IR 05000206/1987025
| ML13323A658 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/05/1987 |
| From: | Cicotte G, Russell J, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323A656 | List: |
| References | |
| 50-206-87-25, 50-361-87-25, 50-362-87-27, NUDOCS 8711190107 | |
| Download: ML13323A658 (11) | |
Text
U: -S. NUCLEAR-REGULATORY COMMISSION
REGION V
Report Nos. 50-206/87-25, 50-361/87-25 and 50-362/87-27 Docket Nos. 50-206, 50-351 and'5O-362 License Nos. DPR-13, NPF-10 and NPF-15 Licensee:
Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Nuclear Generating Station -
Units 1, 2 and 3
"Inspection at: San Onofre clear Generating Station Inspector:
__________________________
.f(1
. Rus diation Specialist Date.Signed Inspector:
G. R. Cicotte, Radiation Specialist Date Signed Approved.,by: :01!6
<7 G. P. Yu
, Chief Date Signed Faciliti Radiological Protection Section Summary:
Inspection on September 14-18 and October 5-8, 1987, (Report Nos. 50-206/87-25, 50-361/87-25 and 50-362/87-27)
Areas Inspected:
Routine, unannounced inspection of licensee action on items of non-compliance, unresolved items and open items; allegation follow-up; Units 1 and 3 - external occupational exposure control; Units 1 and 3 internal exposure control and assessment; Unit 2 - occupational exposure during extended outages; and including tours of the licensee's facilitie Inspection procedures 30703, 83724, 83725, 83729, 92701, and 92702 were addresse Results:
In the five areas inspected, one apparent violation was identified in one area, involving failure to post a radiation area, 10 CFR 20.203,
-Caution signs labels, signals and controls (paragraph 7).
I 711190107 871106 PDR ADOCK 050o0206 Q
DETAILS Persons Contacted Licensee Personnel
+W. Moody, Deputy Station Manager
+J. Reilly, Technical Manager
- + Knapp, Health Physics (HP) Manager
+R. Kreiger, Operations Manager
+D. Shull, Maintenance Manager
- +M. Whartoni Assistant Technical Manager
- + Couser, Compliance Engineer
+ Denotes individuals present at the exit on September 18, 198 *
Denotes individuals present-at the exit on October 8, 198 In addition to the individuals identified, the inspector met and held discussions with other members of the licensee's staf.
Licensee Action on Previous Enforcement Items Item 50-362/86-37-01, violation. (Closed) The licensee failed to report an event involving by-product, source, or special nuclear material that may have.caused-or threatened to cause.exposure to the hand of an individual to.greater than"375'rem. The inspector verified that action, indicated in the licensee's timely reply to assure the occurrence of prompt notification of overexposure events, had been taken and appeared to be effective to prevent recurrenc Item 50-362/86-37-02, violation. (Closed) The licensee failed to prevent the release of licensed material to off-site areas. The inspector verified that action, indicated in the licensee's timely reply, to prevent the release of licensed material, specifically irradiated fuel particles (IFPs), had been taken and appeared to be sufficient to prevent recurrenc Item 50-362/86-37-04, violation. (Closed) The licensee failed to make such surveys as were necessary to reasonably evaluate the extent of radiation hazard present. The inspector verified that the action, indicated in the licensee's timely reply, to perform such surveys as may be necessary to determine the extent of hazard present, had been taken and appeared to be effective to prevent recurrence. A comprehensive IFP control program has been implemented at SONGS and was apparently being effectively executed for the Unit 2 cycle IV outag Item 50-362/86-37-05, violation. (Closed) The licensee failed to make such surveys as were necessary to comply with the extremity dose limit expressed in Part 20. The inspector verified that the action, indicated in the licensee's timely reply, to perform such surveys as may be necessary to comply with the extremity dose limit in Part 20, had been taken and appeared to be effective to prevent recurrenc Item 50-362/86-37-06, violation. (Closed)The licensee failed to limit the-occupational radiation exposure to the hand of an individual in a restricted area to 18.75 rem per calendaraquarter. The inspector verified that efforts were still underway to limit the exposure of personnel to IFPs and to control their spread. The inspector reviewed the licensee's equivalent of Form NRC-5 for the individual in question and verified that the dose of record contained the 511.99 rem from the event in questio.
