ML18139B163
| ML18139B163 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/09/1980 |
| From: | Gibson A, Jonathon Puckett, Wray J, Zavadoski R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18139B159 | List: |
| References | |
| 50-280-80-29, 50-281-80-33, NUDOCS 8103130716 | |
| Download: ML18139B163 (43) | |
See also: IR 05000280/1980029
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100
ATLANTA, GEORGIA 30303
50-280/80-29 and 50-281/80-33
Licensee:
Virginia Electric and Power Company
Richmond, VA
Facility Name:
Surry Units 1 and 2
Docket Nos. 50-280 and 50-281
License Nos. DPR-32 and DPR-37
Inspection at
tfl..,J. R. Wray, Radiation Specialist
Accomp
ying Personnel:
S. Bland, NRC, HQS
Date Signed
I.
D
igned
\\ z f '1/go
Date Signed
. dA
L. Munson, Battelle Northwest
by: ~
~ '/:!Ji R. Will, Consultant to Battelle Northwest 12 Lcr [1.0
A. F. Gibson, Section Chief, FF&MS Branch
Date Signed
Approved
Resident Inspectors:
D. Burke, Senior Resident Inspector
M. Davis, Resident Inspector
SUMMARY
Inspection on August 5-15, 1980
Areas Inspected
This special announced "inspection involved 690 inspector-hours onsite in the
area of health physics appraisal including organization, qualifications, training,
procedures, ALARA programs, external exposure control, personnel dosimeter program,
internal dosimetry, respiratory protection, instrumentation, surveillance and access
control, radwaste control, facilities and equipment.
Results
Of the 15 areas inspected, no items of noncompliance or deviations were identified
in 12 areas; 4 items of noncompliance were found in 3 areas.
1.
2.
DETAILS
Persons Contacted
Licensee Employees
- J. L. Wilson, Station Manager
- R. F. Saunders, Assistant Station Manager
- W. Cameron, Director, Nuclear Chemistry & HP, Corporate
- S. Sarver, Systems Health Physicist
- G. E. Kane, Superintendent, Operations
- T. A. Peebles, Superintendent, Technical Services
- H. W. Kibler, Electrical Supervisor
- L.A. Johnson, Superintendent, Maintenance
- R. M. Smith, Supervisor, Health Physics
- F. L. Rentz, Resident QC Engineer
- W.R. Runner, Administrative Supervisor
- O. J. Costello, Staff Assistant
- C. Folz, HP Assistant Supervisor
- H. Anglin, HP Assistant Supervisor
- M. Beckham, HP Assistant Supervisor
- B. Garber, Health Physicist
- D. Green, Health Physicist
- C. Sorokatch, Engineer Technician
- H. Miller, Training Supervisor
- \\-D .. Hahn, Maintenance Supervisor
- E. Creech, SGRP
- C. Rhodes, SGRP
Other licensee employees contacted included co*nstruction craftsmen, techni-
cians, operators, mechanics, security force members, and office personnel.
NRC Resident Inspector
- D. J. Burke, Senior Resident Inspector
- ',M. Davis, Resident Inspector
- \\-Attended exit interview
Exit Interview
The inspection scope and findings were summarized on August 15, 1980, with
those persons indicated in Paragraph 1 above.
The inspectors reviewed and
examined all aspects of the health physics program at the facility.
This
examination included organization, staffing, audits, procedures, training,
retraining, exposure control, instruments, access control, ALARA, radwaste
surveys and facilities. The inspectors stated that the ventilation filtration
system's maintenance/operations program and procedures should be thoroughly
reviewed and reevaluated by the licensee.
The licensee agreed to review
and reevaluate these programs.
At the exit interview the inspectors also
3.
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identified items of noncompliance which included:
(1) failure to follow
procedures (discussed in paragraphs 8.b.l, 10.c., and 13.a.2); (2) failure
to maintain the process vent filtration system (discussed in paragraph
12. b .1); (3) exceeding the instrumentation limits of an ESF filtration
system (discussed in paragraph 12.b.2); and (4) modifying a safety system
without review (discussed in paragraph 11. b). The plant manager acknowledged
the items of noncompliance.
On November 13 and 17, 1980, additional discus-
sions were held between the station health physics staff and a member of
the regional office staff concerning the station's personnel neutron monitoring
program.
On November 17, 1980, additional discussions were held with the
station manager.
The station manager stated that the station would perform
an evaluation of, the personnel neutron monitoring device in use, to provide
assurance that the device would measure anticipated neutron doses resulting
from neutrons with energies normally encountered at the station.
Summary of Noncompliance, and Inspector Follow-up Items
The following is a summary tabulation of all the noncompliance and inspector
follow-up items identified throughout this report.
Inspector follow-up
items (IFI) are matters which the NRC desires to look into again and which
will be examined during future inspections.
IFI's are discussed in the
paragraph(s) indicated after each item .
IFI (50-280/80-29-01; 50-281/80-33-0l) Creation of Health Physics Superinten-
dent position (paragraph 5.a)
IFI (50-280/80-29-02; 50-281/80-33-02) Establishment of a required reading
file for all updated HP procedures (paragraph 5. c)
IFI (50-280/80-29-03; 50-281/80-33-03) Full implementation of the qualifica-
tion record system (paragraph 6.f)
IFI (50-280/80-29-04; 50-281/80-33-04) Full documentation of HP retraining
program (paragraph 6.f)
IFI (50-280/80-29-05; 50-281/80-33-05) Full implementation of giving five
day training course in the first month (paragraph 6.j)
IFI (50-280/80-29-06; 50-281/80-33-06) Intercomparison of TLD badge and
reader responses with North Anna (paragraph 7.a)
IFI (50-280/80-29-07; 50-281/80-33-07) Evaluation of Neutron Monitoring
Device (paragraph 7.b)
IFI (50-280/80-29-08; 50-281/80-33-08) Excessive downtime for TLD reader
(paragraph 7. d)
IFI (50-280/80-29-09; 50-281/80-33-09) Computerization of dosimetry records
(p~ragraphs 7.e and 7.f)
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IFI (50-280/80-29-10; 50-281/80-33-10) Shop monitoring of dose (paragraph
7.g)
IFI (50-280/80-29-11; 50-281/80-33-11) Incorporation of all items listed in
respiratory training (paragraph 8.a.2)
IFI (50-280/80-29-12; 50-281/80-33-12) Reestablish comparability of medical
tests (paragraph 8.a.3)
IFI (50-280/80-29-13; 50-281/80-33-13) Quantitative fit and annual refit
for respirators (paragraph 8.a.4)
IFI (50-280/80-29-14; 50-281/80-33-14) Tagging respirators at emergency
stations (paragraph 8.a.7)
IFI (50-280/80-29-15; 50-281/80-33-15) Certification of oxygen enriched
SCBA units (paragraph 8.a.8)
Infraction (50-280/80-29-16; 50-281/80-33-16) Failure to follow procedures
(paragraphs 8.b.1, 10.c, and 13.a.2)
IFI (50-280/80-29-17; 50-281/80-33-17) Documentation of whole body spectrum
(paragraph 8.b.2)
IFI (50-280/80-29-18; 50-281/80--33-18) Vendor spike program verification
(paragraph 8.b.4)
IFI (50-280/80-29-19; 50-281/80-33-19) Need for tent during plugging operations
(paragraph 9. a)
IFI (50-280/80-29-20; 50-281/80-33-20) Establisliment of a formal ALARA
program (paragraph 11.a)
Infraction (50-280/80-29-21; 50-281/80-33-21) Lead shielding on pipe without
a safety review (paragraph 11.b)
Infraction (50-280/80-29-22; 50-281/80-33-22) Failure to maintain process
vent system (paragraph 12 .. b.1)
Infraction (50-280/80-29-23; 50-281/80-33-23) Operation of an engineered
safeguards system beyond its design (paragraph 12.b.2)
IFI (50-280/80-29-24; 50-281/80-33-24) Balancing of ventilation flow (para-
graph 12.b.2)
IFI (50-280/80-29-25; 50-281/80-33-25) Permanent piping for liqu{d radwaste
system (paragraph 12.c)
IFI (50-280/80-29-26; 50-281/80-33-26) Consideration of level indications
for liquid waste demineralizers (paragraph 12.c)
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IFI (50-280/80-29-27; 50-281/80-33-27) Consideration of method to collect
groundwater (paragraph 12.c)
IFI (50-280/80-29-28; 50-281/80-33-28) Consideration of chemical control of
wastes prior to treatment (paragraph 12.c)
IFI (50-280/80-29-29; 50-281/80-33-29) Consideration of background during
releases (paragraph 12.c)
IFI (50-280/80-29-30; 50-281/80-33-30) Monitoring of potential (paragraph
12.c)
IFI (50-280/80-29-31; 50-281/80-33-31) New solid waste building (paragraph
12.d)
IFI (50-280/80-29-32; 50-281/80-33-32) Consideration of new compacting
system (paragraph 12.d)
IFI (50-280/80-29-33; 50-281/80-33-33) Additional space for trash compacting
(paragraph 12.d)
IFI (50-280/80-29-34; 50-281/80-33-34) Numbering each waste shipment (para-
graph 12. e)
IFI (50-280/80-29-35; 50-281/80-33.-35) Estimation of groups I and II (para-
graph 12.e)
IFI (50-280/80-29-36; 50-281/80-33-36) Check-off sheets to meet each require-
ment (paragraph 12.e)
IFI (50-280/80-29-37; 50-281/80-33-37) Air conditioning for calibration
room (paragraph 13.a.3)
IFI (50-280/80-29-38; 50-281/80-33-38) Surgeon's caps for respirator wearers
(paragraph 13.b.1)
IFI (50-280/80-29-39; 50-281/80-33-39) Periodic calibration of multi source
gamms calibrator (paragraph 13.b.3.b)
IFI (50-280/80-29-40; 50-281/80-33-40) Review to meet ANSI N323 criteria
(paragraph 13.b.3.b)
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5.
Radiation Protection Organization and Management
a.
The inspectors reviewed the radiation protection organization and how
it relates to the overall plant organization.
The licensee has just
undergone a change in the plant organization.
The health physics
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supervisor now reports directly to the station manager.
The Health
Physics Department appears to have satisfactory rapport and communica-
tions with station management.
The organization of the Health Physics Department as shown in Figure 1
.is not conducive to smooth, efficient operations because the responsi-
bilities of and the interrelationships between the HP Supervisor, the
Health Physicists, and the Assistant HP Supervisors are not clearly
delineated.
Although not in the chain of command between the HP
Supervisor and the remainder of the health physics staff, both Health
Physicists function in this capacity.
The Assistant Health Physics
Supervisors are responsible for specific segments of the total program,
however, it is not clear if they report directly to the HP Supervisor
or the next lower level of supervision.
Nonetheless, it was noted
that the Open Door plicy set forth in HPA 4. 6 appears to prevail
regardless of established chain of supervision.
In a.ddition, the
position of Shift Leader, as set forth in Surry Station Health Physics
Administration Procedure HPA 4.2 (dated June 2, 1980), should be more
clearly defined in relation to the various levels of supervision.
Similarly, the lines of communcation between each aforementioned level
of supervision should be clarified. The inspectors noted, in particular,
that the HP Assistant Supervisor responsible for all aspects of the
Station Dose Control Program was working the backshift ,due to the
simutaneous outage of both units. This extremely important aspect of
the* HP program therefore, appeared to be without decision-making
administrative supervision during the daytime hours of heaviest activity.
The inspector noted several instances in which the daytime shift
leader had obviously not had the benefit of communications with his
Assistant Supervisor on critical poli*cy or procedural matters.
