IR 05000280/1989027

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Insp Repts 50-280/89-27 & 50-281/89-27 on 890911-15.Major Areas Inspected:Review of Licensee Radiation Protection Program Including Followup on Previously Identified Inspector Followup Items
ML18153B942
Person / Time
Site: Surry  Dominion icon.png
Issue date: 09/28/1989
From: Potter J, Shortridge R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18153B941 List:
References
50-280-89-27, 50-281-89-27, NUDOCS 8910260029
Download: ML18153B942 (5)


Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA ST., ATLANTA, GEORGIA 30323 OCT i C !98~

Report Nos.:

50-280/89-27 and 50-281/89-27 Licensee: Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos.:

50-280 and 50-281 Facility Name:

Surry 1 and 2 Inspecto_l

/), Accompanying Approved

. otter, Chief 1989 License Nos.: DPR-32 and DPR-37 Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine, unannounced inspection involved a review of the licensee's radiation protection program including followup on previously identified inspector followup item Results:

The inspector observed continuing progress in health physics performance.* As managements expectati ans are communicated to the technicians, attitude, performance, and moral improve Improvements are still needed in station personnel compliance with radiation protection requirements.

PDR ADOCK 05000280 8910260029 891010 f.*-

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REPORT DETAILS Persons Contacted Licensee Employees

  • R. Bilyeu, Engineer, Licensing
  • W. Cook, Operations Supervisor, Health Physics
  • D. Erickson, S~perintendent, Health Physics
  • E. Grecheck, Assistant Station Manager, Nuclear Safety and Licensing
  • D. Hart, Supervisor, Quality Assurance
  • M. Kansler, Station Manager
  • L. Mor.ris, Supervisor, Health Physics
  • F. Thomasson, Supervisor, Corporate Health Physics Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, and administrative personne Nuclear Regulatory Commission
  • W. Holland, Senior Resident Inspector
  • Attended exit interview Occupational Exposure (83750) Training and Qualification In the past year Surry has experienced an i nord i na te number of violations of regulatory requirements that could be directly attributed to the performance of health physics (HP) supervision and technician The inspector conducted interviews with five HP technicians representing day and night shifts. Questions were asked that related to required reading material for the past six weeks and questions from recent HP continuous training classe Based on HP technician answers, the inspector determined that HP technician knowledge of radiological industry events and knowledge of some areas regarding basic HP requirements needs improvemen The inspector discussed this with the Superintendent of Health Physic,

In interviews with the HP training specialist and manager of training, the inspector learned that, of the approximately 500 tasks on the industry-wide tasks list for HP technician performance based training, the licensee had selected 320 task The inspector reviewed the training matrix and noted that the knowledge and skills associated with tasks were cross referenced and tracked through cl ass room training, lesson pl ans, examinations, and on-the-job trainin Licensee representatives stated that they did not offer any laboratory modules for HP technicians but that they were being

  • considered for inclusion into the performance based training progra Four HP instructors and 11 on-the-job training evaluators were*

responsible for providing training to HP technicians in accordance with their accredited training progra Two successive inspection reports have identified weaknesses with respect to workers complying with station HP requirements when working in radiologically controlled areas (RCAs) of the plan To improve worker compliance with HP requirements and first line supervisor accountabi 1 i ty for assigned personnel, the 1 i censee is providing a workshop on radiological protectio The workshop is specifically for supervisors who have workers that access the RCA and is designed to address changing attitudes and provide an understanding of management 1s standards and expectations of -

supervisor 1s responsibilities for worker radiation protectio The four hour workshop is scheduled for station supervisor attendance from mid-September through mid-December and will have an introduction and surrunary by the Vice President of Nuclear Operation Exposure Control The licensee, in response to a HP performance improvement program (PIP) action item, has stren~thened exposure controls by revising the Radiation Work Permit ( RWP) progra New requirements have restricted verbal or anotated changes to RWPs in the fi~l Now, when changes to radiological requirements are needed a RWP revision is issue ALARA holdpoints are used more frequentl Pre-job ALARA briefing's are now required by RW If the anticipated dose on a job is greater than 1,000 mrem, an ALARA coordinator must attend_the job briefin In practice, the ALARA coordinator has been attending briefings when 500 mrem is the anticipated collective job dos The licensee representatives also stated that by formalizing the RWP program, HP technician performance had improve When interviewed by the inspector, HP technicians stated that RWPs provided clear requirements and not guidelines as in the past. Also, the technician stated that procedure changes and revisions were resulting in requirements that provided a clear baseline for them to operate b HP shift supervisors stated that there are still some complaints from workers on i neons i stent HP requirements between shifts, but that their program was much stronger as a result of formalizing RWP requirements and improved HP procedure In reviewing procedures, the inspector noted that the requirement for posting an area for potential airborne contamination, using loose surface contamination as a criteria, was 400,000 dpm/100 cm 2 *

