ML18152A489
| ML18152A489 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/21/1991 |
| From: | Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A490 | List: |
| References | |
| 50-280-91-13, 50-281-91-13, NUDOCS 9107080238 | |
| Download: ML18152A489 (11) | |
See also: IR 05000280/1991013
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
.JIJ~ 2 l J991 .
R~port Nos.: 50-280/91-13 and 50-2.81/91-13
Licensee: Virginia Electric and Power Company
Glen Allen, VA
23060
Docket Nos.: 50-280 and 50-2~1
Facility Nam~: Surry 1 and 2
License Nos.: DPR-32 and DPR-37
1991
Accompanied b~y.
E *. Pharr
Approved by~
~
.~Cief
Facilities Radiation Protection Section
Radiological Protection and Emergency
Preparedness Branch
Dfre 'signed
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the area of
occupational radiation safety during an extended outage and included
an examination of: audits and appraisals, training and qualification,
external exposure control, internal exposure control, control of
radioactive materials and contamination, surveys and monitoring, and
maintaining occupational exposures ALARA.
In addition, licensee
responses to previously identified inspection findings were reviewed.
Results:
In the areas inspected, violations or deviations were not identified.
Based on interviews with licensee management, supervision, personnel
from station departments, and records review, the inspector found the
radiation protection program to be managed well.
Management and staff
were motivated and knowledgeable and were involved in activities to
reduce personnel exposure.
The licensee's programs for external and
internal radiation exposure controls were effective and functioning
adequately to protect the health and safety of occupational radiation
workers.
91070°0?~ 0
910621
~D~ -~fi5t~ 05000280
Q
1.
Persons Contacted
- Licensee Employees
REPORT DETAILS
- W. Benthall, Supervisor, Licensing
- W. Cook,. supervisor, Health Physics Operations
- D. Erickson, Superintendent, Radiation Protection
- B. Garber, Supervisor, Radiation Protection
- D. Hart, Supervisor, Radiation Protection
- M. Kansler, Station Manager
- J. Keithley, Shift Supervisor, Radiation Protection
- J. McCarthy, Superintendent, Operations
- M. Olin, Supervisor, Radiation Protection, Decon Services
- J. Price, Assistant Station Manager
- R. Saunders, Assistant Vice President, Nuclear Operations
- T. Steed, Radiation Protection ALARA Coordinator
- W. Thornton, Corporate Health Physicist
- R. Warnick, Health Physics Technician
- F. Wolking, Nuclear Operation Services
- K. Wyatt, Maintenance ALARA Coordinator
Other licensee employees contacted during this inspection
included craftsmen, engineers, operators, mechanics, and
administrative personnel.
Nuclear Regulatory Commission
- W. Holland, Senior Resident Inspector
- S. Tingen, Resident Inspector
J. York, Resident Inspector
- Attended May 24, 1991 Exit Meeting
2.
Audits and Appraisals {83729)
Technical Specification {TS) 6.1.C.3. requires audits ~f
facilities to be performed under the cognizance of the Quality
Assurance (QA) Department for conformance of facility operations
to TSs and applicable license conditions~-
The inspector reviewed a recently developed aspect of the
licensee's program of self-appraisal.
In addition to audits
required by TSs and surveillance performed by QA, assessments
have been added to determine the effectiveness of department and
program performance.
The assessment reviewed was conducted
during April 1991 of Surry*s Advanced Radiation Worker (ARW)
program.
3.
2
The ARW.program is used to improve worker knowledge and skills.
Workers are required to perform some similar health physics (HP)
technician duties as part of their job function.
Frequently ai.r
samples, tool surveillance, and* radiation and contamination
surveys to support their specific job are performed by the ARW,
both reducing the demand on HP and improving efficiency of the
- ARW.
Surry's management initiated the request for assessment after
concerns. for some ARW program elements were expressed in
September 1990 by a Quality Maintenance Team (QMT).
The
September 1990 assessment identified that management support for
the ARW Program could be improved and found that there were basic
understanding and identification problems on the part of the ARW.