The inspectors recommended that the licensee consider changing the
organization of the Health Physics Department to provide for more
effective utilization of key professional personnel (Health Physicists)
(IFI 50-280/80-29-01; 50-281/80-33-01).
b.
The concept of dedicating personnel to stated functions, such as dose
control, is satisfactory so long as the individual does not become too
narrowly specialized.
Rotation of technicians throughout the program
on a predetermined periodic basis is vital to the individual in his
technical/ professional development.
However, it is equally vital to
the Health Physics Program in that it provides a broad base of technical
expertise as well as in-depth backup support necessary during absenteeism
and personnel turnover.
The step training program should help alleviate this situation once it
becomes fully operational (see Training, 2. 0, Personnel Selection,
Qualification and Training) .
Health Physics personnel at Surry do not appear to be well appraised
of the overall plan status--scheduling of operations, changes in pro-
cedures, etc.
The "required reading" file, which contains changes to
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and updating of, procedures, memoranda on practices (e.g., drumming),
licensee event reports, etc., revealed that only twice in the period
from December 1979 through the present did mpre than 50% of the Health
Physics personnel initial having read the items as posted.
c.
The organization and management of the health physics program at Surry
are undergoing significant change as a result of the Health Physics
Appraisal Team report at VEPCO's North Anna nuclear facilty.
It is
noted that the complete HP Administrative Manual contains procedures
dated from May 22 through July 28, 1980.
It appears that these, and
many of those in the Health Physics Procedures Manual had been originated
as a result of the North Anna HP* appraisal. These updates and additions
are commendable.
It is recommended that they be included in the
"required reading" file and that staff meetings be held to discuss the
procedures and methods of implementation to ensure that all HP personnel
are fully conversant with the operational aspects of the Department
(IFI 50-280/80-29-02; 50-281/80-33-02).
Based on the above findings, this portion of the licensee's program
appears to be acceptable, but the following matters should be considered
for improvement of the program:
(1)
the responsibilities of all HP personnel be clearly defined;
(2)
a less rigid assignment to functional groups and resultant_ rota-
tion of assignments;*
(3)
- formalization of the HP organization, especially in relation to
lines of authority and communications; and
(4)
full implementation of recent HP procedures, HP Administrative
procedures and the step program for training in the HP Department.
6.
Personnel Selection, Qualifications and Training
a.
The Surry station adheres to the requirements of ANSI-18.1-1971 and
NRC Regulatory Guide 1.8 as these pertain to qualifications of Health
Physics personnel.
In addition, procedures require that the HP staff,
except for the Health Physics Supervisor (RPM), Health Physicists and
Health Physics Assistant Supervisors, complete an 8-step technician
development program.
This program consists of six months of onsite
academic training followed by seven successive on-the-job* training
sessions in stated subjects.
Each step is of six months duration, the
entire eight steps being of four years duration.
Individuals with sufficient documented experience or education may
enter the step program at levels above step 1. For example, a bachelor's
degree (no experience) enters at step three; and, a Navy-trained
technician enters at step five.
However, in all cases individuals
must successfully pass examinations on all subjects covered in the
steps below which he has entered.
In addition, a few whose employment
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pre-dated institution of the step program (circa 1978) had been grand-
fathered in.
A review of records of these individuals confirmed the
justification for such action.
b.
The Health Physics Supervisor (RPM) meets the qualifications set forth
in Regulatory Guide 1. 8 in that, w'hile the guide states that he "should
have a bachelor's degree or the equivalent", his experience in both
Navy and civilian nuclear reactor programs appears to offset the
strictest interpretation of the standard.
As backup for the RPM, one
of the Health Physicists was found to meet or exceed the strictest
requirements of ANSI 18.1 and Regulatory Guide 1.8.
c.
It appears that few previously qualified personnel have been hired
into the Heal th Physics Program recently.
Evidently, management
prefers to select individuals requiring only that they have a high
school diploma or the GED equivalent, be at least 19 years old, and
pass the usual physical, psychological and security screening tests.
The individual is employed as a "technical assistant" and is generally
assigned to decontamination, laundry, waste handling, etc.
After
appropriate supervisory observation, a number of such employees may be
singled out for training in the step program. From that point, progres-
sion toward ultimate "senior technician" status is as described above.
d.
To date, the step training program appears to have been hampered by
the pressing needs of the Steam Generator Replacement Project (SGRP),
and by reorganization in both the Health Physics and Training Depart-
ment.
A review of the training and qualification records of the HP
personnel provided no documentation of the actual training received,
duration of any particular phase in terms of time devoted to subjects,
or evaluation of the trainee's performance in that phase.
The records
are limited to check off sheets, initialed by a supervisor or shift
leader.
Paragraph 2.2 of HPA 4.5, dated June 2, 1980 states:
"Training should
be performed as time permits and should not interfere with daily work
assignments".
Paragraph 3. 3 reads:
"Upon completion of training in
certain work areas, the cognizant supervisor will "DRILL" the trainee
and make appropriate signoffs in the Health Physics Training Log and
Health Physics Qualifications Log".
Interviews with step-program participants indicated that subject prac-
tical training is currently perfunctory and often difficult to obtain.
There are few resources available to the individual who is anxious to
learn and willing to ferret out the information on his own time.
As a
result the station is faced with the a lack of in-depth or backup
support in many areas, especially that of furnishing supervisory level
personnel in ~mergency situations.
It must be recognized that there
is a wide gap in expertise between a shift leader and an Assistant
Health Physics Supervisor.
The former, generally, does not have the
broad spectrum of health physics expertise necessary to cover any
situation facing the Department.
While there are over fifty station
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personnel (plus 12 on contract) in the Department, the number often is
insufficient due to specialization as described above, and failure to
fully implement the step program training.
e.
Health Physics Procedure HPA 4.15, "Training of Contractual Health
Physics Technician Personnel", sets forth instructions for determining
the qualifications of contract personnel.
In part,. the procedure
states that:
(1)
a resume will be provided for each contractual health physics
technician.
(2)
at random, resumes will be checked and previous employers con-
tacted to assure personnel qualifications.
(3)
contract health physics technicians will be trained on Surry
health physics procedures, the health physics manual, and applicable
work assignments by the appropriate Assistant Health Physics
Supervisor.
f.
A detailed Qualification Record (Form HPA 4.15) is to be kept on each
contract technician and signed off, as appropriate, by an Assistant
Health Physics Supervisor.
None of these records were observed in the
Training Department file because implementation of HPA 4.15 has not
- yet taken- place.
In view of the fact that only twelve contract per-
sonnel remain on station at this time (two of these were replaced by
the contractor in the week of August 11, 1980) and that those inter-
viewed were well qualified long-term technicians, delay of.implementation
of the qualification record system until the start of SGRP 2 (projected
at 62 additional contract technicians) appears justified. (!FI 50-280/
80-29-03 and 50-281/80-33-03).
Training and retraining of health physics personnel above the step
program level is not required at Surry.
Some training is presented on
an as needed basis.
The retraining program should be formalized as to
frequency, number of hours per stated time period, areas to be covered,
and documentation of participation in the individual's training and
qualification files (IF! 50-280/80-29-04 and 50-281/80-33-04).
g.
Training is conducted by the Plant Training Department.
The full-time
staff consists of the Supervisor-Nuclear Training, seven Nuclear
Training Coordinators, the Assistant Engineer (Technical Support),
three technicians (assigned to the Simulator), and three clerical
persons.
Other qualified individuals may be utlized for special
needs,
plant supervisory and managment personnel participate as
appropriate.
The Supervisor-Nuclear Training reports to the Station
Manager as recommended during an earlier NRC inspection .
h.
Upon entry, new employees and visitors immediately attend a one-day
general employee *training session.
Permanent employees then attend an
additional five-day training course within one month of entry.
This
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course does not repeat the one-day subjects.
Retraining is required
annually for all employees (except HP personnel) on the four basic
subjects--Health Physics, Radiation Control, Quality Control and
Respiratory Protection.
The Training Department appears to maintain
excellent rapport with all other plant departments and experiences
little difficulty in scheduling sessions or sustaining adequate atten-
dance.
i.
The inspectors audited portions of the five day course, a complete
- one-day course, a respiratory protection and containment entry course
and observed some specialized training.
It was confirmed that vir-
tually every Department or facet of operations, support and management
was represented in the five-day course, indicating that Training does
receive attention from the station management.
The quality of instruc-
tion observed was excellent.
There appears to be a concerted effort
to staff the Training Department with well qualified, experienced
personnel.
Recent additions include trained educators (M.S. degree),
a retired Navy Nuclear Program officer with additional academic training
in Education, and positions for two Health Physicists, yet unfilled.
In addition, the Station is negotiating with several colleges to
establish a full-time on-site accredited program.
The program would
be voluntary and supplemental to the required station training.
Review of the backgrounds of the Training Department staff confirms
that the individuals are experienced and well qualified.
j.
Currently, classes are larger than desirable due to the SGRP.
Under
normal operating conditions attendees in small classes are given
reading assignments in the General Employee Training Booklet, the
Emergency Plan and Implementation Plan, Accident Prevention Manual,
Operational and Administrative Procedures Manuals and Section I of the
Health Physics Manual. It is recommended that this format be resumed
for permanent employees. It is also recommended that the requirement
for attending the five-day course within the first month of employment
be strictly observed (IFI 50-280/80-29-05 and 50-281/80-33-05).
k.
Based on the above findings, this portion of the licensee's program
appears to be acceptable, but the following matters should be considered
for improvement of the program:
(1)
fully implement the eight step training and qualification program;
(2)
institute a detailed training program for senior personnel;
(3)
implement the qualification and training program for contract tech-
nicians as set forth in HPA 4.15; and
(4)
limit the size of general employee training sessions and require
that personnel attend the five-day course within the first 30 days
o.f active employment.
7.
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External Dose Control
a.
Requirements for external dose control at Surry station are described
in the provisions of the Health Physics Manual,Section II, Part 8
(3/29/79), Personnel Monitoring, and Part 9 (3/29/78), Records, Reports
and Notification. Exposure and doses are required to be maintained in
accordance with the limits set forth in 10 CFR 20. 101 and 20. 103.
Station administrative limits are lower than those reference in 10 CFR
20.
The records which were reviewed by the inspector revealed no
current or unreported overexposures.
The dose control program appeared
to be operating adequately.
The basis for determining external radiation exposures is a thermoluminescent
dosimeter (TLD) system, operated entirely in-house, with a backup
check system utilizing 35 Eberline badges assigned randomly to station
personnel (primarily in Health Physics).
Control badges are placed at
Security issue gates. All station employees or visitors are required
by licensee procedures to be issued TLD badges;
Badge holders are
color coded both as to status of the employee (station, visitor, etc.)
and as to cyclic badge period.
Station and Eberline badge readings
apparently compare favorably (within 10%).
All badges are exchanged
and read monthly, as appropriate, badges may be read as needed. It is
recommended that periodic intercomparison checks of TLD reader response
and TL dosimeter response be conducted with the North Anna facility.
(IFI 50-280/S0-29-06 and 50-281/80-33-06).
b.
Solid. State neutron dosimeters (allyl diglycol carbonate monomer) are
issued on an "as needed basis" for neutron monitoring and are read and
recorded by the consultant or vendor.
Examination of the neutron
exposure records revealed no significant dose received by any employee.
Personnel neutron dosimetry is provided by a commercial vendor.
Although the dosimeter has responded favorably when dosed to levels in
excess of 100 mrem using the station's neutron scource, no evaluation
has been performed to determine if the device responds satisfactorily
to low doses resulting from neutrons with energies normally encountered
at the station.