Licensee Action on Unresolved and Open Items Item 50-362/87-12-01 (Closed). An unresolved item was identified for the licensee staff to perform calculations to demonstrate.the ability of their whole body counting systems to detect Ce-144 and Ru-106 activity at the 40 MPC-hr control level specified in 10 CFR 20.103. A memorandum from a member of HP Engineering to the HP Engineering Supervisor dated September 28, 1987, was provided to the inspector. The memorandum documents the ability of the SONGS counters to detect Ru-106 below the control level and thei.r previous inability to detect Ce-144 at the 98 MPC-hr leve SONGS has submitted to their vendor 141 past counts for reanalysis to test for the possible presence of these isotopes. These counts represent those individuals most likely to have'had an uptake due to contamination events. The licensee has also implemented a software upgrade for their counters and now have the ability to routinely detect these isotopes. The inspector considers that the reconfiguration of the whole body counting software and the reevaluation of the counts of those individuals most likely-to-have been exposed to IFPs provides sufficient assurance that significant intakes of the isotopes of concern probably did not occu Item 50-362/87-12-02 (Closed). An open item was identified for the licensee to evaluate whether any unique hazard might exist from deposition of an IFP in the lung of a worker which could produce a localized and highly non-uniform dose. The licensee provided to the inspector a copy of a contractor report, Inhalation of Irradiated Fuel Fragments:
Considerations of Detection and Dosimetry, which provided an evaluation of the risks associated with the intake of IFPs in the light of current knowledge as reflected in current national and international commission reports. The report concluded that 1) the the effects of interest as a result of the deposition of beta emitting particles in the lung are stochastic rather than non-stochastic in nature and 2)
non-stochastic processes are only expected to occur after a deposition of 595 pCi/kg of body weight. The inspector contacted the author of the report to determine the basis of the two conclusions noted above. The author stated that the basis for.conclusion 1) was an extrapolation made by the author from experimental data on the effects of deposition of alpha-emitting particles in the lung, i.e., that since the lesions produced by alpha-emitting particles in the lung are relatively innocuous, the author believed that the lesions produced by beta-emitting particle, although they may be larger in correspondence with the larger range of the high-energy betas, they would be similarly innocuous. The author also stated that the basis for conclusion 2) was an experiment, reviewed in the International Commission on Radiological Protection Publication 31, Biological Effects of Inhaled Radionuclides, involving
the uniform deposition of beta-emitting particles in the-1ungs of:
experimental animals. The experiment documents the production of non-neoplastic pulmonary lesions including fibrosis, radiation pneumonitis and death due to the uniform deposition. The inspector noted and the author concurred that the available experimental data deals only with the stochastic effects of single beta emitting particle depositions and the stochastic and non-stochastic effects of uniform particle depositions. No specific information on the non-stochastic effects and hazards of single beta-emitting particle deposition was available to support the conclusions drawn from the extrapolation of alpha-emitting particle deposition data and the uniform deposition of beta-emitting particle The inspector's critique of this report is tempered by the absence of published data which would tend to invalidate the contractor's-conclusion.
