ML18152B301
| ML18152B301 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/28/1988 |
| From: | Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152B299 | List: |
| References | |
| 50-280-88-42, 50-281-88-42, NUDOCS 8812080184 | |
| Download: ML18152B301 (11) | |
See also: IR 05000280/1988042
Text
UNITED STATES
- NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W.
ATLANTA, GEORGIA 30323
Report Nos.:
50-280/88-42 and 50-281/88-42
Licensee: Virginia Electric and Power Company
Rfchmond, VA
23261
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
Inspection Conducted: October 11-14, 1988
Inspector: C1;)~-
C. H. Bassett
Approved by: C--.;(~. :%:*:_~---
License Nos.: DPR-32 and DPR-37
/
C. M. Hosey, Section Chief
~ Division of Radiation Safety and Safeguards
./
SUMMARY
Scope:
This routine, unannounced inspection involved a review of the
facility's radiation protection program including followup on licensee
Performance Improvement Program (PIP) items and on previously identified
ins.pector followup items (IFis).
Results: Progress has been made toward improving the radiation protection
program at Surry.
One violation was identified involving failure of personnel exiting the site to
follow radiation protection procedures for use of the portal monitors.
1.
Persons Contacted
Licensee Employees
- D. Benson, Station Manager
REPORT DETAILS
- R. Bilyeu, Engineer, Licensing
W. Cook, Operations Supervisor, Health Physics
B. Dorsey, Shift Supervisor, Health Physics
- D. Erickson, Superintendent, Health Physics
A. Friedman, ~uperintendent, Nucleaf Trafning
- E. Grecheck, Assistant Station Manager, Nuclear Safety and Licensing
C. Lufman, Supervisor, Security
W. Meck, Shift Supervisor, Health Physics
- G. Miller, Licensing Coordinator
- H. Miller, Assistant Station Manager, Operations and Maintenance
- J. Ogren, Superintendent, Maintenance
L. Pettaway, Shift Supervisor, Health Physics
- S. Sarver, Superintendent, Health Physics
- F. Thomasson, Supervisor, Corporate Health Physics
W. Thornton, Director, Health Physics and Chemistry, Corporate
F. Walking, Senior Staff Health Physicist, Corporate
Other licensee employees contacted during this inspection included
craftsmen, engineers, operators, mechanics, security force members,
- technicians, and administrative personnel.
Nuclear Regulatory Commission
- F. Cantrell, Section Chief, Reactor Projects
- W. Holland, Senior Resident Inspector
L. Nicholson, Resident Inspector
- Attended exit interview
2.
Control cif Radioactive Materials and Contamination, Surveys, and
Monitoring (83750)
Technical Specification 6.4.D requires that radiation control procedures
be followed.
The company Radiation Protection Plan (RPP), Chapter II, Attachment II-1,
requires in item 2 that individuals obey posted, verbal and written Health
Physics (HP) instructions.
.
HP Procedure, HP-9.0.702, Calibration and Operation of Eberline Model
PMC-4B/PMP-4C (portal radiation monitor), dated August 29, 1988, requires
in Attachment 1, item 2.0 that, once an alarm has sounded, HP is to be
2
notified and the individual causing the alarm is to remain in the area
until released by HP.
HP Instructions posted on the portal radiation monitors at the exits in
the security control points require, in item 5, that when a contamination
alarm sounds with a red lamp:
a.
Confirm contamination by using second monitor.
b.
If alarm sounds again, individual is to remain in the area.
c.
HP is to be notified.
Security General Order Number 24, Duties of Exit Control Officers, dated
March 28, 1988, requires in item 5.0, that the exit control officer notify
HP if an individual cannot clear the radiation portal monitor and have the
person standby for HP instructions.
The inspector reviewed the circumstances and information concerning events
that had been noted by members of an NRC Safety Systems Functional
Inspection (SSFI) Team during the weeks of September 12-16 and 26-30,
1988.
On September 14, 1988,
SSFI team members observed a person leaving
the site through the Security Access Control Building (SACB).
As the
person passed through the portal monitors located in the SACB, the alarm
sounded.
The person who had alarmed the monitor then went to the other
portal monitor and passed through it, sounding another alarm.
The person
waited in the SACB for a few minutes and then exited the security
turnstile and left the area.