A licensee representative stated that the station
would dose several dosimeters to approximately 20-50 mrem (vendor
states that 20 mrem is the minimum detectable dose) using the station's
neutron source, and also by placing the dosimeters in known neutron
fileds in the plant and submit the dosimeters to the vendor for evaLua-
tion (50-280/80-29-07 and 50-281/80-33-07).
It should be noted that
neutron surveys performed by the station indicate that the neutron
doses received by the station employees are sufficiently low to premit
the discontinuance of the use of a dosimetry device.
However, the
station will continue to use neutron dose measuring devices.
c.
Self Reading Dosimeters (SRD' s) are the day-to-day first line of
exposure coµtrol.
These are required for any employee who enters a
Restricted Controlled Area.
SRD's are of the usual 0-200 mrem, or
where applicable, 0-1000 mrem type. The SRD reading is recorded on
form HP-~, Estimated Dose, each time the SRD is turned in at Dose
Control, particularly if the individual is leaving the overall
(.../
d.
e.
f.
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Restricted Area.
SRD and TLD readings are compared periodically and a
"TLD Update" entry is made on the RH-2 card. Variations between SRD
and TLD readings in excess of 20% are reported to the Health Physics
Supervisor for investigation and/or resolution as may be appropriate.
In practice, Dose Control reports variation in excess of 10%.
SRD's and TLD's are calibrated in accordance with station procedure
HP-3. 1. 4.
The inspector observed a complete calibration and drift
check for some 100 SRD's and 20 (two sets of 10 each) TLD ribbons.
All actions appeared to be in accordance with ANSI N-13.5-1972, Regulatory
Guide 8. 4 and the Health Physics Manual and. Procedures.
Further
investigation of calibration sources and a University of Michigan
intercomparison check is discussed in paragraph 13.b.3. It was noted
that an inordinately high number of SRD's appeared to fail drift or
calibration checks, especially upon initial receipt from the manufac-
turer. It is recommended that this situation be investigated in light
of determining whether the station is purchasing an inferior product.
In addition, the TLD calibration equipment currently in use appears to
require an excess of down-time.
Minor problems must be compensated
for or corrected by Dose Control personnel during operation (IFI
50-280/80-29-08 and 50-281/80-33-08).
The daily function of Dose Control consists of issuance of TLD' s,
SRD's, etc., logging of SRD readings, immediate attention to problems
associated with lost or damaged SRD' s or TLD' s* (including prompt
reading of TLD's), determining familiarity of the employee with his
RWP, determination of eligibility to use respiratory equipment, and,
recording and record keeping within the Dose Control. Office.
The
implementation of these functions appeared adequate and satisfactory
under current conditions.
The acquisition of a system-wide computer
system would greatly improve the entire Dose Control Program by assuring
the accuracy of the records, providing invaluable data upon which the
ALARA program-may be upgraded, and insuring more economic utilization
of operational and maintenance personnel at all levels (IFI 50-280/
80-29-09 and 50-281/80-33-09).
Records of some 1900 badged personnel are kept in the Dose Control
Office. Approximately 500-600 of these are permanent station personnel;
100 or so are "system" (Richmond, North Anna, etc.) personnel and are
maintained as "in and out" emp_loyees.
The remainder are contract or
visitor personnel.
It is anticipated that 2500 will be badged with
the onset of the next SGRP.
Random checks of approximately 50 individual records revealed a small
number of errors or discrepancies, mostly clerical or filing, and none
of which were of such significance as to be classified as "severe".
Considering that the work is all done by hand, the records are generally
complete and up*-to-date.
A computer system would provide automatic
revelation of errors and omissions as they occur.
As an example, a
computer printout of overdue annual medical examinations/whole body
counts/respirator refits would have altered a management official of
-12-
his need to satisfy these requirements thereby forestalling refusal of
access in the time of an emergency.
Records of five individuals who had been excluded from the Restricted
Controlled Area due to having reached or approached the licensee's
administrative dose limit were specifically examined.
Each of these
had been closely followed, well documented and flagged.
Exclusions
were lifted and other limitations imposed only if and when appropriate.
All evidence points to adequate record keeping even though done entirely
by hand.
Again, computerization would expedite the process and furnish
invaluable data which supervisory personnel need (IFI 50-280/80-29-09
and 50-281/80-33-09).
g.
Two shops (mechanical & electrical) have devised internal dose control
programs independent of the Health Physics Department.
Large graphs
(charts) each with administrative exposure levels designated by a
differently colored area and alphabetical listing of employees on the
left margin, are covered with a lucite sheet.
The individual records
his exposure by extending the dose line across the graph (through the
exposure level zones) with a grease pencil.
This appears to be a very
useful and graphic way to call the attention of both the employee and
the supervisor to the individual's exposure status.
Unfortunately,
the inspector and a dose control technician discovered that the graph
in one shop had not been updated in a majority of cases (a 5 to 12 day
lag on the average) and was advised by a supervisor that the chart had
not been updated in the other shop.
h.
It is recommended that this system be evaluated, discussed with shop
supervisors, and if found worthy of adoption, instituted in all shops.
Health Physics should provide periodic "monitoring" to determine
whether the graphs are updated, and offer aid in shops as appropriate.
The systems would be much easier to maintain if the dose control
program is computerized (IFI 50-280/80-29-10 and 50-281/80-33-10).
An inspector reviewed the proposed computer program for Surry station,
paying particular attention to its impact on Dose Control and Personnel
Training.
The system has been designed by JOHN BROUGHTON ASSOCIATES
of Richmond, Virginia and was presented for approval in February 1980.
Corporate and Plant Health Physics Supervisors signed off on March 12,
1980.
There appears to be correlation in the proposed system between The RWP
and Personnel Data bases (e.g., Respirator requirements pnd medical/
physical exams).
The Personnel data base appears to be complete.
A
data base entitled Daily Status Report Production provides quarterly
exposure informatin and is designed to assist in "determining the most
efficient utilization of plant personnel." This could be ver~ valuable.
Miscellaneous reports could include a contractor's sub-personnel data
report.
-13-
The inspector concluded that the proposed computer program would
appear to greatly enhance the effectiveness of the station's dose
control records system if implemented (IFI 50-280/80-29-09 and 50-281/
80-33-09).
i.
Based on the above findings, this portion of the licensee's program
appears to be acceptable, but the following matters should be considered
for improvement of this program:
(a)
establish a program with the North Anna facility to periodically
check TLD badge and reader responses;
(b)
improve neutron dosimeter sensitivity;
(c)
investigate high failure rate of self reading dosimeters during
drift and calibration checks;
(d)
acquire a computer system for Dose Control to ensure fact and
accurate implementation of the program; and
(e)
investigate potential usefulness of individual shop dose control
charts.
8.
Internal Exposure Control
a.
Respiratory Protection Program
(1)
(2)
The Respiratory Protection Program was reviewed for content and
adequacy of the training and medical examination programs, respi-
ratory protection equipment fitting program, cleaning and decon-
tamination methods, inspection and testing, repair, packaging and
storage, inventory, use control system and air quality testing
program.
The Respiratory Protection Training Program at Surry is divided
into two approximately one-hour sessions.
Due to the use of
subatmospheric pressure in the Surry reactor containment, the
first hour of instruction is primarily concerned with techniques,
procedures and precautions in entering the personnel access hatch
of the reactor containments.
The second hour session provides
the actual respiratory protection training which is given as a
minimum to all personnel.
For permanent plant personnel, a five
day general employee training program which includes this portion
of the respiratory protection training is required.
The session
attended by an inspector was the Respiratory Protection Program
which is required of all personnel, plant and contract.
The instructor utilized primarily live lectures and demonstrations
of appropriate methods of inspections and donning of equipment
and the various limitations of respiratory protective devices.
Short portions of video tap~ presentations were use~ as part of
(3)
-14-
the course.
However, not all of the training subjects listed in
the facility Respiratory Protection Manual or NUREG-0041 were
included in the training course. Specific discussions of airborne
contaminants, their physical properties, toxicity, physiological
action and means of detection were not included. Also not included
was a discussion of the use of positive controls, such as engineering
features, as well as an explanation of why in a particular case
these may not be used.
A review of radiation and contamination
hazards, including the use of protective clothing and equipment
that may be used with respirators, was also not discussed.
The
material covered was presented in a comprehensive and easily
understood manner, but the training course should be expanded to
address all the items listed in the plant manual (IFI 50-280/80-
29-11 and 50-281/80-33-11).
Demonstrations of the proper methods for donning and removal of
respiratory protective devices, including participation by attendees,
were observed. Records are maintained of personnel who have attended
the class but no examination is required.
Records indicating
attendance at respiratory protection training are forwarded to
the plant dose control personn~l for entering into the personnel
folders.
The medical examination program for fitting respiratory protective
devices is condu~ted .separately for permanent personnel and con-
tract personnel.
Both examinations are given by registered
nurses.
At the time of the appraisal period, a significant
difference was noted between the two programs. For plant personnel,
the entry physical is considered as the initial examination for
approval to wear respiratory protection.
Annual examinations are
conducted as ~ollowup.
Both the initial and annual examinations
include a medical history questionnaire completed by the applicant,
blood pressure checks, pulse, respiration rate and a pulmonary
function test. The pulmonary function test uses a Breon Spirometer
Model 2400 to determine lung capacity.
Acceptance criteria are
documented as required to be 70% of the normal for age and height.
A documented graph of the lung function for each individual is
maintained on file. For permanent personnel, a medical examination
by a physician is given every two years and the respiratory
protection examination is given in the interim years by the
registered nurse..
Any abnormalities or questions in the interim
examination are referred to the doctor for final resolution.
A
selective examination of medical records indicated that the
medical examination records were on file and complete.
For contract personnel,_a separate station is utilized for respir-
atory protection examinations.
The registered nurse at the
station uses a Wright Peak Flow meter to verify lung function .
The use of this meter has been approved by the plant physician as
an indication of adequate respiratory capacity.
Records of
individual performance on this instrument are maintained and a
-15-
signed certification is issued and sent to plant dose control
personnel to indicate that the medical examination has been
given.
However, no other medical evaluation for adequacy to wear
respiratory devices was apparently made for contract personnel.
Discussions with plant representatives indicated that the two
separate programs were initially established to be comparable and
that both programs would be reviewed and appropriate comparability
reestablished (IFI 50-280/80-29-12 and 50-281/80-33-12).
(4)
The respirator fit program at Surry utilizes a qualitative method
for determining proper mask fit.
A test booth and Isoamyl Acetate
solution is used to perform a qualitative fit.
Each individual
is requested to don an MSA respirator.
A negative pressure fit
test is performed by the individual and observed by the booth
operator.
The individual then enters the booth and is instructed
to perform the functions as indicated on instructions placed on
the door of the booth.
The booth operator then (using a paint
spray type sprayer) sprays a solution of Isoamyl Acetate into the
booth.
If the banana oil odor is detectable, the individual is
instructed to exit the booth and attempt to get a refit by adjusting
the mask position.
A log is maintained of each individual taking the test and if an
individual satisfactorily completes the fit test, he is given a
slip of paper indicating so, which is presented to dose control
for personnel files.
No periodic refit is required by the present
. program.
It is recommended that a quantitative fit program be established
to provide documented assurance that appropriate fit has been
achieved.
In addition, it is recommended that all respirator
users be refit annually (IFI 50-280/80-29-13 and 50-281/80-33-13).
(5)
Documentation indicating completion of respirator training,
medical examination, whole body count and respirator fit are
maintained in personnel files at the plant dose control center.