Allegation Followup Allegation Number RV-87-A-056 (Closed). The Region V duty officer was made aware by telephone call from an anonymous HP technician on September 13, 1987, of two alleged deficiencies in the HP program at SONGS Unit These were 1) that HP personnel were not accurately recording stay times in containment because of a computer problem and 2) that workers names were being recorded on one Radiation Exposure Permit (REP) while work was
,actually being.performed-under.,another. The alleger also stated that airborne radioactivity concentrations ranged from 4 to 7 MPC in containment with some workers working up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and that the HP foreman was aware of the improper sign-in of individuals on REP As a regional Radiation Specialist was on the site performing a routine inspection at the time of the allegation, the Region notified the inspector of the allegation which he investigated as part of this inspection. The inspector made several tours of the Unit 2 containment and held discussions with numerous HP technicians and workers therei The inspector determined that airborne iodine concentrations; due to the loss of primary coolant from the valve 2HV-9378, high coolant activity levels and significant fuel cladding failures; in some areas of containment were from 25% to 50% MPC between September 14 and 18 but had gone down to less than 2% between October 5 and 8. Noble gas and particulate activities in containment were generally not significant at these time SONGS employs a computerized radiation control tracking system, the SONGS Record Control system (SRC), which accepts manual input of whole body exposure data (from pocket ionization chamber readings) and airborne radioactivity exposure data. The system is intended to eventually accept entry and exit time inputs together with location codes and to calculate and track airborne exposure. The system would not at the time of inspection accept this form of input so that Dosimetry was tracking airborne exposure using an Individual MPC-hr Tracking Card (IMTC) system, in accordance with HP procedure S0123-VII-4.2.5, MPC Tracking. The dosimetry group maintained, at the containment entry point, an IMTC card catalogue. Upon entry the Dosimetry Technician recorded the individual's
-4 name, the date and time of entry, the REP number of the job, and the intended job location. Upon exit the exit time was recorded together with any variation in job location code.- The entry records were then collected at the end of the day and the containment occupancy time entered into the SRC together with containment airborne activity levels for the various location codes from air sample data. The Dosimetry Supervisor informed the inspector on September 15 that the data inputs had been running behind because of the large number of containment-entries but that airborne exposures were generally being maintained less than their 30 MPC-hr control leve The inspector reviewed the top 100 7-day MPC-hr exposure summary for September 17 and noted that the four highest individuals had between 40 and 50 MPC-h The inspector reviewed over 100 of the completed IMTC cards and noted that most contained adequate information but some did not contain exit times. The inspector was informed by Dosimetry personnel that when a worker fails to retrieve his IMTC card a conservative exit time is entered, e.g., the end of the shift, until the true exit time can be determined, and that this is used to estimate the exposure. The inspector found no evidence that workers were being over exposed to airborne contamination and, although there appeared to be some difficulties handling the large number of IMTC cards, there was no evidence to indicate airborne exposure data was not being adequately tracked. The licensee appeared to be complying with the requirements of 10 CFR 20.103, Exposure of individuals to concentrations of radioactive-materials in-air in restricted areas. The inspector found that allegation 1) could not be substantiate From a review of REPs and discussions with HP personnel, the inspector determined that HP Technicians generally sign-in on one of two REPs,
- 81000 -
Routine Health Physics Functions, or U-2 Ctmt and #81001 Health Physics Functions Zone 3 Areas. Other REPs are sometimes used for specific jobs but the inspector noted that most technicians were signed in on their IMTC cards on one of the two noted REPs. The REPs were general in nature and would allow entry to all areas of the containmen The numerous HP technicians interviewed by the inspector were familiar with the requirements of the REP on which they were signed in. The inspector also noted that SONGS procedure S0123-VII-9.9, Radiation Exposure Permit Program, requires that the workers read and understand the REP they are going to use and that they follow its requirements. The inspector found that allegation 2) could not be substantiate No violations or deviations were identifie.
Planning Pre-outage planning for the Unit 2 cycle IV outage was reviewed as documented in Inspection Report 50-361/87-18. Daily work planning is accomplished primarily with a daily Refueling Outage Meeting and a Daily MO Status/Critical Path meeting. The inspector attended a number of these meetings during the inspection and noted that the various site work groups were represented and provided input. The inspector noted that the scope of work for the outage had changed significantly from the pre outage situation. - The failure of valve 2HV-9873 (see Inspection Report
50-361/87-24) necessitated the complete off-load of the core and the draining of the vessel to below the nozzles with the subsequent delays to repair the valve. More than the expected number of indications were
- found during eddy-current testing of the steam generators necessitating additional repairs and testing. Fuel reconstitution was performed due to the number and severity of defects found in the fuel pins and four pins were broken during this effort. The number of contract HP technicians planned as necessary to support work for the outage was.67 but the licensee's contractor, Nuclear Support Services, could supply only 4 The HP technicians were working a 6-day 12-hour schedule during the time of the inspection. At the time of the October visit, the licensee had obtained some additional HP technician support from three other contractors; Power Systems Energy Services, Bartlett Nuclear, and Allied Nuclear; but had also lost a number of technicians due to the long hours and various personnel problem The inspector reviewed the number of hours HP technicians were working for compliance with paragraph (19) b., Shift Manning (I.A.1.3. SSER No. 1. SSER No. 5), of their license and found that no individual had been required to work in excess of the time limits specified therei Technicians were regularly being paid for 60 to 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> per week but, when allowance was made for lunch and ishift turnover time, none were found to be in excess of.the limits. The long hours did appear to the inspector to have had a significant effect upon technician efficiency and this was reflected in the interviews conducted during the inspectio The Operational HP Supervisor also noted to the inspector that he had observed a reduction in'technician efficienc The inspector reviewed the majority of contract technician resumes an noted all were qualified as journeyman technicians in accordance with ANSI/ANS-3.1-1981, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants, except one individua The technician in question was under the directions of a fully qualified technician foreman that reviewed all his work. The inspector also reviewed select contract technician qualification manuals for adequacy and completeness and checked the computerized Training Records Management System (TRMS) for notations of completion of Nuclear Training Division courses. No inadequacies were found in any of these record No violations or deviations were identifie. Audits The inspector discussed the participation of the Quality Assurance (QA)
organization in the Unit 2 outage with the cognizant QA supervisors and was informed that QA had several projects centered around the outage. By a memo dated September 3, 1987, from the site QA Manager, swingshift and Saturday QA surveillance coverage was initiated for the outage to provide generalized QA field observation of work activities. By memo dated September 11, 1987, a QA surveillance schedule for the outage was submitted for coverage of the major planned jobs and these were still in process at the time of the inspection. The inspector was also informed
on October 7 that a team audit of the REP program was planned to begin on October No violations or deviations were identifie.
