IR 05000219/1994005
| ML20029D104 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/15/1994 |
| From: | Bores R, Eckert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20029D093 | List: |
| References | |
| 50-219-94-05, 50-219-94-5, NUDOCS 9405040035 | |
| Download: ML20029D104 (12) | |
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i U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-219/94-05
Docket No.
50-219 License No.
DPR-16 i
Licensee:
GPU Nuclear Corporation i
1 Upper Pond Road
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Parsippany, New Jersey 07054
Facility Name:
Oyster Creek Nuclear Generating Station (OCNGS)
Inspection Period:
February 28,_1994 to March 4,1994
l Inspector:
Iw SlrC 9////7V Lonny Ifkert, Radiation Specialist Date Approved By:
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Dr. Robert Mres. Chief Date
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Facilities Radiation Protection Section
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Areas Inspected
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Internal exposure control and assessment, radiological discrepancy resolution, and i
radiological controls organization staffing, i
Results The internal exposure control and assessment program was in general, established with conservatism and with good bases. Of those radiological discrepancies reviewed, the NRC determined that appropriate corrective actions had been emplaced by the license's staff. Two non<ited violations of regulatory requirements were identified. No safety concerns were identified.
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PDR ADOCK 05000219
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DETAILS 1.0 Personnel Contacted 1.1 Station Personnel J. Barton, Director Oyster Creek Nuclear Generating Station (OCNGS)
W. Collier, Acting Radwaste Supervisor W. Cooper, Radiological Engineer
- B. DeMerchant, OCNGS Licensing Engineer J. Derby, ALARA8 Supervisor A. Judson, Radiological Engineer
- S. Levin, Director, Operations and Enforcement T. Milligan, Radiological Engineer R. Shaw, Radiological Controls Director (RCD)
J. Stump, Radiological Engineer
- P. Thompson, Site Audit Manager
- K. Wolf, Manager, Radiological Controls Operations Other licensee personnel were contacted during the inspection.
1.2 NRC Personnel L. Briggs, Senior Resident Inspector
- S. Pindale, Resident Inspector
- Denotes attendance at the exit meeting.
2.0 Internal Exposure Control and Assessment 2.1 Audits and Appraisals Licensee Audit S-OC-93-12 was reviewed by the inspector. This audit examined portions of j
the licensee's internal exposure controls program. Licensee auditors selected personnel exposure files and verified that whole body counts were conducted as required. The auditors also verified that quarterly random whole body counting was conducted as required. The licensee audit team also reviewed three instances in which individuals received uptakes greater than 5% maximum permissible body burden and verified that bioassays had been conducted and doses of record were revised to reflect conclusions of the Bioassay
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Investigative Reports.
No internal exposure controls program discrepancies were noted by the licensee audit team.
The inspector assessed licensee auditing of their internal exposure control as well-perfonned and appropriate in scope.
As Low As Reasonably Achievable
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2.2
_Chauges to the Internal Exposure Controls Program Since the last radiological controls program inspection, changes were made to the licensee's internal exposure controls program in order to comply with new 10 CFR 20. Administrative control changes are discussed in Section 2.5 of this report. During interviews with both the RCD and Radiological Engineering Manager, the inspector was informed that:
1) The air sampling program had not been changed, so the number of air samples taken is not significantly impacted.
2) The respiratory protection program would not be greatly impacted as the licensee had implemented a risk balancing program several years ago; and 3) There would likely be less whole body counting conducted, but the program would be extensive enough to continue to ensure the effectiveness of the internal exposure controls program.
