failure to comply with a low level radioactive waste disposal facility's Agreement State's license conditions (Paragraph 7), one involving failure to comply with transportation regulations (Paragraph 7), and the other j involving lack of adherence to radiation control procedures with three examples (Paragraphs 5 and 9), and (2) a licensee identified violation dealing with improper skin dose assessments (Paragraph 4). The licensee acknowledged the inspection findings and took no exceptions. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio l l

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3. Licensee Action on Previous Enforcement Matters (Closed) Violation (50-280/86-21-01 and 50-281/86-21-01) Failure to ,

establish adequate procedures for waste characterization. The inspector reviewed the licensee's response dated October 22, 1986, and verified that the corrective actions specified in the response had been take i 4. External Exposure Control and Dosimetry (83724)

! Control of High Radiation Areas Technical Specification (TS) 6.4.B.1 requires the entrance to each !

radiation area in which the intensity of radiation .is greater than l 100 millirem per hour but less than 1,000 millirem per hour be barricaded and conspicuously posted and that the entrance to each ;

radiation area in which the intensity of radiation is equal to or i greater than 1,000 millirem per hour shall be provided with' locked '

barricades to prevent unauthorized entry into these area l During plant tours, the inspector performed independent radiation j surveys, reviewed records of licensee radiation surveys, observed area postings, and checked the security of selected locked high radiation areas. The inspector determined the areas were being i properly controlle No violations or deviations were identifie i

Exposure Limits i l

10 CFR 20.101 requires that the licensee maintain workers' radiation exposure below specified levels and 10 CFR 20.401 requires that i radiation exposure records be maintaine ,

The inspector reviewed the most recent form NRC-5 equivalent record l of licensee exposures and verified that individual quarterly '

exposures were maintained below regulatory limits. The inspector l reviewed the exposure record folders of selected individuals and ;

verified that the folders were complet No violations or deviations were identifie Skin Dose Assessments 10 CFR 20.201(b) requires each licensee to make or cause to be made surveys as may be necessary for the licensee to comply with the regulations and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be presen CFR 20.201(a) defines survey as an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of condition *

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10 CFR 20.101(a) requires that the exposure to the skin of an individual's whole body be maintained below 7.5 Rems per calendar quarte The inspector reviewed the techniques used by the licensee to assess skin dose when skin contamination events occur. The licensee had established a threshold of 250,000 disintegrations per minute (dpm)

on the skin before an assessment was made. Above that level, the licensee completed a dose assessment work sheet which calculated dose based on the activity, time the contamination was on the skin, and a dose factor of 2 X 10-4 millirem per dpr-hour. The inspector determined that the licensee's dose factor was equivalent to a factor of 0.44 Rem / microcurie (uci)-hour. The inspector also determined tnat, based on Loevinger's Equation, an appropriate skin dose factor for Cobalt-60 would be 4.14 Rem /uC1-hour and for Cesium-137 would be 6.418 Rem /uC1-hou Therefore, use of the licensee's dose factor would cause a significant underestimation of skin dose (by approximately a factor of 10 for Cobalt-60 and a factor of 15 for Cesium-137) for two of the primary contaminants in the plan The inspector stated that the licensee's threshold for performing an assessment of 250,000 dpm may be too high depending on the length of time the contamination is on the skin, the contaminant and the person's prior quarterly skin dose. Licensee representatives stated that a procedure revision was being developed by the corporate health physics staff which would include nuclide specific dose factors and lower thresholds for performing dose assessment The inspector discussed the planned procedure revision and determined that, if implemented as was discussed, the change should be adequate to correct the dose assessment problems that had been identified. The inspector reviewed selected records of skin dose assessments

]erformed during 1986 and determined that use of the low dose factor 1ad not caused any of the employees to have received a skin dose in excess of regulatory limits. Failure of the licensee to adequately assess skin dose from contamination was a violation of 10 CFR 20.201(b); however, pursuant to 10 CFR 2. Appendix C.V.A it was determined that a Notice of Violation would not be issued due to licensee self-identification of the problem (50-280/87-03-01 and 50-281/87-03-01).

