ML18152A274
| ML18152A274 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/20/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A275 | List: |
| References | |
| 50-280-98-03, 50-280-98-3, 50-281-98-03, 50-281-98-3, NUDOCS 9804270236 | |
| Download: ML18152A274 (21) | |
See also: IR 05000280/1998003
Text
1
U.S. NUCLEAR REGULATORY COMMISSION
REGION I I
Docket Nos:
License Nos:
Report Nos:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by:
9804270236 980420
ADOCK 05000280
G
50-280. 50-281
50-280/98-03. 50-281/98-03
Virginia Electric and Power Company (VEPCO)
Surry Power Station. Units 1 & 2
5850 Hog Island Road
Surry. VA
23883
February 8 - March 21. 1998
R. Musser. Senior Resident Inspector
K. Poertner. Resident Inspector
B. Bonser. Senior Resident Inspector. Summer (Section
07.3)
P. Hopkins. Project Engineer (Sections Ml.land E7.l)
D. Jones. Radiation Specialist (Sections Rl.2. Rl.3.
Rl.4 and R7 .1)
M. Morgan. Senior Resident Inspector. North Anna
(Sections 07.1 and 07.2)
R. Haag. Chief. Reactor Projects Branch 5
Division of Reactor Projects
Enclosure
\\ \\ '*
EXECUTIVE SUMMARY
Surry Power Station. Units 1 & 2
NRC Inspection Report Nos. 50-280/98-03. 50-281/98-03
This integrated inspection included aspects of licensee operations.
engineering. maintenance. and plant support.
The report covers a six-week
period of resident inspection: in addition. it includes the results of
announced inspections bj a regional radiation specialist. a regional project
engineer and two senior resident inspectors.
Operations
Observed Unit 1 shutdown activities were conducted in accordance with
approved procedures.
Command and control during unit stabilization at
four percent power was good and operators controlled plant parameters
well during generator voltage regulator testing (Section 01.2).
The licensee's oversight process was effective in identifying
- programmatic problems (Section 07.1).
The operating experience process is adequate and existing weaknesses are
being addressed by the licensee (Section 07.2).
The licensee's deficiency identification and reporting and corrective
action programs were effectively identifying issues. and recommending
and implementing appropriate corrective action. There were
approximately 45 overdue responses to deviation reports with the
majority being assigned to engineering.
The licensee has initiated
action to resolve this backlog.
Licensee self-assessments effectively
evaluated the corrective action program (Section 07.3).
- Maintenance
While testing Number 2 emergency diesel generator. test personnel
followed procedures. recognized that the procedures needed upgrade and
made the appropriate changes.
The use of new data acquisition equipment
provided information that improved the testing methodology (Section
Ml.1).
Uninterruptable power supply lB-2 maintenance activities were performed
in accordance with approved procedures. and the technicians performing
the work activities were knowledgeable and used good electrical work
practices (Section Ml.2).
Turbine driven auxiliary feedwater pump testing was performed in
accordance with approved procedures. and the pump met all acceptance
criteria prior to return to service (Section Ml.3).
A Non-cited Violation was identified for failure to obtain valid
vibration data during an auxiliary feedwater pump surveillance test
(Section M8.1).
l
2
Engineering
The licensee's plans and procedures for the installation of a freeze
seal on a 12-inch safety injection accumulator discharge line were
thorough.
Adequate contingencies were implemented prior to the
placement of the freeze seal (Section El.1).
The engineering self assessment program was comprehensive with good
procedural controls. Audit reviews revealed a good ability to perform
audits. be self critical and address concerns with timely corrective
actions.
The environmental qualification area self assessment was well
performed (Section E7.1).
Plant Support
Health physics practices were observed to be proper (Section Rl.1).
The licensee closely monitored annual and outage collective dose and was
generally very successful in meeting established as low as is reasonably
achi~vable goals.
Maximum individual radiation exposures were
controlled to levels which were well within the licensee's
administrative limits and the regulatory limits for occupational dose
specified in 10 CFR 20.1201(a) (Section Rl.2).
The licensee has maintained an effective program for the control of
liquid and gaseous radioactive effluents from the plant. The radiation
doses resulting from those releases were a small percent of regulatory
limits (Section Rl.3).
The licensee has effectively implemented the radiological environmental
monitoring program.
The sampling, analytical and reporting program
requirements were met and the sampling equipment was being well
maintained (Section Rl.4).
The licensee has complied with the program requirements for conducting
audits of radiological protection and chemistry activities
(Section R7.1).
Security and material condition of the protected area perimeter barrier
were acceptable (Section Sl) .
\\ )
- ~
Report Details
Summary of Plant Status
Unit 1 operated at power until March 20. 1998. when the unit was removed from
service for a maintenance outage (See Section 01.2).
Unit 2 operated at power the entire reporting period.
I. Operations
01
Conduct of Operations
01.1 General Comments (71707. 40500)
- The inspectors conducted frequent control room tours to verify proper
staffing, operator attentiveness. and adherence to approved procedures.
