ML18153A691
| ML18153A691 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/28/1995 |
| From: | Forbes D, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153A692 | List: |
| References | |
| 50-280-95-11, 50-281-95-11, NUDOCS 9507140263 | |
| Download: ML18153A691 (12) | |
See also: IR 05000280/1995011
Text
Report Nos. :
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETIA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
June 30, 1995
50-280/95-11 and 50-281/95-11
Licensee:
Virginia Electric and Power Company
Docket Nos.:
50-280, 50-281
License Nos.:
Inspection Conducted:
June 5-9, 1995
Inspector: D. /J i;j;;;;)
&t.:l.3 /qs
D. B. Forbes
Da~ Signed
Approved el:-:(,()~ R=b
W. H. Rankin, Chief
Scope:
Facilities Radiation Protection Section
Radiological Protection and Emergency Preparedness Branch
Di.vision of Radiation Safety and Safeguards
SUMMARY
This routine, announced 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; internal exposure control; surveys,
monitoring, and control of radioactive material; and maintaining occupational
radiation exposure as low as reasonably achievable (ALARA).
Results:
Based on observations, interviews with licensee management, superv1s1on,
personnel from station departments, and records reviewed, the inspector found
the licensee's program for occupational radiation safety was functioning
adequately to protect the health and safety of the radiation workers and the
general public. Radiation protection (RP) staffing levels appeared adequate
to support on-going activities and RP personnel interviewed were well trained.
The licensee's self-assessment program was conducted in accordance with
requirements.
The licensee continued to implement effective internal and
external exposure control programs with all exposures less than 10 CFR Part 20
limits .
9507140263 6~88~~80
~DR
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REPORT DETAILS
1.
Persons Contacted
D. Anderson, Shift Supervisor, Radiation Protection
M. Biron, Supervisor, Radiation Protection
- A. Brown, Training
B. Campbell, HP Site Coordinator, Numanco
- J. Curry, Materials
- D. Dag, Radiation Protection
B. Dorsey, Supervisor, Radiation Protection
- D. Erickson, Superintendent, Radiation Protection
- B. Garber, Licensing
- D. Hayes, Administrative Services
D. Miller, Supervisor, Radiation Protection
D. Nace, Radiation Protection
M. Olin, Supervisor, Radiation Protection
- J. Price, Assistant Station Manager
T. Steed, ALARA Coordinator, Radiation Protection
- J. Steinert, Quality Assurance
- E. Topping, Radiation Protection
- J. Wilkinson, Health Physics Operations
- J. Wright, Radiation Protection
Other licensee employees contacted during this inspection included:
craftsmen, engineers, operators, contract personnel, and
administrative personnel.
Nuclear Regulatory Commission
M. Branch, Senior Resident Inspector
D. Kern, Resident Inspector
- S. Tingen, Resident Inspector
- Attended Exit Interview conducted on June 9, 1995.
2.
Organization and Management Controls (83750)
The inspector reviewed the staffing of the radiation protection (RP)
organization as related to lines of authority and noted no changes
since the previous inspection conducted May 29-30, 1995, and
documented in NRC Inspection Report (IR) 50-280/95-01 and
50-281/95-01.
At the time of the inspection, Units 1 and 2 were
. operating.
The inspector noted that at the time of the inspection,
the licensee maintained an adequate level of staffing to support
ongoing operations and all RP personnel interviewed were well trained
to perform their assigned duties .
No violations or deviations were identified.
- 3.
2
Radiation Protection Training (83750)
10 CFR 19.12 requires, in part, that the licensee instruct all
individuals working in or frequenting any portion of a restricted area
in the health protection aspects associated with exposure to
radioactive material or radiation; in precautions or procedures to
minimize exposure; in the purpose and function of protection devices
employed; in the applicable provisions of the Commission regulations;
in the individual's responsibilities; and in the availability of
radiation exposure data.
The inspector reviewed the licensee's lesson plan for respiratory
protection training titled, "Nuclear Employee Training," NET-7-LP-1,
Revision (Rev.) 1, and discussed the training with licensee personnel
to verify personnel understood the scope of the training, particularly
as related to radiation exposure controls. The inspector reviewed
training requirements for the various types of respiratory devices
employed at the Surry Nuclear Plant to include half-face respirators,
full-face respirators, and bubble hoods.
The inspector was informed
by cognizant personnel that the licensee does not use cotton mask for
any hazards.
Half-face or full-face respirators are used in
radiological areas in lieu of cotton mask for any licensee determined
non-radiological hazards.