5. Control of Radioactive Materials and Contamination, Surveys , and Monitoring (83726) Audits The inspector reviewed licensee audits and surveillance audits conducted by the Quality Assurance organization of the licensee's health physics program. The audits and surveillances appeared to be of sufficient depth and scope and the findings were well documente Corrective actions were adequate and timely. The audits were conducted by personnel having experience and training commensurate with the complexities of the areas examined and in accordance with

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the requirements of the licensee's Quality Assurance Department '

Instruction Nuclear, Certification Program for Audit Personnel, No. 2.2, Rev. 2, dated December 15, 198 No violations or deviations were identifie I b. Surveys During plant tours, the inspector examined radiation levels and contamination survey results posted outside several areas and l cubicle The , inspector also reviewed selected Radiation Work Permits (RWPs) controlling general, as well as specific, radiological work. It was noted that the licensee had continued to make progress I in efforts to decontaminate and release areas that have previously l only been accessible by the use of personal protective clothin I No violations or deviations were identified, c. Frisking During tours of the plant, the inspector observed workers exiting contamination control zones to determine if proper frisking was being perfonned. The inspector also observed the use of the personnel contamination monitors (Eber11ne PCM-1As) installed at the exit from the radiological controlled are All frisking observed was done properl In past inspection reports it was noted that there had been an increase in the number of both clothing and skin contamination Through records review and discussions with licensee representatives, it was determined that the number of personnel contaminations had l apparently remained constant or continued to increase in spite of the i ongoing decontamination efforts of the licensee. According to the licensee, this was at least in part attributable to the use of the PCM-1A The high sensitivity of these devices facilitated finding low levels of radioactivity present on a worker's skin or clothing that may not had been detected in the past by frisking alone. Other contributing factors were reported to be the lack of proper training and lack of a method to track repeat violators on a real-time basi As solutions to these problems, the licensee had begun to revise the general employee training (GET) curriculum to allow for more time to be spent on contamination control. Also a computer program was being developed to allow health physics personnel to determine if a person had repeatedly been contaminated. The licensee also indicated that efforts would continue on decontaminating as much area as possible and maintaining the RCA as radiologically clean as possible through surveys, massolin moppings of the floors and requiring people to frisk before going from one floor to another in the Auxiliary Buildin _

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No violations or deviations were identified, d. Laundry Facility The inspector reviewed the operation of the laundry facility used by the licensee to decontaminate personal protective clothing (PCs) and i respirators worn into contaminated areas. The inspector reviewed the l technical manual for the laundry monitor, IRT Technical Manual for Automated Contamination Monitor Model ACM-110 and the calibration

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procedure for the monitor Health Physics Procedure No. HP-3.3.3.28, Calibration of the Automated Contamination Monitor: IRT Model ACM-110, dated June 3, 198 The inspector also observed use of the laundry monitor to survey laundered PCs and witnessed a source check / calibration of the monitor. The monitor was checked by placing a 1.8 millirem per hour Cesium-137 source on the conveyor belt of the monito As the belt moved the source under the scintillation detectors, the gamma radiation was detected and the conveyor belt stopped as programme No violations or deviations were identifie e. Calibration of Instruments Licensee Technical Specification 6.4.B required that radiation control procedures be provided and that the radiation protection program be organized to meet the requirements of 10 CFR 20. TS 6. required that procedures described in 6.4.B be followed. Health !

Physics Procedure No. HP-3.3.3.29, Calibration and Operation of l

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Eberline Model PCM-1A, dated October 9,1986, required that a minimum '

l of five perfonnance checks be made of the PCM-1As within a seven day l l perio The inspector reviewed the calibration and operational records of selected licensee radiation detection instruments. It was noted that during a period between December 22 to December 29, 1986, performance l checks of the four PCM-1A Personnel Contamination Monitors had not

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been mad The individual scheduled to perform these checks had injured his hand and did not report for work during that period. The l licensee indicated that the checks had apparently not been performed by anyone els Failure of the licensee to adhere to radiation control procedures by not performing the required checks on the PCM-1As during the period between December 22 to December 29, 1986, was identified as an apparent violation of TS 6.4.0(50-280/87-03-02and50-281/87-03-02).

