ML18152A440
| ML18152A440 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/09/1992 |
| From: | Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A441 | List: |
| References | |
| 50-280-92-16, 50-281-92-16, NUDOCS 9209220077 | |
| Download: ML18152A440 (13) | |
See also: IR 05000280/1992016
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
SEP 101992
Report Nos.:
50-280/92-16 and 50~281/92-16
Licensee:
Virginia Electric and Power Company
Docket Nos.:
50-280, 50-281
License Nos.:
Inspection Conducted:
13-17, 1992
Inspector(~
I
R. B.
Approved By:
n P. P
ter, Chief
Facilitie Radiation Protection
Sectio
Radiological Protection and Emergency
Preparedness Branch
Q&tsigned
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the area of
occupational radiation exposure.
Specific elements of the
program examined included:
organization and management control;
audits and appraisals; training and qualification; external
exposure control; surveys, monitoring and control of radioactive
material; and maintaining occupational *radiation exposure as low
as reasonably achievable (ALARA).
Results:
In the areas inspected one non-cited violation for the failure to
follow radiation protection procedures resulting in a worker
exceeding an administrative exposure limit was identified
(Paragraph 2.d.3).
Inspector followup items were also identified
concerning the operational aspects of a resin transfer operation
(Paragraph 2.d.3) and licensee actions regarding Information
Notice 88-63, Supplement 2 (Paragraph 2.e).
The work observed by
the inspector that was performed inside containment was under
satisfactory radiological controls.
The Radiation Protection (RP) program at Surry continues to be a
strength and adequately protects the health and safety of
employees and the public.
9209220077 920910
ADOCK 05000280
G
1.
REPORT DETAILS
Persons Contacted
- W. Benthall, Supervisor, Licensing
- R. Bilyeu, Engineer, Licensing
- M. Biron, Supervisor, Radiological Engineering
- R. Blount, Superintendent, Engineering
- Q. Bonez, Operation Review Board
- E. Brennan, Coordinator, Water Treatment
- D. Erickson, Superintendent, Radiation Protection
- M. Kansler, Station Manager
- J. Keithley, Shift Supervisor, Health Physics
- J. McCarthy, Superintendent, Operations
- D. Miller, Supervisor, Health Physics Operations
- J. Morelli, Operation Review Board
- R. Morgan, Specialist, Quality Assurance
- K. Okleshin, Operation review Board
- M. Olin, Supervisor, Radwaste Operations
- A. Royal, Supervisor, Nuclear Training
- B. Shriver, Acting Assistant Station Manager
T. Steed, ALARA Coordinator
- E. Smith, Manager, Quality Assurance
- W. Thornton, Corporate Director, Health Physics and
Chemistry
,
K. Wyatt, Maintenance Department ALARA Coordinator
Other licensee employees contacted during this inspection
included:
craftsmen, engineers, operators, contract
personnel and administrative personnel.
Nuclear Regulatory Commission
- J. York, Resident Inspector
- Attended Exit Interview
2.
Occupational Exposure (83750)
a.
Organization and Management Controls
The inspectors reviewed the staffing of the RP
organization as related to lines of authority and
verified that changes had.not been made that would
adversely affect the licensee's ability to control
radiation exposure or radioactivity.
A review of the licensee's program to self-identify and
correct problems via the Radiation Problem Report
(RPRs) system showed that the licensee utilized the
system and radiological performance problems when
identified are promptly* corrected.
The inspector noted
that when a problem has increased significance a
b.
c.
2
station deviation report was issued.
Both systems were
observed to be operating satisfactorily to keep
management appraised of radiological problems to
support oversight of the RP program.
Audits and Appraisals
Technical Specification (TS) 6.1.c.3 requires audits of
station activities to be performed under the cognizance
of Quality Assurance (QA} Department for conformance of
facility operation to TS and applicable licensee
conditions.
