ML18153D328
| ML18153D328 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/27/1993 |
| From: | Bryan Parker, Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153D326 | List: |
| References | |
| 50-280-93-09, 50-280-93-9, 50-281-93-09, 50-281-93-9, NUDOCS 9305120045 | |
| Download: ML18153D328 (11) | |
See also: IR 05000280/1993009
Text
Report Nos. :
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION 11
101 MARIETTA STREET, N.W.
AT.LANT A, GEORGIA 30323
50-280/93-09 and 50-281/93-09
Licensee:
Virginia Electric and Power Company
Docket Nos.:
50-280, 50-281
License Nos.:
Inspection Condr,Pted: ~ch 29 - April 2, 1993
Inspectors:
P>11i,.... ai L
B. At7ParkA / -h
R.,~it:ffr~
Accompanied by:
~- L.' Stinson()
~
Approved B~~
~~
W. H. Rankin, Chief
Scope:
Facilities Radiation Protection Section
Radiological Protection and Emergency Preparedness
Branch
Division of Radiation Safety and Safeguards
SUMMARY
Dite 'Sign d
This routine, announced inspection was conducted in the area of occupational
radiation exposure.
Specific elements of the program examined included:
organization and management control; training and qualification; external
exposure control; internal exposure control; surveys, monitoring, and control
of radioactive material; maintaining occupational radiation exposure as low as
reasonably achievable (ALARA); and previously identified inspector followup
items (IFis).
Results:
In the areas inspected, one apparent violation was identified for failure to
(1) provide positive control over an open locked high radiation area and,
(2) allow two individuals uninhibited egress from a locked high radiation
area.
The licensee's radiation protection program was well-supported by both.
corporate and station management and was functioning effectively to protect
the health and safety of plant personnel and the general public.* The ALARP.
program in general was considered a program strength .
9305120045 930429
ADDCK 05000280
Q
REPORT DETAILS
1.
Persons Contacted
- D. Anderson, Shift Supervisor, Health Physics
- W. Benthall, Supervisor, Licensing
- R. Bilyeu, Engineer, Licensing
- M. Biron, Supervisor, Radiological Engineering
- E. Brennan, Coordinator, Water Treatment
- D. Christian, Assistant Station Manager, Operations
- D. Erickson, Superintendent, Radiation Protection
- B. Garber, Supervisor, H.P. Technical Services
- M. Kansler, Station Manager
- D. Miller, Supervisor, Health Physics Operations
- L. Morris, Superintendent, Radwaste
- M. Olin, Supervisor, Radwaste Operations
- J. Price, Assistant Station Manager, Licensing
- R. Saunders, Assistant Vice President, Nuclear Operations
- E. Smith Jr., Manager, Quality Assurance
T. Steed, ALARA Coordinator
- W. Thornton, Corporate Director, Health Physics and Chemistry
- D. White, Shift Supervisor, Health Physics
K. Wyatt, Maintenance Department QMT Coordinator
Other licensee employees contacted during this inspection included:
craftsmen, engineers, operators, contract personnel, and
administrative personnel.
Nuclear Regulatory Commission
- J. York, Acting Senior Resident Inspector
- Attended Exit Interview conducted on April 2, 1993.
2.
Occupational Exposure (83750)
a.
Organization and Management Controls
The inspectors reviewed the staffing of the radiation
protection (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 during outage and non-outage periods.
A review of the licensee's program to self-identify and correct
problems via the Radiation Problem Report (RPR) system showed
that the licensee utilized the system routinely.
Radiological
performance problems, when identified, were promptly corrected ..
The inspectors noted that when a problem had increased
significance, a station deviation report was issued.
During
the inspection, the inspectors identified an apparent violation
(see Paragraph 2.c) in which the licensee issued a station
deviation report to ensure that the problem received early
, *
3
attention and prompt closure. Management systems were observed
to be operating satisfactorily to keep management appraised of
radiological problemi to s~pport oversight of the RP program.
No violations or deviations were identified.
b.
Training and Qualification
The inspectors noted that the licensee continues to support
staff participation in the National Registry of Radiation
Protection Technologists (NRRPT) certification process.
The
inspector learned that, in 1992, 16 of the licensee's staff
became NRRPT-certified, in addition to 17 others who were
certified in 1991.