j Prior to 1/1/94, the licensee's bioassay program required a whole body count (WBC)
following assignment of12 MPC-hours in any one day or 110 MPC-hours in a calendar
week. There was no procedural guidance as to how soon the WBC should be conducted after assigning the MPC-hours in excess of the criteria. When questioned, the Radiological i
Engineering Manager conveyed to the inspector that the WBC would be conducted as soon as practicable. The Radiological Engineering Manager also conveyed that depending on circumstances, an individual may have continued to work in radiologically controlled areas (RCAs) after recognition that a WBC should be conducted, but prior to the conduct of that l
WBC (i.e., RCA access might not necessarily have been denied while waiting for a WBC),
i The inspector noted that there would have been no violations of old 10 CFR 20 as long as individuals were not accumulating more than 520 MPC-hours in a calendar quarter as a result
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of this practice. The inspector determined that the licensee's whole body counting criteria under revised 10 CFR 20 are similar to what was noted in the first sentence of this paragraph, but enhanced investigation occurs at 10 mrem in any day and 50 mrem in a calendar week committed effective dose equivalent (CEDE), respectively. This is discussed in greater detail in Section 2.4.
l In summary, no degradation of the internal exposure control program was noted as a result of changes to the program.
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2.3 Worker Awareness and Involvement Several radiological controls technicians (RCTs), including Group Radiological Controls Supervisor (GRCS) qualified individuals, were questioned by the inspector on their views concerning the quality of the training received on the internal exposure controls program for the revised 10 CFR 20. RCTs expressed general satisfaction with their training regarding the internal exposure controls program. Some RCTs did indicate that the justification for conducting less frequent bioassays was not clear to them. Specialized instruction on risk balancing has been provided to RCTs. RCTs will be instrumental in ensuring worker acceptance of the new 10 CFR 20 changes. The inspector discussed with licensee representatives an apparent need to explain the internal exposure control program and how it provides an acceptable level of safety, focusing on justification for conducting less frequent r
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whole body counts. The licensee stated that this matter would be evaluated and appropriate action would be taken, if necessary.
2.4 Program Controls NRC review of the licensee's internal exposure control program led to two issues which needed clarification.
The inspector discussed with the licensee adding additional guidance regarding the
frequency and number of bioassay samples required by licensee Procedure 6630-ADM-4025.01, " Bioassay Procedure". The Radiological Engineering Manager agreed to evaluate this matter further but stated that the guidance would be general in nature since it would be difficult to proceduralize all possible internal dose assessment considerations.
At the time of the inspection, the licensee was dismantling portions of the Old
Radwaste (ORW) Building. Much of the dismantling work was being done while using respirators since personnel internal exposure was the controlling parameter (due to the presence of alpha-emitting radionuclides). Step 7.2.5 of Procedure 6630-ADM-4025.01, " Bioassay Procedure", Revision 5, read as follows.
"A WBC is required following assignment of110 mrem internal whole body dose (CEDE) in any one day or 150 mrem internal whole body dose (CEDE) in a consecutive 7-day period. If the airborne radioactivity exposure is due to tritium / beta or alpha activity, the sampling method shall be urinalysis rather than WBC...."
At the time of the inspection, one individual had been assigned 16 mrem CEDE from a-bearing radionuclides in one day. The licensee did not feel that it was appropriate to conduct a bioassay in this case as WBC was inappropriate and urinalysis was not cost-justified. Subsequently, Temporary Change (TC) RC 940001 was initiated to modify Procedure 6630-ADM-4025.01, " Bioassay Procedure", and to read as follows.
"A WBC is required following assignment of110 mrem internal whole body dose (CEDE) in any one day or 150 mrem internal whole body dose (CEDE) in a consecutive 7-day period. If the airborne radioactivity exposure is due to tritium, the sampling method shall be urinalysis. If the airborne radioactivity exposure is due to beta / alpha activity, the need for bioassay and type of bioassay shall be decided by Radiological Engineering...."
The inspector questioned the licensee on how the effectiveness of the internal exposure control program was being monitored in regards to the work conducted in ORW. The licensee informed the inspector that a study on alpha-emittirig radionuclides had been conducted which demonstrated that alpha-emitting radionuclides would result in only small total effective dose equivalent (TEDE)
exposures and result in much less than the required monitoring level of > 10% of an annual limit of intake (ALI). That study will be reviewed in a future inspectio.
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- Licensee review of the above noted issues will be the subject of further inspection efforts (IFl 94-05-01).
As part of this inspection, the following policy, memoranda, engineering calculations, and procedures were reviewed.