The inspector reviewed the QA audit number 92-01,
Nuclear Training Audit, dated February 19, 1992, which
included General Employee Training and training for
Contract Health P~ysics (HP) technicians.
The
inspector noted that the audit contained both, findings
which required corrections, and observations which were
designed to enhance program standards.
The inspector
found the audit to be comprehensive with the findings
being corrected in a timely manner and observations
properly addressed.
The QA assessment program for RP
continues to be a station strength.
During a review of the RPR program discussed in
paragraph 2a the inspector also noted that the licensee
HP routinely performed trend analysis for root causes
to prevent recurrences.
On June,2, 1992 radiological
engineering provided a memorandum to the Operational HP
group identifying half of the personnel contamination
events (PCEs) to date were caused by poor work
practices and that 70 percent of the PCEs involved
contractors.
The summary of the PCE root causes
identified the need for increased training for
contractors and an increase in decontamination using
special mops.
Further recommendations were under
study.
Training and Qualification
The inspector reviewed the training aspects of an event
where a decontamination technician (DT) received an
exposure in excess of administrative exposure limits as
described in paragraph 2.d of this report.
The
inspector interviewed the supervisor responsible for
radiological training and reviewed the training records
for the senior HP technicians.
The inspector found
that although the senior HP technician (HPT) involved
in the event was a contractor, the individual received
the same training for radiological job coverage that a
licensee HP would have received.
The inspector
-
-
d.
3
reviewed in detail the lesson plan and on-the-job
training for Special Job Coverage, HP-TDP-20 and noted
that the training module was comprehensive and covered
important aspects of unplanned events with emphasis on
diagnostics and prevention of recurrence at Surry
station._ The contractor HP technician was also
- qualified in covering w.ork in High Radiation Areas
(>1 R/hr, and Extremely High Radiation Areas
(>15 R/hr).
The Job Performance Measure (JPM) for the
training 6.2.04 was completed on February 13, 1992.
Also, HP continuing training for September 13, 1991
included a Task Training Practical Exercise No. PE-3.1,
Revision D. for work in high radiation and extreme high
radiation areas.
Also, industry events were discussed
during this training.
The DT had also received
continuing training on industry events,- as well as,
Radiation Decontamination Technician training on
August 29, 1990, and performed practical exercises in
decontamination.
External Exposure Control
TS 6.4.B requires *the licensee to have written
radiation control procedures that discuss permissible
radiation exposure, including the,use of radiation work
permits (RWPs), and stringent administrative procedures
to assure adherence to restrictions placed on high
radiation areas (HRAs).
10 CFR 20.202 requires each licensee to supply
appropriate monitoring equipment to specific
individuals and requires the use of such equipment.
During the inspection the inspector reviewed an event
that occurred on June 11, 1992 where a decontamination
technician (DT) exceeded an administrative exposure
limit of 750 millirem (mrem) without prior
authorization.
(1) Description of Events
On April 20, 1992, during the transfer of a Unit 1
mixed bed demineralizer to a high integrity
container (HIC), resin started to mound up in the
HIC.
On April 21, 1992 the mound was flushed
down.
Based on dose rates and slurry content, the.
operating crew believed the spent resin transfer
was complete.
Due to the high level of slurry in
the HIC, the post transfer flush pathway was to*
the Spent Resin Blend Tank (SRBT) *rather than the
normal pathway to the HIC.
Post flush radiation
area surveys showed dose rates up to 30 Rem per
4
hour (R/hr) on a discharge level in the Auxiliary
Building and 5 R/hr on a discharge line in the
decontamination (decon) building.
The areas were
properly posted and subsequent flushes brought
radiation levels back to normal in these areas.
However, the flushes were to the SRBT.
Resin
transfers were believed to have been to the bottom
of the SRBT, but there were known problems with
both the level transmitters and system radiation
monitors.
Therefore, the hose pathway search and
survey team was equipped with both DAD's and
survey meters, to detect any unexpected high dose
rate conditions.