Based on a review of training materials, procedures, records, and
personnel interviews, the inspector determined personnel had been
adequately trained in the area of respiratory protection and that
personnel were complying with the areas of the training reviewed.
No violations or deviations were identified.
4.
Audits and Appraisals (83750)
10 CFR 20.llOl(c) requires that the licensee periodically (at least
annually) review the radiation protection program content and
implementation.
The inspector noted that since the last inspection in this area
conducted February 14-18, 1994, and documented in IR 50-280/94-05 and
50-281/94-05, an audit had been conducted by the licensee's Quality
Assurance (QA) Organization entitled, "Radiological Protection Program
Audit," S-94-07, dated August 24, 1994.
The audit assessed the
following RP Program attributes:
Organization
Instructions, Procedures, Drawings
Document Control
Test Control
Control of Measuring and Test Equipment
Training/Qualification
Corrective Action
QA Records
- * *
3
External Exposure Control
Internal Exposure Control
Control of Radioactive Material
Based on the audit results, the licensee concluded that regulatory
requirements were effectively being implemented.
However, some areas
of weakness were identified in the area of procedural compliance and
worker awareness of radiological work requirements.
The inspector
determined the licensee was identifying areas of weakness or non-
compliance for improvement and the audits being performed were meeting
the licensee's requirements for performing annual audits in the area
of RP.
The inspector also reviewed the licensee's internal program for self-
identification of weaknesses as it related to the RP program other
than those identified during the annual audit and the appropriateness
of corrective actions taken.
The program included Station Deviation
Reports (SDRs) and Radiation Awareness Reports (RARs).
Both systems
were utilized by the licensee to document, investigate, and track
items of concern.
The SDR system was a plant-wide system for
identification of concerns, while the RAR was a lower-tier system
utilized mainly by the RP organization to identify a variety of minor
concerns.
The inspector reviewed various RARs from 1994 and 1995 and noted that
the licensee was identffying substantive items of concern and was
following through with appropriate corrective actions to prevent
recurrence.
No violations or deviations were identified.
5.
Internal Exposure Controls (83750)
a.
Respiratory Protection
10 CFR 20.1703(a)(3) permits the licensee to maintain and to
implement a respiratory protection program that includes, at a
minimum:
air sampling sufficient to identify the hazard;
surveys and bioassay to evaluate the actual intakes; testing of
respirators immediately prior to each use; written procedures
regarding selection, fitting, issuance, maintenance and testing
of respirators; written procedures regarding supervision and
training of personnel and monitoring, including air sampling
and bioassays; record keeping; and determination by a physician
prior to the use of respirators, that the individual user is
physically able to use respiratory protective equipment.
The inspector reviewed records for various employees who had
recently worn respiratory protection equipment.
The inspector
verified that for the records reviewed, each worker had
4
successfully completed respiratory protection training, was
medically qualified, and was fit-tested for the specific
respirator type used in accordance with licensee procedural
requirements.
The inspector discussed with the licensee, respirator reduction
efforts to enhance ALARA concepts with respect to worker
training, successful decontamination efforts, and various
engineering controls to include worksite ventilation, face
shields, and glove bag containments. Total Effective Dose
Equivalent (TEDE)/ALARA evaluations for 1995 were reviewed and
the inspector determined the licensee had performed evaluations
as required by licensee procedure when necessary to determine
if a respirator should be worn to reduce exposure.
The
licensee informed the inspector that the workers actually
performing the work would provide input to the ALARA staff
regarding the work to be performed and would participate when
possible in the TEDE/ALARA evaluations for those jobs requiring
such evaluations to be performed.
Numerous Radiation Work
Permits (RWPs) were reviewed by the inspector to determine if
- engineering controls were being applied, as required by
licensee procedure, for jobs where surveys indicated high
levels of contamination existed and respiratory protection was
not worn.
The inspector noted engineering controls had been
included on the RWPs reviewed.
At the time of the inspection,
the licensee was tracking approximately 45 positive intakes for
1995, of which, all were less than 10 percent of an annual
Allowable Limit of Intake (ALI).
Individual Intakes for 1995
were reviewed with cognizant licensee personnel to verify
methodology for assigning a Committed Effective Dose Equivalent
(CEDE).
The maximum CEDE for a single individual was
approximately 20 millirem which was a small percentage of the
regulatory limits of 5,000 millirem per year.