The team members observed ten other
individuals who exited the area in a similar manner.
Of the total of
eleven individuals who exited, either through an alarming portal monitor
or after alarming a monitor, only four performed a personal contamination
survey with a frisker located in the area.
None of the people w~ited for
HP personnel to arrive prior to exiting the SACB and security personnel
did not stop the people from leaving the area.
When HP technicians did arrive they checked the area for contamination,
checked the monitors for holes in the detectors, reset the monitors, and
checked the gas bottles supplying nitrogen to the detectors to ensure that
there was an adequate supply.
No problems were found and the remaining
shift personnel, including the SSFI team members, exited the site.
During the following week, two people were observed by SSFI team members
exiting the Secondary SACS through a portal monitor that had an
11out of
service 11 * tag posted on it.
The tag or sign was hung on a lanyard
stretched across the opening of the portal monitor and the individuals
were required to bend down slightly in order to pass through the monitor
arid under the sign.
The individuals did not perform a personal
contamination survey but proceeded through the security turnstile and out
of the Secondary SACS.
Again security personnel did not require the
individuals to remain in the area.
3.
3
Through interviews with licensee personnel, the inspector determined that
they had experienced various problems with the portal monitors in the
past.
After a review of this incident and through discussions with the
portal monitor, vendor, the licensee found that the electronic power supply
boards used in the model they ha& purchased were susceptible to temperature
and humidity variations and fluctuations.
The licensee had determined. that
the fluctuations in temperature and humidity were apparently causing
spurious alanns.
Licensee representatives indicated that it*had been hot
the day of September 14, 1988, and that the temperature was well into the
nineties.
They indicated that, at the end of the shift when numerous
people were attempting to exit through the SACB, the door was held open to
accommodate people leaving site.
When this occurred, the temperature
inside the air conditioned SACB rose rapidly and apparently caused spurious
alarms of the portal monitors.
When the HP technicians arrived, they had
checked the monitor detectors for holes and the gas bottles for a~ adequate
supply of nitrogen, both of which had been known to cause spurious alanns
in the past.
Following a tour of the radiologically controlled area (RCA) and through
discussions with the licensee, the inspector determined that it would be
highly improbable that a contaminated person could reach the portal
monitors without first detecting the contamination. It was noted that the
RCA was totally surrounded by a fence or bounded by buildings and a person
exiting the RCA was required to pass through a personnel contamination
monitor or perform a whole body personal frisk in the presence of an HP
technician.
After investigating these occurrences, the licensee initiated several
corrective actions. The portal monitor vendor was contacted and new power
supply boards were acquired and installed which are reportedly not as
susceptible to spurious alarms. Also, previous to this incident, the exit
control officer watched personnel exit the SACB from behind bullet-proof
glass inside the security enclosure of ,the SACB.
Following these events,
an order was issued requiring a security guard to be on duty twenty-four
hours a day in the hallway where the monitors are located. The licensee
is also considering the possibility of interconnecting the portal monitors
with the security exit turnstile. This would allow them to electronically
lock the turnstile if the portal monitors alarm, thus prohibiting anyone
from exiting until the alarm was reset.
Failure of personnel to follow radiation protection procedures when
exiting through the portal monitors was identified as an apparent
violation of Technical Specification 6.4.D. (50-280, 281/88-42-01).
Inspector Followup Items (92701, 83750)
The following inspector followup items (IFis), consisting of licensee
commitments deta;Jed during Enforcement Conferences held April 21 and
July 6, 1988, and issues associated with the resultant Performance
Improvement Program (PIP), were reviewed and discussed with cognizant
licensee representatives during the inspection.
4
a.
(Closed) IFI 50-280, 281/88-FRP-01:
Institute Detailed Pre-job
Briefing Controls.
In early March, three individuals, who were working on the incore
flux mapping system, had pulled an irradiated incore detector and
cable nearly onto the platform where they were working.
Upon
investigation of the incident, it was determined that the briefing
given prior to the work had been conducted without the proper
radiological control being discussed and without the presence of the
Health Physics technician who would be covering the job.
To correct this deficiency, the licensee has instituted two types of
pre-job briefing controls.
