ML18116A204
| ML18116A204 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/17/1979 |
| From: | Collins P, Jenkens G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18116A199 | List: |
| References | |
| 50-280-79-14, 50-281-79-20, NUDOCS 7907260023 | |
| Download: ML18116A204 (7) | |
See also: IR 05000280/1979014
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100
ATLANTA, GEORGIA 30303
Report Nos. 50-280/79-14 and 50-281/79-20
Licensee:
Virginia Electric and Power Company
Richmond, Virginia
23261
Facility Name:
Surry Power Station, Units 1 and 2
Docket Nos. 50-280 and 50-281
License Nos. DPR-32 and DPR-37
SUMMARY
Inspection on March 20-23, 1979
Areas Inspected
Date Signed
.5/11/79
Date Signed
This routine, unannounced inspection involved 43 inspector-hours onsite in
the areas of the radiation protection program for the Unit 2 maintenance
outage, including radiation dose to individuals, compliance with radiation
work permits, radiation surveys, efforts to maintain radiation doses as low
as reasonably achievable (AI.ARA), posting and control, and independent radia-
tion surveys.
Results *
Of the six areas inspected, no apparent items of noncompliance or deviations
were identified in four areas; two apparent items of noncompliance were found
in two areas (Failure to follow a radiation work permit (50-281/79-20-0l) and
Failure to maintain records of efforts to obtain individuals' previous occupa-
tional radiation doses. (50-281/79-20-02)). One apparent deviation was found
(Failure to follow Al.ARA program coDDitments (50-281/79-20-03)) .
DETAILS
1.
Persons Contacted
Licensee Employees
- W. L. Stewart, Station Manager
- A. L. Parrish, III, SGRP Project Manager
- C. W. Rhodes, SGRP
A. K. Reilly, SGRP
- R. M. Smith, Supervisor, Health Physics
- P. P. Nottingham, III, Assistant Supervisor, Health Physics
D. Lindsey, Foreman, Health Physics
J. Dodson, Foreman, Health Physics
C. Foltz, Foreman, Health Physics
Other Organizations
W. Woodham, Daniels Training Coordinator
NRC Resident Inspector
- D. J. Burke
- Attended Exit Interview
2.
Exit Interview
The inspection scope and findings were sW11Darized on Karch 23, 1979,
with those persons indicated in Paragraph 1 above.
With regard to the
deviation, a licensee representative stated that the operation (changing
steam generators) bad never been done before and that much of the work
was of a research and development nature.
He stated that all operations
could not be planned step-by-step and practiced. The inspector replied
that he understood that detailed pre-planning may not be possible for
all jobs, but that it appeared very little pre-planning and worker
pre-briefing was done on several jobs. With regard to the noncompliance
concerning records a licensee representative stated that new requests
for dose histories were being sent out and that efforts would continue
to locate the previous letters. With regard to the noncompliance concerning
the lack of an RWP, a licensee representative stated that every step of
every operation may not be covered by an RWP and that he would look.into
the circumstances further.
With regard to the workers concerns, a
licensee representative stated that hard hats would be made available
and that vented enclosures were being put around areas generating dust .
3.
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Licensee Action on Previous Inspection Findings
Not inspected.
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5.
External Radiation Dose
a.
The inspector discussed the radiation dose monitoring program with
licensee representatives, health physics technicians and workers.
The inspector observed the issuance of TLD's and pocket chambers to
workers at the dose control points and the reading and recording of
pocket chambers upon workers' exits. The inspector observed workers
in Unit 2 containment reading pocket chambers upon exiting high
radiation areas.
Discussions with workers and checks of records
showed that workers knew the dose they had received and the dose
remaining before a limit would be reached.
The inspector checked
pocket chamber readings as recorded by health physics personnel at
dose control against readings made by the inspector.
b.
The inspector examined the radiation dose printout for Karch 20,
1979; the inspector checked the radiation dosimetry files for
selected individuals whose doses were greater than 1250 mrem but
less than 3000 mrem to determine if completed Forms NRC-4 were in
the individual's files. The licensee was required by 10 CFR 20.101;
20.102; 20.20l(b); 20.202; and 20.401 to monitor and limit radiation
doses and maintain records of radiation doses.
10 CFR 20 .102
requires that, before permitting any individual in a restricted
area to receive exposure to radiation in excess of 1250 mrem,
the
licensee obtain a completed Form NRC 4 and make a reasonable effort
to obtain reports of an individual's previous occupational dose.
For selected individuals who bad signed Forms NRC-4 during the
period January 9
through February 21, 1979, there was no record of
letters sent to other licensee's to determine individual's previous
occupational radiation dose.
