ML18143B433
| ML18143B433 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/18/1985 |
| From: | Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18143B431 | List: |
| References | |
| 50-280-85-21, 50-281-85-21, NUDOCS 8508280427 | |
| Download: ML18143B433 (10) | |
See also: IR 05000280/1985021
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION 11
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
AUG 14 1985
Report Nos.:
50-280/85-21 and 50-281/85-21
Licensee:
Virginia Electric and Power Company
Richmond, VA
23261
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.:
Inspection Conducted:
June 17 - 21, 1985
Inspector: ~
T. R. Col ins
Accompanying Personnel:
C. M. Hosey
. ,
{ /'i 8 , K, Revs i n
Approved by:~ /f\\r7'~
C. M. Hosey, Section\\Chief
Division of Radiation Safety and Safeguards
SUMMARY
,Date Signed
Scope:
This routine, unannounced inspection entailed 33 inspector-hours on site
during regular hours inspecting the radiation protection program including:
training and qualifications of personnel; internal and external exposure control;
radioactive materials control, posting and labeling; program for maintaining
exposures as low as reasonably achievable .(ALARA); transportation of radioactive
material; and 10 CFR Part 61 requirements.
Results:
One violation - failure to properly classify radioactive wastes.
( 8508280427 850814 -
1. -~DR
ADOCK 05000280
\\.ll
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- R. F. Saunders, Station Manager
- H. L. Miller, Assistant Station Manager
- R. F. Driscoll, Manager, Quality Assurance
- L. L. Morris, Supervisor, Health Physics
- W. D. Grady, Supervisor, Quality Assurance
- S. P. Sarver, Superintendent, Health Physics
- H. F. Kahnhauser, Corporate Health Physics
M. Beckham, Asst. Supervisor, Health Physics
C. Folz, Asst. Supervisor, Health Physics
L. Thomason, Corporate Health Physics
R. Miller, Training
J. Sukosky, Dose Control
Other
licensee
employees
contacted
included technicians,
operators,
mechanics, security force members, and office personnel.
NRC Resident Inspectors
D. Burke
- M. J. Davis
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on June 21, 1985, with
those perions indicated in paragraph 1 above.
The unresolved item* (URI)
concerned classification of radioactive wastes designated for near surface
land disposal was discussed in detail (paragraph 8).
Licensee management was notified in a telephone conversation on July 1,
1985, between S. Elrod of the NRC
Region II staff and
H. L. Miller,
Assistant Station Manager, that the unresolved item for failure to properly
classify radioactive material designated for near surface burial would be
considered a violation of 10 CFR 20.311.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspectors during this inspection.
- An Unresolved Item is a matter about which more information is required to
determined whether it is acceptable or may involve a violation or deviation.
- 3.
2
Training and Qualifications (83723)
a.
Basic Radiation Protection Training
The licensee was required to provide basic radiation protection
training for
workers by 10 CFR 19.12, with Regulatory Guides 8.27,
8.29, and 8.13 outlining topics that should be included in such
training.
Chapters 12 and 13 of the FSAR contain further commitments
regarding training.
The inspector discussed the initial and refresher
general employee radiation protection training (GET) with the Training
Supervisor and reviewed course outlines and examinations that described
the new GET training program implemented in January 1985, by the
1 i cen see.
A 11 p 1 ant personne 1 had been re qui red to comp 1 ete the new
training program.
The inspector discussed the training tracking system
with the licensee and found adequate controls were in place to assure
that radiation worker training was up-to-date.
b.
Health Physics and Chemistry Technician Training
The licensee was required by Technical Specification 6.1 to qualify
hea 1th physics and chemistry technicians in accordance with ANSI
N18 .1-1971.
The inspector reviewed the course out 1 i ne and 1 es son
p 1 a n s fo r th e he a lt h p hy s i c s ( H P ) t e c h n i c i a n tr a i n i n g pro g ram .
The
program was divided into eight discrete steps, each of which required
six months for completion and which combined classroom as well as
on-the-job training.
The trainee was considered ANSI qualified upon
completion of the training program.
The -licensee projected that the HP
training program will be submitted to the Institute for Nuclear Power
Operations (INPO) for accreditation in August 1985.
A similar program
for chemistry technicians was under development.
The inspector determined that HP technician requal ification was an
on-going process whereby every fifth week, the technician was in
training.
The inspector reviewed the course outline and lesson plans for a new
category of HP technician which had been designated HP Specialist. The
program consisted of training through three, six-month steps, each of
which was specifically related to the job the technician would be
expected to perform.
Individuals in these positions would not rotate
to other HP duties.
c.