The inspectors attended daily plant status meetings to maintain
awareness of overall facility operations and reviewed operator logs to
verify operational safety and compliance with Technical Specifications
(TSs).
Instrumentation and safety system lineups were periodically
reviewed from control room indications to assess operability. Frequent
plant tours were conducted to observe equipment status and housekeeping .
Deviation Reports (DRs) were reviewed to assure that potential safety
concerns were properly reported and resolved.
The inspectors found that
daily operations were generally conducted in accordance with regulatory
requirements and plant procedures.
01.2 Unit 1 Shutdown
a.
Inspection Scope (71707)
The inspectors observed portions of a Unit 1 shutdown for a maintenance
outage.
b.
Observations and Findings.
On Mafch 20. 1998. at 10:54 p.m .. Unit 1 was removed from service for a
maintenance outage.
Major work activities scheduled to be performed
included replacement of the B reactor coolant pump motor. pressurizer
power operated relief valve overhaul. pressurizer manway leak repair.
safety injection accumulator check valve work and generator voltage
regulator work. * The outage repairs were not required by TS.
The inspectors observed portions of the power reduction. removal of the
generator from the system grid and unit stabilization at four percent
power to perform generator voltage regulator testing. Activities
observed were conducted in accordance with approved procedures.
Command
and control during unit stabilization at four percent power was good and
operators controlled plant parameters well during generator voltage
regulator testing.
1
2
c.
Conclusions
Observed Unit 1 shutdown activities were conducted in accordance with
approved procedures.
Command and control during unit stabilization at
four percent power was good and operators controlled plant parameters
well during generator voltage regulator testing.
07
Quality Assurance in Operations
07.1 Nuclear Oversight Department Audit Activities
a.
Inspection Scope (40500)
The inspectors evaluated audit activities performed by the corporate-
based nuclear oversight department ("oversight").
b.
Observations and Findin~
The inspectors interviewed oversight group personnel and reviewed three
1997 audits performed by the group.
Plant oversight personnel were
knowledgeable of oversight requirements and understood departmental
expectations as presented in Corporate Nuclear Department Administrative
Procedure CNOCP) 0213. "Oversight Program.* Revision 0.
The reviewed
audits exhibited good self-assessment techniques and met the
requirements presented in NOCP-0212. "Internal Audit Program."
Revision 2.
The following Audits were reviewed:
ADM 02-04-10(97-01); Security/Fitness For Duty
ADM 02-04-10(97-02); Fire Protection QA Program
ADM 02-04-10(97-10); Corrective Action
Audit finding number one in the corrective action audit stated ..... the
topical report and administrative procedures did not clearly address or
control items classified as routine or deemed not warranting corrective
action." According to NOCP-0212. Step 6.3.3.a. audits "should
completely and accurately document overall results." The inspectors
conclµded that the audit finding description was vague and did not
clearly characterize the deficiency.
The inspectors noted that although finding number one of the Corrective
Action audit referred to concerns with the "topical report." the topical
report was not addressed in the proposed corrective action response for
the finding.
The response called for revisions to VPAP-1601.
"Corrective Action." that would allow for processing of routine
deviation reports by departure from the normally prescribed VPAP-1601
corrective action pathway.
This will provide greater efficiency for
resolving items that do not affect plant safety.
The inspectors further
noted. in discussions with licensee management. that changes to the
"topical report" will not be pursued.
3
c.
Conclusions
The licensee's oversight process was effective in identifying
programmatic problems.
The description of a corrective action audit
finding did not clearly characterize the deficiency.
07.3 Operating Experience Review
a.
Inspection Scope (40500)
The inspectors evaluated activities performed by the licensee's
Operating Experience (OE) group.
b.
Observations and Findings
C .
The inspectors interviewed OE personnel. reviewed in-plant deviation
notifications. and examined various OE information reports.
The OE
group personnel were knowledgeable of their OE responsibilities. They
understood program expectations as presented in Virginia Power
Administrative Procedure (VPAP) 3002. "Operating Experience Program."
Revision 6.
After performing interviews. reviewing current OE program processes. and
evaluating pertinent licensee oversight audit documents. the inspectors
concluded that some weaknesses in the OE process exist. Deficiencies
included: delays in follow-up of industry notifications and events.
deficient tracking of notifications and events. problems with suitable
management notification. and difficulties in the initial screening of
some industry event information.
The inspectors* review noted that a
corrective action effort in this area was on-going.
Weaknesses in OE
initial screening and overall tracking of industry events were presented
in the licensee's oversight department report. dated January 12. 1998.
The inspectors recognized that although some problems existed. the
licensee had actively addressed the issues and the overall OE process
was adequate.
During the OE review. the inspectors observed that the licensee's Human
Perfqrmance Enhancement System (HPES) remained an accepted method for
reporting deficiencies within the licensee's current corrective action
process.
In 1996. about 20 HPES forms were used. while in 1997 only
three forms were used to report/document human performance problems.