1000-PLN-4010.01, "GPU Nuclear Corporation Radiation Protection Plan", Revision
6, 1/1/94
Memo 6600-92-017, " Summing Internal and External Exposures", 2/7/92
Memo 6000-93-001, "10 CFR 20 Policies",1/7/93 Memo 6600-93-060, "10 CFR 20 Policies",1/3/94
6630-ADM-4212.01, " Air Sample Collection and Analysis", Revision 4,1/1/94
6630-ADM-4025.01, " Bioassay Procedure", Revision 5,1/2/94
6633-ADM-4246.01, " Operation of the Canberra Whole Body Counting System",
Revision 14, 1/31/94 6632-93-004, " Assessment of OC Gross Beta, Gamma, and Alpha DAC", 8/20/93
These procedures were assessed as providing adequate guidance for implementing internal exposure controls in accordance with 10 CFR 20 requirements.
Engineering Calculation 6632-93-004 was the basis document for the licensee's determination of weighted effective derived air concentrations (DACs) for use in gross #/ and gross a air
sample analyses. Using 10 CFR 61 analyses of spent filter sludge and spent resin, and HP-210 probe detection factors, effective DACs were calculated. The gross S/y DAC was calculated to be 2 E-08 pCi/cc and the gross a DAC was calculated to be 5 E-12 pCi/cc.
The most conservati"e DAC for each isotope was used with the exception of Co-60.
Licensee experience (using data from WBC analyses) has been that Co-60 at OCNGS is in the form of classes Y and W and is split about equally into these classes. This led the licensee to average the class Y Co-60 DAC and the class W Co-60 DAC for use as an OCNGS effective Co-60 DAC. In light of the work conducted in the Old Radwaste Building, the licensee has sent air samples to be isotopically characterized by a vendor laboratory in order to confirm the validity of the calculated gross a DAC. These results will be reviewed in a future inspection.
A general description of licensee administrative controls over the bioassay program follows.
- The whole body count (WBC) is the principal means of bioassay used by the licensee.
A baseline WBC is required prior to entering a radiation work permit (RWP)-
controlled area. Baseline WBCs will be performed each time an individual returns from another licensed facility where the individual entered an RCA.
- A annual (routine) WBC will be conducted following the baseline count.
Exiting WBCs are conducted upon termination of employment or when it is expected
that an individual will enter another licensee's radiologically controlled area.
A WBC is required following assignment (by airborne sampling results) of A 10
mrem CEDE in any one day or 150 mrem CEDE in a 7-day period.
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A WBC is required for individuals who are contaminated on the neck or higher on the
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when nasal smears show unexpected positive results.
A WBC is required following an event which indicates respirator failure, unless air
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sampling shows that any uptake would result in < 10 mrem CEDE in a day or < 50 l
mrem CEDE in a consecutive 7-day period.
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An investigation level (IL) has been established for any routing WBC showing an
intake of radioactive materials > 50 nanoCuries from an unknown cause.
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2.5 Whole Body Countine Ouality Assurance
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Daily source checks are required by procedure every 4-6 hours and after the last WBC.
Monthly quality assurance checks are performed to ensure system performance standards are l
maintained. Yearly blind spike samples are also performed to ensure proper system l
performance.
1 Since the last inspection reviewing WBC, the licensee has implemented enhancements to WBC quality control. The licensee has established a two-standard deviation investigation level and three-standard deviation action level. These values are plotted and reviewed for adverse trends. If the source check fails to fall within three-standard deviations of the expected value, then three more source checks are performed; all of these checks must fall within specification or the instrument is taken out of service.
2.6 Internal Exoosure Controls Program Summary The inspector assessed the internal exposure controls program as good. Licensee auditing of this area was sufficient. No degradation of the internal exposure control program was noted as a result of changes. Program controls were well established considering that they were changed to implement new 10 CFR 20 requirements, but some issues regarding programmatic controls need clarification.
3.0 Radiological Discrepancy Evaluation 3.1 Improper entry into a Locked High Radiation Area (URI 50-219/93-27-02)
Information provided here was previously detailed in NRC Inspection Report 50-219/93-27.