Each individual required to wear respiratory protection for a job
is required to contact dose control prior to entry.
A dose
control individual verifies that respiratory protection requirements
have been met and issues a respiratory verification slip to the
individual.
The individual then dresses in protective clothing
appropriate for.the job and signs in at the entry desk to the
radiation control area.
The Health Physics person at the entry
desk verifies knowledge of the RWP requirements and verifies that
the individual has the proper radiation dosimeters.
He then
initials the respiratory protection slip. The worker then proceeds
to the respirator issue station and must present the signed slip
to be issued a respirator.
At the respirator station a log is
kept with the respirator number and individual receiving that
specific respirator.
-16-
On presenting the respirator approval slip, the individual is
issued the appropriate respirator for the job he is to do.
The
respirator is contained in a plastic bag with a tag to indicate
who has surveyed the respirator, and that it is appropriate for
issue and a yellow plastic bag in which to place the respirator
is issued for return to the respirator issue station.
Upon
completion of use of the respirator, the individual is instructed
to place the respirator in the yellow bag, survey the outside to
assure contamination free status and return it to the respirator
issue station.
To assure that personnel return respirators to
the issue station, periodic reviews of the issue log are accom-
plished and a notification slip is issued to the individual's
supervisor if the respirator has not been returned after use.
(6)
The respirator issue statioIJ. is also the respirator cleaning,
decontamination, and inspection station.
Respiratory protective
devices are scrubbed and sanitized using MSA sanitizer and air
dried.
Each respirator is inspected and surveyed directly with a
GM instrument and smeared to assure contamination free status.
Filters on particulate respirators are a single use item and are
discarded after each use.
If respi-rators are contamination free
and undamaged, they are placed in a plastic bag containing a tag
indicating inspection and survey and a yellow bag for return and
are sealed for placement on supply shelves.
Several respirators were randomly-selected from the shelves and
surveyed by this appraiser. No contamination was detectable.
(7)
The facility maintains a supply of approximately 150 MSA Ultraview
masks.
In addition, they have approximately 42 self contained
breathing apparatus units plus 50 spare bottles.
Additional
backup supplies are available from the North Anna Station and
from the VEPCO corporate office in Richmond.
Two HP personnel assigned to the respiratory protection program
are MSA certified for mask repair and inspection.
Adequate
supply of repair parts were available to maintain the plant
program.
A monthly test has been established for inspection of
SCBA and respirator units.
This test provides for testing and
inspection of regulators, bottles, and harnesses of all SCBA
units, as well as for inspection of all face pieces on the shelf.
This is a separately documented inspection in addition to the
routine inspection after use of each unit by the mask cleaning
station personnel.
Documentation was in place and complete to indicate that monthly
inspections had been performed.-
The inspection program includes
verification that hydro test of high pressure bottles is current .
A selective examination of SCBA units indicated that not all face
pieces are bagged and that tags are not in place on individual
units to indicate that the inspection has been completed; however,
supporting documents indicated that these actions had been taken.
b.
(8)
-17-
It is recommended that a tag be placed on the respirator in the
emergency stations to indicate that the monthly inspection has
been performed (IFI 50-280/80-29-14 and 50-281/80-33-14).
Tests to assure grade D air quality or better are performed
routinely by the plant.
Certification of quality of oxygen
enriched air was evident and records of tests on quality of air
from bottles and from compressors were available with one except-
ion; the oxygen enriched SCBA units were not tested after being
transferred from the certified bottles through the pump to the
user bottles. It was recommended that a periodic testing at this
point be implemented (IFI 50-280/80-29-15 and 50-281/80-33-15).
The plant has established an adequate capability for refilling
SCBA ?ir bottles both for breathing air use and for oxygen enriched
use.
Whole Body Counting
(1)
Whole body counting is provided onsite using a shadow shield
scanning type whole body counter with an eight inch Harshaw NaI
(Tl) detector coupled to a Nuclear Data 100 multi channel analyzer.
A hand striping process is normally used to identify the 7 common
radionuclides for which the counter has been calibrated. Automatic
striping capability is available,_ but is not normally used.
Procedures for calibration and operation of the whole body counter
are established in Section 3 of the Health Physics Manual.
Records on file indicate the whole body counter calibration was
completed for 1978, 1979 and 1980 using NBS traceable standards.
Documentation includes energy efficiency and KeV per channel
calculations.
An energy reference source using Cesium-137 and
Cobalt-60 is fabricated at each calibration and used daily to
verify that the photo peaks are in the proper channel and of the
proper magnitude.
Operational procedures specify that if *the
efficiency is greater than 10% of the original calculated value,
HP supervision will be notified and determination of need for
recalibration established. These data are logged daily in addition
to background counts.
One procedure discrepancy was noted;
Section D.2 of HP 3.1-15 requires a background count at least
twice daily when whole body counting is in progress, and records
indicated only 1 whole body count background is taken daily
(Infraction 50-280/80-29-16 and 50-281/80-33-16).
(2)
All personnel are required to get a whole body count upon entry
to the facility, termination from the facility, and as requested
by Health Physics.
Permanent plant personnel are required to get
an annual whole body count.
A computer listing of station per-
sonnel with the date of whole body counts and due date for recount
is maintained.
Notification of personnel due for a recount is
issued on a timely basis. Followup verification that all personnel
have received the recount is not complete.
One instance was
-18-
noted where a recount had not been provided even though overdue.
Whole body count data are entered on form* HP 3.1-15-1 and main-
tained in permanent files.
Actual spectra are not normally
recorded.
It is recommended that the whole body counting system
be equipped with a method to permanently document the spectrum to
provide for appropriate supervisory review of each analysis
ensuring that the analysis was satisfactorily performed.
This
will also provide a permanent hist_orical record (IFI 50-280/
80-29-17 and 50-281/80-29-17).
Although the whole body counting
system is calibrated for 7 common radionuclides, procedural
requirements provide for identification of photo peaks at any
point on the spectrum and for supervisory evaluation of those
unknown peaks.
Discussions with licensee representatives indicated that new hire
and termination check sheets are used to assure personnel receive
whole body counts.
Past difficulties with getting whole body
counts on exiting contract personnel created the requirement that
final pay checks would be withheld until whole body count records
had been completed on these personnel.
(3)
Action levels have been provided in procedure HP 3.1-15 to address
positive whole body counts. Action levels are:
a) greater than
5% but less than 10% of the maximum permissible body burden
(MPBB); b) greater than 10%. but less than 25%; c) greater than
25% but less than 50%; and d) greater than 50%.
Discussions with
licensee personnel indicate that oral instructions have been
given to print out each channel of raw data from the whole body
counter if results are greater than 10% of the MPBB.
Written
instructions should be provided. It is recommended that a list-out
of data by channel, X-Y plot or photograph of the spectrum be
retained as a permanent record for each positive whole body
count.
Action levels provide for additional bioassay sampling in
the form of urine or fecal analysis at various points. In addition
a periodic test program for urinalysis has been established as
discussed below.
(4)
Verification of the effectiveness of the respiratory protection
program is accomplished by a series of periodic tests. A periodic
test (PT 38.25) provides for a weekly frequency of whole body
counting.
Ten individuals are selected for a whole body count
based on the probability of their entrance into contaminated at-
mospheres and their wearing of respiratory protection during the
period.
These participants are then counted and the results of
the whole body count evaluated for verification of the effective-
ness of the program. In addition PT 38.26 provides for a quarterly
selection of 30 personnel to participate in urinalysis evaluations.
These routine samples are sent to a commercial contractor to be
analyzed fo tritium and mixed fission products. Results of these
periodic tests are routinely reviewed by supervision.
-19-
Discussions with licensee personnel indicated that no spike
program for verification of vendor analysis performance was
conducted.
It is recommended that a vendor per:f;ormance spike
program be established and implemented (IFI 50-280/80-29-,18 and
50-281/80-29-18).
c.
Based on the above findings, this portion of the licensee's program
appears to be acceptable, but the following matters should be considered
for improvement of the program:
(a)
expand the training program to include all requirements in the
respiratory protection manual;
(b)
review medical programs and establish comparability between the
contract and plant programs;
(c)
establish a routine testing program of SCBA cylinders after they
have been refilled with oxygen from certified bottles as is being
done with service air and breathing air SCBA units;
(d)
implement a quantitative respirator mask fit program and require
routine refit tests;
(e)
equip the whole body counting system with a method to permanently
document the spectrum provided; and
(f)
establish a vendor urinalysis performance spike program.
9.
Exposure Controls In Practice - Steam Generator Tube Plugging
Unit 1 was shut down for plugging of defective tubes in steam generator "C"
during the period of this appraisal. The dose control system for the steam
generator jumpers was reviewed.
Dose rates in the primary side head of the
steam generator ranged from 12 to 15 rem/hr.
A special beta radiation
survey was performed of the area by using beta sensitive TLDs in five
different locations.
It was determined that the gamma dose was the con-
trolling radiation for exposure control.
Air surveys in the channel head
showed I-131 concentrations in the mid 10- 6 range with Co-60 concentrations
a factor of 100 lower.
Cubicle airborne activity was in the 10- 10 range
Dose controls for personnel entering this area
are very critical to prevent overexposures.
Personnel who are assigned as steam generator jumpers spend significant
time prior to work performance in a cold mockup away from the* radiation
area to become familiar with the job site and their specific responsibil-
ities. Health physics personnel are specifically assigned to control doses
to steam generator _jumpers.
A separate RWP is generated for all work per-
taining to this maintenance operation.
A separate card and dose record is
completed for each individual under this RWP number.
..
-20...:
Two inspectors observed work performed on steam generator "lC" on August 5,
1980.
A tent enclosed the bottom of the steam generator and the entire
scaffold.
A small filtration system drew suction on the opposite manway
from where work was to be performed.
Another filtration unit was drawing suction on the tent.
The inspectors
observed that this evacuation unit was not providing a large negative
pressure differential inside the tent.
Dripping water was also observed
forming a puddle on the canvas tent floor presumably originating from the
leaking steam generator tube.
Two health physics technicians were assigned to the job.
They controlled
access to the steam generator from outside the steam generator cubicle
where dose rates were appreciably lower.
One technician was in continuous
voice contact with the workers through the use of headphones, although
never in visual contact during the actual work performance.
Vocal instruc-
tions and worker responses along with a stop watch are used to limit workers'
exposure time to that of the previously calculated maximum allowable stay
time.
Workers wore air supplied bubble hoods and rain suit pants.
High and low
range pocket dosimeters were taped onto the top of the hoods.
Headphones
were comfortably worn inside the air supplied hood.
The workers were
assisted in removing their protective clothing by health physics tech-
nicians who used razor blades to cut the duct tape sealing the plastic
suit.
The lC steam generator tube plugging operation marked the inaugural use of
mechanical plugs at the Surry Nuclear Power Station.
This mechanical plug-
ging outage was completed in less time and with far fewer radiological
concerns as had previously been experienced with explosive tube plugging
outages. Health Physics estimated that approximately 20 man-rem was expended
to plug 64 steam generator tubes.
An inspector asked how much exposure was used to install the tent.
That
information was not immediately available, but this kind of information
would be more rapidly retrievable when the new computerized dose control
system is installed.
The inspector stated that there appeared to be little
need for the tent now that mechanical plugs are being used and a filtration
unit is installed drawing suction on the channel head.
A licensee represent-
ative stated they will investigate fhis matter further (IFI 50-280/80-29-19
and 50-281/80-33-19).
10.
Routine Surveillance Program
a.
