IR 05000280/1991036
| ML18153C892 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/17/1992 |
| From: | Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153C891 | List: |
| References | |
| 50-280-91-36, 50-281-91-36, NUDOCS 9202050011 | |
| Download: ML18153C892 (9) | |
Text
Report Nos. :
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 JAN 2 2 1992 50-280/91~36 and 50-281/91-36 Licensee:
Virginia Eiectric and Power Company Glen Allen, VA 239-6 Docket Nos.:
50-280 and*so-2~1 License No.:
DPR-32 and.PPR-37 Facility Name:
Surry 1 and 2 Inspection 1991 Inspector:
/ /t 7 /p 2-Approved by:
tter, Chief Faciiiti s kadiation Protecition Secti n Date Signed
. Radiological Protection and Emergency Preparedness Branch
Division of *Radiation.Safety and Safeguards
SUMMARY Scope:
This routine inspection was announced and c.onducted in the area of occupational radiation safety* during normal operations*.
Elements of the program inspected incl.uded an examination of audits.and appraisals, exte~nal exposure control, control of radioactive materials and contamination, surveys and monitoring, and maintaining occupational exposure as low as reasonably achieva_ble (ALARA).
During the inspection, the licensee provided a detailed briefing of. the capabilities, and tour of the new radwaste facility (NRF) for both regional and headquarters NRC
~ersonne *
Results:
In the areas inspected, no violations or deviations were identifie The r&diation protection (RP) program was well supported by both corporate and station management and was
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functioning effectively to protect the health and safety of plant personnel and the general publi Management oversight, audits and appraisals, exposure control~ and collective dose/source term reduction were considered RP ~rogram strength *
9202050011 920122
. PDR ADOCK 05000280 G
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Persons Contacted Licensee Employees JAN 2 2 1992 REPORT DETAILS
- W. Benthall, Supervisor, Licensing
.*R. Bilyeu, Licensing Engineer
- M. Biron~ Supervisor, Radiological Engineering
- J. Butrick, Health Physics Supervisor
- D. Hart, Supervisor, Quality Assurance
. *M. Kansler, -station Manager
- D. Miller, Heal th Physics Supervisor *
- L. Morris., Supervisor, Radwaste
- M. Olin, Supervisor Decontamination Services
- J. Pri6e, Assistant Station Manager
- T. Steed, Station ALARA Coordinator
- D. White, Health Physics Supervisor
- W. Wigley, Manager, Corporate Nuclear Operations Support Other licensee employees contacted during this inspection included:
craftsmen, engineers, operators, and ad~inistrative personne Nuclear Regulatory Commission
- M. Branch, Senior Resident Inspector
- Attended December 20, 1991 Exit Meeting Occupational Exposure (83750) Audits and Appraisals Technical Specification (TS) 6.1.C.3 requires audits of station activiti~s to be performed under the cognizan6e of Quality Assurance (QA) Department for conformance of facility operations to TS and applicable license condition The inspector reviewed QA' s audit of the * RP* program,*
number 91-13, dated October 8, 199 The audit identified strengths, findings, observations and enhancement The inspector found the audit to contain
- substantive findings and observations that were programmatic in natur The audit report stood alone in the documentation of the audit scope and findings and presented them in a narrative section of the report entitled "program implementation."
The inspector noted that this method of auditing and documenting results departed from the compliance type audit and described how the subject item fit into, and contributed to or detracted from the progra The inspector also noted
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- .2 that items.identified in the audit were *corrected in a
- timely manne The QA group routinely performs a followup audit to determine if the corrective action taken corrected the problems, verifying that the correct root cause was identifie.
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- . In January 199~, the QA department published the results*. of a RP program assessmen This assessment program was conducted in parallel with the QA audit program and was designed to* be a performance-based assessmen In November 1991,* QA published the results of the RP program assessmen The assessment covered areas.that.were initially identified as marginal from a performance standpoint, as well as other areas tha were not asse*ssed in the or:i:.gi:nal report.. The inspector noted that both programs were functioning to improve the RP program and were in fact identifying and correcting items that would otherwise be,in violation of NRC regulation In addition, RP staff make daily r.ounds and identify radiological discrepancies on radiological assessor reports (RAR).
