ML20082U280

Responds to NRC Re Violations Noted in IE Insp Repts 50-280/83-10 & 50-281/83-10.Health Physics Procedure HP-3.3.2 Revised to Provide Detailed Guidance for Evaluation of Airborne Radioactivity

ML20082U280
Person / Time
Site:	Surry
Issue date:	06/03/1983
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20080C383	List: ML20082U192 ML20082U228 ML20082U280
References
299, EA-83-036, EA-83-36, NUDOCS 8312160292
Download: ML20082U280 (9)

Text

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VIRGINIA ELECTRIC AND Powna COMPANY j

RIcnwoxn, VIRGINIA 20261 i

W.L.StewAmr Vac. P... n.wr won. . o,. uo.. June 3, 1983 United States Nuclear Regulatory Commission Serial No. 299 Attn: Mr. Richard C. DeYoung, Director N0/WDC:acm Office of Inspection and Enforcement Docket Nos. 50-280 Washington, D. C. 20555 50-281 License Nos. DPR-32 DPR-37 Gentlemen: ,/

We have reviewed your letter of May S, 1983 in reference to the inspection conducted at Surry Power Station between March 21, 1983 and March 25, 1983 and reported in IE Inspection Report No. EA 83-36. Our response to the specific infraction is attached.

We have determined that no proprietary information is contained in the report.

Accordingly, the Virginia Electric and Power Company has no objection to this. inspection report being made a matter of public disclosure. The information contained in the attached pages is true and accurate to the best of my knowledge and belief.

Very truly yours, T

("O W. L. Stewar Lb Attachments '

l. Response to Notice of Violation

2. Voucher Check in payment of Civil Penalty' ,

cc: Mr) CameilP T O'Reilly]

Regibnsl'Admi'istrator n ,

Region II ."

Mr. D. J. Burke ,

NRC Resident Inspector '

Surry Power Station g i'

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a B312160292 830723 <

PDR ADOCK 05000280 0 PDR

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Attachment Page 1 Serial No. 299 t

RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY NRC COMMENT _1 The licensee began a refueling outage on Unit 1 on February 9, 1983. Prior to the outage, failed fuel cladding in the unit had caused a marked increase in the concentration of radioactive material in reactor coolant. When the unit was shut down for refueling, many workers entered the Containment Building and the systems which had contained the highly contaminated reactor coolant were

. . . . opened for maintenance. As a result of these activities, workers were exposed to airborne radioactive material and radiation from radioactive contamination.

The concentration of radioactive fission and activation product contamination or surfaces inside the Containment Building was unusually high as a result of the fuel cladding failure. The licensee, in an attempt to assess the beta dose rate due to this contamination, made measurements with thermoluminescent dosimeters (TLDs) and interpreted the measurement results to indicate that beta dose rates in the Unit 1 containment were insignificant when compared with gamma dose rates. Subsequent measurements performed at the request of the NRC inspector indicated that 'che beta contribution to dose rate was quite significant (beta was found to be 5 - 15 times gamma) and that the potential for individuals to exceed prescribed limits did exist. Because of this inadequate evaluation, comprehensive radiation dose monitoring had not been performed. Reconstruction of the circumstances has not indicated that any worker exceeded the limits of 10 CFR 20.

A second consequence of the unusually high contamination levels was an increased potential for elevated concentrations of airborne radioactivity.

The NRC inspector observed work being performed on the Residual Heat Removal System in the Unit I containment which entailed potentially high levels of airborne contamination. Although the workers were wearing respirators fitted with air purifying canisters, air samples were not taken to determine if the protection factor afforded by the respirators was adequate to limit the workers' uptake of airborne contamination to the prescribed limits in 10 CFR

20. Subsequent questioning of the licensee and excmination of available Y records indicated that the licensee did not always sample the air breathed by workers who were at risk in high airborne radioactivity areas. The licensee did measure internal deposition of radioactivity by whole body counting of selected workers and these measurements showed no excessive internal contamination. The NRC inspector observed situations in which station and contractor personnel disregarded radiological control requirements despite adequate training in the content of those requirements. The enforcement of these requirements by plant management and supervisors was apparently ineffective.