Routine Indoors Survey
(1)
The routine surveillance program of Surry facility was reviewed
for completeness and adequacy.
The program is outlined in radia-
tion protection procedure HP 3.12-2, Radiation Survey Schedule.
...
b.
(2)
(3)
-21-
The procedures provides for daily, weekly and monthly radiation
surveys, contamination surveys and airborne contamination level
sampling.
The survey location and frequency appear adequate for
a radiation protection program.
A selective examination of radiation survey records for 1979 and
1980 was performed. Records appeared to be complete and adequate.
Check sheets were initialed to indicate that surveys had been
completed for each month during 1979 and 1980 and spot check of
surveys in the file supported that indication. Review of completed
surveys indicated that surveys were adequate and appropriate for
the location.
Radiation work permit records were reviewed to verify appropriate
requirements for work being performed.
Of the RWPs reviewed, the
stipulated requirements appeared to be appropriate to the work
and to be complete and adequate for radiation protection of
personnel.
For the period from January 1 to August 13, 1980,
2046 radiation work permits were issued by the facility.
Obser-
vations of the radiation work permit procedure in action appears
to provide radiation protection control for work activities.
Air Sampling Program
(1)
The routine air- sampling program is conducted in accordance with
plant procedure HP 3 .12-2, which requires daily air samples of
reactor containment, auxiliary building, chem labs, health physics
area, and the counting room, and under certain conditions, daily
air samples of the turbine building. It also requires specified
weekly air samples and monthly air samples.
The plant radiation
protection program requires the use of respiratory protection
when specified operations such as welding, grinding, cutting,
etc., are performed, when surface contamination levels exceed
200,000 d/m per 100 square centimeters, and when indicated by air
sample results.
In addition to the routine program, special air
samples are taken as indicated on Radiation Work Permits for jobs
having potential for airborne contamination.
A review of air
sample log records indicated a typical frequency of 150 air
samples per month.
A review of the locations and frequency of
air sampling indicated an appropriate and adequate program was
conducted.
(2)
Air samples are normally counted on a GeLi detector and multi
channel analyzer system in the counting room.
A Nuclear Data
computer is used for sample analysis and produces a hard copy
print out of results.
These records are maintained permanently.
Calibration, performance and background checks of instrumentation
were performed and documented.
A recent review of analytical
capability was performed by NRC regional personnel with the
Region II Mobile Laboratory.
(See NRC :RII Inspection Report
50-280/80-21; 50-281/80r22.)
-22-
(3)
MPC hour accountability is not normally maintained on individual
personnel.
A routine program has been established whereby a
fictitious person is used to verify that individual exposures to
airborne concentrations of radioactive materials are maintained
less than 75% of the MPC hour limit on any seven consecutive day
period.
This fictitious individual is assumed to work in areas
of highest air concentration as established by air sample results
for those areas where respiratory protection is not required.
MPC hour accountability is maintained on that individual. Verifi-
cation of internal exposure is primarily performed as part of the
whole body counting program.
c.
Worker Compliance With Procedures
During the two week period of the assessment, an inspector evaluated
the scope of worker compliance with health physics procedures.
In
this subject area, numerous examples of noncompliance were observed.
(1)
On August 7, 1980, workers were observed in the Unit 2 cable
vault performing work without a RWP (Radiation Work Permit)
though the area was posted with signs indicating that such a
permit was required.
The Radiation Protection Manual
(RPM)
paragraph 2.1.A.1 requires the use of an RWP when certain condi-
tions exist, one of which is the presence of a sign requiring an
RWP. * Such a sign is used when, in the. opinion of responsible HP
supervision, the health and safety of individual radiation workers
can best be served by HP awareness of ongoing work in potentially
radiologically hazardous areas.
In this area, a licensee repre-
sentative accompanying the inspector stopped the work, and ultimately,
the individuals involved were disciplined.
(2)
On many occasions, an inspector observed individuals wearing
protective clothing (PCs) in an improper manner.
In every case,
a licensee representative corrected the persons involved.
The
specific problem was that individuals were wearing PC hoods
without securing the chin flaps.
The ambient temperatures were
quite high, sometimes in excess of 100°F, yet appropriate wearing
of PCs depends not on temperature, but upon the need to prevent
skin contamination.
The RPM, paragraph 2.2.C.1.c, requires PCs
to be worn properly and hood chin flaps to be properly secured.
(3)
An individual was observed by an inspector to be wearing his TLD
(thermo-luminescent dosimeter) in an improper manner on his right
rear hip belt-loop.
The RPM, paragraph 1.3.1.B, requires TLDs to
be worn on the upper portion of the anterior surface of the
trunk.
(4)
An inspector, in the company of a licensee representative, ob-
served an individual .entering the Turbine Building from the
Radiation Controlled Area
(RCA) pass by a frisker without
checking himself for contamination though a prominently pos~ed
(5)
-23-
sign indicated that he should do so.
RPM, paragraph 1.3.G.2,
requires individuals to survey themselves when leaving areas of
potential loose surface contamination and entering "clean" areas.
An inspector observed an individual lying prone atop a grey
equipment cabinet in the Unit 2 valve pit area.
This area was.
posted as both a radiation area and a contamination controlled
area.
This individual was not observed to be asleep, and when
questioned by a licensee representative, he indicated that he was
waiting for area survey results prior to resuming work.
The
inspector observed, and the licensee representative agreed, that
the practice of waiting in a radiation area was a poor ALARA
practice, and that lying prone in a contamination controlled area
was not appropriate to minimizing the potential for skin contami-
nation.
(6)
On August 14, 1980, an inspector observed an individual reaching
across a contamination controlled area barrier rope at the blow-
down station in the Unit 2 Turbine Building.
A licensee repre-
sentative confirmed this observation.
RPM,
paragraph 1. 3 .E
requires that protective clothing requirements be obeyed unless
specific exception is granted by HP.
The above are examples of individual workers' failure to observe the
requirements of health physics procedures which implement the Tech-
nical Specification (TS) requirement (TS.6.4.B) for procedures meeting
the requirements of 10 CFR 20 (Infraction 50-280/80-29-16 and 50-281/
80-33-16).
There appeared to the inspector no single cause for these procedural
noncompliances, and in discussions with licensee representatives,
including the assistant station manager, no reason could be discerned
for their occurrence. It was, however, indicated by licensee represent-
atives that increased emphasis would be placed on ensuring adequate
survei.llance of worker activities by supervisors and foremen.
The
inspector had no further questions regarding this matter.
d.
Neutron and N-16 Surveys
e .
Accompanied by licensee representatives, two inspectors entered the
Unit 1 containment while the unit was at approximately 68% power for
the purpose of approximating the Nitrogen-16 fields inside the biolog-
ical shield walls. Specially prepared TLDs were used for the measure-
ments (results not yet available) and a comparison was made with the
facilities portable instrumentation and plant TLDs.
Outdoor Routine Surveys
Over a three day period, beginning on August 4, 1980, an inspector
....
-24-
conducted radiation surveys outside the restricted area at the following
locations:
(1)
Non-VEPCO property:
Surry County, Virginia, Sanitary landfill
facility (this landfill is the depository for the Surry Plant
clean trash) .
(2)
Owner controlled (VEPCO) property:
(a)
intake structure
(b)
salvage yard
(c)
transmission yard storage area
(d)
construction scrap storage area
(e)
Steam Generator mausoleum
(f)
training building
(g)
environmental survey office
(h)
four miscellaneous scrap areas
(i)
discharge structure
(j) all roads onsite which could be traversed by the truck
supplied
These surveys were conducted with an Eberline PRS-1 utilizing a
2" x 2" sodium iodide (NaI) detector, or alternately, a HP-21
Geiger Muller thin window detector.
The results of these exten-
sive surveys, with one exception, revealed no levels of radiation
above normal background levels.
The exception was discovered in
the environmental office where fossilized sharks teeth and sand
from a nearby outcropping on a beach of the James River were
found to be from 10-20 times normal background levels.
The
radioactivity in these items is naturally occurring, expected,
and not attributable to the power plant operations.
The extensive survey firmly established the efficacy of the
licensee's policy of having only trained Health Physics (HP)
personnel permit release of items from the restricted area to the
environment.
This practice utilizes a "green tag" system, author-
ized by HP personnel only, and each item, vehicle, or piece of
equipment is individually scrutinized both visually and by radiation
detection instruments.
Liquid samples taken of the sediment and also effluent liquids in
the storm drain discharge from the restricted area to the discharge
canal were below the plant multi channel analyzer minimum detectable
activity levels.
These results indicate, despite. the relatively
large quantities of contaminated materials resulting from the
Unit 2 Steam Generator repair which are stored on pads and open
to the effects of the elements, that the storm drains are not
currently an unmonitored source of radiative -material release to
the environment.
The extensive use of kerbs and collection sumps
around the aforementioned pads is a practice which is highly
recommended for this type of temporary storage as a prophylactic
measure.
-25-
On August 7 and 8, 1980, an inspector conducted radiation surveys
and loose surface contamination surveys utilizing the previously
mentioned instruments in the following locations:
(a)
Construction area:
1)
tool storage room
2)
tool repair room
3)
instrument repair shop
4)
construction lunch room and locker area
5)
weld shop scrap pile
6)
pipefitter's shop
7)
construction HP control point
8)
sheet metal shop
(b)
Protected Area
1)
Unit .1 turbine building
2)
Unit 2 turbine building
3)
auxiliary boiler room
4)
turbine building roof
5)
auxiliary building roof
6)
cable spread and switchgear area
7)
Unit 1 main condenser waterbox
8)
general areas outside buildings.
As a result of these surveys the inspector concluded that the
licensee had identified and appropriately marked with barrier
ropes and signs, all areas required by 10 CFR 20.203 and licensee
contamination control procedures.
Areas designated as contamination controlled areas by the licensee
included:
(a)
Auxiliary boiler
(b)
Condenser waterboxes
(c)
Turbine building sumps and drain chases
(d)
Steam Generator blowdown stations
(e)
Cable trays in cable room.
Of these, the auxiliary boiler deserves special mention.
The
licensee was aware of the requirements of NRC IE Bulletin 80-10,
entitled "Contamination of Non-radioactive System and Resulting
Potential for Unmonitored, Uncontrolled Release of Radioactivity
to Environment".
The licensee has recently experienced auxiliary
boiler tube leaks with simultaneous radioactively contaminated
feedwater resulting in mud tank contamination levels of approxi- _
mately 1 x 10- 5
µCi/ml.
At an inspector's request, licensee
representatives conducted a thorough review of the environmental
sample results and correlated this information with the known boiler
11.
-26-
radioactivity levels for the past two years. No abnormal environ-
mental levels were apparent and there was no correlation discernable.
Some perturbation of the environmental results came from atmospheric
nuclear weapons testing by the Chinese, but isotopic and temporal
consideration eliminated the power plant as a source of these
elevated levels.
The licensee is eng-aged in a 10 CFR 50. 59
analysis of the Auxiliary Boiler operation in a radioactively
contaminated status as a result of IEB 80-10 and will respond in
accord with those separate requirements to the regional NRC
office.
An inspector noted that HP personnel were evaluating the use of a
portable, clip-on dose rate meter. The use of personal instruments
and their easy portability and continuous availability (exemplified
by this particular instrument) undoubtedly contributed to the
lack of fin~ing of noncompliance with the posting requirements of
HP assistant supervisors on walking tours of the
radiation controlled area frequently check radiation levels and
appropriate posting. This technique appears to be very effective.
f.
Based on the above findings, this portion of the licensee's program
appears to be acceptable .
ALARA Considerations
a.