A licensee representative stated that
these letters (Form HP-9) were the method used to meet the reasonable
effort" requirements of 10 CFR 20 .102. He stated that if no response
to this letter was received after forty days, the individual would
be assigned a dose for records purposes in accordance with 10 CFR
20.102(c). The inspector discussed the letters (HP-9's) with the
contractor training coordinator
who had previously signed the
requests on behalf of the licensee, with licensee representatives,
and with workers.
From these discussions it appeared that the form
letters bad been sent, but that copies made to be placed in indi-
vidual's dose records bad been lost.
A licensee representative
atated that a search of both dose control offices and the records
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vault had not found the records.
The inspector observed workers
completing form HP-9's to be re-sent to previous licensees and so
that copies of these letters could be placed in individuals' files.
The inspector informed licensee representatives that the failure to
maintain records of the reasonable efforts to obtain previous
occupational doses would be considered an item of noncompliance
with 10 CFR 20.401 (50-281/79-20-2).
c.
In discussing dosimetry records with workers, several workers
expressed questions concerning changes in their dose cards that
they did not understand.
The inspector examined the radiation
dosimetry files for selected individuals, including dose cards, for
the period January 1, 1979 through March 21, 1979, and January 1,
1977, through December 31, 1977.
The inspector discussed changes
to dose cards with licensee representatives. The inspector deter-
mined that the majority of the changes in dose cards resulted from
substituting TLD readings for pocket chamber readings and mathematical
errors made by individuals summing pocket chamber readings.
A
licensee representative stated that these mathematical errors were
corrected when the computer sums of doses were compared to the dose
cards.
The inspector compared dose cards with permanent dose
records for selected individuals.
The inspector informed workers
of the bases for changes to dose cards and emphasized to workers
that any questions concerning changes to dose cards should be
promptly addressed to the licensee's heal th physics group for
prompt resolution.
A licensee representative stated that, to
assure changes to dose cards are correct, a system would be
established to specify individuals who would have authority to
correct dose cards.
d.
While reviewing records at the SGRP dose control point, the inspector
observed a worker discussing the need to have his TLD read with a
health physics technician.
The worker stated that both his high
range (Oto lR) and low range pocket chambers had gone off scale
and had been contaminated. The HP technician stated that he would
have the badge read when he had a chance.
The worker told the HP
technician that he would go to a break area to await the results.
After the worker left the inspector asked the technician if he was
going to read the TLD promptly.
The technician stated that he
would read it when had bad a chance. The inspector questioned the
technician several times over the next two hours, but the technician
stated he had not read the TLD yet.
The inspector discussed the
work circumstances with the worker and again talked to the technician
about the results, informing him that the worker was concerned
about the dose he may have received.
The inspector then informed a
HP foreman of the situation. The foreman called the technician and
told him to read the TLD innediately. The inspector was informed
that the TLD read 157 arem. The inspector bad no furt.her questions.
'
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6.
Maintenance Operations
a.
On March 20-22, 1978, the inspector made tours to the Unit 2 Con-
tainment to observe operations.
The licensee was required by 10
CFR 20.20I(b) and 20*.203 to survey and post radiation caution
signs, and by Condition 2(e) of the license dated January 24, 1979,
to implement the steam generator replacement program (SGRP) health
physics procedures.
In addition, Section 6 of the "Steam Generator
Replacement Program Manual II lists specific measurements to be
implemented to maintain radiation doses as low as reasonably
achievable.
The inspector examined radiation work permits (RWP's)
for jobs in work areas; observed operations; discussed operations
with workers, foremen, superintendents, and health physics technicians; -
and made independent radiation level surveys.
b.
During tours of containment on March 20-22, the inspector observed
workers frequently waiting in the area outside the C cubicle on
the - 3' 6" elevation near the RHR platform. The inspector measured
radiation levels of 10 to 20 mrem/hour in the area. These radiation
levels were confirmed by measurements by the licensee's heal th
physics technicians. The inspector observed individuals waiting in
these areas on many occasions for five to ten minutes. A designated
low dose waiting area was approximately fifty feet away.
The
inspector questioned individuals waiting in the area outside the
cubicle on these occasions and the individuals moved to lower dose
areas.
c.
The inspector discussed the use of low dose waiting areas with
workers and foremen.
Both workers and foremen appeared to know the
purpose and location of waiting areas.
Workers stated that they
were being encouraged to remain in the general work locations
rather than in waiting areas.
Foremen stated that they had been
told by their superintendents to get their workers at work locations
and out of waiting areas.
d.
On March 20, 1979, the inspector examined the work area for the
electrolysis of the reactor coolant pipe and discussed the proposed
cleaning with licensee representatives, health physics technicians,
and contractor workers.
When the inspector left the site at approx-
imately 1930 on March 20, the pipe to be cleaned was in the containment
basement with shiedling tack welded to the pipe ends.