On June 11, 1992, a decon foreman, a DT and HP
technician (HPT) entered a locked HRA gate in the
decon building to search for a hose pathway to
transfer sludge from the building sump to the
SRBT.
Due to high dose rates and poor lighting at
the normal pathway to the 8 foot diameter, 10-12
feet tall SRBT, the HPTs assessed one wall as
being too difficult to obtain access to the tank
top, so he asked the DF and DT to remain in the
area while he turned the corner and assessed
access via the adjacent wall.
After climbing up
two thirds of the way to the top of the tank, the
HPT heard the DTs digital alarming dosimeter (DAD)
of the DT alarming.
As the HP technician reached
the top of the shield wall he observed the DT
standing on the SRBT top; the R02 radiation
detection measuring device of the HPT was off
scale and the HPT told the DT to get off the tank
and exit the radiologically controlled area (RCA)
immediately.
Subsequent surveys that day showed
radiation levels of 70 R/hr contact, 45 R/hr at
12 inches, and 30 R/hr at two feet.
Detailed
surveys the next day revealed contact dose rates
of 300 to 600 R/hr on a band approximately six
inches wide around the circumference of the top of
the tank.
The DAD of the DT showed a reading of
808 mrem for the entry which exceeded the 750 mrem
administrative limit.
A special reading of the thermoluminescent
dosimeter (TLD) assigned to the DT was close to
the DAD reading.
The quarterly total dose for the
DT after the event was 868 mrem .
Radiological Engineering performed an
investigation into the event and listed two root
causes and a number of contributing factors.
The
( 2)
5
root causes were the failure of the DT to wait for
the HP to perform a radiation survey prior to
accessing the SRBT and continuing to remain in the
area with his DAD in an alarm mode.
Contributing
factors listed were:
more detailed surveys of the
resin discharge line of the resin transfer, the
flush operat*ion to the SRBT was not procedurally
controlled, the DT thought that he was on a 1750
mrem dose extension but was not, and level
transmitters on the SRBT were thought to be
inoperable but in fact were working; however, only
one of the six radiation monitors was working
properly;
Also, no ladder or lights in the
immediate area added to the amount of time the DT
took to get off of the SRBT when directed by HPT.
Inspection of Facilities/Equipment
The inspector toured the radwaste building and
area of the SRBT with a radiological engineer who
was already slated to visit the SRBT for other
- purposes.
The inspector noted that the lighting
in the area was very poor and high radiation
levels (without knowing the radiation levels
above) would prevent using this normal access to
the tank.
Also noted was the difficulty that
anyone would have gaining access to the top of the
SRBT using either wall.
The inspector reviewed
the licensee data and noted that the DT was in the
high dose rate area for 99 seconds.
The inspector
reviewed the licensee method for establishing the
dose based on the DT's position on the tank top
and agreed with the method.
The inspector
interviewed the contract H~T involved in the event
and noted that he was very knowledgeable of HP
requirements at Surry and responded well to
questions regarding changing radiological
conditions.
The inspector reviewed the training
records for a11* personnel involved in th~ event
and found all personnel to be well qualified in
accordance with training requirements.
Noteworthy
was the fact that Surry provides the same on-the-
job training and continuing training for
contractor HP technicians as it does for their
licensee HP technicians.
At the end of the
inspection the licensee had not determined how to
remove or where the spent resin in the SRBT should
be moved to .
6
(3)
Regulatory Implications
Based on review of the incident, associated
documentation and discussions with licensee personnel,
the inspector identified two examples of a violation of
Technical Specification 6.4.b for the failure to follow
radiation protection procedures:
The failure to adequately* survey the SRBT and
discharge line in accordance with RWP 92-2-1478,
Revision 1, and
The failure of the decontamination technician to
immediately exit the high radiation area when both
the dose rate and integrated dose alarms were
received on the digital alarming dosimeter in
accordance with RWP 92-2-1479, Revision 1, and
general employee training.