To emphasize the need for internal and external dose monitoring and procedural compliance, particularly in the performance of evaluations to ensure compliance with radiation protection requirements and supervision of personnel to ensure procedural complisnce, the Nuclear Regulatory Commission proposes to impose a civil penalty in the: amount of Forty Thousand Dollars for this matter. In accordance with the NRC Enforcement Policy 47 FR 9987 (10 CFR Part

2. Appendix C) (March 9, 1982), and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205, the particular violation and associated civil penalty is set forth t .

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Attcchment Pcgs 2 Serial No. 299 10 CFR 20.103(a)(3) requires that for purposes of determining compliance with the requirements of the section, the licensee use suitable measurements of concentrations of radioactive materials in air, for detecting and evaluating airborne radioactivity in restricted areas.

10 CFR 20.201(a) states that survey means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other source of radiation under a specific set of conditionc.

10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as may be necessary for the licensee to comply with the regulations in 10 CFR 20, and are reasonable under the circumstances to evaluate the extent of radiation hazards that may bo present.

Technical Specification 6.4.B requires that a radiation protection program be, organized to meet the requirements of 10 CFR 20.

Technical Specification 6.4.B.I.(e) requires that any individual or group of indivfduals permitted to enter a high radiation area be provided with a radiation monitoring device which continuously indicates the radiation dose rate in=the area.

Technical'Specificatios 6.4.B.I.G requires the entrance to each radiation area. -in which the incensity of radiation is equal to or greater than 1000 mrem /hr, be provided with locked barricades to prevent unauthorized entry. ,

"- Technical, Specification 6.4.D requires that all radiation control procedures be followed.

Contrary to the above and as evidenecd b:r the following examples, the

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licensee's radiation protection program failed to meet the requirements of 10 CFR 20 and certain specific Technical Specification provisions as follows:

(Note: The Notice of Violation cites five (5) specific examples of failure to meet the requirements of 10 CFR 20 and certain Technical Specifications. For clarity, the remainder of this response will address each example separately. -This is a Severity Level III Violation (Supplement IV).)

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! Example ~1. e Notwithstanding 10 CFR 20.103 (a)(3), the requirements to use su'itable measurements of concentrations of radioactive materials in air were not met in that airborne radioactivity surveys were

, not performed in the following instances:

! a. On March 24, 1983, during maintenance activities on the l residual heat removs1 (RHR) flat in Unit I containment.

b. On March 21 and 22, 1983, an the breathing zone of personnel  !

working on the RHR flat in Unit 1 containment. l s l

c. Between March 2 and March 20. 1983, on the platform or in the channel ' head of. Unit 1 "B5yand "C" steam ' generators to ,

. determine the concentrations in the breathing zone of workers.

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. . Attachment

• P:gs 3 Serial No. 299 RESPONSE to Example 1:

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

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The violation is correct as stated for Example 1.

(2) REASONS FOR VIOLATION: .,-

The need to obtain adequate air samples in the breathing zone of the workers stated in the example was not recognized due to the lack of appropriate procedural guidance for air sampling criteria. Additional-ly, respiratory protection policies in effect at the station were deemed conservative for the situations encountered. Thus, health physics personnel failed to obtain more representative air samples to verify that protection factors afforded to the workers were adequate.

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(3) _ CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

Health Physics Procedure HP-3.3.2, Health Physics Survey-Air Sampling, was revised and approved on April 7, 1983 to , provide more detailed guidance for the evaluation of airborne radioactivity. Health Physics Technicians were provided specific training on the revised procedure and were tested to ensure adequate understanding.

The revised procedure specifically directs technicians to assess airborne radioactivity at the workers breathing zone to ensure these measurements are suitable.