During the recent Steam Generator repair project on Unit 2, extensive
shielding and other ALARA techniques were utilized, however, and this
resulted in keeping overall project exposures at or below predicted
estimates.
Similar plans are in effect for the upcoming repairs in
Unit 1.
An inspector was informed that the health physics department
made requests in January 1980, for engineering support of an ALARA
effort, but that such support has not been forthcoming.
Also, an
inspector was provided with a draft copy entitled "Statement of Policy
and Management Commitment -
Personnel Radiation Exposure".
This
document encompasses the heart of an effective ALARA program, yet the
inspector was informed it has been under review by corporate management
for about a year with no action.
b.
ALARA, as practiced, evolves as a professional commitment on the part
of individual HP supervisors, fore~en, and technicians.* There is no
formal program.
The inspectors recommended to the licensee that a
formal . ALARA program with engineering support be established (IFI
S0-280/80-29-20 and 50-281/ 80-33~20).
An inspector questioned a licensee representative about temporary lead
shielding blankets wrapped around the discharge piping of Unit lA, B,
and C charging pumps. *unit 1 was at approximately 68% power at the
time (August 12, 1980).
An investigation by the licensee was unable
to reveal who had placed the shielding on the pipes and no analysis of
the seismic significance and dynamic load changes to the system was
documented as having been performed.
10 CFR S0.59(b) requires that
c.
-27-
analyses of changes made to systems as described in FSAR be documented
and if a question of safety is discerned, permission must be obtained
from the NRC prior to operation in the changed mode.
The operation of
the charging system with an unanalyzed seismic and dynamic load change
is in noncompliance with 10 CFR 50.59(b) (Infraction 50-280/80-29-21
and 50-281/80-33-21).
Based on the above findings, except for the item of noncompliance,
this portion of the licensee's program appears to be acceptable, but
the establishment of a formal ALARA program should be considered.
12.
Radioactive Waste Management
a.
Process Waste Gas System
The Process Waste Gas System is composed of two separate subsystems:
the Process Vent Subsystem and the Ventilation Vent Subsystem.
The*
Process Vent Subsystem regulates the discharge of potentially high
activity waste gases from the Liquid Waste Disposal System, the gas
stripper in the Boron Recovery System, the Vent and Drain System,
various pressure relief valves, and the Containment Vacuum System.
The Ventilation Vent Subsystem regulates the discharge of potentially
low activity air streams from building exhausts, cable vaults, Safe-
guard areas, and the Main Control and relay room areas. Ra~ioactive
waste discharges from both subsystems.are filtered and monitored.
An inspector reviewed records of gaseous releases from Containment
Purges (1980-1 to 1980-154) and Waste Gas Decay Tanks (1980-1 to
1980-16) for the calendar year 1980.
Total gaseous effluents for
calendar years 1977, 1978, and 1979 were selectively examined from
yearly Reports of Radioactive Effluents. All requirements of Techni-
cal Specification 3.ll(b) appear to have been performed as prescribed.
Technical Specification 4. 9 (D) requires that all process radiation
monit6rs be checked, tested, and calibrated in accordance with Table
4.1-1.
Table 4.1-1 states that process radiation monitors will be
checked daily, tested monthly, and calibrated each refueling period.
Through record reviews and discussions with licensee representatives,
the inspector concluded that all requirements of the Technical Specifi-
cations were being met.
An inspector accompanied Instrument Technician personnel during their
monthly process and area radiation monitoring equipment test (Periodic
Test No. 26.2). This test procedure tests the alert and alarm setpoints
of each monitor.
The inspector verified that alert and alarm setpoints
produced visual and audible indicatio:r;1s in the control room when
exceeded.
The waste gas decay tank outlet flow valve (FCV-FW-101) was
observed to shut upon alarm activation from the Process Vent Gas and
Particulate Monitors (RM-GW-101 and RM-GW-102).
The automatic functions
of the Condenser Air Ejector Monitor (RM-SV-111) were also observed to
occur as required.
I--
-28-
An inspector reviewed calibration procedures CAL-RM-001 and CAL-RM-044
for process monitors RM-GW-101, RM-GW-102, and RM-SV-111 and verified
that these procedures had been followed during each refueling since
the plant went operational:
The procedure uses both Ba-133 and Cs-137
sources, traceable to an NBS standard, for calibration of scintillation
detector effluent monitors.
NUREG 0578 requires installation of high range effluent monitors on
all gaseous discharge pathways.
The inspector was informed by licensee
representatives that high range effluent monitors are installed and
operable at the present time.
Discharges from the Condenser Air
Ejector which are normally released to the atmosphere are diverted to
the containment building upon a high radiation reading from the Con-
denser Air Ejector Monitor (RM-SV-111).
The inspector had no further
questions concerning the gaseous waste processing system and its
associated monitoring equipment.
b.
Filtration/Ventilation Systems
(1)
An inspector reviewed results of Periodic Test Procedure Nos.
32.1 and 32.2 (HEPA and Charcoal sample test respectively) for
the Control Room Emergency Ventilation System, the Auxiliary
Building Filter System, and the Relay Room Filter System to
determine compliance with the requirements of Technical Specifi-
cation 4.12.
Records show.frequency and acceptance criteria for
these filter systems were met.
However, numerous adverse comments
listed on the filter testing consultant's records during its
visual inspections of the filter housing prompted a similar
visual examination by appraisal team members accompanied by the
resident NRC inspector and a licensee representative.
The Process Ventilation Filter Unit, since it must process poten-
tially high radioactive gaseous material, was inspected first.
The housing was disassembled to afford a clear look at the pre-
filter, HEPA filter, and charcoal absorber trays.
The pre-filter
was heavily loaded and torn in places. It was immediately evident
after viewing the HEPA filter frame that the filter housing had
been previously filled approximately half way with liquid.
The rusted frame and discolored filter paper indicated that this
had occurred some time ago.
Control room personnel informed the
inspectors that water occasionally enters the filter housing when
filling and venting certain tanks if the tank is overfilled. If
this occurs, the housing is drained and dried but no filter
replacement action is initiated.
The inspector informed licensee
management that liquid ruins HEPA filters and charcoal such that
they are unable to adequately perform their design functions.
Technical Spe~ification 4.9(A) sfates that equipment to control
gaseous radioactive effluents shall be maintained to keep levels
of radioactive material in effluents released to unrestricted
L
-29-
areas as low as practicable.
Failure to maintain the Process
Vent Filter System in a condition such that it could perform as
designed constitutes an item of noncompliance with Technical
Specification 4. 9 (A).
(Infraction 50-280/80-29-22 and 50-281/
30..:.33-22).
(2)
The Auxiliary Building Filter unit was disassembled and inspected.
Although not as deteriorated as the Process Vent Filter System,
the auxiliary building filters appeared to be overloaded.
The local Magneholic pressure differential gage was pegged off
scale high (greater than 5 inches water). Literature (ORNL-NSIC-65)
suggests replacement of HEPA filters when the resistance reaches
2 inches water.
However, HEPA filters are capable of withstanding
pressure drops of 10 inches water withou~ damage.
Technical Specification 4.12(a)(4) states that procedures shall
conform with the recommendations in ORNL-NSIC-65, "Design, Con-
struction, and Testing of High-Efficiency Air Filtration Systems
for Nuclear Application".
Section 2.2.5 of ORNL-NSIC-65 states
that HEPA filters are routinely operated to resistance as high as
5 to 6 inches water before changeout is recommended.
Failure to
provide procedures specifying the maximum pressure drop acceptable
for operation of the Auxiliary Building Filter Banks, and operating
the filter banks at greater t_han 5 inches water and with an
unknown pressure drop constitutes an item of noncompliance with
Technical Specification 4.12(A) (4) (Infraction 50-280/80-29-23
and 50-281/80-33-23).
On August 9 and 14, inspectors accompanied by a licensee repre-
sentative examined air flow patterns throughout the Auxiliary and
Decontamination Buildings and the Chemistry hot laboratory.
The
buildings inspected were determined to have slight negative pres-
sures compared with the outside environment.
A few cubicles in
the basement of the Auxiliary Building had air flows from higher
contamination areas to areas of lower contamination.
During an
entry into the Containment Building, the inspectors observed air
flowing out of the personnel hatch into the Auxiliary Building.
Most areas of the buildings had almost stagnant air.
With high
temperature and humidity conditions, the working environment in
the Auxiliary Building was especially poor.
An inspector reviewed a design change request entitled "Auxiliary
Building Ventilation System Modification". Most of the objectives
of this modification is concerned with post LOCA filtration.
However, one objective is "to provide adequate cooling of the
Auxiliary Building cubicles and adequate purgin*g of the containment
by restoring original design air flow rates when exhausting
through filters."
A licensee representative estimated that
completion of the modification would be in the fall of 1981.
The
inspecto~ has concerns for the interim period ~uring which Unit 2
-30-
will be operating at full power following its Steam Generator
Replacement outage.
The licensee should provide adequate temporary
ventilation to ensure air flows from areas of low contamination
to areas of higher contamination (IFI 50-280/80-29-24 and 50-281/
80-33-24).
An inspector tested the hot chem lab air hoods with a hot wire
anemometer.
The hood had to be at least half closed before
100 linear feet per minute suction was obtained.
By discussions
with chemistry personnel, the inspector determined that the
actual procedure for working in the hood is with the door half
down or more.
The licensee posted a directive to have a hood
door at least half closed while working under the hood as
suggested by the inspector.
The inspector had no further
questions or comments.
Based on the above findings, improvements in the following areas
are required to achieve an acceptable program:
(a)
formulate a program to maintain effluent filter systems in
designed operable condition; and
(b)
provide adequate ventilation to ensure air flow patterns
from areas of low contamination to areas of higher contami-
nation are maintained.
c.
Liquid Waste Processing System
Radioactive liquid waste is processed by a portable demineralization
system designed, built, and operated by plant personnel. It is capable
of processing 100 percent of the radioactive liquid presently generated.
Two separate cation/anion trains are arranged in parallel with the
capability to connect with the pre-filter demineralizer in series to
form the process train.
The equipment is situated in the decontamina-
tion building on a sealed stainless steel floor which directs any
All connections are flexible temporary
hoses.
The inspector stated that since this system is a permanent
processing system, all connections should be permanent piping (IFI
50-280/80-29-25 and 50-281/80-33-25).
When asked how leaks, spills, and overflows are detected, a licensee
representative stated that it is totally up to the experience of the
operator in watching test tank and decontamination sump levels.
No
automatic alarms or functions are provided.
The inspector suggested
that level indicators, pressure sensors, and addition control equipment
should be considered to improve the system (IFI 50-280/80-29-26 and
50-281/80-33-26) .
Influent to the demineralization system is sampled prior to processing
to determine if processing is required.
Processed water is .stored and
J
-31-
sampled in the Liquid Waste Disposal System's Test Tanks prior to dis-
charge or reprocessing depending on sample results.
An effort is made
to separate non-contaminated from contaminated water.
Laundry wastes
are collected and sampled separately and usually discharged without
processing.
However, further reductions in collected water to be
processed can be made~
A licensee representative stated that a report
by an outside consultant indicated that approximately 40% of the water
collected in the Auxiliary Building sump is from clean groundwater
inleakage through cracked walls.
A method to collect the groundwater
prior to processing to reduce the amount of processed water should be
investigated further by the licensee (IFI 50-280/80-29-27 and 50-281/
80-33-27).
The efficiency of demineralization processing systems varies with the
type of water processed (i.e., pH, conductivity, etc.).
During the
Steam Generator Replacement Project (SGRP) acidic liquids were collected
and processed which reduced the capacity of each bed to approximately
22,000 gallons.