The inspectors were concerned that use of the HPES process could result
in incomplete corrective action due to the lack of familiarity and
differences between HPES and the widely used DR process. Several other
infrequently used reporting methods remained in the licensee's overall
corrective action program which could cause similar problems.
Conclusions
The operating experience process is adequate and existing weaknesses are
being addressed by the licensee.
4
07.3 Deficiency Reporting and Corrective Action Program
a.
Inspection Scope (40500)
The inspectors reviewed the licensee's deficiency reporting system and
corrective action program.
This included a review of the programmatic
controls. the deficiency reporting process. and the assignment and
completion of corrective action.
b.
Observations and Findings
The inspectors reviewed the procedural guidance governing deficiency
reporting and the corrective action program.
Two procedures govern
deficiency reporting and the corrective action program. VPAP-1501.
"Deviation Reports." Revision 10. and VPAP-1601. "Corrective Action."
Revision 8.
The licensee's Deviation Report (DR) program has a low
threshold for deficiency reporting. ensures the scope of evaluation is
based on deficiency significance. and tracks corrective action.
The
inspectors concluded that the licensee has established a well defined
process for the identification. assessment and resolution of conditions
potentially adverse to quality and operability.
The DR system was the primary means to report deficiencies.
The
inspectors found that the DR system. administered by Station Nuclear
Safety (SNS). was used plant wide to report deficiencies. The DRs were
assigned different levels of significance (Significant. Potentially
Significant. and Routine) based on defined criteria. The significance
level generally determined the level of root cause evaluation and the
effort necessary to resolve a DR.
The inspectors concluded from their
review of DRs that the deficiency reporting system was understood by
plant personnel. that there was a low threshold for reporting
deficiencies. and that the process for assigning significance to DRs was
effective.
The inspectors reviewed the assignment and tracking of DR responses.
The DRs were assigned to specific groups and responses were returned to
SNS with proposed corrective action plans.
The inspectors* review found
that. in general. DR responses were timely with acceptable proposed
corrective action.
During this review the inspectors identified
approximately 45 overdue Potentially Significant and Routine DRs.
Most
of these were assigned to engineering. Licensee management had
recognized that this was an engineering resource issue and was taking
corrective action.
The inspectors reviewed corrective action by reviewing a sample of Root
Cause Evaluations (RCEs). recommended corrective actions. and the most
recent licensee trend report that identified trends in DRs.
The
licensee's DR and RCE programs appeared to be effective tools for
identifying corrective action to resolve issues.
The trend report was a
useful means to determine t~ends for significant equipment concerns and
human performance issues.
The inspectors concluded that the licensee
was identifying equipment and human performance problems and was
C .
5
monitoring the effectiveness of corrective actions for these problems by
trending DRs.
The ihspectors concluded that corrective action was
addressing identified deficiencies adequately.
The inspectors reviewed the completion of corrective action for DRs.
Corrective action for significant DRs and higher tier RCEs was tracked
through a Commitment Tracking System (CTS) monitored by plant
management.
The corrective action for less significant DR related
issues was assigned and tracked by the responsible departments.
To
assess the timeliness of corrective action completion. the inspectors
reviewed outstanding items in the CTS and a recent comprehensive
assessment of corrective action performed by SNS.
The inspectors found
that corrective action. in general. was being completed within the
prescribed timeframes.
The inspectors did note that the licensee's
self-assessment identified several instances where corrective action was
not timely.
The licensee's corrective action audit made several
recommendations that would enhance the corrective action process to
ensure actions were completed as scheduled.
The inspectors concluded
that overall corrective action completion was adequate and that the
licensee was taking corrective action to enhance the timely completion
of corrective attion ..
Conclusions
The licensee's deficiency identification and reporting and corrective
action programs were effectively identifying issues. and recommending
and implementing appropriate corrective action. There were
approximately 45 overdue responses to deviation reports with the
majority being assigned to engineering.
The licensee has initiated
action to resolve this backlog.
Licensee self-assessments effectively
evaluated the corrective action program.
II. Maintenance
Ml
Conduct of Maintenance
Ml.1
Number 2 Emergency Diesel Generator (EOG)
a.
Inspe*ction Scope (61726. 62707)
b.
From February 9. 1998. through February 12. 1998. the inspectors
observed personnel perform portions or 2-0PT-EG-008. "Number 2 Emergency
Diesel Generator (EOG) Starting Sequence Testing," Revision 5.Pl. and
2-0PT-EG-001. "Number 2 Emergency Diesel Generator Monthly Start
Exercise Test." Revision 11.Pl. The licensee used new data acquisition
test equipment for the tests.
Observation and Findings
Updated Final Safety Analysis Report (UFSAR) Section 8.5 indicated that
the EOG start circuit was designed such that. upon an automatic start
signal. the EOG would make three attempts or start cycles to start the
C.
6
diesel engine and energize the generator.
Periodic test 2-0PT-EG-008
verified that on the third start cycle. the EOG successfully performs
these functions.
During this test of the Number 2 EOG on February 9.
the diesel engine started but the generator field flash circuit failed
to energize the generator.