On November 15,1993, the licensee identified that three contractor personnel had entered a
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l posted locked high radiation area (LHRA) without proper monitoring as required by station procedures. A radiological controls technician (RCT) identified the condition and immediately directed the individuals to exit the LHRA. As indicated by the individuals' self reading dosimeters (SRDs), two workers received no radiation exposure and one individual received 2 mrem.
The LHRA discussed above is under the main stack. The entrance is a locked door, located within the radiologically controlled area (RCA). The door was posted with a sign l
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designating the area as a LHRA. The area is locked due to the potential for the area to become greater than 1000 mrem /hr during resin transfer activities. The inspector toured the area and found that the general area dose rates were less than 40 mrem /hr during this time.
The three contractors had read and signed the associated Radiation Work Permit (RWP No.
930429), which required an alarming dosimeter in the LHRA. However, they stated that
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they had not historically worn alarming dosimeters without wearing protective clothing. That is, they incorrectly associated the alarming dosimeter with a contamination area (that was also a HRA) rather than with a HRA. All three contractor workers were experienced radiation workers at Oyster Creek, were knowledgeable regarding the RWP requirements, and liad received the appropriate training in accordance with the radiation worker training program reqmrements.
The contractors were pre-staging scaffolding equipment in preparation for subsequent scaffold erection (inside an adjacent contaminated HRA). The contractors stated their intent i
to obtain and wear the alarming dosimeters prior to entry into the contaminated HRA.
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The licensee conducted a formal critique and issued a Radiological Investigation Report (RIR) to evaluate this event to determine the root causes and to develop corrective actions to prevent recurrence. The licensee determined that the root cause was improper self-checking by the contractor workers.
The inspector toured the area and concluded that the LHRA entrance door was properly posted. The licensee subsequently modified LHRA posting to read " Dose Rate Meter or Alarming Dosimeter Required," in addition to the required posting. The licensee also initiated several other corrective actions, including combining the issuance of both the LHRA key and the alarming dosimeter so that both are issued at the same time. Disciplinary action was taken against the three contractor individuals.
The licensee utilized a human performance enhancement process to investigate this event and found that habit intrusion was the primary causal factor. Other licensee actions are noted above in the previous paragraph. These actions address other causes identified by the inspector. The licensee defines " root cause" as the primary contributing factor of an incident.
The inspector used a hazard barrier target (HBT) analysis to evaluate licensee corrective actions. The inspector assumed the hazard to be unintended entry into a LHRA, thereby exceeding the licensee's annual administrative exposure limit or the federal exposure limit.
The inspector noted that several barriers had been emplaced by the licensee prior to the occurrence of this event including: LHRA door control; alarming dosimeter or RCT or a survey meter; posting; briefing, radiation worker training, procedures, and administrative requirements (i.e., the RWP). The inspector assumed that the target was any radiation worker.
A key could be acquired before meeting other requirements (i.e., key control was maintained separate from alarming dosimeter issuance). Also, briefings might be conducted separate from key and alarming dosimeter issuance. The area was posted as mandated by federal
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regulations. LHRAs are the licensee's most significant RCAs (licensee analysis found no very high radiation areas at OCNGS). Licensee posting of L'HRAs was less descriptive than posting for less radiologically hazardous areas, such as Airborne Radioactivity Areas, which were posted with more information on the requirements to be fulfilled prior to entry. For example, airborne radioactivity areas were posted with information that notes " Respiratory Protection Required."
NRC Conclusions The inspector concluded that the licensee adequately documented this event and had initiated adequate corrective actions. The consequences of the event were minimal, since the dose rates were considerably less than one rem per hour and the time spent in the LHRA was less j
than one minute, As stated previously, the licensee viewed the root cause as the primary contributing factor. While the licensee did not specifically identify other contributing causes of the incident in their investigation report, the licensee did emplace corrective actions for all of the contributing causes identified by the inspector. Based on the above and the licensee's prior performance in the radiological controls area, the violation of failing to wear alarming
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dosimetry as required by Technical Specification 6.13 is not being cited, since the event meets the criteria of 10 CFR 2, Appendix C, VII. B. for enforcement discretion.
