IR 05000280/1990003

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Insp Repts 50-280/90-03 & 50-281/90-03 on 900212-16.No Violations or Deviations Noted.Major Areas Inspected:Review of Licensee Radiation Protection Program,Including Followup on Previously Identified Inspector Followup Items
ML18153C181
Person / Time
Site: Surry  Dominion icon.png
Issue date: 04/02/1990
From: Potter J, Shortridge R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18153C180 List:
References
50-280-90-03, 50-280-90-3, 50-281-90-03, 50-281-90-3, NUDOCS 9004170209
Download: ML18153C181 (8)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, ATLANTA, GEORGIA 30323

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ReportQNos.:

50-280/90-03 an9 50-281/90-03 Licensee:

Virginia Electric and Power Company Glen Allen, VA 23060

Docket Nos.:

50-280 and 50~281 Facility Name_:

Surry 1 and 2 License Nos.: DPR-32 and DPR-37 Inspection Conducted:

February 12-16, 1990 Inspector:

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Accompanying Personnel: J. P. Potter Approved by:

Scope:

R. Paltemaa, Finnish Centre for adiation and Nuclear Safety

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Fac i lit i es Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Date Signed 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 determined, based on observation of Radiation Protection Program development and a review of station documentation, that station management is actively involved in and fully supportive of the progra The inspector observed con ti nu i ng improvement in both hea 1th physics performance and development of a stronger radiation protection progra New additions to the radiation protection staff and personnel reassignments within radiation protection have resulted in improved attitudes and morale within the departmen No violations or program weaknesses were noted and one inspector followup item was*close PDR ADOCK 05000280 G!

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PDC

  • REPORT DETAILS
  • Persons Contacted Licensee Employees
  • R. Bilyeu, Engineer, Licensing
  • S. Burgold, Supervisor, Instrument and Controls
  • J. Butrick, Shift Supervisor, Radiation Protection
  • W. Cook, Operations Supervisor, Radiation-Protection
  • E. Grecheck, Assistant Station Manager
  • D. Hart, Supervisor, Quality Assurance
  • M. Kansler, Station Manager
  • L. Morris, Radwaste Superintendent, Radiation Protection
  • T. Sowers, Superintendent, Engineering
  • W. Thorton, Director of Health Physics and Chemistry, Corporate
  • F. Wolking, Radiological Assessor, Nuclear Operations Support, Corporate Other licensee employees contacted during this inspection included craftsmen, engineers, operators, administrative personne Nuclear Regulatory Commission
  • W. Holland, Senior Resident Inspector
  • Attended exit interview Background (83750)

In 1988, after an inordinate number of violations of NRC regulations by both radiation protection (RP) technicians and station workers, Virginia Power management committed to the NRC to upgrade the station 1s radiation protection program and to provide the necessary management suppor Radiation Protection Organization Late in 1988, the licensee identified the need for an engineering department internal to RP that reported directly to the Radiation Protection Manager (RPM).

At the same time new personnel were assigned to the positions of RP Manager, Engineering Supervisor, ALARA Coordinator, and Radiological Assesso The position of engineering supervisor was occupied by a contractor for the major portion of the past year; however, the 1 icensee has permanently selected the supervisor for the seven person grou During 1989, several RP shift supervisor position assignments/

reassianments were made by the licensee that have resulted in a better balance in experience among shift *

In *August 19.89, * the resident and region inspectors identified an adverse trend in workers* compliance with station RP requirement Upon identification of the problem, and after two similar events that quickly followed, the station and RP managers took decisive actions to quickly correct the adverse tren The inspector noted that efforts by management to correct this trend appear to have improved worker support for the RP progra Al so, management participation, both corporate and station, indicated a change at the station to develop and implement a "RP program with high standard Based on interviews and observations during the week, the inspector and the Region II Facilities Radiation Protection Section Chief noted that improved enthusiasm, attitudes and morale of the RP staff technicians were contributing.to worker support for the RP program at the statio Source Term Reduction The inspector observed that Surry and corporate management are proactive in their approach to source term reductio The in~pector reviewed Vi rgi ni a Power* s source term reduction program at Surry Nuclear Power Station:

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Surry Units 1 and 2 elevated pH in the reactor coolant system (RCS) to inhibit crud production and transfer, in the Summer of 1988 for Unit 1, and in the fall of 1989 fof Unit Fuel with zircaloy grid spacers is used to reduce the material available for production of.radioactive cobal The program is being implemented during refueling outages with 1/3 core symmetr To date each unit contains a 1/3 core complement of fuel with zircaloy grids spacer Both units will continue refueling with zircaloy grids spacers in subsequent outage To reduce cobalt in the reactor coolant system, the station has selected several safety injection and charging valves as replacement candidates for the Fa 11 1990 and Spring 1991 outage In addition to reducing valves containing stellite, corporate engineering is represented on an Electric Power Research Institute Technical Review Group studying field test guidelines for cobalt replacement in component Filters in the letdown and reactor coolant systems have been replaced and reduced in size gradually to remove large cobalt particles from the coolan Chemical decontamination of the Boron Recovery Gas Stripper was performed in 1986 and is rescheduled for 199 Also, the licensee is targeting full system (RCS) decontamination for the 1990 1 *