The inspector
reviewed licensee procedures regarding respiratory protection
which included the following:
HPAP-1042, Respiratory Protection Program, Rev. 0
HP-1042.10, Respirator User Qualification, Rev. 1
HP-1042.150, Respirator Issue, Rev. 0
HP-1042.220, Airborne Radioactive Material Exposure
Authorization, Rev. 0
HP-1042.230, Airborne Radioactivity Exposure Tracking,
Rev. 1
HP-1032.050, Airborne Radioactivity Surveys, Rev. 1
5
Based on the review conducted in this area, the inspector
determined the licensee had effectively controlled internal
exposures.
No violations or deviations were identified.
b.
Breathing Air Quality
30 CFR 11.121 requires that compressed, gaseous breathing air
meet the applicable minimum grade requirements for Type 1
gaseous air set forth in the Compressed Gas Association {CGA)
Commodity Specification for Air, G-7.1 {Grade Dor higher
quality).
The inspector reviewed and discussed with the licensee
representatives the program for testing and qualifying
breathing air as Grade D.
The inspector examined breathing air
manifolds for physical integrity, current calibration of
gauges, and the presence of carbon monoxide monitoring
equipment.
In addition, the inspector further noted that the
- *supplied air hoods and hoses available for use were compatible
per manufacturer's instructions as were air supplied
respirators and hoses .
Review of breathing air testing records verified that the
licensee was calibrating in-line carbon monoxide monitors and
sampling in-use breathing air systems for certification in
accordance with procedural requirements.
For the tests
reviewed, breathing air met Grade D requirements.
No violations or deviations were identified.
6.
External Exposure Controls {83750)
a.
Personnel Dosimetry
10 CFR 20.lSOl{c){l) and (2) requires that dosimeters used to
comply with 10 CFR 20.1201 shall be processed and evaluated by
a processor accredited by the National Voluntary Laboratory
Accreditation Program {NVLAP) for the types of radiation being
monitored.
10 CFR 20.1502{a) requires each licensee to monitor
occupational exposure to radiation and supply and require the
use of individual monitoring devices by:
(1)
Adults likely to receive, in one year from sources
external to the body, a dose in excess of 10 percent of
the limits in 10 CFR 20.120l{a);
b.
6
(2)
Minors and declared pregnant women likely to receive, in
one year for sources external to the body, a dose in
excess of 10 percent of any of the applicable limits of
10 CFR 20.1207 or 10 CFR 20.1208; and
(3)
Individuals entering a high or very high radiation area.
The inspector selectively reviewed the licensee's dosimetry
program to ensure the licensee was meeting the monitoring
requirements of revised 10 CFR Part 20.
The inspector verified
the licensee was NVLAP accredited. A licensee assessment of
the External Exposure Control Program was conducted from
March 6 through March 19, 1995.
This assessment was performed
to evaluate the effectiveness of program changes initiated in
response to the 1994 NVLAP assessment at the Surry Nuclear
Station.
The NVLAP assessment identified dosimetry program
areas needing changes to comply with NVLAP program standards to
be implemented in July of 1995.
The assessment concluded the
licensee has implemented these program changes.
During tours
of the Radiation Control Area (RCA), the inspector observed
- personnel wearing dosimetry devices appropriately as required
by RWPs .
No violations or deviations were identified.
Total Effective Dose Equivalent (TEDE) Exposure
10 CFR 20.1201 (a) requires each licensee to control the
occupational dose to individual adults, except for planned
special exposures under 20.1206, to the following dose limits:
(1)
An annual limit, which is the more limiting of:
(i)
The total effective dose equivalent being equal
to 5 rems; or
(ii)
The sum of the deep-dose equivalent and the
committed dose equivalent to any individual organ
or tissue other than the lens of the eye being
equal to 50 rems;
(2)
The annual limits to the lens of the eye, to the skin,
and to the extremities, which are:
(i)
An eye dose equivalent of 15 rems; and
(ii)
A shallow-dose equivalent of 50 rems to the skin
or to any extremity.
Licensee representatives stated and the inspector independently
confirmed that all TEDE exposures assigned since the previous
NRC inspection of this area were within 10 CFR Part 20 limits.
No violations or deviations were identified.
7
7.
Control of Radioactive Material and Contamination, Surveys, and
Monitoring (83750)
10 CFR 20.ISOI(a) requires each licensee to make or cause to be made
such surveys as (I) may be necessary for the licensee to comply with
the regulations and (2) are reasonable under the circumstances to
evaluate the extent of radiological hazards that may be present.
a.