Respiratory Protection Training
The licensee was required by 10 CFR 20.103 to establish a qualification
program for workers who
wear respiratory protective
equipment.
Elements of the qualification program outlined in 10 CFR 20.103 were
delineated in NUREG-0041.
The inspectors discussed the respiratory
protection training with the training supervisor, and the course
outline and examination were reviewed.
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No violations or deviations were identified.
4.
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
During plant tours,
the inspector examined radiation level and
contamination survey results outside selected cubicles.
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 June 1985 and discussed with
licensee representatives methods used to disseminate survey results.
The inspector reviewed the Radiation Work Permit (RWP) controlling the
1 oop seal valve repairs and examined beta survey results associated
with this repair.
The inspector noted that selected lock.ed high
radiation areas inside the auxiliary building were maintained as
required by Technical Specification 6.3.
The inspector also noted that
since January 1985, 12% of previously designated contamination control
areas had been cleaned and were 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 workers and if proper
direct and removable contamination surveys were performed on materials.
The
inspector
reviewed
selected records
of
skin
contamination
occurrences.
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 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 .
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d.
4
Release of Materials for Unrestricted Use
The inspector discussed with a health physics technician and the Health
Physics Supervisor (Operations) the program for releasing items from
contaminated areas and reviewed the procedures for such releases.
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.
No violations or deviations were identified.
5.
Facilities and Equipment (82727)
FSAR Chapters 1 and 12 specified plant layout and radiatio"n protection
facilities and equipment.
During plant tours, the inspector observed the
flow of traffic thru change rooms, the use of temporary shielding, and the
use of ventilated containment enclosures.
No violations or deviations were identified.
6.
Audits (83728, 86721, 83724 and 84722)
The jnspector discussed the audit and surveillance program in the areas of
radiation protection and transportation of radioactive material
with
licensee representatives.
The
following Quality Control
audits were
examined:
SAC-37,
11 Radiation Work Permits,
11 February 24, 1984
SAC-06,
11 Health Physics Dose Control Records," March 29, 1984
SAC-32,
11 Respiratory Protection Program,
11 April 9, 1984
SAC-05,
11General Employee Training,
11 April 11, 1984
SAC-25,
11 Radioactive Waste,
11 September 14, 1984
No violations or deviations were identified.
7.
Transportation (86721)
10 CFR 71.5 required that shipments of radioactive material be prepared in
accordance with Department of Transportation (DOT)
regulations.
The
inspector observed the preparation of shipment #B85-48 of dry active waste
(DAW) and discussed the shipment with the shipping supervisor and a health
physics technician.
The inspector reviewed the procedure under which the
shipment was made and the resulting documentation.
The inspector reviewed
recent changes to shipping procedures and selected records of shipments of
radwaste for the month of June 1985 and verified that the licensee was
registered with the NRC for packages used in June 1985.
5
No v1olations or deviations were identified.
8.
Solid Wastes (84722)
10 CFR 20.311 required that licensees who transfer radioactive waste to a
land disposal facility prepare all wastes so that the waste is classified
according to 10 CFR 61.55.
10 CFR 61.55(a)(8) provided that the concentration of a radionuclide may be
determined by indirect methods such as the use of sealing factors which
relate the inferred concentration of one radionuclide to another that is
measured provided that there is reasonable assurance that the indirect
methods can be correlated with actual measurements.
The NRC
11 Low-Level Waste Licensing Branch Technical Position of Radioa~tive
W a s t e C l a s s if i cat i o n ," May 19 8 3 , pa rag rap h C , s tat e d that a re a so n ab l e
target for determining measured or infe~red radionuclide concentrations is
that the concentrations are accurate within a factor of ten.
The factor of
ten was permitted to take into account the various uncertainties involved
with obtaining a representative sample and with performing the laboratory
analysis.
The inspector reviewed procedure HP-3.2.9,
11 Radwaste
..c
Packaging and
Shipment of Solid Radioactive Waste to Barnwell, South Carolina,
11 June 17,
1985.
The licensee I s program for determining sealing factors for estimating
concentrations of difficult to measure radionuclides from concentrations of
readily measurable radionuclides was developed by an off-site contractor and
submitted to the licensee in April 1984.
The measurements were performed on
samples collected in 1983.
In 1984, additional samples from various plant
waste streams were sent for analysis in order to verify the original set of
scaling factors.
The licensee compared the analytic results of the 1984
samples with results obtained by ca lcul at i ng the concentrations of these
same radionuclides using the 1983 scaling factors.
Analysis of ratios from
comparing actual measurements versus concentrations determined by using the
scaling factors resulted in nonconservative nuclide concentration deter-
minations for 61% of the 20 scaled nuclides in the seven waste streams.