A review of RARs by the inspector indicated that this*program continues to.provide positive results toward identifying problems before_ they become serious. *In interviews with licensee management, the inspector determined that management is familiar with these programs and
- knowl.edgeable of the findings, and that the programs enabl~d good management oversight of the RP progra The inspector discussed the quality of all assessment programs with licensee management and indicated the
- self-identification of problems as a RP program strength.
. *Radiological Problem Reports As of December 1, 1991,* the licensee had written 64 Radiological Problem Reports (RPRs) in 199L Of the RPRs reviewed by tlle inspector, all appear to be resolved and the paperwork completed in. a timely manner with t_hree minor exception RPR Nos. 91-07, 91-44 and 91-49 do not appear to have been closed ou When the inspector inq*uired about
them, the licensee indicated that the issues had been resolved but the closeoµt paperwork had not been complete The three RPRs* in question did not pose any significant safety hazards and the licensee indicated that these and future RPRs would be monitored more closely for timely completion. *
- External.Exposure Control TS 6.4.B requires the licensee to have writte radiation control procedures that discuss permissible
radiation exposure, including the use of radiation work permits (RWPs), and stringent administrative prpcedures to assure adherence to restrictions placed on high radiation area The inspector observed the preparation and, the initial phase of a job*that required entry into the Uriit 1 *
containment while subatmosphe.ric and at 100 percent powe The work to be accomplished was the w~ld repair of a drain valve on the Regenerative Heat Exchanger (RHX) -on the 3'6" elevation of containmen RWP 91-2-2045 was issued that specified radiological requirement Radiatio_n levels ranged from 3, ooo millirem per hour (mrem/hr) general area: to 5,000 mrem/hr contact on the RHX drain.pipin Conta~ination levels to. 335; 000 dpm/ 100 cm2 were expected, as well as water from the leaking component. *Dress requirements included full protective clothing with self-contained breathing apparatus (SCBA) for entry into the containmen In addition, plastic suits were required for those personnel that may come in close proximity.to the leaking componen The inspector. received a special training session to qualify for work in a SCB The licensee performed a*
person-rem cost benefit analysis that showed that it
-*was riot beneficial to shut the unit down to make the repai The inspector attended the initial scoping
_meeting that involved all departments required to perform/support the operatio A rough schedule was developed during the meeting and various departments received certain assignments to perform to support the final planning meeting to be held later that da The inspector noted that health physics (HP) ALARA personnel at the initial planning meeting were able to show other departments a picture of the area and the.
specific valve that was leaking from the ALARA Visual Information System (VIMS).
This information alone was able to give interfacing personnel enough information to save one trip into containment and the radiation exposure that would have been incu~re In addition to the final planning meeting, the licensee was required to brief and obtain approval from the Station Nuclear Safety* and Operating Committee (SNSOC) any time an entry was made into containment while at powe The inspector attended the final planning meeting and* th meeting where SNSOC approval was grante At this point, all personnel involved in the operation, as well as station management, were knowledgeable of each step required to be performed in the drain va:lve repair and the radiological requirements and conditions.