Posting and Labeling
b.
10 CFR 20.1904(a) requires, in part, each container of licensed
material containing greater than Appendix C quantities to bear
a durable, clearly visible label identifying the radioactive
contents and providing sufficient information to permit
individuals handling or using the containers, or working in the
vicinity thereof, to take precautions to avoid or minimize
exposures.
During tours of the Unit 1 and Unit 2 Reactor Buildings,
Auxiliary Building, and various radioactive material storage
- locations, the inspector independently verified that selected
containers of radioactive material were labeled consistent with
regulatory requirements.
The inspector interviewed selected
workers to ensure personnel were properly trained to understand
posting and labeling requirements.
Discussions were conducted with selected cognizant individuals
in RP regarding their responsibilities as described in the
licensee procedural requirements.
Based on observations during
the inspection, discussions with cognizant licensee personnel,
and records reviewed, the inspector determine cognizant
personnel were knowledgeable of the licensee's procedural
requirements for controlling and surveying potentially
radioactive material.
No violations or deviations were identified.
Personnel and Area Contamination
The inspector reviewed selected Personnel Contamination Events
(PCEs) and discussed contamination control practices for
selected outage operations. During plant tours, the inspector
observed adequate housekeeping and contamination control
practices. The inspector observed.handling, packaging, and
surveying of contaminated equipment for movement and judged the
work evaluations satisfactory. At the time of the inspection,
the licensee was maintaining less than one percent (less than
200 ft
2
) of the total RCA as recoverable contaminated space.
The licensee Maintained approximately 1.8 percent of the total
RCA as contaminated during the last Refueling Outage of Unit 2.
~- -----
8
At the time of the inspection, the licensee had incurred
approximately 131 PCEs in 1995, of which 127 PCEs occurred
during the Unit 2 ten year In Service Inspection (ISi)
refueling outage.
The licensee incurred approximately 199 PCEs
in 1994, which included refueling outages on Units 1 and 2 in
addition to two other outages performed on Units 1 and 2 for
the purposes of steam generator chemical cleaning.
No violations or deviations were identified.
c.
TS 6.12.1 required, in part, that each High Radiation Area
(HRA) with radiation levels greater than or equal to
100 millirem/hour but less than or equal to 1000 millirem/hour
be barricaded and conspicuously posted as a HRA.
In addition,
any individual or group of individuals permitted to enter such
areas are to be provided with or accompanied by a radiation
monitoring device which continuously indicates the radiation
dose rate in the area or a radiation monitoring device which
continuously integrates the dose rate in the area, or an
individual qualified in RP procedures with a radiation dose
rate monitoring device.
During tours of the Unit 1 and Unit 2 Reactor Buildings, and
Auxiliary Building, the inspector noted that all HRAs and
locked HRAs inspected were locked and/or posted, as required.
No violations or deviations were identified.
d.
Radiation Detection and Survey Instrumentation
The inspector reviewed the plant procedure which established
the licensee's radiological survey and monitoring program and
verified that the procedures were consistent with regulations,
and good HP practices. During facility tours, the inspector
observed health physics personnel operating survey instruments
during the performance of radiation and contamination surveys.
The inspector noted that survey instrumentation and continuous
air monitors in use within the RCA were operable and displayed
current calibration stickers. The inspector further noted an
adequate number of survey instruments were available for use.
The inspector discussed source check requirements*with selected
RC personnel and noted no problems.
The inspector reviewed selected records of radiation and
contamination surveys performed during 1995 and discussed the
survey results with licensee representatives.
Licensee
per_sonnel interviewed were knowledgeable of the radiation
9
survey results for the areas to which they were assigned.
The
inspector received a thorough briefing on the dose rates inside
the Auxiliary Building and Reactor Building prior to entry.
No violations or deviations were identified.
e.
Independent Surveys
During facility tours, the inspector verified by independent
surveys or observation of surveys, radiation and/or
contamination levels in Unit 1 and Unit 2 Reactor Buildings,
selected outside areas, and other radioactive material storage
areas.
The inspector determine the licensee had performed
required surveys for those areas reviewed and for work packages
reviewed.
No violations or deviations were identified in this area.
8.
Operational and Administrative Controls
(83750)
a.
- Radiation Work Permits System
The inspector reviewed licensee procedures which provided
guidance to personnel preparing, briefing, and controlling work
following radiation work permit requirements to RP personnel
conducting radiological pre-job briefings. The inspector
reviewed selected RWPs and discussed the RWP system with
licensee representatives.