Of
this 61%, 25% were nonconservative by greater than a factor of ten.
The
majority of these differences were observed for the nuclides Sr-90, Tc-99
and C-14.
Consequently, new scaling factors were determined for these
nuclides based on the 1984 sample analyses.
All other scaling factors,
i.e., those determined from the 1983 sample analyses, were retained.
Examination of the ratios of the transuranic elements obtained from actual
measurements versus the concentrations determined by using scaling factors
revealed that 1984 nuclides computed with 1983 scaling factors resulted in
nonconservative nuclide concentration determinations for 65 percent of the
14 scaled transuranic nuclides in the seven waste streams.
Of this 65%,
fifteen percent were nonconservative by a factor greater than ten.
The most
significant nonconservative result was seen in sample #61-1091, liquid waste
6
resin,
where
13
of
the
14
transuranic nuclides were
estimated
nonconservatively, with six or 46 percent being nonconservative by a factor
greater than ten.
The data from sample #61.:.1091 appears below.
In the
ratio column, those values preceeded by a minus indicate that the scaled
measurement is in the nonconservative direction.
Sample #61-1091
Nuclide
Pu-241
Cm-242
and Pu-240
Pu-242
and Np-237
Cm-243
and Cm-244
Scaled
To:
Ce-144
Ce-144
Ce-144
Ce-144
Ce-144
Ce-144
Ce-144
Scaling
Factor
4 .18E-1
5.08E-3
3.87E-3
8.61E-5
3.46E-3
3.69E-5
1.14E-3
1.16E-5
2.36E-3
3.50E-5
3.2E-5
4.6E-7
9 .13E-3
l.60E-5
Calculated Using
Scaling Factor
l.32E-3
3.79E-3
2.69E-5
6.68E-5
9.21E-6
2.73E-5
2.86 E-6
8.54E-6
9.67E-6
2.64E-5
1. 26E-7
3.47E-7
4.65E-6
4.58E-6
- Indicates differences greater than a factor of ten.
Measured
Value
(µCi/cc)
8.lE-3
8. lE-3
6.2E-5
6.2E-5
1. 60E-4
1. 60E-4
8.4E-5
8.4E-5
5.0E-5
5.0E-5
<1.4E-5
<1.4E-5
6.0E-5
6.0E-5
Ratio
-6.14
-2 .15
-2.31
1. 08
-17.4*
-5.87
-29.4*
-9.83
-5 .17
-1.89
-112.0*
-40.4*
-12.9*
-13.1*
These data indicated that use of 1983 scaling factors was inadequate for
inferring 1984 transuranic nuclide concentrations in that when compared with
actual measurements, a factor greater than ten in a nonconservative
direction was often observed.
Additionally, it should be noted that the
transuranic actinides of Pu-242, NP-237, Cm-243 and Cm-244 should be scaled
to the fission product Ce-144 and not the activation product Co-60.
Isotopic analyses of the facility samples were performed by two different
contractors in 1983 and 1984 and it was noted that, in general, the analyses
performed in 1983 had a lower limit of detection (LLD) an order of magnitude
lower than that achieved by the 1984 contractor.
Such differences in
analytical results contribute to a variation greater than a factor of ten
when comparing measured to scaled results thus leading to nonconservative
estimates of scaled transuranics.
Use of nonconservative factors for
scaling transuranic elements may result in incorrect classification of waste
shipments.
7
Failure of the licensee to use actual measurements to determine scaling
factors as required by 10 CFR 61.55(a)(8) was identified as an apparent
violation of 10 CFR 20.311 (280, 281/85-21-01).
Previous plant history of the two units suggested that there may be
significant differences in ratios between scaled and measured isotopes
within the waste streams of the two units, particularly for DAW whose
difficult to measure radionuclides are scaled based on analyses of plant
smears.
Examination of DAW sample analyses from both 1983 (sample numbers
10397 and 10398) and 1984 (sample number 61-1093) showed considerable
variability in conformance to the factor of ten criterion suggesting that
distributions of the radionuclides were different in the various areas of
the plant where smears were obtained.
Smears were not identified as to
their point of origin so that it remained unclear as to whether potential
differences between Unit 1 and Unit 2 had been examined.
During the review of licensee records, the inspector noted that the licensee
used a single set of scaling factors for all transuranic radionuclides.
A
comparison of actual measurements v_ersus scaled transuranic radionuclide
ratios between the seven samples collected in 1984 suggested that sample
- 61-1091 (previous table) may represent a different waste stream since 46%
of its scaled transuranic isotopes differed by a factor greater than ten and
this degree of variation was not observed in the other samples.