To confirm the adequacy of respiratory protection 1.rovided to workers during the Unit No. 1 outage, whole body countr, were obtained of all potentially contaminated personnel (170) and an avaluation was performed to determine if significant uptakes had occurred. This evaluation showed no evidence of such uptakes.

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

Further review and evaluation will be performed to improve the procedural guidance provided to technicians in the assessment of airborne radio-activity. Improvements will be investigated in the development of specific action points, quick assessment techniques and guidance on immediate follow-up actions.

. (5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance will be achieved by June 15, 1983.

Example 2. Notwithstanding 10 CFR 10.201(a) and (b), the requirements to conduct surveys to ensure compliance were not met in the following instaneen:

a. Beta radiation surveys performeo by the ' licensee failed to identify the presence of significant beta radiation levels in-Unit I containment.

b. The evaluation performed prior to decontamination of six reactor coolant pump bolts on March 24, 1983, did not result in the placement of the whole body TLD on-the part of the whole body'that would receive the highest dose and did not s result in the use of extremity monitoring.

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Serial No. 299 RESPONSE to Example 2:

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION: .

The violation is correct as stated for Example 2.

(2) REASONS FOR VIOLATION:

Approved health physics procedures had established the use of TLDs as an acceptable method for performance of beta survey measurements. The existence of abnormally high contamination levels in Unit No. I containment due to failed fuel was not fully recognized to result in the potential for significant beta radiation levels. Although the survey technique used (i.e., TLDs) disclosed no significant beta problem, the possible inadequacy of the surveys (i.e. TLDs) was not thoroughly evaluated when considered in relation to the contamination levels present.

With regard to the inadequate evaluation performed prior to decontamina-tion of reactor coolant pump bolts on March 24, 1983, the apparent cause has been determined to be improper surveys to identify changing radiological conditions at the work site.

(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

Surveys to evaluate beta radiation levels are being performed utilizing portable radiation survey instruments rather than TLDs until such time as the apparent discrepancy between these two methods may be resolved.

Additionally, analyses of contamination sources have been performed to provide further data which will be useful in developing improved guidance for assessment of beta radiation hazards.

An evaluation was performed to determine if regulatory limits were exceeded due to improper personnel dosimetry placement during the decontamination of reactor coolant pump bolts on March 24, 1983. Through personnel interviews and by reconstruction of the operation, it was determined that no regulatory limits were exceeded. Reassessment of the individual's whole body and extremity doses, using a conservative occupancy time in the decon enclosure and proximity to the source during work, resulted in adjusted quarterly accumuated dose estimates of 1.717 rem whole body and 2.285 rem to the extremities.

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

An evaluation is currently being performei to resolve the discrepancy between beta radiation dose rate measurements made with portable survey instruments - versus those made with TLDs. This evaluation will also provide improved understanding and guidance with regard to proper use of portable survey instruments for beta radiation assessments.

A review of the RWP program will be performed to provide increased assurance that ' surveys will properly identify non-uniform radiation fields and ensure appropriate placement of personnel monitoring devices.

(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The corrective steps referred to above will be completed by July 5,1983.

Attachmsnt Page 5 Serial No. 299 Example 3. Notwithstanding Technical Specification 6.4.B.1.(e), the requirement for personnel to have a radiation dose rate instrument , when entering a high radiation area was not met in that on March 24, 1983, three workers entered the "B" cubicle on the 18' elevation of Unit 1 containment, a

, posted high radiation area, without a radiation survey instrument.

RESPONSE to Example 3:

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The violation is correct as stated for Example 3.

(2) REASONS FOR VIOLATION:

The reason for the violation of Technical Specification 6.4.B.1.(e) was

determined to be failure of personnel to follow procedures and posted health physics requirements.

(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

The workers involved were instructed on the importance of following all health physics procedures and posted requirements. Written memorandums were issued by the Station Manager to reemphasize to all station .

personnel the requirement for strict adherence to health physics I instructions.