In addition, the inspector observed
personnel being briefed prior to entering the RCA.
The RP
group conducted briefings for personnel entering an area for
the first time on a specific RWP.
Personnel were also required
to notify RP prior to entry into the RCA.
The inspector
reviewed and discussed RWP requirements for personnel entering
the refueling floor to perform spent fuel movement operations
that were occurring during the inspection. During tours of the
Auxiliary Building and Reactor Buildings, the inspector
observed personnel performing work on RWPs relative to meeting
the dress and other special requirements with no discrepancies
noted.
The inspector found the licensee's program for RWP
implementation to adequately address radiological protection
concerns, and to provide for proper control measures.
No violations or deviations were identified.
10
b. *
Notices to Workers
10 CFR 19.ll(a) and (b) require, in part, that the licensee
post current copies of 10 CFR 19, 20, the license, license
conditions, documents incorporated into the license, license
amendments and operating 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 NRC Form-3,
Notice to Employees.
Sufficient copies of the required forms
are to be posted to permit licensee workers to observe them on
their way to or from licensee activity locations.
During the inspection, the inspector verified that NRC Form-3
was posted properly at various plant locations permitting
adequate worker access.
In addition, notices were posted
referencing the location where the license, procedures, and
supporting documents could be reviewed.
- No violations or deviations were identified.
9.
Program for Maintaining Exposures As Low As Reasonably Achievable
(ALARA) (83750)
10 CFR 20.llOl(b) states that the licensee shall use to the extent
practical, procedures and engineering controls based upon sound
radiation protection procedures to achieve occupational doses to
members of the public that are ALARA.
Regulatory Guides 8.8 and 8.10 provide information relevant to
attaining goals and objectives for planning and operating light water
reactors and provide general philosophy acceptable to the NRC as a
necessary basis for a program of maintaining occupational exposures
The inspector reviewed and discussed with licensee representatives
successful ALARA initiatives used during the most recent 46 day Unit 2
10 year ISI refueling outage.
These initiatives included the
utilization of approximately 86,000 pounds of temporary shielding,
teledosimetry, remote video cameras, and radio communications.
The
recent Unit 2 outage resulted in a final exposure of approximately
157.7 person-rem, which was the lowest radiation exposure for a
refueling outage in the Company's history.
The inspector also
reviewed the licensee's long term five year radiation exposure
reduction plan to maintain occupational doses ALARA that included:
continued plans for source term reduction initiatives such as the
replacement of valves and valve components with non-stellite
materials, continued replacement of fuel assemblies with Zircaloy grid
spacers (99 percent complete for Units 1 and 2), continued use of
11
submicron filters tn the Reactor Coolant System and other associated
systems while evaluating optimal filters to be used, hot spot flushes,
scheduled system decontaminations, and the addition of permanently
installed shielding to eliminate several HRAs in the plant.
Based on a review of the licensee's ALARA program, the inspector
determined the licensee was continuing to implement initiatives to
maintain occupational exposures ALARA.
No violations or deviations were identified in this area.
10.
Review of Previously Identified Inspector Followup Item (IFI) (83750)
(Closed) IFI 50-280/89-14-04:
Review resolution of actions taken by
the licensee to track recommendations to improve the Station RP
Program.
The licensee's Radiological Engineering Section was tracking
information relevant to improvements in the area of RP.
The
information*tracked included ALARA initiatives and monthly topics,
exposure control/trending and five year exposure reduction plan, ALARA
suggestions, respirator reduction efforts, contaminated square
footage, personnel contamination events, inspection findings and
assessments performed by various organizations, radioactive waste
management, shipments of radioactive materials, program summaries,
problem reports, leak containments, and chemistry issues.
Based on observations and the reviews performed, the inspector
determined the licensee's response to tracking improvement items which
may effect radiological controls was adequate; therefore, the
inspector informed the licensee the IFI would be closed.
11.
Exit Meeting (83750)
The inspector met with licensee representatives indicated in
Paragraph 1 at the conclusion of the inspection on June 9, 1995.
The
inspector summarized the scope and findings of the inspection.
The
inspector also discussed the likely informational content of the
inspection report with regard to documents or processes reviewed
during the inspection. The licensee did not identify any such
documents or processes as proprietary. Dissenting comments were not
received from the licensee.
Item Number
50-280, 281/89-14-04
Status
Closed
Description and Reference
IFI - Followup on licensee's
actions to track improvement items
effecting radiological controls .