ML18142A483
| ML18142A483 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/08/1985 |
| From: | Albright R, Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18142A482 | List: |
| References | |
| 50-280-85-13, 50-281-85-13, NUDOCS 8506270694 | |
| Download: ML18142A483 (7) | |
See also: IR 05000280/1985013
Text
Report Nos.:
50-280/85-13 and 50-281/85-13
Licensee:
Virginia Electric and Power Company
Richmond, VA
23261
Docket Nos.:
50-280 and 50-281
License Nos.:
Facility Name:
Surry 1 and 2
Inspection Conducted:
April 15-19, 1985
Inspectors: ~ ~
R.H. Alb~\\
~,~
B. K. Revs_r __
\\
Approved by* f:.N\\ Jl~
. ~C~-
. ...e,M~. ""H--cff--s>,.jef-y-,-S-e_c_t-1,-i~-n-C~h-i-e~f-----------
Di vision of Radiation Safety and Safeguards
SUMMARY
Date Signed
Date Signed
~,t: ,i~r:
Scope:
This routine, unannounced inspection involved 66 inspector-hours on site
in the areas of external occupational dose control and personal dosimetry,
i nterna 1 exposure contro 1 and assessment, contra 1 of radioactive materi a 1 s and
contamination, surveys and monitoring, audits, and radiological problem reports.
Results:
One violation - failure to properly label radioactive material.
r- -8506270694 850516 _____ -~
1
ADOC~ 05000280
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2
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
2 .
- H. L. Miller, Assistant Station Manager
- W. D. Grady, Supervisor, QA
- S. P. Sarver, Superintendent, Health Physics
- G. R. Belongia, Quality Assurance
- R. C. Bilyeu, Licensing Coordinator
- K. R. Lefevre, Corporate Health Physics
- L. L. Morris, Supervisor, Health Physics
P. Nottingham, Assistant Health Physics Supervisor
D. Densmore, Assistant Health Physics Supervisor
Other licensee employees contacted included technicians, mechanics, and
office personnel.
- Attended exit interview
Exit Interview
The inspection scope and findings were summarized on April 19, 1985, with
those persons indicated in paragraph 1 above .. The unresolved item* (URI)
concerning labeling of radioactive material was discussed with licensee
management (paragraph 6).
Licensee management was notified in a telephone conversation on May 2, 1985,
between S. Elrod of the NRC Region II staff and H. L. Miller, Assistant
Station Manager, that the failure to properly label radioactive material
would be considered a violation of 10 CFR 20.203(f).
The licensee did not identify as proprietary any of the materials provided to
or reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Inspection Findings
Not inspected.
- An Unreso 1 ved Item is a matter about which more information is required to
determine whether it is acceptable or may involve a violation or deviation .
3
External Occupational Dose Control and Personal Dosimetry (83724)
During plant tours, the inspector checked the security of the locks at
locked high radiation areas and observed survey results and the use of
controls specified on selected radiation work permits (RWPs).
a.
Use of Dosimeters and Controls
b.
C.
The licensee was required by 10 CFR 20.202, 20.201(b), 20.101, 20.102,
20.104, 20.402, 20.403, 20.405, 19.13, 20.407, and 20.408 to maintain
worker's doses below specified levels and keep records of and make
reports of doses.
The licensee was required by 10 CFR 20.203 and
Technical Specification 6.4 to post and control access to plant areas.
During observation of work in the plant, the inspector observed the
wearing of Thermoluminescent Dosimeters (TLDs) and pocket dosimeters by
worker~._ ~uri ng p 1 ant tours, the inspector observed the posting of
areas and made independent measurements of dose to assure proper
posting.
Processing of Dosimeters
The inspector discussed with the Dosimetry Supervisor the flow of the
TLD badge from -its, return by a worker through the record.i ng of
information (dose) from the readout on the worker
1 s dose record, to
determine areas where information could possibly be mishandled.
The
inspector discussed, with the Dosimetry Supervisor, the system for
comparison of TLD and pocket dosimeter results. The inspector reviewed
selected exposure investigations for the period January 1984 to April
1985.
The inspector discussed with the Dosimetry Supervisor, the
licensee 1s quality control and assurance measures for assuring accurate
dosimetry results.
Dosimetry Results
The inspector reviewed selected plant group TLD results for the period
January 1985 to Apri 1 1985.
For ten i ndi vi dua 1 s who received greater
than 1.25 rems in one quarter, the inspector examined each individual 1s
dosimetry file to determine if NRC Form 4s had been completed.