The inspectors reviewed the required background readings for
the health physics (HP) staff. The reading material appeared
appropriate with the majority of it relating to HP work in
general.
The readings were accomplished in a timely manner and
no problems were noted with the subject matter.
10 CFR 1.53 contains the requirements for use of the NRC seal
or replicas.
10 CFR 1.59 requires that in order to ensure
adherence to the authorized uses of the NRC seal as provided in
this subpart, a report of each suspected violation of this
subpart, or any questionable use of the NRC seal should be
submitted to the Secretary of the Commission.
During participation in site specific training, the inspectors
noted that the licensee used the NRC seal a number of times in
several training publications. The inspector found that when
the publications discussed NRC-related information such as NRC
regulatory philosophy; Form NRC-3, "Notice to Employees;" and
the Resident Inspection Program, NRC seals were used as graphic
illustrations in the document margins.
While the use did not
appear inappropriate, the regulation does not allow latitude
with regard to authorization for use, nor for reporting
suspected unauthorized use.
The resident inspectors recall~d
discussing the subject with the licensee and regional
management, but were not sure if the NRC Office of the
Secretary was contacted as required.
To ensure the matter was
resolved, the inspector discussed the licensee's use of the NRC
seal with Regional II Counsel, who in turn contacted the Office
of the Secretary. The Assistant Secretary of the Commission
agreed that the licensee's use of the NRC seal did not appear
to be inappropriate.
The inspectors informed the licensee of
the Office of the Secretary's ruling and cautioned the licensee
to seek pre-approval for future uses of the NRC seal.
No violations or deviations were identified .
. *
C.
4
External Exposure Control
10 CFR 20.101 requires, that no licensee possess, use, or
transfer licensed material in such a manner as to cause any
individual in a restricted area, to receive in any period of
one calendar quarter a total occupational dose in excess of
1.25 rem to the whole body, head and trunk, active blood
forming organs, lens of the eyes, or gonads; 18.75 rem to the
hands, forearms, feet and ankles; and 7.5 rem to the skin of
the whole body.
As of March 30, 1993, the licensee had experienced 31 personnel
contamination events (PCEs).
The inspector reviewed selected
PCE reports and noted no significant external exposures.
Skin
dose assessments were performed as required and only relatively
low skin doses resulted.
No problems were noted with the
licensee's methods or reporting requirements.
10 CFR 20.202 requires each licensee to supply appropriate
monitoring equipment to specific individuals and requires the
use of such equipment.
During tours of the plant, the
inspector observed workers wearing appropriate personnel
monitoring devices.
The licensee routinely issued digital
alarming dosimeters and tracked dose via a computerized system .
For relatively high dose jobs, the licensee utilized a
teledosimetry system to track dose real-time.
10 CFR 20.202(c) requires that personnel dosimetry used in
accordance with 10 CFR 20.202 (a) be processed by a processor
accredited by the National Voluntary Laboratory Accreditation
Program (NVLAP) for the appropriate types of radiation.
The
inspector noted that the licensee was NVLAP-approved to process
dosimetry for all eight categories of radiation.
10 CFR 20.203(c)(2)(iii) requires that each entrance or access
point to a high radiation area be maintained locked except
during periods when access to the area is required, with
positive control over each individual entry.
10 CFR 20.203(c)(3) states that the controls required by
10 CFR 20.203(c)(2) of this section be established in such a
way that no individual will be prevented from leaving a high
ra<:liation area.
Technical Specification (TS) 6.4.1.B requires that procedures
for personnel radiation protection be prepared consistent with
the requirements of 10 CFR Part 20 and be approved, maintained,
and adhered to for all operations involving radiation exposure.
Attachment 1, Requirements and Responsibilities to Enter a
Locked High Radiation Area, of Health Physics Procedure HP-
8.0.61, High Radiation Area Key Control, Revision 1, dated
5
April 16, 1991, requires the individual who has cognizance over
the area to verify (1) that the entrance to the locked high
radiation area (LHRA)" is under constant surveillance while it
is unlocked to prevent unauthorized entries (Step 2.3); and,
(2) that no one is left in the area and the entrance is
securely locked when leaving the area (Step 2.4).