For jobs involving anticipated general
area dose rates from 100 to 1,000 mi 11 i rem per hour (mr/hr), a
detailed outline of items to be covered and discussed has been
developed.
These items include:
1) a review of the dosimetry
required, the radiation and contamination levels in the job area, and
the protective clothing requirements needed, 2) a discussion of the
controls established by the radiation work permit (RWP), the
potential for airborne problems/need for respiratory protection, and
the assigned stay time, if necessary, 3) verification that everyone
has been briefed on the details of the work to be done, and 4)
discussions of the effects of operations in adjacent areas on the
workers,
survey instrumentation that will
be used, the
responsibilities of workers for high radiation area control and
actions to be taken in the event of radiological problems.
Briefings for work to be conducted in areas with a general area dose
rate greater than 1,000 mr/hr requires reviews and discussions as
outlined above plus the completion of a detailed sign-off sheet to
ensure that all aspects of the job have been covered.
In addition, a
stay time worksheet has been included to ensure that maximum
allowable dose and stay time is not exceeded.
The form also requires
the signature of the HP Shift Supervisor or designee conducting the
briefing prior to commencement of the job.
Through discussions with licensee representatives and review of the
briefing forms, the inspector determined that the required briefings
should provide adequate information for the worker to understand what
the job entails, what the radiological controls will be and what to
do in case a problem arises.
-
b.
(Closed) IFI 50-280, 281/88-FRP-02:
Management Review of the Event
With HP Personnel.
Through interviews with licensee representatives, the inspector
determined that the station manager had conducted a review o.f the
aforementioned incident with
HP personnel.
The event and
contributing factors were discussed and each individual's personal
accountability and responsibility for radiation protection was
stressed.
5
c;
(Closed) IFI 50-280, 281/88-FRP-03:
Management Review of the Events
with all Station Personnel.
Through interviews with licensee representatives, the inspector
determined that the station manager had also conducted a review of
the aforementioned incident with all other facility personnel.
The
event and contributing factors were discussed and each individual 1s
personal accountability and responsibility for radiation protection
was stressed.
d.
(Closed) IFI 50-280, 281/88-FRP-04: . Retain a Consultant to Evaluate
the Radiation Protection Program.
Through interviews with licensee representatives, the inspector
determined that an initial review of the radiation protection (RP)
- program had been completed by an HP consultant.
As a result of the
review, a number of corrective actions have been implemented. These
included hiring a relief HP superintendent, forming a radiological
engineering section on site in* the HP group and separating the
radioactive waste and decontamination functions from the HP
operations section. Although followup reviews are ongoing, this item
is considered closed.
e.
(Open) IFI 50-280, 281/88-FRP-05:
Complete .Radiation Protection
Program Implementation.
Following evaluations of the utility's radiation protection program
(RPP) by outside contractors in 1983, a comprehensive RPP document
was developed to implement both the corporate and the site RPP
policies and requirements.
This document, entitled Virginia Power
- Nuclear Operations Radiation Protection Plan, was officially approved
in 1985, along with an implementation plan.
The implementation plan
established a schedule for implementing the various aspects of the
RPP within approximately two years.
The utility hired another
contractor to develop the needed procedures and the implementation
plan was continuously updated to reflect the contractor's progress.
However, by early 1988, the station had not implemented all areas of
the RPP.
This failure to implement the RPP was identified by the
licensee as one of the contributing factors for the potenti~l and
actual overexposure problems experienced in March and May, 1988.
Licensee representatives indicated that the RPP would 6e fully
implemented by December, 1988.
f.
(Closed) IFI 50-280, 281/88-FRP-06:
Implement and Train Personnel in
Group I Procedures by September 1988.
As a means of implementing the RPP at the station, the licensee was
expediting the review, revision and implementation of the HP
procedures.
At the time of the inspection, the licensee had
completed revising an initial number of HP procedures, designated as
"Group I" procedures, and* had completed their implementation before
6
the outage that had started in September.
- Group I procedures
consisted of those dealing with respiratory protection, the radiation
work permit program, contamination control, radioactive material
control., instrumentation and surveys.
The inspector reviewed the
lesson plans used for training the HP technicians on these procedures
and verified that the topics listed above were covered.
g.
- (closed) IFI 50-280, 281/88-FRP-07:
Additional Training Sessions
with Station Personnel by July 31, 1988.