When

  • interviewed, RWP writers and HP shift supervisors all stated that this criteria was too high and that they would post an area as a potential airborne contamination area at lower levels; however, each used a different loose surface contamination leve The inspector pointed out the differing policy and practices to the HP Operations Supervisor and Superintendent of Health Physic Both licensee

representatives agreed with the inspector's comment and stated that the requirement would be revised downwar The inspector noted during reviews of record keeping by HP technicians that technician performance in this area had improved measurabl Also, the inspector noted that the morale and attitude of the HP technicians was better than in previous year The inspector attributed these to program improvements and new licensee managemen During tours of the auxiliary building, the inspector examined radiation levels and contamination survey results as posted by the license When compared, the inspector measurements were in agreement with licensee posting The inspector reviewed RWPs for appropriate radiological job protection requirements and monitored the area for unlocked high radiation gate/doors and personnel compliance with high radiation area access requirement No discrepancies were note Maintaining Dose ALARA The inspector reviewed. the licensee's program for maintaining radiation dose to workers ALAR Through August, the licensee had acquired 750 person-rem collective dos The licensee has had Unit 1 in an outage from September 1988 through_June 1989, and Unit 2 in an*

outage from September 1988 through August 198 During the inspection, Unit 2 was moving to hot shutdown* and anticipated criticalit While the scope of work performed during both outages could not be quantified or compared to previous outages, it appeared to the inspector that* Surry is improving in dose reductio The licensee now manages collective dose based on dose estimates for specific jobs* instead of managing dose on a daily outage or routine*

day goa In discussions with the ALARA coordinator and staff, the inspector learned that the appointment of a new chairman to the station ALARA committee and new station and program management changes had resulted in improved management parti ci pati on -in the ALARA progra Al so, that worker attitude changes toward, and department participation in, the ALARA program were increasing dail The licensee representatives stated * that the formalization and improvements in the RWP program better communicated ALARA requirements to the worke A second sheet of the RWP contains dose reduction methods for the specifi~ job and is required at the job site with the RW The ALARA coordinator stated that job dose estimates submitted by departments, unnecessary dose due to surveys for RWPs that were never worked, and attendance at post job debriefings had been a problem in the past, but improvements were being mad Also, noted was that their work space was too restrictive, but plans were under way to move to a larger office spac Licensee ALARA representatives stated that the station goal for 1989 was 502 person-rem but that the length

',*

  • of the outage had caused the goal overru Al so, an additional 40 person-rem was in the approval circuit to reclaim approximately 3,300 ft 2 of contaminated area in the RC The inspector discussed the station's leak identification _and repatr program with the cognizant HP supervisor and ALARA staff. The program continues to be aggressive and is considered a program strengt The contaminated area of the RCA is approximately 17 percen Areas reclaimed are coated with an epoxy paint that provides a very smooth surface and reduces adherence of contaminatio During previous inspections, a need for a procedure requirement to have ALARA coordinators from each station department, who would work full time on dose reduction, was discussed with licensee representative Full time department ALARA coordinators have been assigned by maintenance, operations, and site services departments to tnterface with the station's ALARA staff. However, both the company Radiation Protection Plan and HP procedure 5.4.10, Station ALARA Program, require that dedicated ALARA coordinators be assigned from training, technical services, and power engineering se'rvice The inspector informed the licensee that the assignment of dedicated ALARA department coordinators would be reviewed during subsequent inspections and would be tracked by the NRC as Inspector Followup Item (!FI) 50-280/89-27-01.

No violations or deviations were identifie Exit Interview The inspection scope and findings were summarized on September 15, 1989, with those persons indicated in Paragraph The inspector described the areas inspected and discussed the inspection findings with licensee managemen No dissenting comments were received from the license The licensee did not identify, as proprietary, any of the material provided to, or reviewed by the inspector, during this inspectio Item Number 50-280/89-27-01 Description and Reference IF! - Designation of dedicated department ALARA coordinators (Paragraph 2.c).