During one of the tours of Unit 2 containment to assess
radiological performance, the inspectors stopped at the
entrance to
11C
11 Reactor Cool ant Pump Loop Room, a LHRA, and.
inquired of a HP technician in the immediate area the
requirements for entry into the loop room.
The HP technician
replied that extra shoe covers and gloves were needed and
proceeded to supply the inspectors with the items.
Two
inspectors donned the items and immediately proceeded to enter
the area.
The inspectors were wearing digital alarming
dosimeters (DADs) and had been briefed and authorized to enter
high radiation areas under RWP No. 93-2-2045, Rev. 001.
The
rope barrier into the area was posted "DAD, Dose Rate Meter, or
HP Required for Entry" and "Extra Shoe Covers and Gloves
Required."
The inspectors crossed the stepoff pad, noted that
the loop room door was unlocked and open, and proceeded into
the loop room.
Dose rates in the loop room were greater than
1000 millirem per hour at 12 inches. After touring the area
for approximately three minutes, the inspectors returned to the
entry point and found the loop room door chained and padlocked
from the outside. Momentarily, a HP technician arrived to
unlock the door for an individual entering to perform work in
the area and the inspectors exited the loop room.
No
unnecessary radiation exposures were received due to the event.
Later, the licensee informed the inspector that the door was
found unlocked upon the inspectors' entry due to the presence
of an advanced radiation worker (ARW) in the loop room.
The
ARW apparently exited the area after the inspectors entered and
neither party saw the other while in the loop room.
The
inspector learned that the unseen ARW in the LHRA was actually
in charge of the area and not the HP technician contacted
outside the loop room prior to the inspectors' entry since the
ARW was issued a key with which to enter the area. This was
consistent with the aforementioned procedure HP-8.0.61.
The
inspector concluded that the failure to maintain constant
surveillance over the LHRA entrance while it was unlocked, and
the failure to ensure that no one was left in the area prior to
locking the entrance, thereby preventing the inspectors' exit
from LHRA constituted an apparent violation of 10 CFR 20.203(c)
(VIO: 50-280, -281/93-09-01).
One apparent violation was identified .
- *
d.
6
Internal Exposure Control
10 CFR 20.103(a)(3) requires, in part, that the licensee, as
appropriate, use measurements of radioactivity in the body,
measurements of radioactivity excreted from the body, or any
combination of such measurements as may be necessary for timely
detection and assessment of individual intakes of radioactivity
by exposed individuals.
The inspector reviewed selected PCE reports and noted no
significant internal exposures. All exposures were well below
the 40 MPC-hour limit in 10 CFR Part 20.
10 CFR 20.103(b)(l) 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 20.203(d)(l)(ii).
10 CFR 20.103(c)(2) permits the licensee to maintain and
implement a respiratory protective program that includes, at a
minimum:
air sampling to identify the hazard; surveys and
bioassays to evaluate the actual exposures; written procedures
to select, fit, and maintain respirators; written procedures
regarding supervision and training of personnel and issuance of
records; and determination by a physician prior to the use of
respirators, that the individual user is physically able to
use respiratory protective equipment.
10 CFR 20, Appendix A, Footnote (d), requires adequate
respirable air of the quality and quantity in accordance with
NIOSH/MSHA certification described in 30 CFR Part 11 to be
provided for atmosphere-supplying respirators.
30 CFR 11.121 requires that compressed, gaseous breathing air
meets 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 the licensee's respiratory
protection program with cognizant personnel.
The licensee
maintains a total of 36 active self-contained breathing
apparatus (SCBAs), 17 of which contain compressed air and 19
that contain a mixture of 35 percent oxygen/65 percent
The mixed SCBAs are used for containment entries at
power due to the subatmospheric operating condition. Staged
SCBAs were pressure-checked weekly and checked for function on
a monthly basis.
SCBA maintenance was performed by a factory-
certified technician onsite.
.
.
~ *
7
The inspectors reviewed the licensee's breathing program and
noted that the 35/65 air was purchased in 300 cubic foot
bottles and transferred via a cascade-type *system to the SCBA
bottles as needed.
Other compressed air used for breathing air
was required to meet Grade D criteria.
No atmospheric
compressed air was purchased and the inspectors verified that
the compressed breathing air produced onsite met the Grade D
criteria. Air checks were performed every six months with the
last occurring in October 28, 1992.