On May 27, 1988, a contractor, working on the reactor vessel flange
in Unit 1 during a refueling outage, received an exposure of
2,527 millirem to the head.
When added to his previous quarterly
dose, the total for the quarter was 3,279 mi 11 i rem, which was in
excess of the NRC quarterly allowable limit of 3,000 millirem to the
whole body.
Following this incident, the station manager authorized
additional training sessions for station employees to reemphasize
every person's responsibility for keeping his own dose as low as
reasonably achievable (ALARA) and not to rely solely on HP.
The -
inspector reviewed the training given by the training department and
verified that the incident, contributing factors and personal
responsibilities were discussed.
h.
(Open) IFI 50-280,* 281/88-FRP-08:
HP Supervisors Visitation to Sites
of Superior RP Performance.
Due to the sma 1 l number of HP supervisors the licensee had from
outside the utility's organization, it was determined that it would
be beneficial to have all first and second line supervisors visit
other facilities which had a good record.in the HP area. It was felt
that this would give the supervisors exposure to new ideas and
operational methods.
At the time of the inspection, only one
supervisor had had the opportunity to visit another facility. A trip
for another supervisor was scheduled for November, 1988, with the
supervisor participating as a team member on an Institute for Nuclear
Power Operations (INPO) evaluation team.
All other supervisors were
to be given the opportunity to visit another site following the
outage that was in progress. These visits were scheduled for 1989.
i.
(Open) IFI 50-280, 281/88-FRP-09:
Implement and Train Personnel on
Group II Procedures by December 31, 1988.
The licensee had not completed revision, implementation and training
of HP technicians on
11Group II 11 procedures. This group of procedures
dealt with external dosimetry, solid radioactive waste control,
effluent control, radioactive environmental monitoring, surveillance
and evaluations, and radiological incident investigation and
analysis.
7
Licensee representatives indicated that they were confident that the
revision, reviews and training required to implement the Group II
procedures would be completed by the end of December 1988 as
originally scheduled. (See item f. above.)
j.
(Open) IFI 50-280, 281/88-FRP-10:
Establish Two Additional
Radiological Engineer Positions Onsite.
Through discussions with the licensee, the inspector determined that
a new group, radiological engineering, had been established within
the site HP organization.
This group was set up to have a staff of
three radiological engineers.
At the time of the inspection one
radiological engineering position had been filled with a station
person and two contractors had also been hired to assist until
permanent replacements could be found.
The licensee indicated that
the functions of this group would be field engineering or assisting
in the field especially in the area of dose reduction.
Such areas as
shielding and containment design were to be the major areas of
concern..
Work package review was also anot~er function to be
assigned to the group.
k.
(Closed) IFI 50-280, 281/88-FRP-11:
Add an Additional Person as a
Relief HP Superintendent Prior to the Unit 2 Outage.
The inspector interviewed the individual who had been hired as a
relief HP Superintendent.
The inspector also reviewed the
individual's qualifications and experience
which appeared to be
adequate and appropriate for the position. The person had only
recently arrived on site but appeared familiar with the apparent
problems that had been experienced at the facility.
1.
(Closed) IFI 50-280, 281/88-FRP-12:
Add a Director of Radiological
Assess.ment at the Corporate Office.*
The inspector interviewed the individual who had been hired to fill.
the position of radiological assessor.
The individual's experience
and qualifications were reviewed, as well, and appeared to be*
adequate and appropriate for the position.
The person was assigned
from corporate to the site during the outage to provide the outside
assessment function the licensee had felt was needed.
Two contract
assessors were also onsite to assist in finding and ,identifying
problems during the* outage.
The radiological assessor reported
directly to the station manager.
m.
(Open) IFI 50-280, 281/88-FRP-13:
Acquire a Reverse HP Loanee From
INPO Prior to the Unit 2 Outage.
The licensee indicated that this had not been accomplished but that
discussions were still in progress with INPO to acquire the needed
person.
,,
8
n.
(Closed) IFI 50-280, 281/88-FRP-14:
Contractors - Training and
Accountability.
Through di scussi ans with 1 i censee training representatives, the
inspector determined that this training had been provided to
contractor HP technicians and other contractors as wel 1.