During the subsequent investigation of the
data. the licensee determined that a timing relay required adjustment
and the method in which the first two start cycles were defeated
introduced an unwanted time delay into the test. The method used to
defeat the first two cycles involved manually holding the fuel racks
closed until the EOG shaft stopped rotating: Since the third start
cycle begins before the EOG shaft comes to rest. the operators were
inadvertently defeating the initial portion of the third start cycle by
holding the fuel racks closed too long.
The revised technique was to
release the fuel racks closer to when the second start cycle actually
ends. i.e .. when the EOG air start motor stops and the EOG coast down
begins.
The unwanted time delay would sometimes result in the start
cycle timer. on the third start cycle. timing out and energizing the
start failure lockout circuit before the diesel engine obtained the
required speed for flashing the generator field.
The licensee adjusted
the relay and modified the test procedure to change the technique used
to defeat the first two start cycles such that the unwanted time delay
was reduced. After the discrepancies were corrected and the procedures
were modified. the resulting tests were satisfactory .
The use of new data acquisition equipment provided information that
allowed electronic*components to be examined and analyzed.
This
resulted in an improved testing methodology.
Conclusions
While testing Number 2 emergency diesel generator. test personnel
followed procedures. recognized that the procedures needed upgrade and
made the appropriate changes.
The use of new data acquisition equipment
provided information that improved the testing methodology.
Ml.2 Uninterruptible Power Supply CUPS) Maintenance
a.
Insp~ction Scope (62707)
The inspectors observed maintenance activities* conducted on UPS lB-2.
b. Observations and Findings
The inspectors observed portions of the work activities associated with
Work Order (WO) 00380394, Cleaning, Inspection and Lamp Replacement for
Battery Charger Inverter and Static Switch.
The work was performed in
accordance with approved procedures and the technicians performing the
work activities were knowledgeable and used good electrical work
practices .
7
c.
Canel usi ans
Uninterruptible power supply lB-2 maintenance activities were performed
in accordance with approved procedures and the technicians performing
the work activities were knowledgeable and used good electrical work
practices.
Ml.3 Turbine Driven Auxiliary Feedwater (TDAFW) Pump Testing
a.
Inspection Scope(61726)
The inspectors observed TDAFW pump testing activities.
b.
Observations and Findings
The inspectors observed Unit 2 TDAFW pump testing performed in
accordance with procedure 2-0PT-FW-003. "Turbine Driven Auxiliary
Feedwater Pump 2-FW-P-2." Revision 11.
The test procedure implements
the TS required inservice pump and valve testing requirements for the
TDAFW pump.
The inspectors observed the operations prejob briefing prior to
performance of the procedure and witnessed the performance of the test
procedure.
The inspectors verified that the test data obtained met the
procedure acceptance criteria. The prejob briefing was thorough and the
test was performed in accordance with the procedure.
c.
Conclusions
Turbine driven auxiliary feedwater pump testing was performed in
accordance with approved procedures and all the test acceptance criteria
was met.
MB
Miscellaneous Maintenance Issues (92700)
M8.1
(Closed) Licensee Event Report CLER) 50-280/98001: Deficient Test Due to
Faulty Test Equipment Results in Tech Spec Violation. This LER
descr~bed the circumstances surrounding a failure to obtain valid pump
vibration data on a Unit 1 motor driven auxiliary feedwater pump during
ASME Section XI testing resulting in a violation of TS 4.0.5. This
event was identified by the licensee during a programmatic review
initiated following a subsequent failure of the vibration collection
equipment.
The inspectors revi~wed the LER and proposed corrective
actions to prevent recurrence and found them adequate.
The corrective
actions included issuance of a memorandum to all operations personnel
stressing the need to use caution when taking vibration data and
coaching of personnel responsible for taking or reviewing vibration data
on the need to review new data for adverse trends or questionable data.
The licensee also plans to purchase a calibration exciter to enhance the
operators ability to determine that the vibration analysis equipment is
operating properly. This non-repetitive. licensee identified and
corrected violation is being treated as~ Non-cited Violation (NCV)
.*
8
consistent with Section VII.B.l of the NRC Enforcement Policy. This
matter is identified as NCV 280/98003-01.
III. Engineering
El
Conduct of Engineering
El.l Review of Freeze Seal for Isolation of l-SI-145
a.
InsRection ScoRe (37551)
The inspectors reviewed the licensee's plans and procedures for the
installation of a freeze seal to perform maintenance on the lC safety
injection accumulator discharge check valve l-SI-145.
b.
Observations and Findings
On March 20. 1998. the licensee plans to remove Unit 1 from service to
perform an eight day maintenance outage.
During the outage. the
licensee plans to repair l-SI-145. During the operating cycle. the lC
accumulator level continually increased Cat approximately 0.01 gpm) due
to back leakage from the reactor coolant system through l-SI-145.
As a
part of the repair. a freeze seal will be installed on the 12-inch
accumulator discharge pipe to assure an adequate isolation boundary is
maintained during maintenance.
Prior to the installation of the freeze
seal. the inspectors reviewed the licensee's plans and procedures for
the installation and control of a freeze seal.