The inspector noted that the licensee performed a
thorough review of the subject event and had
.
implemented adequate corrective actions.
These actions
included:
posting of the area as an Extreme High
Radiation Area, retraining and cross-training, conduct
of a resin recovery study, implementation of elevated
approvals for resin transfers, improved pipe labeling,
and initiation of a study to determine the need for
additional installed radiation monitors.
Because the
licensee's actions identifying and correcting the
violation met the criteria specified in Section V.G.1
of the Enforcement Policy, the inspector informed
licensee representatives that the violation would not
be cited. (Non-cited Violation:
50-280, 281-92-16-01).
However, in reviewing the overall incident, it was not
apparent to the inspector that Operations had
adequately identified all operational problems
associated with the event.
In meeting with the
Operations Superintendent and the Licensing Supervisor,
the inspector stated that due to these unanswered
radwaste operational questions regarding system
certification and procedures, this area would be
identified for future followup by Region II Radiation
Effluents and Chemistry Section personnel (In'spector
Followup Item 50-280, 281/92-16-02).
During the inspection the inspector observed the final
portion of the installation of Unit 2 pressurizer
safety valve and noted that the operating crew was
knowledgeable of the radiological conditions in their
e.
7.
work area and of the operation and use of DADs.
The
inspector performed radiation surveys in Unit 2
containment and in the auxiliary building to verify
licensee postings.
There were no discrepancies.
Surveys, Monitoring and Control of Radioactive Material
During a tour of Unit 2 containment the inspector noted
- that the incore seal table area was easily accessed and
- noted after exiting containment that the power to the
Incore Moveable Detectors (IMDs) was not tagged out, as
a backup means for protection against inadvertent
operation of the system, with personnel in containment
and in close proximity to the IMD pathway.
The inspector reviewed the following procedures for
appropriate radiologicai and operational controls:
1-0P-57, Incore Movable Detector System, Revision 1,
dated July 31, 1991
2-0P-57, Incore Movable Detector System, Revision 1,
dated July 31, 1991
1-0P-57A, Incore Movable Detector System Alignment,
Revision 1, dated June 6, 1991
2-0P-57A, Incore Movable Detector System, Revision 0,
dated September 11, 1987
1-NPT-RX-002, Reactor Core Flux Maps, Revision 2, dated
May 22, 1992
2-NPT-RX-002, Reactor Core Flux.Maps, Revision 2, dated
May 22, 1992
IMP-C-IFM-20, IFM Detector System, Revision 1, dated
October 2, 1990
1-IMP-C-IFM-38, Cleaning Incore Flux Thimbles,
Revision 0, dated May 26, 1987
2-IMP-C-IFM-85, Cleaning Incore Flux Thimbles,
Revision 0, dated June 26, 1989
MMP-C-RC-028, Flux Thimble/Thermocouple Assembly
Withdrawal and Reinsertion, Revision-0, dated
September 13, 1988
0-MCM-1101-01 Flux Thimble/thermocouple Assembly
Withdrawal and Insertion, Revision 0, dated
April 20, 1992
8
In addition, the inspector reviewed a checkoff list
maintained by HP which appeared to provide necessary
radiological .precautions and limitations which were
supplemented by RWP special instructions.
However, the
procedures in general lacked consistency and were
generally lacking in formal requirements such as only
trained.and qualified people be allowed to perform the
applicable operation; specific verbal and mechanical
communication requirements, general radiological
radiation warnings, and system tagouts.
The inspector reviewed Information Notice (IN) 88-63,
Supplement 1, High Radiation Hazards from Irradiated
Incore Detectors and Cables dated October 5, 1990 and
the licensee's review for applicability.
Also reviewed was a second notice for review of IN-88-
63-Sl which is part of corporate Industry Operating
Experience Review (IOER) for all INs.
The inspector
noted that Surry did not make procedure changes and add
warnings to the extent that North Anna did.