The QA assessment conducted in April 1991 focused on program
concepts, implementation, and training of ARWs.
Of primary
concern by the ARW was job scope.
The ARWs stated that they were
unsure as to whether their training was adequate, what level of
job performance HP would expect of them, how much of HP duties
they were to assume, and where the radiological ownership for ARW
job performance was to reside.
The assessment was interview driven and concluded that while the
ARW program was performing satisfactorily it could be more
efficient and the ARW workers should receive more training to
improve their confidence in performing HP related tasks.
Assessment recommendations included upgrading the program to meet
worker needs such as hands on training during both initial and
recertification ARW training, improve communications between
ARWs, HP, and management, and continue to monitor the interface
and track and assess ARW effectiveness.
In response, the licensee has completed a group training mockup
that incorporates some system capabilities inplant and utilizes
similar type components inplant.
The inspector determined that the assessment performed by QA was
resulting in improvements to licensee programs and was*
supplementing the licensee's comprehensive problem
self-identification program.
No violations or deviations were identified.
Organization and Management Controls (83729)
The inspector reviewed changes made to the licensee's
organization, staffing levels and lines of authority as they
related to radiation protection, and verified that the changes
had not adversely affected the licensee's ability to control
radiation exposures or radioactivity.
3
The inspector reviewed the licensee's program for self-
identification of weaknesses related to the radiation protection
program and the appropriateness of corrective action taken.
By
use of Radiological Assessor's Reports (RARs), Radiological
Problem Reports (RPRs), and Personnel Contamination Events
(PCEs), the licensee was able to identify and document
radiological control weaknesses~
The inspector' reviewed RARs performed weekly by HP
technicians
during the period January 1, 1991 to May 15, 1991.
Problems
identified were mainly associated with housekeeping, downed or
not clearly visible postings, posting of expired RWPs, and ALARA
issues.
The inspector noted that corrective actions were taken
immediately and that recurring problems were identified and
corrective actions addressing the root cause were proposed.
The
inspectors also reviewed RPRs, PCEs, and station Deviation
Reports and noted that the licensee was adequately conducting
investigations to identify root causes.
No violations or deviations were identified.
4.
Training and Qualifications (83729)
10 CFR 19.12 requires the licensee to instruct all individuals
working or frequenting any portions of the restricted areas in
the health protection aspects associated with exposure to
radioactive material or radiation, in precautions or procedures
to minimize exposure, and in the purpose and function of
protection devices employed, applicable provisions of the
Commission Regulations, individual's responsibilities and the
availability of radiation exposure data.
The inspector discussed with licensee representatives initiatives
being taken in ARW training following the April 1991 ARW program
assessment.
A major problem identified during the audit was that
more. than 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of practical training, as currently
provided to ARW trainees, was needed to provide.for a more
thorough training.
Training representatives plan to allow for
more practical training sessions, both initially and !°or
retraining, and to continue all training under simulated
conditions in their group training mock-up facility.
The
resources available at the training facility allow the training
personnel to practically duplicate the environment to which ARWs
will be exposed.
Their plans are that this practical experience
will condition the ARWs to recognize changing radiation
conditions and how to respond to them.
The inspector discussed with cognizant licensee representatives
the licensee's HP continuing training program.
The licensee
stated that the facility's HP technicians are organized into six
shifts with one shift in training all the time.
Training cycles
4
encompass emergency preparedness, current industry events, new
instrumentation, and plant systems.
Outside the scope of the set
training plans, the HP and training departments have "need to
know" meetings in which HP adds* to the training plan those things
they believe the technicians should know.
- Licensee representatives informed the inspector that. prior to the
outage two HP supervisors and two HP technicians attended a week
of training with representatives from Westinghouse.
Both
lectures.and mock-up training sessions were performed to provide
valuable insight into the licensee's upcoming steam generator
work during the outage.
The inspector was informed by the HP
Operations Supervisor that this training was beneficial in
reducing 02 outage exposure due to S/G work by more than
30 percent as compared to 1990 outage S/G work.