The inspectors also
reviewed a study performed by Radiological Engineering
(CAF #91-RE-402) that verified that the breathing air systems
utilized onsite met ANSI Standard Z88.2-1980.
No problems were
noted with the licensee's methods or findings.
The inspectors noted the licensee's reduction of respirator
usage.
Numbers of respirators issued this outage compared to
numbers from previous outages indicate a reduction by as much
as 80 percent.
The licensee indicated that a combination of
more ALARA planning, worker training, and the use of
faceshields to help to minimize the increase in PCEs and
internal contamination expected with less respirator usage.
However, the licensee's extensive use of engineering controls
in and around potential airborne radioactivity areas was the
major contributing factor in avoiding the consequences often
accompanied by a reduction in respirator usage .
The inspectors noted that the licensee had replaced the rubber
masks used with the 35/65 SCBAs with silicone masks.
This was
done in response to a finding from a study in which Virginia
Power participated with Lawrence Livermore National Laboratory
(LLNL).
The study was conducted to support a
10 CFR Part 20.103(e) request to the NRC from Virginia Power
for specific authorization to use 35/65 SCBAs in containment,
at reduced pressure, under both routine and emergency (e.g.
fire fighting) conditions. A series of tests were performed
including flame-testing of the 35/65 SCBA equipment.
One
recommendation was made as a result of the study regarding
replacement of rubber facepieces on 35/65 SCBAs with silicone
facepieces. This was based on a finding that the rubber
facepieces continued to burn around the exhalation valve after
flame-testing due to the enriched oxygen.
In another related matter, the licensee was investigating the
effects of replacing old SCBA brass parts with parts made of
This was due to the fact that aluminum burns under
enriched oxygen conditions. The results of this investigation
were pending.
No violations or deviations were identified .
' .
8
e.
Surveys, Monitoring, and Control of Radioactive Material
During the previous inspection, the inspectors toured Unit 2
containment and noted that the incore seal table area was
easily accessed. After exiting containment, the inspectors
noted that the power to the Incore Moveable Detectors (IMDs)
was not tagged out. This tagout would serve 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 inspectors noted the same accessibility to the
incore seal table this inspection; however, the licensee now
provides tagout protection in the control room when the
containment is open.
In response to an inspector concern for inconsistency in
radiological precautions and warnings in operations and
maintenance procedures, the licensee instituted changes to the
following procedures to correct the deficiency:
0
0
0
0
0
0
0
l-OP-57, Incore Movable Detector System, Revision 1,
dated July 31, 1991
2-0P-57, Incore Movable Detector System, Revision 1,
dated July 31, 1991
l-OP-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
l-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
l-IMP-C-IFM-38, Cleaning Incore Flux Thimbles,
Revision O, 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 O, dated
September 13, 1988
,.
9
O-MCM-1101-01, Flux Thimble/Thermocouple Assembly
Withdrawal and Insertion, Revision 0, dated April 20,
1992
.
The inspector reviewed the listed procedures and noted the
corrective actions were comprehensive and sufficient. This
action contributes to the closure of inspector followup item
(IFI) 50-280/92-16-03.
The licensee's program to control contamination at the source
has greatly improved.
The licensee's goal for 1993 is to
maintain approximately 98 percent (135,000 square feet (ft 2))
of the auxiliary building as clean and free of contamination
above 1,000 disintegrations per minute per 100 square
centimeters (1,000 dpm/100 cm2). The licensee initiated a
reclamation project in 1992 to reclaim many contaminated areas
and, as a result, the licensee ended 1992 with only 1,574 ft 2
of contaminated area (1.2 percent of the RCA).
Licensee
representatives indicated that during the outage, the
contaminated area of the plant had expanded to 6,549 ft 2 ,
mostly due to laydown area requirements.
The supervisor in
charge of decontamination activities indicated that seven
foremen, 28 senior decontamination technicians, and 12 junior
decontamination technicians were required to complete the major
job of reclaiming chronic contaminated areas.
The inspector toured the licensee's onsite laundry facilities
and discussed laundry activities with some of the
aforementioned decontamination technicians.
The inspectors
reviewed the licensee's methods for laundering, surveying and
decontaminating protective clothing (PCs) and respirators.