External Occupational Exposure Control The inspector interviewed the Unit 2/3.HP Supervisor, HP foremen, various
_HP technicians, the Dosimetry Supervisor and various Dosimetry personne The inspector reviewed records including select REPs, area and job specific surveys, airborne surveys, daily Radiation Exposure Monitoring Summaries (REMS reports), SONGS equivalent of Forms NRC-4 and 5, Exposure Limit Extensions (SONGS Form 312), dosimetry evaluations, and the top 100 exposure total report. No exposures in excess of 10 CFR 20.101 exposure limits were noted and exposure limit extensions and Form NRC-4 equivalents appeared to have been properly complete The inspector observed work in the Unit 2 containment, the Unit 2 Fuel Handling.Building and the Units 2/3 Radwaste/Auxiliary Building and noted personnel in the various areas were wearing personnel dosimetry. When questioned, workers were generally aware of the requirements of the REP's under which they they were working, their personal exposure totals and limits and the need to perform work such that radiation exposures are as low as reasonably achievable (ALARA). The inspector also observed various jobs in-progress both inside and outside containment including refueling,-fuel ultrasonic testing, fuel reconstitution, steam generator eddy-current testing and repair, pressurizer modifications, reactor coolant pump motor work, waste packing and laundry sorting and processing. The inspector also reviewed paper work for and held discussions with personnel that performed a mode 1 entry into the Unit 3 containment on September 16 to perform surveys and subsequently to check calibration of level transmitters on Safety Injection Tanks 8, 9 and 1 Radiation and high radiations areas in the various areas toured were posted in accordance with 10 CFR 20.203, Caution signs, labels, signals and controls, and licensee HP procedure S0123-VII-7.4, Posting and Access Control, with the exception of an area of room 335B-C on the 37 foot elevation of the Radwaste Building which was toured by the inspector on September 14, 1987. Approximately one third of the room, an area of about 15' by 25'., had measurable dose rates of greater than 4 mrem/hr and a maximum dose rate of 30 mrem/hr, as measured with an Eberline RO-2 ionization chamber, serial number 837, calibrated on August 21, 1987, and due for recalibration on November 21, 1987. The primary source appeared to be an adjacent high radiation, radioactive material storage area which had an entrance at the back of room 335B-C. A number of bagged items also contributed to the general area dose rate. There was no sign which indicated that the room or the referenced portion of the room was a radiation area and the room was unattende CFR 20.203 (b), Radiation Areas, reads:
"Each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
CAUTION RADIATION AREA" Additionally, 10 CFR 20.202 defines a radiation area as:
"...any area accessible to personnel, in which there exists radiation, originating in whole or in part within licensed material, at such levels that a major portion of the body could receive in any one hour a dose in excess of 5 millirem, or in any 5 consecutive days a dose in excess of 100 millirem."