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3 Resistance Temperature Detectors ( RTDs) by-pass 1 i nes * are scheduled for removal in 1992 and 199 The RTD 1 ines are responsible for very high dose rates in the loop room,

A hot spot reduction program has been implemented to reduce the number of piping/component-s-:-that have small areas of very high radiation level In 1989, eight hot spots were successfully flushed and cumulative radiation dose rates were reduced by 320 rem/hr~

In January 1990, thirteen hot spots were being tracked with six flush requests submitted for operations approva To. quantify source term reduction, the ALARA group has established 75 survey points in each unit to characterize plant ambient dose rate Source term reduction wi 11 be measured against these survey points to determine progres The inspector acknowledged the progress in reducing collective dose at Surry and will continue to monitor the licensee's progress in this*

area as source term reduction remains a major challenge at the plan Collective Dose Reduction The co 11 ecti ve dose goa 1 for 1989 was 880 or 1 ess person-rem*.

Collective dose _for both units in 1989 was 846 person-re The Station ALARA Committee, in conjunction with each department, establishe~ the collective dose goal for 1990 at 607 person-re Licensee representatives stated that the goal was aggressive in that a nine week*outage is scheduled for later in the yea The inspector noted that RP had the highest annual dose allotment for a department at the station with 164 person-re Surry RP has historically had high annual department dose, which has been attributed to station decontamination and reclamation of contaminated area To assist in obtaining the 1990 collective dose goal Maintenance, Operations, Site Services, and Radiation Protection Departments have been tasked with developing and implementing department action pl ans to minimize personnel dos To assist in the daily effort to reduce collective station dose and to comply with the Corporate Radiation Protection Plan requirements, ALARA coordinators have been assianed for 199 The station's ALARA Committee determined that a primary and an alternate coordinator be assigned from the Maintenance, Site Services, Operations, Engineering, Training, Quality Assurance (QA), and RP Department The department ALARA coordinators will participate in the station's ALARA committee meetings, evaluate ALARA suggestions, and perform other duties that primarily concern minimizing departmental personnel dose *

The station recently implemented the Vi rgi ni a Power policy on lifetime radiation exposure to enforce the companies*. commitment to reducing collective dos The stati-0n now requires that each worker

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is responsible for ~nsuring that thei~ lifetime dose does not exceed their age in year For individuals whose cumulative lifetime dose exceeds their age in years, they may cnntinue to work, however, they will be assigned a 750 millium quarterly dose limit each quarte In addition, each worker must provide the station with a copy of their dose history with supporting documentatio Licensee representatives stated that these requirements-will be incorporated into all major contract In performing radiation surveys at the station, the inspector noted higher than normal radiation levels over the spent fuel poo With a dose rate instrument placed at the handrail of the spent fuel pool (8 1 to 10 1 above the water), dose rates were observed up to 60 *

mrem/h Licensee representatives stated that dose rates had become so high on the spent fuel pit Unit lA and Unit 2A mixed bed ion exchangers that shipping was questi.onabl Dose rates ranged from 325 R/hr to 1,500 R/hr contac To continue with spent full pool water clean up, the licensee installed four temporary ion exchangers but the beds soon loaded up and the ion exchangers leake The licensee has discontinued use of the temporary ion exchanger As the dose rates increased in the spent fuel pool, RP increased work controls by requiring a cost benefit analysis for all work to be performed in the area. This has resulted in the delay for a major,ity of jobs scheduled in the are *RP representatives stated that the beds in the system ion exchangers had been sampled recently and could be shipped for buria The licensee plans to slurry both the system ion exchangers and temporary ion exchangers in the near future and ship the spent resins for burial at a waste repositor Until this is accomplished, work in the spent fuel pool will result in higher than normal or unnecessary personnel dos Procedure Upgrade Program The inspector reviewed the licensee 1s development of Health Physics Administrative procedures (HPAPs) and Virginia Power Administrative procedures (VPAPs).