The inspectors reviewed procedure O-MCM-1918-03. "Freeze Seal of
Piping.n Revision 4 and a one time only procedure change prepared for
this specific evolution.
The procedure was detailed and thorough.
The
area of piping to be freeze sealed is required to be visually and liquid
penetrant inspected prior to the installation and after the removal of
the freeze seal. The procedure contained adequate contingencies to be
performed in case of a freeze seal failure.
Because the work was being
performed inside containment. adequate measures were established to
ensure that adequate liquid nttrogen was available inside containment to
main~ain the freeze seal in the event it became necessary to rapidly
establish containment integrity.
The inspectors discussed the installation of the freeze seal with the
cognizant engineer. maintenance foreman. and contractor supervisor. All
persons were knowledgeable of the requirements for installation.
maintaining. and removing the freeze seal.
c. Conclusions
The licensee's plans and procedures for the installation of a freeze
seal on a 12-inch safety injection accumulator discharge line were
thorough.
Adequate contingencies were implemented prior to the
placement of the freeze seal.
9
E7
Quality Assurance in Engineering_ Activities
E7.1 Onsite Engineering Self Assessment
a.
Inspection Scope (37551)
The inspectors reviewed self assessment audits. procedures and training
records to evaluate the licensee's controls and self assessment of
engineering activities. The inspectors also interviewed personnel to
ascertain their understanding of implementing procedures and actual
participation in the self assessment process.
b.
Observations and Findings
The inspectors reviewed. inspected and evaluated segments of the
engineering organization document and test controls. corrective action.
Design Change Packages (DCPs). Engineering Work Requests (EWRS). and
10 CfR 50.59 safety evaluations.
The inspectors reviewed VPAP-0104. "NBU Management Station Self
Assessment program." Revision 2. which implements the station management
self assessment program.
This program outlines the objectives.
standards. and the significance of how to achieve departmental and
integrated station performance .
Procedure SSES-1.13. "Controlling Procedure for Engineering Self
Assessment." Revision 0. provides direction for assessing and
documenting corrective actions for engineering functions that were
important to Surry Power Station. Other procedures reviewed by the
inspectors that added strength to the program were VPAP-2701. "Station
Training Program. Virginia Power Root Cause Evaluation Program Manual ...
SSES-1.06. **controlling Procedure for Engineering Commitment Tracking
System." and INPO 90-015. "Performance Objectives and Criteria for
Operating and Near Term Operating License Plants." The Engineering
Department has an active training program for engineers in root cause
analysis. self assessment and professional development.
A review of the
training area is performed quarterly by the technical staff training
review board.
The inspectors review of the audits performed on the Design Control and
Engineering Program and personnel interviews indicated that the audit
was extensive and thorough.
The audit areas consisted of design
input/design process. interface controls. design verification. design
change controls. document control and records. drawing controls. set
point controls and corrective actions. The audit identified
achievements and concerns. These concerns were placed in a tracking
system for resolution.
The inspectors reviewed the Nuclear Engineering Environmental
Qualification (EQ) self assessment which was performed by corporate and
station engineering personnel.
During the self assessment engineering
found where logged temperatures were not consistent with the parameters
- ..
I ,
10
stated in the UFSAR Section 9.1.3.4. A Technical Report EQ-0051.
Revision 0. provided a summation of the temperature monitoring data
recorded at Surry as part of the EQ program.
These differences were
already beihg addressed by the licensee's corrective action program.
However the audit found that an engineering task tracking assignment had
not been initiated for an Updated Final Safety Analysis Report (UFSAR)
change submittal.
The UFSAR change was initiated immediately. This was
an example of in-depth self assessment audits.
c.
Conclusions
The engineering self assessment program was comprehensive with good
.procedural controls. Audit reviews revealed a good ability to perform
audits. be self critical and address concerns with timely corrective
actions.
The environmental qualification area self assessment was well
performed.
IV. Plant Support
Rl
Radiological Protection and Chemistry (RP&C) Controls (71750)
Rl. 1 General
C 71750)
On numerous occasions during the inspection period. the inspectors
reviewed Radiation Protection (RP) practices including radiation control
area entry and exit. survey results. and radiological area material
conditions.
No discrepancies were noted. and the inspectors determined
that RP practices were proper.
Rl.2 Occupational Radiation Exposure Control Program
a.
Inspection Scope (83750)
b.
The inspectors reviewed implementation of selected elements of the
licensee's radiation protection program pertaining to control of
occupational radiation exposure.
The review included examination of
licensee records and reports for annual and outage collective dose. and
comparison of the collective doses to the licensee's established ALARA
goals*.
The inspectors also reviewed records and reports of individual
personnel exposures and compared those exposures to the occupational
dose limits specified in Subpart C to 10 CFR 20 and the licensee's
procedurally established administrative limits for personnel exposure.
Observations and Findings
The inspectors compiled the 1997 annual and outage collective dose data
presented in the table below from the licensee's Personnel Radiation
Exposure Management System (PERMS) and outage As Low As is Reasonably
Achievable (ALARA) reports.