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j I 6 l 6. SolidWastes(84722) Manifests 10 CFR 20.311(b) requires that each shipment of radioactive waste to

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a licensed land disposal facility be accompanied by a shipment

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manifest and specifies required entries on the manifest The inspector reviewed selected records of radioactive waste shipments performed during 1986 and verified that the manifests had been properly complete No violations or deviations were identifie Waste Classification 10 CFR 20.311(d)(1) requires that any generating licensee prepare all wastes so that the waste is classified according to 10 CFR 61.5 The licensee used the RADMAN computer code to classify their wast The inspector reviewed the RADMAN Topical Report from Waste 1 Management Group, Inc. and the July 25, 1983, acceptance letter for j the report from the NRC Low Level Waste Licensing Branch. The :

inspector also perfonned independent calculations of waste I classification based on nuclide concentrations listed on selected 1986 shipping papers and verified that the shipments had been 1 properly classifie No violations or deviations were identified, l Waste Stability 10 CFR 20.311(d)(1) requires that any generating licensee prepare all waste so that the waste meets the waste characteristics requirements in 10 CFR 61.5 Technical Specification 6.4.8.2 requires that written procedures shall be established, implemented and maintained covering the Process Control Program implementatio The inspector reviewed the following licensee Process Control Program procedures:  !

- PCP for Incontainer Solidification of Class A Stable, Class B l and C Bead Resin at Maximum Packaging Efficiency, January 7, 1986 i

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- OP 20.4, Resin Waste Solidification, March 21, 1986 i

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Through discussions with licensee representatives and review of selected 1986 shipping records, the inspector determined that shipment preparations had been in conformance with the licensee's Process Control Program.

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No violations or deviations were identifie l 7. Transportation (86721) l Transportation Events

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10 CFR 30.41(c) requires that before transferring byproduct material l to a specific licensee of an Agreement State, the licensee .

transferring the material shall verify that the transferee's license l authorizes the receipt of the type, form, and quantity of byproduct i material to be transferre CFR 71.5.a requires that each licensee who transports licensed j material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport shall comply with the applicable requirements of the Department of i Transportation in 49 CFR Parts 170 through 18 '

On October 24, 1986, the licensee was informed by the State of South Carolina Department of Health and Environmental Control that their Shipment Number 1086-198-A of dewatered resin, packaged in a High Integrity Container (HIC), which was placed inside a Chem-Nuclear 14-195 shielded cask, was found, upon its arrival at the low level radioactive waste disposal site near Barnwell, SC to be in violation of the disposal site's State of South Carolina licens When the HIC was unloaded from the cask, moisture was observed on the bottom of the HIC and bead resin and soil was observed in the bottom of the cask. The noisture and material inside the cask were adsorbed onto paper towels, which were then placed in a plastic bag. Dose rates on the outside of the bag measured to 11 millirem per hou Three smears were also taken inside the cask. The highest measured contaraination level was 135,323 disintegrations per minute per 100 square centimeter In a letter dated October 28, 1986, the licensee was informed by the State of South Carolina that the contaminated resin and soil inside the shipping cask was a violation of two license conditions of the disposal site's license, No. 097, Amendment 4 License Condition 60 prohibited loose radioactive material within shipping casks. License Condition 26 requires advance written notification of any potential hazard, such as excessive removable contamination on disposal containers shipped inside casks. The licensee was assessed a $2,000 civil penalty for the violations by the State of South Carolin I

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Licensee personnel conducted an investigation of the event, which :

included a visit to the disposal _ site on October 27, 1986. The licensee concluded that the problem had likely been caused during the filling of the HIC prior to shipment. When HICs were filled, they were placed inside a shielded enclosure to minimize exposures to radwaste personnel. The floor of the enclosure was found to contain approximately one inch of resin beads which was probably attributable l to spills that had occurred during previous HIC filling Some of the contaminated resin and moisture apparently adhered to the HIC when it was raised from the enclosure and transferred to the shipping cas No inspections, cleaning or contamination surveys of the -

shipping cask internals were performed . prior to ' loading. The i licensee identified that additional controls were needed during resin

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filling to preclude the HIC from coming in contact with contaminated surfaces and that shipping cask interiors should be surveyed and cleaned if necessary prior to us .