The present capacity for relatively clean post SGPP
water is approximately a factor of 10 higher.
The licensee should
initiate a program to control the chemical nature of water to be
processed prior to contact with the demineralizer processing system
(IFI 50-280/80-29-28 and 50-281/80-33-28).
Processed liquid wastes are discharged to the environment through the
Liquid* Waste Disposal System Monitor (RM-LW-108).
This monitor is
located on the 2 foot elevation of the Auxiliary Building in a high
background area.
The background (approximately 20,000 cpm shielded)
is due to internal contamination from discharges as well as external
contamination from previous basement floodings.
A licensee represent-
ative stated that a new monitor will be bought soon and relocated in a
higher level of the auxiliary building. The background is not presently
recorded on the liquid .discharge permits nor is the monitor backf.lushed
after each discharge. Through discussions with licensee representatives
and review of station records, the inspector concluded that the background
has lately been very consistent.
However, the inspector stated that
the background must be closely monitored when the new detector is
installed to ensure Technical Specification release limits are not
exceeded if the background count rate were to change.
The inspector
also stated that it might be wise to record the background and release
count rate before and after each release.
A licensee representative
said this matter will be considered when the* new detector is installed
(IFI 50-280/80-29-29 and 50-281/80-33-29).
Groundwater inleakage through cracks in the Auxiliary Building basement
walls raised the question of potential outleakage when the basement is
flooded.
On August 14, 1980, the inspector accompanied by a licensee
representative toured the 2 foot level of the Auxiliary Building where
an estimated 8 inches of water covered the entire floor.
Station
personnel had not as yet ascertained from where the water was leaking.
A potential exists for water to leak through the cracks to the pipe
tunnel connecting the Auxiliary Buidling with the Turbine Building.
-32-
The water is pumped to the Turbine Building sump where it is automati-
cally discharged to the environment unmonitored through the storm
drain system. Discharges from this sump are sampled.
The inspector was informed that the control room stopped pumping to
the Turbine Building Sump from the pipe tunnel when flooding was
identified.
A licensee representative also stated that corrective
action has been initiated in monitoring the potentially radioactive
release pathway.
The inspector stated that the efficacy of the licen-
see's actions will be reviewed at a later date.
(IFI 50-280/80-29-30
and 50-281/80-33-30).
The inspector accompanied licensee representatives while they performed
Periodic Test No. 26.2 entitled "Radiation Monitoring Equipment Test"
on the Liquid Waste Disposal System Monitor (RM-LW-108).
Alert and
alarm visual and audible annunciation was verified when the predeter-
mined setpoints were exceeded.
With assistance from an operator in
the basement of the Auxiliary Building, closure of discharge valves
HCV-LW-014A and B upon alarm activation was confirmed.
From estimates
of valve closure time and distance between monitor and valves, the
inspector concluded that no activity would be discharged following
alarm actuation.
A licensee representative stated that provisions for
flushing the discharge line upstream of HCV-LW-104A and B to the
discharge tank are available. The inspector had no further questions.
An inspector reviewed calibration records for* Liquid Waste Disposal
Monitor (RM-LW-108) and determined that all requirements of Technical
Specification 4.9(D) and Technical Specification Table.4.1-1 are being
fulfilled.
The inspector reviewed the licensee's method for determina-
tion of setpoints.
All requirements of Technical Specification
3.ll(A) are being met.
In fact, liquid discharge is based on 4% of
the MPC values listed in Appendix B of 10 CFR 20 rather than 16% as
specified in 3.ll(A)(2).
Total liquid effluents for calendar years 1977, 1978 and 1979 were
selectively reviewed from yearly Reports of Radioactive Effluents.
Discharges from the Liquid Waste Test Tanks (1980-1 to 1980-1981) and
discharges from the Contaminated Drain Tank (1980-1 to 1980-1982) for
calendar year 1980 were examined. All release requirements of Techni-
cal Specifications 3.ll(A) appear to have been performed as prescribed.
An inspector discussed with a licensee representative the station
program for monitoring strontium 90 (Transport Group II) and transmanics
(Transport Group I) in liquid releases.
A licensee representative
stated that a monthly composite, made from a certain small percentage
of each release, is sent to an outside consultant for strontium 90
analysis. Result-s are i~cluded in the Report of Radioactive Effluents.
A gross alpha analysi~ is performed oµ site and also included in the
effluent report.
The inspector had no further questions or comments
concerning strontium 90 or gross alpha analysis on liquid releases.
(However, see paragraph 12. e for comments and recommendations on
Transport Groups I and II evaluations on Solid Waste shipments).
d .
-33-
Based on the above findings, this portion of the licensee's program
appears to be acceptable, but the following matters should be considered
for improvement of the program:
(1)
permanent piping for the portable demineralization ~ystem;
(2)
installation of water level indicators, pressure sensors, and
other equipment .to monitor the portable demineralization system
for potential leaks and control such leaks;
(3)
collection of groundwater prior to processing to reduce volume of
liquid handled by portable demineralization processing system;
(4)
establishment of system to control chemistry of water processed
prior to demineralization system to improve bed capacity;
(5)
relocate Liquid Waste Disposal System Monitor to area of lower
background; and
(6)
provide monitoring of potential radioactive release pathway from
Turbine Building sump.
Solid Waste Management
An inspector reviewed licensee records of solid waste generated in
1977, 1978 and 1979.
Volume and activity values were similar for 1977
and 1978.
An increase of almost 50% in solid waste volume shipped off-
site was experienced in 1979.
The activity correspondingly decreased
by almost a factor of two.
This abrupt change can be attributed to
the large volumes of low level waste resulting from the Steam Generator
Replacement Project (SGRP).
The licensee is planning a concerted effort to further reduce the
volume of radioactive solid waste generated from the Unit 1 SGRP.
Reuse of a large volume of material and equipment from the Unit 2 SGRP
will be beneficial, especially reusing wooden scaffolding.
A licensee
representative stated that new scaffolding is expected to be metal so
that it can be decontaminated to reduce accumulation of radioactive
solid waste. Wood scaffolding will later be cut up and shipped offsite.
A Health Physics technician will be positioned at the. entrance to the
Containment Building to restrict as much as possible the flow into the
building of material which would have to be handled as radioactive
waste afterwards.
Color coded trash bags are used throughout the
Radiation Control Area to separate radioactive from nonradioactive
trash.
Radioactive waste reduction is emphasized throughout worker
training.
Management of onsite solid waste will be facilitated by the construc-
tion of a Solid Waste Storage Building.
This facility is scheduled to
be completed by mid September 1980 and will be able to handle 100,000
cubic feet of solid waste.
The effectiveness of this building on the
solid waste management program for the Unit 1 SGRP will be reviewed
during a later inspection (IFI 50-280/80-29-31 and 50-281/80-33-31).
-34-
An inspector discussed with a licensee representative the feasibility
of acquiring a new LSA box compactor which has shown reductions of
noncompressible and compressible solid waste on the order of five to
one at other power plants.
The licensee representatives stated that
budget and adequate space problems have prevented the acquisition of
such a unit.
The inspector recommended that VEPCO seriously renew
their efforts to obtain this compacting system since reduction in
burial costs should offset initial acquisition costs and the system
would be very beneficial to the overall solid waste management effort
of the Unit 1 SGRP (IFI 50-280/80-29-32 and 50-281/80-33-32).
The existing compactor is located in the Auxiliary Building.
Daily
compacting is required to maintain the compacting room in an operable
condition.
The compactor operator is fully dressed out and wears a
respirator at all times.
He cuts open each bag before placing it in a
drum to* be compacted and removes any protective clothing or wet material
found.
Air is drawn from the room to the Auxiliary Building Exhaust
by the building ventilation system.
A licensee representative stated
that a portion of this room will be used by the Chemistry Department
as a post accident sampling station to meet the requirements of NUREG
0578.
The inspector concluded from discussions with licensee repre-
sentatives and personal observations that if this modification were to
occur as planned, additional space would be required for the trash
compac~ing operation (IFI 50-280/80-29-33 and 50-281/80-33-33).
Ari inspector reviewed the li~ensee's concrete solidification program
and was informed that only 55 gallon drums containing moist material
(i.e., mop heads, rubber booties, etc.) and contaminated water or acid
are concreted.
This operation is performed by the health physics
department.
All of the contaminated liquid from the Unit 2 Contain-
ment Building during the SGRP was solidified in the basement prior to
removal from the building. Health Physics Procedures HP-3.9-6 covers
the operation.
The inspector had no further questions on waste soli-
dification.
An inspector reviewed the licensee's resin dewater,ing program.
When a
demineralizer process train is depleted and removed from service, it
is placed in a roped off area for exposure control purposes. Operations
department has responsibility for handling the liquid waste disposal
system as well as dewatering spent demineralizers.
An inspector
observed a demineralizer being dewatered and verified that operations
procedure OP 22.9 was being adhered to.
The inspector had no further
questions or comments in this area.
Based on the above findings, this portion of the licensee's program
appears to be acceptable, but the following matters should be considered
for improvement of the program:
(1)
acquisition of an improved LSA compacting system to reduce compact-
able and non-compactable waste by a factor of four or five; and
-35-
(2)
move the existing compactor from its present location to an area
where more room is available in which to work.
(This becomes
imperative if a portion of the existing room is to be utilized by
the Chemistry Department as a post accident sampling station in
fulfillment of NUREG 0578 requirements.)
e.
Radioactive Waste Shipping
Following problems with a shipment of radioactive waste (see NRC:RII
Inspection Report 50-280/80-16 and 50-281/80-17) which resulted in the
imposition of an $8,000 civil penalty, the station completely revised
its "Packaging and Shipment of Radioactive Waste" procedure HP-3.9-4.
An inspector reviewed this procedure and concluded it properly addresses
the generic problems associated with the solid waste handling program
identified in the referenced inspection report. It appears to comply
with all applicable NRC, DOT, and State of South Carolina shipping and
burial regulations.
The procedure requires multiple surveys on containers before storage
on the radioactive waste storage pad. It is unlikely, therefore, for
any hot package to be stored and loaded with insufficient identification.
An inspector observed licensee's preparation and loading practices
surrounding a shipment of approximately 78 55-gallon drums on August 7,
1980.
A Quality Control engineer and an Assistant Health Physics
.Supervisor reviewed the two independent radiation surveys on each drum
performed in accordance with procedures by health pnysics technicians.
Operations, Quality Control, and Health Physics must sign off different
procedural steps before approval for shipment is granted.
The inspector selectively reviewed shipments records for calendar year
1980 and discussed preparation of shipping papers with licensee repre-
sentatives.
Activity is determined from dose rate readings at a
certain distance from the contain~r using tables supplied by a con-
sultant.
The inspector reviewed the consultant's calculations and had
no questions or comments.
Package weight estimations were obtained by
a weight cell located in the drumming room.
The inspector was informed
that each package is numbered and listed on shipping records rather
than a single shipment identification number.
The inspector recommended
that the licensee number each shipment in addition to each package to
facilitate tracking particular shipments if more than one is handled
on a given date (Inspector Followup Item 50-280/80-29-34 and 50-281/
80-33-34).
The inspector was informed by a licensee representative that the
isotopic abundance is determined by a GeLi analysis on a direct sample
of the waste in the case of spent resin shipments or a compilation of
smear survey results (mostly from a steam generator diaphragm) for
shipments of compacted trash. The inspector stated that some methodical
sampling of trash may give a more ac.curate indication of isotopic
abundances.