The annual collective dose was verified to
be consistent with the PERMS data base which is used by the licensee to
record and monitor personnel radiation exposure.
The data for the years
11
1994 through 1996 was taken from similar tables contained in previous
inspection reports.
As indicated in the table. the licensee was generally successful in
meeting established ALARA goals.
The 1997 ALARA goal for annual
collective dose was successfully met.
The ALARA goal for the 1997 Unit
One (U-1) Refueling Outage (RFO) collective dose was exceeded due to
unplanned emergent work which caused the outage to be extended from the
planned 36 days to 56 days.
The ALARA goal for the 1997 Unit Two (U-2)
RFO was initially established at 115 man-rem. but due to exceptional
success at maintaining low exposure during the first fourteen days of
the outage. the goal was reduced to 83 man-rem.
The final collective
dose for that RFO was the lowest ever achieved at the site. The table
also indicates a decreasing trend in the three year moving mean for
annual collective dose.
I
Co 11 ect i ve Dose (man-rem)
I
Annual Dose
Outage Dose
Year
Actual
Goal
3 Year
Outage
Actual
Goal
Days
Mean
Type
1994
378
642
450
U-11
233
312
64
U-22
29
20
22
U-12
29
22
28
1995
403
460
390
U-21
158
164
47
U-13
.197
191
34
1996
214
209
332
U-23
155
164
35
1997
320
358
312
U-13
222
181
56
U-23
78
83
25
1 10 year Inservice Inspection (ISI) and Refueling Outage CRFO)
2 Steam Generator cleaning
3 RFO
The licensee also provided the inspectors with data from the PERMS
pertaining to maximum individual radiation exposures for the year 1997.
The inspectors verified that the data were consistent with the PERMS
data base and tabulated the data in the table below.
The data for the
years 1995 and 1996 were taken from similar tables contained in previous
inspection reports.
C.
12
Maximum Individual Radiation Doses (Rem)
Year
Skin
Extremity
Eye Lens
1995
2.817
3.674
3.674
2.850
1996
2.160
2.220
2.220
2.160
1997
2.079
4.359
5.421
2.079
Regulatory and Administrative Limits
5.000
50.000
50.000
15.000
Admin.
4.000
40.000
40.000
12.000
The administrative annual dose limits established by the license were
delineated in procedure VPAP-2101. "Radiation Protection Program.*
As
indicated in the table. the maximum individual radiation exposures for
1995 and 1996 were well within the licensee's administrative limits and
the regulatory limits specified in 10 CFR 20.1201(a).
The inspectors reviewed the licensee's procedures for follow-up actions
to Personnel Contamination Events (PCEs) and reviewed selected records
for those events which occurred during 1997.
Procedure HP-1061.020 .
"Personnel Contamination Monitoring and Decontamination.* indicated that
the threshold for initiating follow-up actions was skin or clothing
contamination in excess of 100 net counts per minute (ncpm) as measured
by a hand held frisker.
The licensee's records indicated that during
1997 there were 244 PCEs. 89 of which occurred during the U-1 RFO and 54
during the U-2 RFO.
There were no assignments of skin dose to the
involved individuals as a result of PCEs during 1997 but two of those
events did result in assignments of internal dose from uptakes of
radioactive material. The inspectors reviewed those two dose
calculations and determined that the calculations for the assigned doses
were consistent with licensee dose calculation procedures.
No
regulatory dose limits were exceeded.
The inspectors also reviewed the licensee's records for contaminated
floor space within the Radiation Control Area (RCA).
Radiation
Protection personnel maintained records of the areas within the RCA.
excluding the Containment Buildings, which had contamination levels in
excess of 1000 disintegrations per minute per 100 square centimeters
(dpm/100 cm2).
The contaminated square footage was tracked on a daily
basis and monthly averages were calculated.
The inspectors noted that
during non-outage periods the monthly averages for contaminated floor
space during 1997 were less than one percent of the RCA floor space.
Conclusions
The licensee closely monitored annual and outage collective dose and was
generally successful in meeting established ALARA goals.
Maximum
individual radiation exposures were controlled to levels which were well
13
within the licensee's administrative limits and the regulatory limits
for occupational dose specified in 10 CFR 20.120l(a).
Rl.3 Radioactive Effluent Control Program
a.
Inspection Scope (84750)
The inspectors reviewed the overall results of the radioactive effluent
control program as documented in the Annual Radioactive Effluent Release
Report for 1996.
The amounts of radioactivity released and the
resulting radiation doses for the years 1994 through 1995 were also
tabulated from the annual reports to evaluate long term performance of
the effluent control program relative to the design objectives in
10 CFR 50. Appendix I for radiation doses from plant effluents.
b.
Observations and Findings
The data presented in the table below was compiled from the licensee's
effluent release reports for the years 1994 through 1996.
The
inspectors reviewed the report for the year 1996 and discussed it's
content and the data presented in the table with the licensee. The
annual effluent reports for the amounts of activity released during the
previous year and the resulting doses from those releases are due to be
submitted by May 1 each year.