In discussions with the HP Operations Supervisor, the inspector
was informed that all six HP shifts have been sent to different
utilities to observe their radiation protection programs for a
week.
The supervisor stated that he had received excellent
management support and that he felt the entire HP program had
benefitted from the training.
The licensee felt that not only
had each shift learned from the other utilities but also that
they had gained confidence in their own HP program.
The
inspector determined that the licensee training program continued
to improve performance at the facility *.
No violations or deviations were identified.
5.
External Exposure Control and Personal Dosimetry (83729, 83750)
a.
RWP Implementation
TS 6.4.B requires the licensee to have written procedures,
including the use of radiation work permits (RWPs), prepared
consistent with the requirements of 10 CFR Part 20 and they
shall be approved, maintained, and adhered to for all
operations involving personnel radiation exposure.
The inspector reviewed selected RWPs related to reactor head
work for appropriateness of the radiation protection
requirements based on work scope, location, and conditions.
The inspector was informed by cognizant licensee
representatives that throughout the outage these workers
were briefed on certain RWP requirement changes as
pertaining to the particular job they would be performing.
The inspector also noted that as work conditions changed the
RWP was updated as appropriate.
During tours of the
Containment Building, the inspector observed the adherence
of plant workers to the RWP requirements.
The inspector
found the RWPs to be thorough and complete with worker
adherence and knowledge to be adequate.
b.
5
Personal Dosimetry
10 CFR 20.202 requires each licensee to supply appropriate
personnel monitoring equipment to specific individuals and
require the use of such equipment.
During tours of the Containment Building and Auxiliary
Building, the inspector observed the continued use of
digital alarming dosimeters (DADs).
The inspector noted
that an alarm point is set for both dose and integrated dose
as prescribed by the individual's RWP.
During discussions
with licensee representatives, the inspector was informed
that in high noise areas workers have on occasion not been
able to hear their alarming DADs.
The inspector discussed
with these representatives the possible use of vibrating
DADs that would provide the workers an added sensory
indicator of the alarming dosimeter.
c.
Licensee Control of Incore Detector Systems
The inspector reviewed Operating Procedure, 1-0P-57 and
2-0P-57, Incore Movable Detector System, which provides
requirements for operations personnel for flux mapping and
for calibrating the incore movable detector system prior to
obtaining the flux map.
The procedure pertaining to Unit 1
calibration and flux mapping (1-0P~57, dated August 6, 1986)
requires the operator to gain HP's permission to enter the
Containment Building during flux mapping and requires the
permission of the Operations Shift Supervisor to operate the
flux mapping system prior to calibration.
The Unit 2
procedure (2-0P-57, dated February 2, 1990) has the same
requirements as Unit 1 except that the Shift Supervisor
grants the operators permission to enter the containment
during flux mapping without notifying HP.
The inspector
informed licensee management of this oversight of HP
notification prior to Unit 2 movement of the incore
detectors for calibration and flux mapping.
The licensee
acknowledged the inspector's comments.
The inspector also reviewed Instrument Maintenance
Procedures, IMP-C-IC-81, Incore Movable Detector System
Checkout, dated June 26, 1989, and IMP-C-IFM-20, IFM
Detector System, dated October 2, 1990.
Both procedures
were used to determine operability and performance checks of
the Incore Detector System.
Both procedures require that
both the operations and HP shift supervisors have knowledge
of the work to be performed and both have granted permission
for the work to be done.
Both procedures also require
adherence to the necessary RWP, and the RWP must be approved
by the station's Nuclear Safety Operating Committee,
continuous HP coverage, as well as a pre-job briefing
between the HP and instrument technicians for work inside
6
the Containment Building.
The inspector noted that the
procedures were thorough and required the initials of the
responsible party to verify performance of the procedure
requirement.
The inspector verified that HP also has a sign off sheet for
incore detector operations.
The checklist requires the
authorization of the HP supervisor and the Operations Shift
Supervisor, as well as adherence to the appropriate RWP, and
continuous HP coverage.
The inspector found the licensee's
control of incore detectors operations to be adequately
managed.