Even
though the corporate IOER group pointedly referred to
Surry as having been a primary player in the original
IN~88-63.
The inspector noted that in the second
review Surry disagreed with the majority of changes
proposed by corporate.
The inspector inquired of the
supervisor over the IOER program as to why these
changes were not applicable and was informed that the
incorporation of items such as: adding sufficient
precautions and limitations to Incore Maintenance
procedures; adding specific instructions to prevent
unusual or unexpected situations; or to provide
adequate communications for workers who were on
respirators; were not needed because of the lack of
probability of occurrence of similar events at Surry.
The inspector informed the resident inspector and
licensee management of the conversation.
In reviewing further the inspector noted that IOER
group in corporate failed to send IN 88-63-S2 to Surry
station for a station review.
A detailed review of the
corporate IOER Review for IN 88-63-S2 revealed that
incorrect assumptions were made for Surry controls and
operation of the incore detectors; the most significant
being that, "considerable emphasis was placed by both
Operations and personnel operating the Incore Detector
system to ensure that no one is in containment when the
detectors are being moved."
"This is emphasized in the
operating procedures, the flux mapping procedures, arid
the maintenance procedures."
The inspector found this
to be contrary in that several Surry procedures that
specifically allow personnel in the containment where
9
the IMDs are operated.
This point becomes significant
because at Surry station the entry way to Unit 1, Seal
Table Room is discrete and can be (and is) locked while
the entry way to Unit 2 Seal Table Room is shared for
the "C" Reactor Coolant Pump Room and has no door for
locking.
In a meeting with the Licensing_Supervisor, Operations
Manager, and Acting QA and Assistant Station Manager,
the licensee stated that IN-88-63-S2 did not come to
Surry for* review and their program would be corrected
to ensure this did not recur.
Also, the IMD procedures
would be reviewed and necessary radiological
precautions, warnings, and system tagouts added as
necessary.
The inspector informed the licensee that
the actions needed to correct procedures embraced the
safety of personnel and that extra precautions were
necessary regarding operation of the IMDs until
necessary changes were made.
Also, that this item
would be tracked by the NRC as an Inspector Followup
Item and reviewed during subsequent inspection for
correction:
IFI 50-280/92-16-03.
The inspector reviewed the program to control
contamination at it's source and noted that to date for
1992 the licensee had experienced 107 personnel
contamination events (PCEs) as opposed to the
projection of 118, or they were 19 percent under
projection.
The annual goal is 160 PCEs or less for
the station.
The station's goal for2 contaminated area
is to be under 8,000 sq¥are feet (ft).
Currently, fhe
station is at 10,802 ft with approximately 2, 000 ft .
of scabbing now complete and being painted.
The
station does not have any contaminated area that is
considered unreclaimable. Currently 55 catch
containments are in use and 70 contamination control
devices are in use.
The inspector noted that the
program to reclaim contaminated area has become more
aggressive with management's increased support.
f.
Program to Maintain Occupational As Low As Reasonably
Achievable (ALARA)
10 CFR 20.1. (c) states that persons engaged in
activities under licenses issued by NRC should make
every reasonable effort to maintain radiation exposures
as low as reasonably achievable.
The recommended
elements of an ALARA program are contained in
Regulatory Guide 8.8, Information Relevant to Ensurirtg
10
that Occupational Radiation Exposure at Nuclear Power
Stations will be ALARA, and Regulatory Guide 8.10,
Operating Philosophy for Maintaining Occupational '
Exposures ALARA.
The inspector discussed the ALARA program with the
Station ALARA coordinator and the Maintenance
Department ALARA coordinator.
In addition, the
inspector reviewed methods the licensee used to
maintain occupational exposure ALARA.
In 1992, the licensee had a m~jor outage with
significant work being performed in Resistance
Thermocouple Detector (RTD) Bypass Manifold removal and
Service Water System work, as well as, refueling the
Unit 1 reactor.