At the time of this inspection. the
annual report for 1997. which was not due to be reported for two months.
had not been finalized but the amounts of activity released and the
resulting doses had been compiled by the licensee and are included in
the table below.
SURRY RADIOACTIVE EFFLUENT RELEASES
GASEOUS EFFLUENTS
Curi'es Released
Year
F&AP
Part.
_ji_
1994
275
4.05E-3 3.15E-4
15
1995
227
2.20E-3
1. 63E-4
17
1996
400
2.69E-4 l.77E-4
22
1997
498
3.68E-3 6.06E-5
40
Dose (mrem)
Air
Organ
[v 10 mrad]
[15 mremJ
[/3 20 mrad]
V 5.5E-2 (0.6%)
4.lE-2 (0.27%)
/3 l.7E-l (0.9%)
V 5.6E-2 (0.6%)
2.2E-2 (0.15%)
/3 1. 7 E -1 C O . 8% )
V l.lE-1 (1.1%)
3.0E-3 (0.02%)
/3 3. 2E-l Cl. 6%)
V 8.6E-2 (0.9%)
3.7E-2 (0.25%)
/3 2.8E-l 0.4%)
LIQUID EFFLUENTS
Curies Released
1994
0.06
1995
0.06
1996
0.20
1997
0.40
979
831
991
1110
l.24E-6
8.22E-5
7.34E-3
4.19E-3
14
F&AP
Fission and Activation Products
3H
D&EG Dissolved and Entrained Gases
T.B.
Total Body
[ J
Limits/Unit
( )
% of Limits/Unit
Part Particulates
v
Gamma
f3
Beta
Dose Cmrem)
T.B.
Organ
[3 mrem]
[10 mrem]
3.0E-4 (0.010%) 3.9E-4 (0.004%)
l.9E-4 (0.006%)
2.lE-4 (0.002%)
2.2E-4 (0.007%) 8.4E-4 (0.008%)
4.lE-4 (0.014%)
l.lE-3 (0.011%)
The inspectors made the following observations from the above tabulated
data and discussed those observations with the licensee.
The amounts of
fission and activation products released in liquid effluents were less
than one half of a curie per year but slightly larger amounts were
released during 1996 and 1997 than were released during 1994 and 1995.
The licensee indicated that the increase was due to a change in liquid
waste processing methods. i.e .. evaporation versus reverse osmosis.
The
inspectors also noted that the doses from the liquid effluents were
approximately one hundredth of one percent of their regulatory limits.
which is indicative of exceptional performance in controlling
radioactive effluents from the plant.
The amounts of fission and
activation gases released in gaseous effluents during 1996 and 1997 were
larger than the amounts released during 1994 and 1995.
The licensee
indicated that the increase was due to leaking fuel in U-1 and that
additional radioactivity would have been released if actions had not
been taken to reduce the amounts released. Those actions included
extended degas of the reactor coolant at the start of the 1997 U-1 RFD
and repair of leaks in the waste gas processing system.
The inspectors
noted that the air doses from gaseous effluents were all less than one
and one half of one percent of their regulatory limits and the maximum
organ doses were all less than one half of one percent of their
regulatory limits. This was also indicative of good performance in
controlling radioactive effluents from the plant.
The inspectors also observed a batch release of liquid waste from Waste
Monitor Tank Bon February 11. 1998.
The waste water had been processed
through the liquid waste evaporator system and. when sampled. no man-
made radionuclides were detected at concentrations greater than the
15
analytical lower limits of detection required by the Offsite Dose
Calculation Manual (ODCM).
By direct observation. the inspectors
determined that the liquid waste was released in accordance with
procedure ROP-1.04. "Releasing Liquid Waste Monitor Tanks 1-RLW-TK-4A or
B Using DCS." and sampled in accordance with procedure CH-31.362.
"Liquid Waste Monitor Tank B: Sampling Liquid at Sink." The inspectors
also observed that Radioactive Liquid Waste Release Permit No. 9800086
was generated for the release in accordance with procedure HP-3010.020.
"Radioactive Liquid Waste Release Permits." The inspectors also
verified that the alarm setpoint for the liquid effluent radiation
monitor (RRM-131) had been calculated in accordance with procedure
HP-3010.040. "Radiation Monitoring System Setpoint Determination." and
that the actual alarm setpoint of the monitor had been set more
conservatively than required by the ODCM.
c.
Conclusions
The licensee has maintained an effective program for the control of
liquid and gaseous radioactive effluents from the plant.
The radiation
doses resulting from those releases were a small percent of regulatory
limits.
Rl.4 Radiological Environmental Monitoring Program
a.
Inspection Scope (84750)
The inspectors reviewed the overall results of the radiological
environmental monitoring program as documented in the Annual
Radiological Environmental Operating Report for 1996.
Those results
were compared to the program requirements delineated in the ODCM.
b.
Observations and Findings
The inspectors noted that. in accordance with the ODCM. the report
included a description of the program. a summary and discussion of the
results for each exposure pathway. analysis of trends during the
operational years as compared to the pre-operational years. and an
asses_sment of the impact on the environment based on program results.