PCs
were sorted, laundered, surveyed on a conveyor system,
inspected for flaws/defects, and either folded for reuse or
discarded.
If one of the eight detector zones was triggered
during the survey, the conveyor belt would immediately stop,
allowing the technician to identify the contaminated article.
The article would be relaundered and resurveyed or discarded as
radioactive waste.
Respirators were washed, dried, and surveyed for fixed and
removable contamination.
If contamination was found, those
respirators were rewashed and surveyed or discarded.
The
respirators were then inspected, sealed in bags, and tagged as
usable for 30 days.
If unused after 30 days, the respirators
had to be pulled from the shelf and reinspected before being
bagged and tagged again for reuse.
The inspectors noted that
lead technicians over the area were closely tracking respirator
and PC usage as well as the failure rates of specific items.
10
No problems were noted with the licensee's methods or
procedures.
No violations or deviations were identified.
f.
Instrumentation
The inspectors toured the licensee's instrument repair and
calibration shop.
The licensee utilized a number of sources
for calibrating instruments with cesium-137 (Cs-137) being the
isotope of primary use.
Most of the sources were of millicurie
activity, although a nominal 400 curie Cs-137 source was used
for calibrating high ranges.
The inspectors noted that the
licensee tracked instruments through a bar-code system to
assist in completing periodic inventories and calibrations.
No problems were noted with the licensee's methods or
procedures.
No violations or deviations were identified.
g.
Program to Maintain Occupational As Low As Reasonably
Achievable (ALARA)
10 CFR 20.l(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 Ensuring That
Occupational Radiation Exposure at Nuclear Power Stations will
be ALARA, and Regulatory Guide 8.10, Operating Philosophy for
Maintaining Occupational Exposures ALARA.
The inspectors discussed the ALARA program with the Station
ALARA coordinator and the Maintenance Department ALARA
coordinator.
In addition, the inspectors reviewed methods the
licensee used to maintain occupational exposure ALARA.
The licensee's total collective dose goal for 1993 was
595 person-rem or less, with one outage to be performed.
Currently, the licensee collective dose for the outage was an
actual 118 person-rem compared to a projected 185 person-rem
for that point in the schedule.
For the year to date, the
licensee stood at 149 person-rem compared to 240 person-rem
projected. Licensee HP and Maintenance ALARA representatives
indicated that some of the following were responsible for the
improved performance:
85 percent of pre-job ALARA reviews were
completed prior to the outage start; all known work orders were
received prior to outage start and were reviewed; 48 shielding
packages utilized 65 tons of temporary lead shielding; job
briefings were performed using enhanced surrogate tour for dose
intensive jobs; and specific ALARA training was provided to all
personnel working the outage.
In addition, the projected dose
11
for removal of the Resistance Temperature Detectors {RTDs) was
11 person-rem, but the operation was actually performed for six
person-rem.
The inspectors also reviewed a number of other dose reduction
initiatives including the installation of permanent shielding.
Water shields were erected in the Ion Exchange Alley in the
basement of the auxiliary building, resulting in a 70 percent
reduction in general area dose rates. Also, permanent lead
shielding was installed on more operating systems, including
letdown lines and charging pumps.
Including valve 2-SI-85 that
was being replaced during the inspection, the licensee has
replaced four valves with non-stellite valves. A number of
other valves were scheduled for replacement during future
outages. Other initiatives noted by the inspector included the
use of green flashing lights to call attention to low dose
waiting areas and the performance of ALARA reviews for low-
dose-per-person, high-man-hour jobs.
The inspectors noted the ALARA program to be a significant
strength to the licensee's overall program.
Strong management
support and heavy worker involvement contributed to the
continued success in the area of ALARA.
No violations or deviations were identified.
3.
Exit Meeting
The inspectors met with licensee representatives denoted in
Paragraph 1 at the conclusion of the inspection on April 2, 1993.
The
inspectors summarized the scope of the inspection findings including
those listed below 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 comments were not received from the
licensee.
Item Number
50-280, 281/93-09-01
Description and Reference
VIO -
Failure to (1) provide
positive control over an open
locked high radiation area and,
(2) allow two individuals
uninhibited egress from a locked
(Paragraph 2.c).