S0123-VII-7.4, paragraph 6.1.2.1, reads:
"Each accessible area having radiation levels of"2.5 mrem/hr (penetrating, i.e., gamma, x-ray or neutron) or greater, shall be identified as a Radiation Area and shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
CAUTION RADIATION AREA" This observation was brought to the attention of licensee management at the entrance interview on September 14, 1987. The inspector noted that the area had been properly posted during a tour the next day. In-subsequent discussions with the HP Manager, the inspector was informed that the area was not posted due to an oversight and that i should have been posted as a radiation area in accordance with the licensee procedure and 10 CFR 20.203. Failure to post a radiation area is a violation of 10 CFR 20.203 (50-361/87-25-01).
Within this area, one violation was identifie.
Internal Exposure Control and Assessment The inspector held discussions with the Dosimetry Supervisor, various Dosimetry personnel and technicians and other licensee personne The inspector was informed that the leak from valve 2HV-9378 presented significant problems to SONGS. Not only was the outage critical path affected but it also resulted in higher than normal airborne iodine levels (see Inspection Report 50-361/87-24). The leak occurred when primary coolant activity levels were high due to a chemical shock initiated by the addition of hydrogen.peroxide. Approximately 18,000 gallons of primary coolant were released to the containment sump before being cleaned-up by plant letdown. This water was used for reactor cavity fill without clean-up and produced significant airborne activity levels (see paragraph 4).
During the period from plant shutdown until the final day of onsite inspection all containment entries were tracked with IMTCs. Delays of up to a day were initially encountered in entering this data into the SR The inspector reviewed the top 100 MPC-hr log (see paragraph 4), airborne surveys, the placement of air sampling equipment, select internal dose assessments (forms 214), select IMTCs, REPs, whole body counts, release
permits and internal deposition and dose calculations. These appeared to have been completed in compliance with program requirements expressed in HP procedures S0123-VII-4.2, Internal Dose Program, and S0123-VII-4.2.5, MPC Tracking. Program implementation appeared to be in compliance with the requirements of 10 CFR 20.103, Exposure of individuals to concentrations of radioactive materials in air in restricted areas. No overexposures to airborne radioactive material were noted although four exposures of greater than 40 MPC-hr in one week and ten whole body counts indicating depositions of greater than 5% of a maximum permissible body burden of 1-131 were note.The inspector noted that there have been continuing challenges to the Containment Purge Isolation System (CPIS) and the Fuel Handling Building Isolation System (FHIS).
FHIS actuations have been reported to the NRC via telephone to the duty officer and by follow-up License Event Report (LER) due to purging of radioactive gases to the FHB from the pressurizer and due to accumulation of radioiodine on the sampling filter of the FHB ventilation monitor. Sample filters were being changed shiftly to avoid actuation due to activity build-up. CPIS isolations due to
- spurious monitor indications at Unit 2 from 2RT-7856 have drastically increased. Twenty such actuations were reported via.LER between September 5 and 21 and three were noted by the inspector to have occurred during one morning of the inspection on October 7. The inspector noted that the containment was no longer being evacuated when an isolation occurs and that grab air samples were not always being taken to verify sthat.high airborneradinactivity.does not exis The inspector discussed these spurious actuations with the Assistant Technical Manager and was informed that deliberate action is ongoing to correct the root cause of the problem. Currently, the licensee is evaluating increasing the time delay in the circuitry to 0.5 sec as the noise spikes are of 0.2 - sec duratio No violations or deviations were identifie.9. Control of Radioactive Material The inspector interviewed the HP supervisor, the RMC supervisor, the chairman of the IFP task force, the Nuclear Fuel Services Group supervisor, select other HP, Dosimetry and RMC technicians and personnel and various plant workers. The inspector also reviewed select Contamination/Injury reports (SONGS Form 26), the Personnel Contamination/Injury Report Log (SONGS Form 307), surveys, REPs and External Dosimetry Investigation There were,more than 250 Contamination/Injury reports written in September 1987, of these, 190 were skin contaminations and 66 were clothing. Ten particle contaminations, with activities greater than 0.01 pCi, were noted to have occurred as of October 7, of these, the largest particle found on a persons skin was 0.5 pC No exposure limit appeared to have been exceeded because of these contaminations. More than 250 particles in excess of 0.001 pCi had been found as of October 1, these included IFPs, Co-60 particles, Cerium particles, Ruthenium particles and crud particle During several containment tours, the inspector noted a continuing effort to decontaminate the 17' elevation from the 2HV-9378 event. By the last day of the inspection, most areas of the 17' elevation outside the bioshield had been decontaminated to Zone I status and only a few Zone III areas remained.