The presence of the unpacked radioactive material inside the shipping i cask and the licensee's failure to notify the State in advance of !

this potential hazard was identified as an apparent violation of 10CFR30.41.c(50-280/87-03-03and50-281/87-03-03).

The inspector learned that there had been a second shipment that had been identified as being in noncompliance with Department of Transportation requirements on November 21, 1986, upon its arrival at '

the Barnwell disposal site. The shipment consisted of solidified !

cartridge filters in a HIC and a 14-195-H shipping cask under Control '

Number 1186-295- The inspector reviewed the November 26, 1986, letter from the State of South Carolina Department of Health and Environmental Control which informed the licensee of the problems that had been identified at the disposal site and discussed the event- I with licensee representatives. The shipping cask was posted with a Radioactive Yellow II label. 49 CFR 172.403(q)(2) requires that the blank space on the radioactive label be annotated with the activity of the package expressed in appropriate curie units. The State inspector noted that units had not been entered on the label after the numerical value which represented the activity within the package. It was also noted that the gross weight-of the empty cask was stamped on the outside of the cask, but the combined weight of the cask and contents was not marked on the outside of the cask as required by 49 CFR 172.310(a)(1). The third problem noted by the State inspector was that an " empty" posting was displayed on the

" Drive Safely" sign on the cask trailer. The licensee was cited for a violation of 49 CFR 172.502(a)(2), which prohibits display of a placard described in 49 CFR 172 Subpart F, unless the placard represents a hazard of the material being transported. The inspector determined that a more appropriate reference for the citation would have been 49 CFR 401(a)(2), which prohibits display of a label described in 49 CFR 172 Subpart E, unless the label represents a hazard of the material in the package, since the " Empty" posting is

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described in 49 CFR-172 Subpart E as a label, but is not described in 49 CFR 172 Subpart F as a placar Failure of the licensee to comply with the requirements of the Department of Transportation in regard to the problems discussed above was identified as an apparent violation of 10 CFR 71. (50-280/87-03-04and50-281/87-03-04).

b. Procedures The inspector reviewed the following licensee procedures regarding the transportation of licensed material:

HP 2.7, Control and Accountability of Radioactive Material, April 29, 1986 HP 3.2.22, Radwaste - Packaging and Shipment of Solid Radioactive Waste to Hanford, Washington, October 24, 1985 HP 3,2,25, Spent Fuel Shipping Procedure for Shipments to Idaho National Engineering Laboratory, November 19, 1985 HP 3.2.26, Radwaste Shipments to Scientific Ecology Group, Inc.,

December 8, 1986 The inspector noted that the description of vehicle surveys in the procedures appeared to be incomplete. 49 CFR 173.441(b)(2) required that radiation levels at any point on the outer surface of exclusive use vehicles, including the top and undersidt of the vehicle, must not exceed 200 millirem per hour during transportatio CFR 173.475(1) requires that before each shipment of any radioactive materials package, the shipper shall ensure by examination or appropriate tests, that external radiation levels are within allowable limits. The inspector noted that the shipping procedures did not require the tops of exclusive use closed transport vehicles be surveyed prior to transport. The inspector identified I that no surveys of the top outer surfaces of the transport vehicles were perfonned for Radioactive Material Shipments SEG-3 on December 17, 1986, and SH-1987-003 on February 8, 1987. Failure of the licensee to perform these vehicle surveys prior to transport was identified as another example of an apparent violation of 10CFR71.5.a(50-280/87-03-04and50-281/87-03-04).

c. Shipping Papers 49 CFR 172.202 and 49 CFR 172.203 specify the requirements for I radioactive material shipping paper l 10 CFR 20.401(c)(1) and 10 CFR 30.51(c)(3) requires that records of disposal of licensed radioactive material and transfer of byproduct material be maintained.