No violations or deviations were identified.
6.
Internal Exposure Control (83729)
10 CFR 20.103(b) (1) requires that the licensee use process or
other engineering controls to the extent practicable to limit
concentrations of radioactive materials in the air to levels
below those which delimit an airborne radioactivity area as
defined in 10 CFR 20.203(d) (1) (ii).
10 CFR 20.103(b) also requires that when it is impracticable to
apply process or other engineering controls to limit
concentrations of radioactive material, .other precautionary
procedures shall be used.
The precautionary procedures include
respiratory protective equipment.
During discussions with licensee representatives, the inspector
was informed that in preparation for the revised 10 CFR Part 20
the licensee has been comparing work in respirators as opposed to
work without respirators for the purpose of keeping exposures
The licensee currently uses lapel air samplers to enhance
their breathing zone sampling representativeness.
Cognizant
licensee representatives stated that during the outage,
detensioning of the reactor head was done in full-face
respirators and lapel air samplers so that thorough sampling data
could be collected and reviewed.
The inspector noted ~hat all
lapel air results were below 25 percent of the Maximum
Permissible Concentration (MPC).
Decontamination efforts
followed and when tensioning of the head took place, workers wore
only face shields along with lapel air samplers.
Again, lapel
results were less than 25 percent MPC.
The inspector was informed that in all previous outages workers
had always worn full-face respirators when performing both
operations.
The licensee noted that the workers were able to
perform the retensioning a little faster and expended a little
less dose than in previous operations where respirators were
worn.
Most significantly; though, they noted a more positive
worker attitude due to the fact that both physically and mentally
7
the situation was less stressful and communications were much
improved.
The inspector recognized the licensee's efforts in
preparation for the 10 CFR 20- revisi_ons.
No violations or deviations were identified.
7.
- Tours of Facilities (83729)
10 CFR 19.ll(a) and (b) require, in part, that the licensee post
current copies of Part 19, Part 20, the license, license
conditions, documents incorporated into the license, license
amendments and operation procedures, or that a licensee post a
notice describing these documents and where they may be examined.
10 CFR 19.ll(d) requires that a licensee post Form NRC-3, "Notice
to Employees."
Sufficient copies of the required forms are to be
posted to permit licensee workers to observe them on the way to
or from licensed activity locations.
During the onsite inspection, the inspector verified that Form
NRC-3 and notices referencing the appropriate 10 CFR Part 19 and
Part 20 and licensee documents were posted in accordance with the
applicable regulation.
Forms were posted at the entrance of the
Turbine Building to the Radiation Control Area (RCA) in view of
all employees entering the area.
No violations or deviations were identified.
8.
Control of Radioactive Material, Surveys, and Monitoring (83729,
83750)
10 CFR 20.201(b) requires each licensee to make or cause to be
made such surveys as (1) may be necessary for the licensee to
comply with the regulations and (2) are reasonable under the
circumstances to evaluate the extent of radioactive hazards that
may be present.
10 CFR 20.401(b) requires each licensee to maintain records
showing the results of surveys required by 10 CFR 20. 2_01 (b).
During plant tours, the inspector examined radiation levels and
contamination levels posted for various areas in the Auxiliary
Building and Unit 2 containment.
The inspector performed
independent surveys of selected areas and noted that there were
not major differences with those posted by the licensee.
The
inspector also verified that observed radiation detection
instrumentation was in current calibration.
The inspector reviewed all Personnel Contamination Events (PCEs)
reports.
To date, the licensee had experienced only 60 PCEs of
the 116 projected.
Licensee representatives attributed the good
performance in this area to better contamination awareness by
8
personnel and the early containment decontamination.
The
licensee was observed to have 266 catch containments for
radioactive leaks throughout the plant.
Licensee representatives
stated that they considered this a large number of leaks and
would emphasize the repair rate.
- The licensee goal for c~::mtaminated square feet (ft2) of RCA was
10,000 for 1991.
Currently, there was 19,280 ft2 of contaminated
area.