Licensee representatives stated that prior to the development of administrative instructions there were no upper tier documents stating radiological requirements or guidance that existed between the Corporate RP Plan and operational radiatio protection procedures. The inspector noted that three_ VPAPs and 12 HPAPs were in final stages of development, or in the approval proces The inspector reviewed licensee progress in upgrading procedures to replace guidance with requirements and noted that the progress in this area was continuing and satisfactor e~

. Trainjng In reviewing training, the inspector observed that the licensee was actively involved in providing personnel training in areas that concentrate on radiological awarenes Licensee representatives stated that a problem had been previously identified, in that,

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increased super11i sory pl ant survei 11 ance had not decreased poor radiological work practice To strengthen the RP program, the licensee scheduled all plant supervisors to attend a seminar given by RP and the Vice President of Nuclear Operations. The seminar stressed the types of problems occurring, methods of observation, and expressed management expectations for program improvement The four months of seminars were completed in December 198 The Superintendent of RP informed the inspector that additional training would be provided to plant supervisio The corporate radiological assessor is scheduled over the next two year period to provide, one-on-one in-plant training, with each supervisor regarding improving radi.ological performance and supervisor accountability for worker performanc The inspector noted that training would also be provided for the newly appointed department ALARA coordinators and their alternate ALARA coordinators have been appointed for each of the major departments to interface with the ALARA group in reducing collective dos The training program is intended to familiarize the coordinators with all aspects of dose management at the station *and show how each department effort can contribute to reducing station collective dos Licensee representatives stated that training was being provided. to contract administrators in the new policy that restricts a worker 1s lifetime dose to their age in.year The training is intended to support the inclusion, of the new pol icy in major subcontracts involving work in radiation areas of the plan Assessment Program The inspector observed improvements in the licensee 1s program that identify problems internally. The HP assessment log was developed to enable HP technicians to identify facility related radiological problems and track these problems to correction. This element of the program has been operating for approximately one year and has resulted in numerous problem corrections in-plant, as well as higher standards in the RP progra Reports by the Corporate Radiological Assessor regarding personnel. compliance with the radiation protection proaram and HP technician performance continue to be issued to manaaemen The assessments have identified programmatic problems that, when corrected by management and super-vision, have also resulted in program improvement The inspector noted that a significant number of internally identified problems are assigned to the radiological engineering section for resolution.* The items are added to the commitment tracking 1 og maintained in engineering and are being resolved in a timely manne The inspector found that using a technical approach to resolving many of the problems having a radiological interface has given the licensee 1s radiation protection program a new dimensio Contamination Controls The licensee's program to control con_tamination at its source continues to be effectiv The station 1989 aoal for reduction of co~taminated square feet (ft 2 ) in the radiologically-controlled area (RCA) of the plant was 18,567, or less, and the goal for personnel contamination events (PCEs) was 400 or les The station performed better than projected in both area Actual contaminated ft 2 at years end had been reduced to 14,250 ft 2 and the station documented 199 PCEs in 198 Goals in both areas *fo.r 1990 have been established at 155 PCEs and 11,500 ft 2 of contaminated RC Licensee representatives attributed the improved performance in both areas to better participation by supervision and station personnel in the station's radiation protection program, and to the aggressive participation in the program to reduce/repair radioactive leaks and track contaminated area T,able 1 below shows improvement in performance using certain indicators measured within the industr Table 1 Plant Data Goal 1987 1988 1989 1990 Collective Dose 356*

771 432 304 (per unit/person-rem)

PCEs 493 501 199 155 Controllable ft 2 92,127 92,127 92,127 92,127 Contaminated ft 2 23,475 20,630 14,250 11,500

  • Non-outage year No violations or deviations were identifie.

Information Notices (92701)

The inspector determined that the*following Information Notices ((Ns) had been received by the licensee, reviewed for applicability, distributed to appropriate personnel, and that action, as appropriate, was taken or scheduled:

IN 88-79: Misuse of Flashing Lights for High Radiation Area Controls

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IN 89-27: Limitations on the Us~ of Waste Forms and High Integrity Containers for the Disposal of Low-Level Radioactive Waste IN 89-47: Potential Problems.with Worn or Distorted Hose Clamps on Self Contained Breathing Apparatus Action on Previous Inspection Findings (92701, 92702).

(Closed) Inspector Followup Item (IFI) 50-280/89-27-01:

Failure to appoint department ALARA coordinators as required by the RP Plan and by HP procedure 5.4.10, Station ALARA Progra The inspector observed that dedicated department ALARA coordinators have been assigned as require Thts item is considered close Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on February 16, 199 The inspector summarized * the scope and findings of the inspection with 1 i censee.

managemen No dissenting comments were received from the licensee. The licensee did not identify, as proprietary, any of the materials provided to, or reviewed by the inspector, during this inspectio Licensee management was informed that the !FI discussed in Paragraph 4 was considered -close Acronyms and Initialisms RPM - Radiation Protection Manager RP -

radiation Protection RCS - Reactor Coolant System RTD - Resistance Temperature Detectors QA - Quality Assurance HPAP - Health Physics Administrative Procedure IN - Information Notice ALARA - As Low As Reasonably Achievable PCE - Personal Contamination Event