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The inspector reviewed selected records of radioactive material shipments performed during 1986 and the first quarter of 1987. The

inspector determined that the shipping papers had been completed

consistent with regulatory requirements and were being properly maintained.

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No violations or deviations were identifie Staffing The inspector reviewed the staffing and experience . level of. the

personnel assigned to the licensee's Radwaste Section. The Section.

was supervised by an Assistant Health Physics Supervisor who reported i directly to the Health Physics Supervisor. ~ Two technicians .were i

assigned to the Section and two technicians were in trainin The training program consisted of classroom and practical training.over

an 18-month period. Three contractor personnel were also _ assigned j and were responsible for operation of the solid waste box compacto The inspector determined that the staffing of the Radwaste Section i was adequate.

I i No violations or deviations were identified.

i j Special Nuclear Material Shipment Records

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10 CFR 70.51(b)(5) requires ' that records of transfer of special nuclear material be maintained.

10 CFR 70.54(a) requires that each licensee who transfers special nuclear material complete a Nuclear Material Transaction Report on i DOE /NRC Fom 741.

The inspector reviewed the record of a special nuclear material shipment that had been made on December 13, 1985, to the Idaho 4 National Engineering Laboratory under Control Number SH-1985-18 The inspector noted that the record did not contain a copy of DOE /NRC Form-74 Licensee representatives stated that the forms were j maintained at the corporate office. The licensee obtained the forms j and they were reviewed by the inspector and determined to be acceptable. Licensee representatives stated that the Form-741s would be posted to the special nuclear material shipment records.

i I No violations or deviations were identified.

I i Inspection of Dry Storage of Spent Nuclear Fuel (TI 0110/2)

i l (Closed)SFS(50-280/87-FRP-01and50-281/87-FRP-01)

On July 2, 1986, the licensee received License No. SNM-2501 to store spent '

fuel in casks at the Surry Independent Spent Fuel Storage Installation (ISFSI). The ISFSI was constructed in a vacant area adjacent to the

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i low-level radioactive waste storage facilit The ISFSI was located within a fenced, restricted area, and another chain-link fence was erected

, around the storage pad to further restrict access for safeguards and j radiation protection control.

The inspector reviewed the Periodic Test Procedure, PT-58.3, Independent

Spent Fuel Storage Installation (ISFSI) Radiological Surveillance, dated

September 12, 1986, and related surveys of the loaded casks. The- Surry

ISFSI Safety Analysis Report (SAR) and Technical Specification were also

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reviewe TS 4.2.2 states that the dose rates were to be within those listed in the SAR. Section 7.3.2.1 of the SAR specifies that dose rates

on the side surfaces of the cask must be less than or equal to 24 millirem

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per hour (mr/hr) neutron and less than or equal to 67 mr/hr- gamm Surface contamination levels less than or equal .to one thousand

disintegrations per minute per one hundred square centimeters (dpm/100 cm2) were also specified. During an inspection of the ISFSI area, the inspector, using NRC and licensee equipment, verified that the

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radiation and contamination levels were below the limits. The highest neutron dose rate measund at contact with the side ' of the cask was j 8 mr/hr and the highest ganna dose rate was 8 mr/hr. The highest dose i rates two meters from the cask were 2 mr/hr neutron and 1 mr/hr ganna, j All smears taken measured less than 1000 dpm/100 cm2.- A gamma survey was j also conducted along the perimeter of the inner access fence. The highest

, dose rate measured at the perimeter was 0.8 mr/hr.

, Control of the area was also observed during inspection of the ISFSI area.

j Entrance inside the access fence required.both Security and Health Physics

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personnel and TLDs were also required for entry. Inside the fenced area, an area extending approximately 20 feet out from the loaded casks was

i barriered off to prevent inadvertent exposure to neutron _ radiation. Prior

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to entry into the neutron barrier, health physics personnel were required

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to perfonn a detailed neutron radiation ' survey of the loaded casks to

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establish dose rates for different zones around the casks. Personnel could then enter the barrier after being signed into the area. A health

physics technician kept track of personal stay times in the various zones

! to provide an overall neutron dose assessment by multiplying the dose rate by the time spent by each person in each specific zon No violations or deviations were identified.

k 9. Low-Level Radioactive Waste Storage Facility (65051)

The inspector Low-Level reviewed Radioactive the op(erational Waste procedures LLRW) storage facilityand andstatus of the discussed procedures for transferring waste to the facility with licensee personne The storage facility was located within a fenced, restricted area about

one mile from the main plant. It had been in operation for about six 1 years and, at the time of the inspection, was used to store drums and boxes of LLR >.