Licensee representatives stated that prior to the Unit 2
refueling maintenance outage1 t.he contaminated square footage was
14,000 and that the 6,000 ft area should be easily reclaimed.
The licensee has been relatively slow in recovering contaminated
area, but area recovered has been coated with epoxy to minimize
difficultr in future decontaminations.
Meeting the goal of
10,000 ft in 1991 would show improvement over previous years.
The inspector also reviewed the licensee's policies for
installing temporary step off pads for contaminated areas in
overhead areas.
This item was also discussed with the resident
inspectors.
No discrepancies were noted with licensee policies
on this issue.
No violations or deviations were identified.
9.
Program for Maintaining Exposures As Low As Reasonably
Achievable (ALARA)
(83729)
10 CFR 20.1c states that persons engaged in activities under
licenses issued by the 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 Ensuring that
Occupational Radiation Exposure at Nuclear Power Stations will be
ALARA, and Regulatory Guide 8.10, Operating Philosophy for
Maintaining Occupational Radiation Exposures ALARA.
The inspector reviewed licensee documentation for station
collective dose and interviewed ALARA personnel to determine
current program status.
The licensee's collective dose for the
outage was 339.168 person-rem on May 21, 1991.
This was slightly
above the projected dose due to gas stripper repairs in the
previous quarter.
The inspector reviewed methods used by the licensee to reduce
collective dose in 1991.
The installation of fuel with grid
spacers made of zircoloy reduced cobalt in the system.
In
addition, the new fuel installed is designed to have a life of 20
months.
Several other dose reducing methods were i~plemented but
had not yet been quantified regarding dose saved.
These were:
0
Hot spot piping flushes on both the pressurizer and cold leg
safety injection valves
0
0
0
0
0
0
9
Utilization of a valve packing extraction tool
Utilization of robotics for up~er internal inspection
Increase of temporary shielding by over 300 percent during
the outage
Hydrogen peroxide addition and early boration at shutdown
Dedication of containment for 6 days of decontamination at
the outage start
Utilization of pop end plugs vice welded plugs on the Non-
Regenerative Heat Exchanger
The inspector discussed progress made with the Maintenance
Department ALARA Coordinator and reviewed several Maintenance
Department Monitoring ALARA reports.
The inspector determined
that both HP and maintenance were very involved in dose reduction
and worked together to minimize collective station dose.
Maintenance appears to be assuming a greater share and
responsibility for the Station's ALARA program.
No violations or deviations were identified.
10.
Licensee Actions on Previously Identified Inspector Findings
(92702)
(Closed) VIO 50-280/90-18-0l and 50-281/90-18-0l:
Between
March 23-30, 1990, the licensee failed to utilize process or
other engineering controls to the extent practical so that
licensee personnel were in an average airborne concentration of
25 Maximum Permissible Concentration hours per week (MPC-hrs/wk)
when the radioactivity concentration in the licensee's Auxiliary
Building reached 99 times that specified in Appendix B, Table 1,
Column 1, of Part 20, on March 26, 1990.
The inspector reviewed and verified implementation of corrective
actions stated in the VEPCO response dated July 11, 1990.
Corrective actions included installation of a permanent drain
line for resin shipping container dewatering activities, a matrix
tabulation describing proper ventilation alignment during a given
event or situation, updating Surry administrative procedure,
SUADM-0-11, to require that a temporary modification be performed
and documented for the use of temporary hookups which will be
used for handling radioactive process fluids, and balancing of
the Auxiliary Building's central and general ventilation exhaust
systems.
Based on review of these licensee corrective actions and
additional actions which have included walkdowns to identify
other contamination control barrier breakdowns due to ventilation
'
p
10
perturbations and purchasing and utilizing continuous air
monitoring equipment, the inspector informed licensee
representatives that this issue would be considered closed.
11.
Exit Meeting
- The inspector met with licensee representatives indicated in
Paragraph 1 at the conclusion of the inspection on May 24, 1991.
The inspector summarized the scope and findings of the inspection
with licensee'management.
The licensee did not identify any such
documents or processes as proprietary.
Dissenting comments were
not received from the licensee.