Failure to
use individual sets of scaling factors for each distinct waste stream was
identified
as
another apparent violation
of
10 CFR
20.311. (280,
281/85-21-01).
9.
External Occupational Dose Control And Personal Dosimetry (83724)
During plant tours, the inspector checked the security of the locks at
various high radiation areas and observed postings of survey results.
a.
Use of Dosimeters and Controls
The licensee was required by 10 CFR 20.202, 20.20l(b), 20.101, 20.102,
20.104, 20.402, 20.403, 20.405, 19.13, 20.407, and 20.408 to maintain
worker
1 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.
FSAR Chapter 12 also contained commitments regarding dosimetry and dose
controls.
During observation of work in the plant the inspector
observed the wearing of thermoluminescent dosimeters (TLDs) and pocket
dosimeters by workers.
During plant tours, the inspector observed the
posting of areas and made independent measurements of dose to assure
proper posting.
b.
Dosimetry Results
The inspector reviewed the TLD results from .the Unit 2 outage and
verified that no radiation worker had exceeded administrative hold
points without proper authorization, that no worker had exceeded
' .
8
1.25 rems for the quarter without a complete Form NRC-4, and that no
worker had exceeded any regulatory limit.
TLD beta correction factors
were reviewed.
No violations or deviations were identified.
10.
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
keep records of and make reports of such uptakes.
FSAR Chapter 12 al so
includes commitments regarding internal exposure control and assessment.
The inspector discussed the internal exposures associated with the Unit 2
outage which was drawing to a close.
Individuals who gave a positive body
burden upon whole body counting (WBC) were required to shower and be
recounted.
Upon recount, no positive body burdens were observed.
No violations or deviations were identified.
11.
ALARA (83728)
10 CFR 20.lc states that persons engaged in activities under licenses issued
by the NRC
should make every reasonable effort to maintain radiation
exposure as low as reasonably achievable (ALARA).
The recommended elements
of an ALARA program are contained in Regulatory Guide 8.8,
11 Information
Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power
Stations will be ALARA,
11 and Regulatory Guide 8.10,
11 0perating Philosophy
for Maintaining Occupational Radiation Exposures ALARA.
11
The inspector discussed the ALARA goals and objectives for the current year
with licensee representatives and reviewed the man-rem estimates and results
for the current year.
As of the inspection, the actual collective exposure
for calendar year 1985 as measured by self-reading dosimeter was 1265 man-
rem.
The projected dose for the entire year of 1985 was 1144 man-rem.
Reaching the years' projected collective dose by June 1985 was explained by
execution of unbudgeted and thus unplanned maintenance and design changes
during the Unit 2 outage.
The inspector was informed that new collective
dose estimates were in the process of being projected for 1985.
The ALARA input into the Radiation Work Permit (RWP) system, staffing of the
ALARA section, use of engineering controls and shielding accountability, and
management support and commitment to the ALARA program was discussed with
the licensee.
The extent of contaminated areas within the facility had decreased during
the current year. even though Unit 2 had been in a major outage for
refueling, maintenance, and inspection for the past three months.
In 1985,
approximately 12 percent or 4000 square feet had been recovered and was
being maintained as clean.
The active clean up program initiated by the
licensee was responsible for this progress.
-* .
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9
As of May 1985, 37,399 cubic feet of radioactive waste containing 879.02
curies had been shipped off-site for disposal.
No violations or deviations were identified.
12.
IE Information Notices (92717)
The following IE Information Notices were reviewed to ensure that receipt
and r~view by appropriate licensee management was performed.
84-24, Physical Requalification of Individuals to Use Respiratory
Protective Devices
84-34, Respirator User Warning:
Defective Self-Contained Breathing
Apparatus Air Cylinder
84-40, Emergency Worker Doses
84-59, Deliberate Circumventing of Station Health Physics Procedures
84-60, Failure of Air-Purifying Respirator Filters to Meet Efficiency
Requirement
84-61, Overexposure of Diver in Pressurized Water Reactor (PWR)
Refue 1 i ng Cavity
84-75, Calibration Problem - Eberline Instrument Model 6112B Analog
Detectors
No violations or deviations were identified.
13.
Followup On Previous Open Items (93701)
(Closed) IFI (50-280/83-23-01) The inspector verified that procedures were
in place to ensure access to the Operations Support Center in the event of
an emergency.
(Closed) IFI (50-280/84-02-03) The inspector verified that the cable of the
containment radiation monitors of both Units 1 and 2 had been placed in
conduit.
(Closed) IFI (50-280/83-34-04) The inspector verified that the licensee was
in the process of establishing a policy for the use of canister respirators
in contaminated areas and that this policy will be incorporated into
procedures that were in the process of being written.
_J