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Q Because of the location of the LLRW facility, the licensee stated that waste containers generated at the plant had to be loaded on a truck and transported to the storage area. The transit route was entirely on owner-controlled property and waste shipments were only made under= the-cognizance and control of an* American. National Standards Institute (ANSI)

qualified health physics technician. The technician was responsible for following the shipment and surveying the LLRW facility upon completion of the waste transfe Technical Specification 6.4.0 required thht radiation control procedures be followe Health Physics Procedure No. HP-3.2.18, Temporary Low Level Waste Storage Facility, dated April 29, 1986, required that an inventory of the material in the LLRW storage facility be conducted at least once a quarter and be documented in the log. The procedure also required daily routine surveys to be performed of the building and the perimeter when material was moved in or out of the building and weekly if no material was transferre The inspector reviewed the LLRW facility inventory log which documented movement of containers into and out of the storage area and reviewed survey maps of the facility. It was noted that a quarterly inventory of all material in the LLRW facility had been documented in the inventory log in April and July of 1986 but no further inventories were noted for 1986 and, as of February 11, 1987, none had been documented for 198 Inspection of the surveys performed in the facility during the period from January 1 through February 11, 1987, showed that no dose rates were documented inside the building and snears had been taken on only two occasion )

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Failure of the licensee to follow radiation control procedures by not documenting two quarterly inventories in the log book and not completing the required surveys of the LLRW building and the perimeter from January 1 through February 11, 1987, were identified as two additional examples of an apparent violation of TS 6.4.D (50-280/87-03-02 and 50-281/87-03-02). l 11. FollowuponIEBulletins(9$703)

l (Closed)BUL(50-280/87-FRP-02and50-281/87-FRP-02)

On April 5,1978, two radiation protection technicians at Portland General Electric Company's Trojan Nuclear' Power Plant received whole body l radiation doses of 27.3 and 17.1 rem while performing a survey adjacent to l an exposed section of the fuel element transfer tube during the plant's '

first refueling outage. As a result, the NRC issued IE Bulletin 78-08, Radiation Levels from Fuel Element Transfer Tubes, dated June 12, 197 The bulletin required licensees to perform a review of shielding design of plant areas adjacent to fuel transfer tubes to identify potential high radiation areas, both continuous and transient, assure positive control of the areas, conduct special surveys and provide a written response of the findings and actions to resolve any problems to the NR ;

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n In a response dated August 14, 1978, to IE Bulletin 78-08, the licensee

- stated that. all; areas where a whole body dose of 100 mrem could. be-received during the movement of a- single fuel element would be locke During subsequent inspections, the licensee also indicated that consideration would be given to installing additional shielding-to.those areas to reduce localized high levels of radiation streaming through gaps between the shield blocks and containment wall The inspector reviewed licensee actions on these matters.

, 'The licensee stated that the ~ areas where radiation streaming was noted -

were not locked, but access-to the area was administratively controlled.

L Provisions to lock the areas were not made due to three factors:

(1) after measuring the dose rates in the areas where streaming was-occurring and measuring the time these dose rates were present, it was considered highly improbable that a person, even if allowed to remain in the area for an hour during various fuel transfers, would receive a whole body dose of -100 mrem, (2) it was not ' cost effective to construct barricades and gates that would only be used for a period of a few days every refueling outage (approximately every 18 months) and (3) the administrative controls established during fuel transfers were considered to be adequate protection for facility personnel. These administrative controls consisted of placing a barrier rope across predetermined access '

routes, posting a. health physics technician with a radiation survey mete .

in the area to monitor radiation levels and directly control access to the

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identified areas of radiation streaming. With regard to shielding, the licensee stated that installation of additional shielding would not be practical due to the building expansion joint from which the streaming was coming. Also the administrative controls were again cited as sufficient to prevent overexposure problems and therefore preclude the' need for additional shielding. The inspector agreed with the findings and actions

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of the licensee and determined that the actions were apparently adequate to preclude exposure problems.