The
inspector reviewed the lesson plans used and the lists of personnel
who attended the sessions.
It was also noted that a system had been
established to assess all contractors* performance in order to ensure
that only trained and qualified people were brought in to work at the
station.
o.
(Closed) IFI 50-280, 281/88-FRP-15:
Radiological Assessment Function
of the Unit 2 Outage.
The 1 i censee had hi red a person to function as a corporate
radiological assessor and assist at both the utility's power stations
to improve the radiation protection program.
(See item 1. above.)
The person was onsite full time during the outage to assist and find
problems that needed to be corrected.
The licensee had also hired
two contractor assessors to provide nearly round the clock coverage
of the radiological control activities during the outage.
The
inspector reviewed various reports generated by this group and
determined that radiological problems were being identified.
The
corporate radiological assessor indicated that, although no major
prob 1 ems or trends had been i denti fi ed, the assessment program
appeared to be functioning as originally outlined.
He also indicated
that this type assessment would continue after the outage but that
his time would then be split between the two stations and corporate
headquarters.
p.
(Open) IFI 50-280, 281/88-FRP-16:
Consolidate Procedure Development
to Ensure Consistency and Integration.
q.
The licensee indicated that a centralized procedure development staff
was needed to ensure consistency and proper integration of procedures
at the site.
The program was to be a general program for the entire
nuclear operations department and would involve upgrading all
procedures including maintenance, operations, and instrumentation and
contra 1 *
HP procedures were not to be inc 1 uded in this effort
initially due to the recent RPP revision and implementation program
that was in place.
A standard for the preparation of procedures -had
been completed and a procedure writer 1s guide was being developed.
(Open) IFI 50-280, 281/88-FRP-17:
Ensure Proper Procedural
Architecture and Human Factors Implementation.
A writers group was to*be established at each site to ensure proper
procedural architecture of each procedure ( to standardize all
procedures) and to upgrade the procedures to include human factors
into all procedures.
The inspector determined that a writers group
9
had been assembled at the site and work was underway on the upgrade
project.
Due to the current revision and implementation of the HP
procedure, they were not to be included in this upgrade project
initially but would be revised/standardized at a later date.
However, the licensee indicated that all the procedures were to be
revised by December 1991.
r.
(Open) IFI 50-280, 281/88-FRP-18:
Consultant Review of Station
Activities Planning and Management.
The inspector reviewed the results of a review performed at the
station by a management consultant team.
The consultant review
indicated several areas where improvement was needed and the licensee
was formulating an action ~lan to correct the noted deficiencies.
Also, the licensee indicated that, although the initial review was
completed, the management review was ongoiflg and may yet provide
still further items for improvement.
s.
(Closed) IFI 50-280, 281/88-FRP-19:
Unit 2 Outage:
Reduce Loading
and Levelize Containment Activities.
Through interviews with licensee representatives, the inspector
determined that the scope of the Unit 2 outage had been reduced with
more "windows" or separate activity hold points established.
This
caused a slowdown in accomplishment of certain activities but allowed
for better coordination of the activities toward the overall outage
goal.
This reduced outage scope would have aided in shortening the
1 ength of the outage, however Unit 1 had a forced outage, which
strained all the resources at the facility and added more work to the
outage.
t.
(Closed) IFI 50-280, 281/88-FRP-20:
Standards Reinforcement.
Through interviews with 1 i censee representatives, the inspector
determined that two people from corporate, designatep as
11 coaches, 11
were onsite for one week every other week.
The coaches were trained
in observation techniques and had participated in past INPO
evaluations.
They reported directly to the station manager and were
used in the field to observe standards/procedure compliance and to
help upgrade the standards when required.
The station manager
indicated that, following these individuals' efforts to ensure that
things were done properly, not as many problems had been noted.
4.
Exit Interview
The inspection scope and results were summarized on October 14, 1988, with
those persons indicated in Paragraph 1.
The inspector described the areas
inspected and discussed in. detail the inspection findings.
No dissenting
comments were received from the licensee.
The licensee did not identify
as proprietary any of the material provided to or reviewed by the
inspector during this inspection.
Item Number
50-280, 281/88-42-01
10
Description and Reference
Violation - Failure to follow approved
radiological control procedures for using
portal monitors (Paragraph 2).