-The inspector made the initial entry into containment with licensee personnel and noted that all aspects of
- the.operation went as planne The crew observed the area and verified the leak position on the drain fitting to be repaire Weld machines were also taken in and positioned for the subsequent repai Ali'
pe~sonnel worked as a team and monitored their digital a-iarming dosimeters (DADs) during the operatio The highest DAD dose received on the first entry*was 35 mre: The inspe*ction ended before the full.job was complete The inspector determined that the licensee was using every means to inform workers of the radiological environment and exercised excellent exposure* control during the operatio Procedure HP-6.1.21, Contaminated Skin Dose Assessment,
- ij.ev. 1, dc;1ted November 6, 1990, provides instructio for calculating skin dose due to contaminated skin or clothin Skin dose assessments (SDAs) are required if, {1) a*hot particle~on skin measures> 100,000 disintegration per minute (dpm);.(2) a hot particle on clothing measures > 1,00*0,000 dpm; (3) skin area contamination measures
> 1,000,000 dpm; or (4) skin contamination measures> 10,000 dpm after decontaminatio As of DecE?mber 19,.1991,. two personnel contamination events (PCEs). in*. 199i required a SD Both were
- evaluated as*required.by HP-6.1.2 PCE Report N, from June 1991, involved a hot particle on a worker's neck measuring 200,000 dp The skin dose was calculated to be 286 mrem. * PCE Report No.91-119, from December 1991, involved contamination on a worker's skin and clothing measuring up to 380,000 dp The skin dose was calculated to be 1833 mre Both SDAs were performed as required by HP-6.1.21 and followup of both events was completed in a timely manne Control of Radioactive Material,. Surveys, and Monitoring 10 CFR 20.201(b) requires each licensee to make or cause to be made* such surveys as {l) may be necessary
- for the licensee to comply with the regulations and
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(2) are reasonable und~r the circumstances to evaluate the extent of radioactive hazards that may be present *.
During tours of the auxiliary building, the inspector performed radiation and contamination surveys and noted that the results agreed with the survey results posted by the license All postings and labels on
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radioactive material were as required by station
- procedur The inspector reviewed the licensee program to control_
contamination at the sourc The program is tracked by maintenance and progress is* statu~ed by monthly report In order to determine "effectiveness," the reports weigh the importance of each item and this, multiplied by the' completion percentage, gives a weighted perqent of program effectivenes Items tracked include:
painting, decontamination, installation of permanent shielding, ground water intrusion, out-of-core source term reduction, radioactive leaks, and insulation replacemen As of Dec~mber 17, 199i, 67.49% of the 1991 project completion goal had been achieve Specific areas *of achievement included reduction of contaminated areas,.radioact-ive*hot spots, and personnel contamination events (PCEs)~
The goal of 10,000 square feet (ft2 ) of contaminated area or less was achieve In mid-December, the station reported
- 9,635 ft2 of the 89,500 ft2 total radiologically controlled area as contaminate As of December 20, 1991, 123 PCEs had occurred in 199_1,.
exceeding the 1991 station goal of 160 PCE The licensee contin~es to investigate each PCE to determine root cause and take pertinent corrective ac:tion.*
As of December 3, 199],, the licensee had reduced*
out-of-core source term by flushing 36 radioactive hot spots and removing 403 rem/hou Based on a review of the program to control contamination at the source, the
- inspector determined that the licensee has been effectiv Licensee representatives stated that for the remainder of: 1991, special emphasis had been given to repairing 104 known radioactive leak Radioactive leaks _have been placed on the station commitment-list and extra maintenance crews have been assigned to reduce the number of radioactive leak To improve the rate of reducing contaminated area, twelve additional decontamination technicians are being added to the reclamation effort Licensee representatives stated that a concerted effort will be needed for a long duration to reduce radioactive leaks and contaminated square *footag Maintaining Occupational Exposure As Low As. Reasonably Achievable (ALARA)
10 CFR 20.l(c) states that persons engaged in activities under licenses issued by the NRC.should make
- every reasonable effort to maintain.radiation exposures as low as reasonably achievabl The* recommended elements of an ALARA program are contained in
Regulatory Guide 8.8, Information Relevant to Ensurin that Occupational*Radiation Exposure at Nuclear Power Stations.will be ALARA,. and Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposure ALAR The inspector reviewed the licensee's programs to reduce out-of-core source term, as well as, collective radiation exposur A review of the major dose _