The
inspector examined one case where a dose was adjusted. The inspector
reviewed the results of the TLD vs. pocket chamber comparisons for the
month of August 1984.
No violations or deviations were identified.
5.
Internal Exposure Control and Assessment (83725)
The licensee was required by 10 CFR 20.103, 20.20l(b), 20.401, 20.403, and
20.405 to control uptakes of radioactive material, assess such uptakes, and
kee~ records of and make reports of such uptakes .
4
a.
Control Measures
During plant tours, the inspector observed the use of temporary
ventilation systems, containment enclosures, and respirators.
b.
Respiratory Maintenance and Issue
The inspector observed the issuance of respirators and reviewed records
for five workers who were issued respirators to determine if they were
qualified for the respirators issued.
c.
Respiratory Fit Testing and Training
The inspector bbserved operation of the respirator fit test booth and
discussed fit testing with the operator of the booth.
d.
Uptake Assessment
The inspector discussed whole body counting and bioassay sampling with
a whole body counter operator.
No personnel were identified during the
period January 1984 to April 1985 who required uptake evaluations due
to receiving greater than 40 maximum permissible concentration-hours
(MPC-HRS) in one week or greater than 10% maximum permissible body
burden.
No violations or deviations were identified.
6.
Control of Radioactive Materials and Contamination, Surveys, and
Monitoring (83726)
The licensee was required by 10 CFR 20.20l(b), 20.403, and 20.401 to perform
surveys and to maintain records of such surveys necessary to show compliance
with regulatory limits. Survey methods and instrumentation were outlined in
the FSAR, Chapter 12, while Technical Specification 6.4 provided the
requirement for adherence to written procedures.
Radiological control
procedures further delineated survey methods and frequencies~
a.
Surveys
The inspector observed, during plant tours, results of surveys
performed by the radiation protection staff. The inspector reviewed
two Radiation Work Permits, one for removal of the lower reactor
internals and one for steam generator girth weld inspection, to deter-
mine if adequate controls were specified. The inspector discussed the
controls and monitoring with a Radiation Protection Supervisor and with
the Health Physics Superintendent.
During plant tours, the inspector examined radiation level and
contamination survey results for selected areas.
The inspector
performed independent radiation level surveys of selected areas and
compared them. to licensee survey results.
The inspector reviewed
selected survey records for the month of April 1985, and discussed with
licensee representatives, methods used to disseminate survey results.
5
The inspector noted that all observed locked high radiation areas
inside and outside containment were maintained as required by Technical
Specification 6.4. The inspector also noted that during the past year,
approximately 41% of the previously designated contamination control
area had been cleaned and was now maintained as clean.
b.
Frisking
During tours of the plant, the inspector observed the exit of workers
and the movement of material from contamination control to clean areas
to determine if proper frisking was performed by wo*rkers and if proper
direct and removable contamination surveys were performed on materials.
The
inspector reviewed selected records of skin contamination
occurrences and resulting evaluations and corrective actions.
Records
and discussions with licensee representatives showed that contamination
had been promptly removed from the workers using routine washing
techniques.
Subsequent whole body counts showed less than detectable
internal deposition of radioactive material.
c.
Instrumentation
During plant tours, the inspector observed the use of survey instru-
ments by the plant staff., and -compared plant survey instrument readings
with readings made by the inspector using NRC equipment.
The inspector
examined calibration stickers on radiation protection instruments in
use by licensee staff, stored in the calibration facility and the
instrument issue room, and at frisker and air sampling stations
throughout the plant. The inspector discussed calibration methods and
methods for performing source checks prior to each instrument use with
the radiation protection technician in charge of calibrations and with
the Health
Physics Superintendent.
Procedures and methods for
calibration of teletectors, R0-2s and R0-2As, as well as beta and
frisker calibrations were reviewed.
Several areas of the instrument calibration program were identified as
needing upgrading.
These were as follows:
(1) Verification of *calculated decay curves for all calibration
sources.
The inspector stated to the licensee that calculational
errors in
source decay corrections may
affect instrument
calibration and should be verified by an individual other than the
radiation protection technician who performed the original decay
calculations.
(2)
Procedural revisions to include Co-60 beam recertification every
three years, retention of repair/maintenance histories for each
instrument, independent review of each calibration certificate to
insure adequacy and completeness of each instrument calibration,
and evaluation of appropriate test points for use in instrument
reproducibility (precision) testing, and inclusion of two such
test points for teletectors since they have both a high range and
a low range detector.