The outage collective dose goal was
477.312 person-rem and the* actual dose incurred at
completion of the_ outage was 478.496 person-rem.
The
licensee's collective dose goal is 654.3 person-rem for
1992.
The licensee has accrued 538.42 person-rem
against the projection for this point the year of
555.36 person-rem.
The RTD by-pass manifold removal
was projected to cost 136 person-rem.
Licensee
representatives stated that utilization of actual size,
space restrictive mockups, with training under actual
dress out conditions were partially responsible for the
person-rem savings.
Another factor that aided in
exposure control was the outfitting of all personnel
with multi-digital alarming dosimeters (DADs).
Through
special computerized telemetric systems for monitoring
exposure, the licensee maintained constant real time
monitoring for each person in the dose intensive work
area.
Closed circuit television monitors were utilized
showing four different views of the job for each
monitor.
The Visual Information Management System
(VIMS), a computerized system of photographs of the
actual area were also used to aid in the training of
over 300 personnel, specifically trained for the
operation.
Also, overlays were used in conjunction
with the VIMS on large screen TVs showing the removal
sequence, for insulation and piping, all part or mark
numbers, as well as, component names and dose rates on
the components.
Other methods utilized by the licensee to reduce dose
included:
the replacement of valves containing
stellite, hot spot reduction by flushing and permanent
shielding on high dose operating systems.
The licensee
has performed 102 system flushes and reduced dose rates
by 816.8 R/hr both in containment and in the auxiliary
building.
The inspector observed shielding that was
purchased to be installed on both unit letdown lines
11
and the fuel pool skimmer system.
This concept had
worked well in reducing dose on the Unit 2 charging
pumps and has been approved for Unit 1 charging pumps.
The licensee uses 12,500 dollars to equate the
reduction of 1 person-rem in cost versus benefit
analysis.
To further reduce collective dose, the
licensee left 11 boxes of temporary lead shielding in
containment for use during-the next outage.
Thus, the
dose required to remove and transfer the 66,000 pounds
of lead to containment was saved.
The inspector informed licensee management that Surry's
ALARA program and the support of plant personnel for
the program was a RP program strength.
No violations or deviations were identified.
3.
Information Notices (92701)
4.
The inspector determined that the following Information
Notices INs) had been received by the licensee,
reviewed for applicability, distributed to appropriate
personnel, and that action as appropriate was taken or
scheduled:
IN 91-36, Nuclear Plant Staff Working Hours
IN 91-37, Compressed Gas Cylinder Missile Hazard
IN 91-39, Compliance with 10 CFR Part 21, "Reporting of
Defects and Noncompliance"
IN 91-91-60, False Alarms of Al~rm Ratemeters Because
of Radiofrequency Interference
IN 91-76, 10 CFR Part 21 and 50.SS(e) Final Rules
IN 92-25, Potential Weakness in Licensee Procedures for
Loss of Refueling Cavity Water
IN 92-30, Falsification of Plant Records
IN 92-34, New Exposure Limits for Airborne Uranium and
Exit Meeting
The inspector met with licensee represeritatives denoied
in Paragraph 1 at the conclusion of the inspection on
July 17, 1992.
The inspector summarized the scope of
the inspection findings including those listed below
12
and stated that the RP program at the station is a
strength.
The licensee did not identify any documents
or processes as being proprietary.
Dissenting corrunents
were not received from the licensee.
Item Number
50-280, 281/92-16-01
50-280, 281/92-16-02
50-280/92-16-03
Description and Reference
Non-cited violation of TS 6.4.B for the failure to
follow radiation protection
procedures resulting in an
exposure in excess
administrative limits
(Paragraph 2.d.3).
Inspector Followup Item (IFI)
Review Radwaste operations/
system performance during the
June 11, 1992 spent resin
transfer incident
(Paragraph 2.d.3).
Inspector Followup Item (IFI)
Review licensee review of
applicability of IN 88-63
Supplement 2. (Paragraph 2.e)
,