The report also included a tabulation of the summarized analytical
results for the samples collected during 1996.
From a review of this
data the inspectors determined. for selected exposure pathways, that the
sampling and analysis frequencies specified in the ODCM had been met.
As indicated in the report conclusions. the analytical results were as
expected for normal environmental samples.
Very low concentrations of
man-made isotopes were occasionally detected in the samples but were of
no dose consequence.
It was further concluded that there were no
adverse environmental affects as a result of plant operations.
The
inspectors also reviewed the analytical results for environmental
samples collected from selected locations during the first three
quarters of 1997 and determined that those results were consistent with
the previous years results.
16
The inspectors also observed the collection of particulate and
charcoal cartridge filters at five air sampling stations. The
inspectors noted that the samples were collected in accordance with
procedure HP-3051.010. "Radiological Environmental Monitoring Program."
The inspectors also noted that the sampling equipment was operable and
in good working order. and that the sampling stations were located as
indicated in the ODCM.
c.
Conclusions
The licensee has effectively implemented the radiological environmental
monitoring program.
The sampling. analytical and reporting program
requirements were met and the sampling equipment was being well
maintained.
R7
Quality Assurance. in RP&C Activities
R7 .1 Audits
a.
Inspection Scope (83750 and 84750)
The inspectors reviewed selected audit reports for consistency with.
Technical Specifications 6.1.C.2.h&j regarding program areas required to
be audited and audit reporting requirements.
b.
Observations and Findings
The inspectors reviewed Nuclear Oversight Audit Reports 97-06 and 97-13
which documented the licensee's most recent audits in the areas of
chemistry. radiological protection. effluent monitoring. environmental
monitoring, radwaste processing. and transport of radioactive materials.
Those reports delineated the specific elements of the program areas
-
evaluated and included overall conclusions. based on audit results. that
the programs were being effectively implemented.
The inspectors also
reviewed the Completed Audit Checklists which provided extensive
documentation of the supporting details for the audit conclusions.
Substantive issues identified by the audits were entered into the
licensee's corrective action program by issuance of Deviation Reports.
The inspectors determined that the audits were of sufficient scope and
depth to identify potential problems and that corrective actions for
identified issues were documented and tracked for completion of
warranted follow-up.
The audit results. were well documented and
reported to facility management in a timely manner.
c.
Conclusions
The licensee has complied with the program requirements for conducting
audits of radiological protection and chemistry activities .
17
Sl
Conduct of Security and Safeguards Activities
On numerous occasions during the inspection period. the inspectors
performed walkdowns of the protected area perimeter to assess security
and general barrier conditions.
No deficiencies were noted and the
inspectors concluded that security posts were properly manned and that
the perimeter barrier's material condition was properly maintained.
V. Management Meetings
Xl
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee
management at the conclusion of the inspection on March 31. 1998.
The
licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during
the inspection should be considered proprietary.
No proprietary
information was identified.
X2
Management Title Changes
During the inspection period. a number of title changes took place with
senior onsite managers.
The Station Manager's title was changed to Site
Vice President: the title of the Assistant Manager. Operations &
Maintenance was changed to Manager. Station Operations & Maintenance.
and the title of the Assistant Manager. Nuclear Safety & Licensing was
changed to Manager. Station Safety & Licensing.
The changes were
effective March 1. 1998.
PARTIAL LIST OF PERSONS CONTACTED
M. Adams. Superintendent. Engineering
R. Allen. Superintendent. Maintenance
R. Blount. Manager. Nuclear Safety & Licensing
D. Christian. Site Vice President
M. Crist. Superintendent. Operations
E. Collins. Director. Nuclear Oversight
B. Shriver.* Manager. Station Operations & Maintenance
T. Sowers. Superintendent. Training
B. Stanley. Supervisor. Licensing
W. Thornton. Superintendent. Radiological Protection
- *
IP 37551:
IP 40500:
IP 61726:
IP 62707:
IP 71707:
IP 71750:
IP 92700:
18
INSPECTION PROCEDURES USED
Onsite Engineering
Effectiveness of Licensee Controls in Identifying. Resolving, and
Preventing Problems
Surveillance Observation
Maintenance Observation
Plant Operations
Plant Support Activities
Occupational Radiation Exposure
Radioactive Waste Treatment. and Effluent and Environmental
Monitoring
Onsite Followup of Written Reports of Nonroutine Events at Power
Reactor Facilities
ITEMS OPENED, CLOSED, ANO DISCUSSED
Opened
50-280/98003-01
Failure to obtain valid pump vibration
data on a Unit 1 motor driven auxiliary
feedwater pump (Section M8.1).
Closed
50-280/98003-01
50-280/98001
Discussed
None
LER
Failure to obtain valid pump vibration
data on a Unit 1 motor driven auxiliary
feedwater pump (Section M8.1).
Deficient test due to faulty test
equipment results in Tech Spec violation
(Section M8.1)