reduction/source term reduction items listed on the five year business plan for Surry showed that the licensee's,program is.aggressive and on schedul Currently, Surry is op.erating on elevated pH,. utilizing hydrogen peroxide injection arid early boration and sub-
- micron*filtration for letdown coolan Stellite minimization in the reactor coolant system (RCS) is also being conducted to both minimize introducing cobalt into the RCS and reduce its activatio To m1n1m1ze stellite, low stellite grid spaces-are oil all new fuel being installed, and valves with low or no stellite*are replacing valves with stellite.. The licensee is in the process of construction of*a full-size mockup for resistance temperature detector (RTD)
replacement scheduled for Unit 1 in 199 In discussions with ALARA personnel, the*. inspector learned that-the licensee will not be performing chemical decontamination (loop stop to loop stop valve) as intende This is a concern since the decontamination of the steam generators (S/G) would drastically reduce general area loop room dose rates for both S/G work, as well as, RTD removal. Licensee management stated that chemical decontamination could not be adequately planned for the Unit 1 outage but would be performed for Unit 2 in 199 A review of the RP Depart~ent Exposure Reduction Action Plan for 1991 showed that 14 of the 15 ac:tion iteins had been_complete Many of the department action items dealt with remote monitoring eqQipment, digital alarming dosimeters, and process reviews regarding operator round One of the more significant accomplishments was the addition*of permanent.shielding for operating components. *The station ALARA coordinator stated that engineering personnel had performed seismic studies and engineering safety analysis for all charging pumps and was providing support for*the permanent shielding of other major*
high~dose component In discussion regarding planning for the replacement of RTDs, licensee personnel stated that a full-size mockup with space restrictions was to be use The licensee
portion of the operation would be removal of the RTDs with contract personne~ performing installation of th new component The licensee also stated that all personnel involved *in the operation would be monitored telemetrically with digital alarming dosimeters and that four closed-circuit television cameras had been approved for the RTD operation to provide better exposure control and dose reductio The licensee, through specifically-contracted equipment, will have the capability to telemetrically monitor up to 300 peopl The system to be used will readout each
_person's dose almost continuously and maintain the highest doses on a computerized readout that lists personnel doses in descending orde Based on a review of ALARA docume'ntation, the inspector noted that one of the Surry assistant station managers attended the REM Semina The seminar is a major
annual event for utilities to discuss the current and future status of technology for reducing personnel radiation exposur In reviewing the trip report, the inspector noted that a good assessment of Surry's ALARA program relative to industry wide progress was obtaine The inspector also noted that the attendance of management, as well as staff at the seminar, was indicative of the extent that teamwork is utilized to reduce dose and maintain program oversigh The-inspector noted that the 1991 collective dose at the end of the inspection was approximately 570 person-re This is below the station collective dose goal projection for this time in the calendar year and it appears that Surry will be below the 1991 station goal of 598 person-re~.
No violations or deviations were identifie.
New Radwaste Facility (NRF) (84750)
The inspector and radwaste personnel from NRC head-quarters received a tour and detailed brie~ing on the capabilities of the NR The inspector noted that although the NRF has only been operational for a short time, significant results have been realized from processing liqqid radwaste and sludg In October -
December, 1991, the NRF processed 750,000 gallons of liquid radwaste with no release above potable water limit Also, radwaste from the emergency sump in the auxiliary building was processed using Bitumen solidificatio The material from the sump had radiation levels of 1,500 rem/h After processing, none of the.30 solidified drums containing the
radioactive waste read over 60 mrem/h Licensee representatives stated that the_ vapor evaporator and bitumen solidification systems haq performed fl~wlessly since startup on September 27, 199 The inspector learned that the licensee currently has the capacity to store dry radwaste for 18 months and solidified radwaste drums.for 24 months*(at the current rate*of generation).
In addition, the NRF has four 30,000
gallon tanks for receiving and storing liquid radwast.
Exit Meeting The inspector met with the licensee representatives
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indicated in Section 1 at the conclusion of the inspection on December 20,* 199 The inspector summarized the scope and findings of the inspection and discussed the hig standards obs*erved in implementation of the RP progra The*
licensee did not identify any documents or processes used or observed by the inspector as proprietar Dissenting comments were not.received.