- - - - - -
6
The licensee acknowledged the improvement items identified by the
inspector and stated that source decay calculations would be verified
by a health physicist by June 1, 1985.
The licensee further stated
that this requirement for verification of source decay calculations
would be incorporated into written procedures by January 1, 1986.
The
licensee informed the inspector that calibration certificates for all
instruments will be revised to reflect precision test points by
September 1, 1985, and that these test points would be incorporated
into written procedures by January 1, 1986.
The inspector informed the
licensee that the instrument calibration program and the above items
would
be
reviewed
during
a
subsequent
inspection.
(50-280,
281/85-13-01).
d.
Release of Materials for Unrestricted Use
The inspector discussed with a radiation protection technician and a
Health Physics Supervisor, the program for surveying items released from
contaminated areas and reviewed the procedures for such rel ease.
During tours of plant areas, the inspector observed posting of
containers and performed independent surveys to determine if containers
of radioactive material were properly identified
e.
Caution Signs, Labelsr Signals and Controls
10 CFR 20.203(a) required that symbols prescribed by this section shall
use the conventional radiation caution colors (magenta or purple on
yellow background).
10 CFR 20.203(f) required that each container of
licensed material shall bear a durable, clearly visible label
identifying the radioactive contents when quantities of radioactive
material exceed those specified in Appendix C.
During tours of the plant, the inspector observed the use of purple
plastic bags with black markings for containing radioactive material.
In addition, a piece of contaminated insulation was noted which had
been wrapped in yellow herculite and placed behind a rope barrier
posted with a radioactive material sign.
The side of the herculite
package was labeled with a dose rate; however, the radiation caution
symbol and the words
11Caution
11 or
11Danger - Radioactive Material
11 were
not present.
The dose rate from this package was approximately
30 mR/hr.
These practices are inconsistent with the requirements
pursuant to 10 CFR 20.203(a) and 10 CFR 20.203(f).
The inspector discussed these areas with licensee representatives who
indicated that the Radiological Control Area (RCA) was considered a
work area, and thus would not require specific labeling for each
container since the RCA, itself, is posted as both as a radiation area
and
a radioactive materials area.
Additionally,
the licensee
representative indicated that the purple bags with black, warning
markings met the intent of 10 CFR 20.203(a) since workers had been made
aware of this situation. The inspector stated that the use of purple
bags with black markings appears not to meet the labeling requirements
of 10 CFR 20.203(a) and (f).
, ...
7
Failure of the licensee to label containers of radioactive material with
a label that bears the standard radiation caution symbol and the words
-
11 CAUTION or DANGER RADIOACTIVE MATERIAL
11 is an apparent violation of
10 CFR 20.203(f) (50-280, 281/85-13-02).
7.
Audits
The licensee was required by Technical Specification 6.1 to perform audits
of radiological controls and chemistry operations.
The inspector reviewed
audits of the radiation protection operations dated June 1984 and January
1985, the responses to these audits, and the status of selective corrective
actions resulting from the audits.
The inspector discussed the results of
these audits with licensee representatives.
No violations or deviations were identified.
8.
Radiological Problem Reports
The inspector discussed with the Superintendent of Health Physics a
Radiological Problem Report dated April 16, 1985.
The Radiological Problem
Report described a situation where workers had signed in on an incorrect
Radiation Work Permit (RWP) for snubber removal.
The result was that the
workers wer~ not properly dressed for the snubber removable (i.e., no rain
suit or respirator).
When the workers reported to the health physics (HP
technician, who would provide health physics coverage for their work, the HP
technician told the workers that they could not start work, that they were
not properly dressed and that he needed time to set up the job and change
his air samp 1 er head.
The four workers i nvo 1 ved were new contract
mechanics.
When the HP technician returned to t~e job site, he found that
the work had been completed. Three of the four workers were found to have
facial contamination.
Whole body counts performed on the four workers after their decontamination
did not indicate any internally deposited contamination.
The licensee
restricted the workers from the RCA until corrective action (counseling the
workers on compliance with requirements for radiological work) was complete.
The licensee was notified that the failure of the workers to comply with the
RWP requirements was a violation, however, this would be considered a
licensee identified violation because the criteria in 10 CFR 2, Appendix C
(V)(A) for a licensee identified violation had been satisfied.