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

Additional training sessions are being planned for radiation workers at Surry. Consultants will assist the company in this training effort.

This effort is scheduled to be complete by August 15, 1983.

(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance has been achieved.

Example 4. Notwithstanding Technical Specification 6.4.B.I.G, the requirement to lock high radiation areas with intensities equal to or greater than 1000 mrem /hr was not met in that on March 24, 1983, the regenerative heat exchanger room in Unit I containment was not provided with a locked barricade. Radiation levels in the toom were as high as 7000 mrem /hr.

RESPONSE to Example 4:

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The violation is correct as stated for Example 4.

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' *** Attcch;cnt Pags 6 Serial No. 299 (2) REASONS FOR VIOLATION:

Previously established controls with regard to high radiation areas (i.e., those greater than 1,000 mrem /hr) inside the containment building had been considered acceptable to satisfy the intent of Technical Cpecification 6.4.B.I.G. Therefore, no locked barricade was provided for the regenerative heat exchanger room.

(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

A locked barricade (i.e., gate) has been installed at the entrance to the regenerative heat exchanger room in Unit 1 containment. The Unit 1 containment has been reviewed for other high radiation areas (i.e. those greater than 1000 arem/hr) and appropriate control methods taken.

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHEk VIOLATIONS:

A review of all high radiation areas within the Unit No. 2 containment building will be performed to identify those areas requiring locked barricades. Barricades to prevent unauthorized access will be provided where feasible. Where lockable enclosures do not exist, alternative methods to ensure positive access control will be established. These measures will be taken before general access is allowed to the containment at the start of the next outage.

(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Installation of lockable barricades will be accomplished inside each containment building during the next outage of sufficient length.

Example 5. Notwithstanding Technical Specification 6.4.D. the requirement to follow radiation control procedures was not met in that:

a. On March 22, 1983, a worker did not follow the posted instructions as required by Station Health Physics Manual, paragraph D, page 1.3-4. The worker was observed on the 47' elevation of Unit I containment sitting next to a high radiation area sign which included instructions "Do Not Stand in Area".

b. On March 24, 1983, three workers did not follow posted instructions as required by Health Physics Manual, paragraph D, page 1.3-4. The workers failed to notify Health Physics personnel prior to entering the "B" cubicle on the 18' elevation of Unit I containment as instructed on the high radiation area sign at the entrance to the cubicle,

c. On March 22, 1983, a worker failed to follow the instructions on radiation work permit 698 as required by Station Health l Physics Manual, paragraph F.2, page 1.3-a. The individual failed.to notify Health Physics personnel as required by the RWP prior to beginning work on the 47' elevition of Unit 1 containment.

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Attachment Page 7 Serial No. 299

d. On March 24, 1983, a worker in "B" cubicle on the 18' elevation of Unit I containment was observed wearing his respirator over his protective cloth hood instead of und'er it as required by the Station Respiratory Protection Manual, Section 7.

RESPONSE to Example 5: -

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The violation is correct as stated for Example 5.

(2) REASONS FOR VIOLATION:

iaRIElm The reasons for the violations of Technical Specification 6.4.D werc  ;;, .

personnel error and failure to follow posted requirements, radiation work , ig l '

permit instructions, and approved procedures. P i ' ' ' .?

..g .... n (3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED: ][l({[

Meetings with all station supervisory personnel aere held by the Station gj][/,

Manager to emphasize and further delineate supervisory responsibilities 3 (: t with regard to worker compliance. Additionally, written memorandums were hem 3?.

Issued by the Station Manager to ensure full understanding of the jf. ;;

requirement for strict adherence to radiation control procedures. ( lf ~ 3 a :Lh '

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS: (k[i '  ;

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More agressive surveillance and enforcement of radiological control procedures will be implemented by Health Physics personnel to ensure strict compliance. Additional training sessions as outlined in the response to Example 3 are being planned.

(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance has been achieved.

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