-36-
When asked how Transport Groups I and II are determine<l, a licensee
representative stated that previous calculations indicate values less
than a small percentage of LSA limits.
The inspector stated that a
better estimate of Groups I and II isotopes should be made as these
isotopes are expected to concentrate in resin beds, evaporator bottoms,
and possibly trash.
A ratio of applicable isotopes in the primary
coolant can be used to determine isotope abundance from GeLi analyses
on waste packages.
The inspector stated that the only exemption from
listing Groups I and II isotopes on the shipping records is that found
in 10 CFR 71.7(a) which exempts the licensee from all requirements for
packaging and transporting radioactiv*e wastes, including isotope
identification, if each package contains less than 0.002 microcuries/
gram of licensed material.
A licensee representative stated that
further investigation of this matter will be done (IFI 50-280/80-29-35
and 50-281/80-33-35).
The inspector asked why no specific verification is documented for 1)
shoring and bracing when applicable, 2) strong-tightness containers
for LSA packages, or 3) issuance of special instructions to drivers of
exclusive-use vehicles.
A licensee representative stated that the
shipping form requires the Assistant Health Physics Supervisor to sign
a statement which verifies that all regulation requirements are satisfied.
The inspector informed the licensee representative that other power
plants provide adequate documentation and that the paper package would
not be too cumbersome.
It was recommended that the licensee provide
more detailed documentation for certain radioactive waste shipment
requirements (IFI 50-280/80~29-36 and 50-281/80-33-36).
Based on the above findings, this portion of the licensee's program
appears to be acceptable, but the following matters should be considered
for improvement of the program:
(1)
provide more accurate estimates of the amount of Transport
Groups I and II isotopes in each radwaste shipment;
(2)
establish shipment numbering system; and
(3)
document in more detail the verification of certain shipment
requirements (i.e., shoring and bracing, strong-tight containers
for LSA material, and special instructions to drivers of exclu-
sive-use vehicles).
13.
Facilities and Equipment
a.
Facilities
(1)
Personnel Decontamination
Separate sinks, showers and radioactive drains are provided in the
auxiliary building access control area. Radiation detection instru-
ments for alpha, beta and gamma are available as well as personnel
-37-
decontamination supplies.
Specific procedures are in place for
removal of skin contamination (Health Physics Manual section 2.4).
A relatively large change room area, individual lockers, showers,
and bathroom facilities are located adjacent to the radiation con-
trol area entrance. During the time of the appraisal, the change
area appeared very crowded and required continuous housekeeping
efforts.
The number of people using the area, the location of
protective clothing sources, and spacing of aisles provided for a
very inefficient and conflicting traffic pattern.
(2)
Laundry
The protective clothing processing area is located near the auxil-
iary building access control point.
The area has a stainless
steel floor, radioactive drains and filtered ventilation as well
as provisions for survey, folding, and storage of the laundry on
change room shelving.
The maximum radiation level for reuse of
laundry on change room shelving.
The maximum radiation level for
reuse of laundry is 2.5 mR/hr (fixed activity).
An independent
survey of clean laundry ready for issue indicated all ievels less
than one mR/hr.
Surveys of individual garments indicated levels
within the requirements of the procedure.
The Standing Radiation Work Procedure for laundry work specified*
lab coats as minimum protective clothing.
On two occasions the
appraiser noted laundry personnel in personal clothing, with no
protective clothing other than gloves (Infraction 50-280/80-29-16
and 50-281/80-33-16) .
. (3). Calibration Room
(4)
The calibration facility is a-room of approximately eight feet by
twelve feet adjacent to the entrance to the auxiliary building.
The area is normally locked and is posted as a radiation area. The
room has no ventilation or air conditioning and, at the time of
the appraisal, was extremely hot and humid.
The ambient condi-
tions were such that the efficiency of the calibration operation
was affected and could affect the accuracy of the instrument
calibration itself.
Discussions with licensee representatives indicated an awareness
of this problem and that corrective action was being implemented
(IFI 50-280/80-29-37 and 50-281/80-33-37).
Counting Room
The counting room is located adjacent to the health .physics
office area.
It provides space for two GeLi detectors, scintil-
1;:ition counter, gas flow proportional counter and GM counting
equipment.
t
-38-
(5)
Dose Control Areas
Two dose control areas are provided at the Surry facility.
The
primary dose control area is adjacent to the health physics
office at the entrance to the clean change room.
All personnel
entering radiation controlled areas are required to report to dose
control for issuance of self reading dosimeters and respiratory
protection authorization.
Personnel record files are available
for use in verification of respiratory authorization.
The second
dose control area is provided for the special steam generator
replacement project at the entrance from the construction site.,
Similar facilities are available at that location.
(6)
Respirator Cleaning, Decontamination, Inspection, Packaging and
Issue Area
A respirator work area is located near the entrance to the auxil-
iary building. Separate sinks with radioactive drains are provided
for respirator cleaning and decontamination.
Racks are provided
above the sinks for air drying of cleaned respirators. Friskers
are provided for surveys and a storage shelf is available for
placement of ready for issue respirators.
The operator at this
station is also responsible for recording mask numbers and personnel
to whom ma~ks are issued upon presentation of an approved mask issue
slip.
A random sampling of respirators were removed from the ready for
issue shelves and surveyed for radiation and contamination.
No
significant radiation or contamination levels were detected.
(7)
Respirator Repair Area
A separate room located in the auxiliary building is provided for
respirator repair.
Supplies of respirator repair parts and work
benches are located in this area.
(8)
Access Control Points and Friskers
An access control point is provided in the service area at the
entrance to the auxiliary building.
Personnel entering the
radiation control area are required to log in with name and
radiation work procedure to be followed.
HP personnel verify
familiarity with Radiation Work Permit requirements and assure
appropriate dosimeters on the individual.
Also located at this
control point is a building floor plan of the auxiliary building
and Unit 1 and 2 containments. Current radiation and contamination
levels and radiation area barriers are tndicated on these floor
plans.
Copies of Standing Radiation Work Permits are posted at
this location.
Friskers and portal monitors are located at the
exit from the radiation control point which is adjacent to the
access control point.
b.
-39-
Equipment
(1)
Protective Clothing
An adequate supply of protective clothing, lab coats, coveralls,
shoe covers, gloves, and plastic clothing is readily available in
the change room area.
It is recommended that surgeon caps be
provided for those personnel who are required to wear full face
- respirators or SCBA units (IFI 50-280/80-29-38 and 50-281/80-33-38).
(2)
Laboratory Instruments
(a)
Two computer based multi channel analyzer systems with GeLi
detectors are provided.
(b)
A liquid scintillation counting system is provided.
(c)
A proportional counter system is provided for counting of
alpha and beta samples.
The response of all equipment to check sources is determined
daily. Calibrations are performed routinely. Analytical capability
of the laboratory was recently evaluated by NRC regional personnel
with the Region II Mobile Laboratory (see NRC:RII Inspection Report
50-280/80-21; 50-281/80-22).
(3)
Portable Instruments
(a)
The station maintains a supply of approximately 300 radiation
detection instruments, including friskers, air sample counters,
portal monitors to dose rate instruments.
The facility pri-
marily uses GM tube-type instruments for both survey and
exposure rate measurements.
(b)
Instrument repair records and history are maintained by the
Electronic Calibration laboratory. A card file of instrument
calibration due dates is maintained and notification *made to
Health Physics when instruments are due for recalib~ation.
Instruments are returned to the calibration laboratory for
electronic calibration and repair as_necessary, and are then
sent to HP for radioactivity calibration.
A calibration
sticker issued by the calibration laboratory is then placed
on each instrument.
A random review of instrument history
and repair records indicated that repair history did not
appear to be excessive for the number of instruments in
service.
History and calibration records were in place and
complete .
The station has available two neutron sources, two cobalt-60
sources, several millicurie size cesium-137 _sources and a
multiple source gamma calibrator.
The multiple source gamma
~
-40-
calibrator, an Eberline model lOOOB, is the primary calibra-
tion device for dose rate instruments and for the thermo-
luminescent dosimeters (TLD).
Source certification from the
manufacturer was in place for the sources.
Documentation to
support the dose rate values posted on the multiple source
gamma calibrator was not available at the time of the appraisal.
Discussions with the licensee representatives indicated that
calibration of the device using condensor R chambers had been
accomplished. Review of intercomparison between self reading
pencil dosimeters (calibrated with a certified cobalt-60 source)
and TLD readings supported the values of the multi source gamma
calibrator. In addition, results of the University of Michigan
intercomparison tests indicated results consistent within an
appropriate calibration.
The appraisers recommended a review of the calibration of the
multi source gamma calibrator using certified transfer instru-
ments and documentation of that calibration. It was also
recommended that a routine calibration of the device onsite
by implemented (IFI 50-280/80-29-39 and 50-281/80-33-39).
Observations of instrument calibrations indicated that not
all the recommendations of ANSI N323-1978 were being met.
It is recommended that a review of the calibration probram
be made to assure meeting the criteria of ANSI N323 (IFI
50-280/80-29-40 and 50-281/80-33-40).
Portable radiation detection instruments are electronically
calibrated and only selected probes (those used for smear
counting stations) are calibrated to a radiation source to
determine detector efficiency.
All other probes such as
those used for routine surveys and personnel frisking are
response checked and are assumed to have a 10% detector
efficiency.
Response checks, as recommend~d in section 4.6
of the above standard, should be implemented to assure
appropriate response of detection instruments (IFI 50-280/
80-29-40 and 50-281/80-33-40).
Neutron sources are available and are primarily used as a
check of detector operation.
For these sources to be con-
sidered as a calibration source, it would be advisable to
have an onsite National Bureau of Standards traceable cali-
bration source.
Calibration of neutron instruments was not
observed during this appraisal.
Data on calibration of each instrument is completed on form
HP 3.2-17.1 and filed in the calibration laboratory in each
instrument history file .
-41-
c.
Based on the above findings, this portion of the licensee's program
appears to be acceptable, but the following matters should be considered
for improvement of the program:
(a)
provide ventilation and/or air conditioning for calibration room
as excessive heat and humidity affects calibration sensitivity;
(b)
provide surgeon caps for personnel required to wear full face
respirators or SCBA units;
(c)
ensure accurate calibration of multi-source gamma calibrator
using certified transfer instruments;
(d)
implement a routine on-site calibration of the multi-source gamma
calibrator; and
(e)
review the calibration program to ensure adherence to all recommenda-
tions of ANSI N323-1978 .
HEALTH PHYSICIST
R. GAR.~ER
P.P. !'\\OTTINGHAH
c.E. rotz
ASS 'T. SVPERVISOR,
H.P.
Plant Survey Team, AL.ARA
Program, EBASCO & S & W
effort coordination, RWP
Desk operation RWP program.
H.~. TRAINING
..
- ----
--- ------- - ---
STATlON MANAGER
R. M. S!-1:ITH
SUPERVISOR
HEALTH Pl
HEALTH PHYSICIST
D. G:lEENE
- ADMINISTRATIVE ASSISTANT
M.B. MOODY
CLEJU~-TYPIST
C .11. CROWLEY
- ' *
D. DENS!-10RE
ASS')'*, SCP!~RVISOR.
H.P.
All aspects o!: the Stn-
tion Dose Control Pro-
gram.
H, P, ;.'RAINING
H.A. ANGLIN
ASS'T. Sl1PFRVISOR,
11. p.
All aspects of Statjun
Laundry Operations and
Respiratory Protection
Programs. Jnstrument Ac-
countability. Decontami~
nat:ion Team.
11. P. 'l'l{AINING
M.R. BECKHAM
ASS'T. SUPERVISOR,
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