No violations or deviations were identified.

11. Onsite Followup of Events of Operating Power Reactors (93702)

The inspector reviewed the health physics aspects of a rod drop accident which occurred in Unit 1 on September 18, 1986. As a result of this problem, health physics (HP) technicians and electricians were required to i make entries into the Unit I containment building while the reactor i remained at powe The inspector reviewed the exposure records of those involved in the entries and the survey records of the reactor head work area. The HP technicians covering the work received doses of 353 millirem (mrem) neutron and 25 mrem gamma and the electricians received a neutron dose of'251 mr. A review of the RWPs and control measures implemented to govern the work indicated that the radiological controls had been adequate

. and in accordance with licensee procedures and applicable regulatory requirements.

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l 12. Followup on Allegations

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. Allegation (RII-86-A-0167)

Due to the cramped working conditions involved in work being done on the steam generator repair, a worker must crawl into the generator and work while laying on his stomach. Although a radiation survey showed a radiation field of 4-20 mrem, there are hot spots in the generator running up to 200 mrem. Workers have been issued a single TLD which is worn on the upper left chest. Multi-dosimetry should be used to ensure radiation from hot spots is recorded. A contractor work group technician made statements that reflect a casual attitude regarding ALARA practice Discussion The inspector discussed licensee criteria for issuing multiple TLDs with licensee health physics personnel, who stated that the criteria was that the general radiation levels in the work area must be greater than or equal to 100 millirem per hour and that the expected exposure gradient near other whole body locations be at least 50 percent higher than that being measured by the chest TLD. The work described in the allegation did not meet the licensee's criteria for issuing multiple TLD Finding The inspector determined that the licensee's criteria was acceptabl In regard to the statement made by the contractor technician, worker exposures were controlled below NRC regulatory limits by licensee administrative practices and health physics personnel. The allegers j quarterly exposure of 700 millirem was well below the NRC limit of

3,000 millirem per quarter stated in 10 CFR 20.10 I

The allegation was substantiated in that the statements made by the l alleger were essentially factual, however, no violation of or deviation from regulatory requirements were identified.

1 i j Allegation (RII-86-A-0168)

The refueling outage at Surry is a mess and the plant is filthy with contamination. Workers are threatened that if they get contaminated they will be fired. Workers are afraid to contact NRC for fear of i losing their jobs if they do so. Workers are wiping off " hot spots"

before leaving the contaminated area The change room is contaminate Workers are remaining in radiation areas even though they do no have work to do.

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Discussion The inspector reviewed the licensee's written response to this allegation to Region II, dated January 23, 1987. The licensee did not substantiate any of the concern Through discussions with licensee representatives and observation of activities in progress, the inspector determined that the licensee's investigation of these concerns had been adequate and that the findings reported to Region II were accurat Finding ( .The allegation was not substantiate No violations or deviations were identified, Allegation (RII-86-A-0124)

A named individual had intentionally turned off a radiation alarm in the emergency switch gear room in March 1986, and disciplinary action had been taken against the individual. The alleger was concerned the individual may repeat this action in the future and endanger worker's safet Discussion The inspector discussed this allegation with licensee representatives. The inspector determined that there had been no i

instances of workers turning off alarms inappropriately to the best of the licensee's knowledge since the March 1986 even Finding The allegation was not substantiate No violations or deviations were identifie . IE Information Notices (IEN) (92727)

l The inspector determined that the following information notices had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that actions, as appropriate, were taken or schedule IEN 86-103: Respirator Coupling Nut Assembly Failures IEN 86-107: Entry Into PWR Cavity with Retractable Incore Detector 1 Thimbles Withdrawn l

IEN 87-03: Segregation of Hazardous and Low-Level Radioactive Wastes l

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