- Anti-contamination clothing was required for entry to all areas of -the Unit 2 containment but general surface contamination levels were minimal, less than 1000 dpm/100 cm2. -Some areas of the FHB required only street clothe The inspectors observed numerous jobs in progress including steam generator inspection and repair, pressurizer modifications, refueling, fuel alignment plate modification and fuel reconstitution. Contamination control practices exercised during these jobs appeared to be appropriate and in accordance with site procedures and, specifically, S0123-VII-7.12, Fuel Fragment Exposure and Contamination Contro The inspectors observed the removal of a broken fuel pin from bundle E-022 and noted that commitments made to NRC in the letter from M. 0. Medford dated June 18, 1987, were being fulfilled. Specifically, withdrawal of tools from the fuel-pool were minimized, a vacuum system was installed and operating to remove particles from the area at the top of the fuel bundle, a spraydown.-system was used when tools were withdrawn from the pool, the fuel pool cleanup system was in continuous operation, and Zone III enclosures were setup to contain removed tools but most were kept wiped-down and were Zone II area.The-inspectors were informed that, after-examination of the entire core, 74 defective pins had been found in 48 different bundles. Where possible, the bundles with defective pins were replaced in the core with new fuel bundles. However, the E bundles had to be reconstituted to-remove defective pins before return and 4 pins were broken during the reconstitution effort. During the pin break events, contamination control in the FHB was maintained such that all spreads of contamination were controlled and cleaned-up prior to work proceeding. It was also noted that dedicated technicians, specifically trained for the reconstitution effort, were assigned to the job and a full time HP engineer provided support. These appeared to contribute to the comprehensive controls exercised as well as did the expressed commitment of the Nuclear Fuels Services Group Supervisor to "do the job right."
The inspector interviewed the chairman of the IFP Task Force to ascertain current activities of the group and to evaluate its impact on the Unit 2 outage. The chairman stated that his goal to make the program more aggressive was meeting with apparent success in that the number of particle contaminations had been significantly reduced from the number experienced during the Unit 3 outage and was well below the Unit 2 outage
..
,,goal of 80. The use of more sturdy coveralls had been instituted in the Zone III areas and this appeared to be helping to reduce the number of contaminations from torn protective clothing. The use of sticky foot pads and more frequent surveys in select areas also seemed to be contributing to enhanced contro No violations or deviations were identifie.
ALARA The inspector interviewed select members of the ALARA engineering grou and the ALARA engineering supervisor to determine their involvement in the outage. The inspector also reviewed select ALARA Pre-Job Exposure Estimates (SONGS Form 57s), ALARA Pre-Job Checklists (SONGS Form 58s),
ALARA Job Review Records (SONGS Form 59s) and Temporary Shielding Authorizations (SONGS Form 260s). Current exposures for the Unit 2 outage were reviewed and.the majority appeared to be well under their assigned goal as of the September 27, fourth weekly report. The outage exposure goal had been revised to 260 person-rem, an increase of 40 person-rem due to additional steam generator and shutdown cooling valve work. The aggressive exposure-goal set by the operational HP supervisor for his personnel appeared to be in jeopardy due to the undermanning situation (see paragraph 5).
The inspector also reviewed the final Unit 1 mid-cycle maintenance outage exposure report and noted that 89.8 person-rem had been expended as compared to their initial aggressive goal of 80 person-rem and a revised goal of 105 person-rem. The exposure goal had been revised when the outage was extended from 45 days to 51 days and due to an increase in the scope of work on let-down valve The licensee appeared to be effectively implementing their ALARA program for the Unit 2 outage and the Unit 1 effort appears to have been a succes The inspector made several tours of the Unit 2 containment, the Radwaste Building, the Safety Equipment Buildings, the Fuel Handling Buildings, and various radioactive material storage and processing areas during the inspection. Housekeeping in these areas appeared good with the exception of the Unit 2 containment during the last week of the inspectio Conditions appeared to be deteriorating in this area but the inspectors did note that licensee management was aware of the.problem and action had been initiated to rectify the proble No violations or deviations were identifie. Exit Interview The inspector met with the licensee representatives, denoted in paragraph 1, at the conclusion of the inspection on October 8, 1987. The scope and findings of the inspection were summarized.