When the
inspector returned to the basement at approximately 0800 on March 21,
1979, he observed that the shielded plugs bad been removed from the
pipe and there was no cutting slag in the pipe. The inspector was
informed by a health physics technician that the dose rate at the
pipe opening was 10 rem/hour. The inspector discussed the removal
of the end caps with health physics technicians, licensee represen-
tatives, and a project engineer. The inspector exaained radiation
r
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-s-
work permits nos. RWP-SGRP-79-109 and RWP-SGRP-79-108 which covered
two methods of removing the shielded plugs. The inspector questioned
individuals to determine what methods were used to remove the end
plugs and the slag, but could find no definitive statement.
The
inspector could find no RWP covering the removal of the slag.
A
health physics technician stated that the removal of the slag had
resulted in contamination on the flo*or of approximately 250,000 dpm
per hundred square centimeters and that workers bad worn respirators.
The inspector examined the record of air sample results for the
work; License Condition (2) (e) dated January 24, 1979, required
that the health physics (HP) program and procedures be implemented.
HP procedure 4, "Radiation Work Permits", required that all work in
containment be covered by a RWP and the RWP' s be obeyed.
SGRP-79-109 stated that it limited work to the removal of shield
covers by use of chipping welds.
It stated that any other work
must be done under RWP SGRP-108, which required the use. of a tent,
which was not used.
Licensee representatives were informed that
the performance of work not covered by a RWP would be considered an
item of noncompliance (S0-281/79-20-01).
e.
During the morning of March 21, the inspector returned to the
basement on many occasions to observe the electrolysis operation.
The operation did not begin until after noon.* During this period a
health physics technician remained in the area in dose rates of 5
to 50 mrem per hour to maintain surveillance over the pipe and warn
workers to observe the ropes and warning signs surrounding the
pipe. Licensee representatives, operators, and contractor personnel
waited in this same area.
Licensee representatives stated that
they were waiting for the use of the polar crane to move the pipe
into the electrolysis tank.
Throughout the morning they said that
they were told on many occasions that the crane would be available
for their use in approximately fifteen minutes.
On one occasion
when the inspector returned to the basement he noted that the pipe
bad been moved approximately forty feet to a location near the
tank.
A Licensee representative stated that the cart on which the
pipe was setting bad been moved by hand.
At approximately 1200 the
workers decided to leave the area. Later that afternoon the inspector
returned to the basement and observed that the pipe bad been placed
in the electrolysis tank.
f.
On March 21, the inspector discussed with workers operations in the
basement of Unit 2 Containment. The workers stated that they were
to fabricate pipe supports and run pipe in the basement.
The dose
rates in the area were 5 to 10 mrem per hour. The workers stated
that they bad welded end plates on the pipe support pieces the
night before. The inspector asked why the end pieces could not be
welded outside conta1nment.
The workers stated that this bad been
done outside containment before, but that it was now done inside
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containment.
They stated that they knew no reason why the work
could not be done outside containment again.
g.
On March 21, the inspector discussed with workers in the Unit 2
Containment basement what their job assignment was.
They stated
that they were to set some pipe, but that their foreman had to find
the superintendent to get details of the job and blue prints. The
dose rates in the area were 5 to 10 mrem per hour. The inspector
observed the men in [ the area for approximately thirty minutes.*
When the foreman returned the men had to walk to an upper level of
containment to obtain.tools.
The foreman, who had been told that
the blue prints were in the basement, then began to search the area
for the prints.
h.
On the night of March 22, the inspector discussed work plans with
workers in Unit 2 containment.
The workers stated that they were
looking for pipe fitting's that had previously been brought into
containment but were not located where they were supposed to be.
The inspector made dose rate measurements at their location and
occasionally at later times at other locations where these workers
were looking for the fittings for the following two hours.
When
the inspector left containment the workers had found some of the
fittings but were still looking for others.
i.
Table 6-1 of the "Steam Generator Replacement Program Manual" lists
' specific measures to be implemented to maintain radiation doses as
low as reasonably achievable. Licensee representatives were informed
that the above examples would be considered a deviation from a
co11111itment to the NRC (50-281/79-20-3).
j.
During discussions with workers, workers expressed concern over the
lack of bard hats, inadequate scaffolding, and dust from wall
removal operations.* The inspector examined air sample results for
the period March 18-20 in the area where dust was generated. The
inspector informed these workers that these concerns were not
within the NRC regulatory jurisdiction, but that they would be
brought to the licensee's attention. The inspector informed licensee
management of the worker's concerns.
The inspector had no further
questions.
7.
Tour of Unit 1
The inspector toured Unit 1 Containment, which was not operating, to
observe work in progress.
No items of noncompliance or deviations were
observed by the inspector .