3.2 Imoroper Shinment of Contaminated Component (URI 50-219/93-24-02)
Information provided here was previously detailed in NRC Inspection Report 50-219/93-24.
On October 27,1993, the licensee initiated a Deviation Report in accordance with the OCNGS discrepancy resolution system to document that a component was shipped to an offsite calibration facility. That component which was subsequently determined to have been contaminated at a level greater than OCNGS release limits. The component, a motor operated valve torque / thrust cell, was shipped from the station as a " clean" component (i.e.
no radioactive contamination). OCNGS was notified by the receiving facility that the component was contaminated to a level of about 250 cpm as measured with an HP-210
probe. The highest smear count was about 8,000 dpm/cm. The Oyster Creek
contamination limits for release are 100 cpm with an HP-210 probe and 1,000 dpm/cm as described in licensee Procedure 6630-ADM-4200.01, " Radiological Surveys".
The Radiological Engineer who conducted this event investigation conveyed to the inspector that it was his belief that the component was reassembled inside the contaminated area and this fact was not subsequently communicated to the control point radiological controls technicians, who would have performed a survey to determine whether or not the internals of this component were clean.
Licensee corrective actions included disseminating information on this event to appropriate station staff, re-emphasizing expectations on responsibilities regarding the removal of components from RCAs, conduct of a comprehensive survey of the clean tool room, and conduct of surveys on other torque thrust cells. In essence, licensee corrective actions were intended to address a failure to adequately survey the component.
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NRC Conclusions The inspector concluded that the licensee adequately documented this event and had initiated adequate corrective actions regarding the failure to survey the internal portion of the valve cell. The consequences of the event were minimal, since the contamination was limited to internal valve surfaces. Based on the above and the licensee's prior performance in the radiological controls area, the violation of 10 CFR 20.201 is not being cited, since the event meets the criteria of 10 CFR 2, Appendix C, VII. B. for enforcement discretion.
3.3 Awareness Reporting Several licensee awareness reports were reviewed. Licensee awareness reports deal with minor discrepancies and ALARA suggestions. The following paragraph is taken from NRC Inspection Report 50-219/93-18 and this situation is an example of a licensee awareness report which has remained open for several months.
The inspector reviewed the ALARA evaluation generated for work on drywel' fans to
inspect, lubricate, change filters, and replace fan belts. Radiation Work Permit (RWP) 92-1196 was generated to support this work. Also, surveys taken to support this RWP were reviewed by the inspector. A formal ALARA committee review was not required since the planned collective exposure was less than five rem. The work scope was increased by the licensee to resolve deficiencies found during system inspection. There has been a history of vibrational problems associated with these drywell fans. At the time of the inspection, the licensee was evaluating the feasibility of using fan belts made of an alternative material (e.g.,
Kevlar was under evaluation). No discrepancies were noted with existing station procedures.
The Radiological Engineer responsible for keeping track of the status of awareness reports did convey that efforts are made to periodically update the concerned party (ies) on the status of items which remain open due to long-term investigation of the suggestion / discrepancy.
There was no procedurally required frequency at which concerned parties are updated on the status of their concern. Licensee Procedure 9300-ADM-1201.02, " Awareness Reporting",
Revision 3,2/11/88, step 7.8.3 requires that completed awareness reports be forwarded to the individual initiating the awareness report, i,
4.0 Staffing / Organization Since the last radiological controls program inspection, one of the licensee's Radiological l
Engineers became certified by the American Board of Health Physicists. Also, the licensee I
hired two contractor senior radiological controls technicians (RCTs) to fill the two Group Radiological Controls Supervisor (GRCS) positions which had been vacant.
5.0 Open Items (VIO 93-06-01) Closed. High Radiation Area (HRA) not barricaded.
Licensee corrective actions included the following.
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- Placement of a barrier at the HRA that was not barricaded.
- Conduct of a search for other improperly set up HRAs.
Promulgation of guidance to all OCNGS and Parsippany staff on the importance of
restoring HRA boundaries.
These actions were verified by the inspector and were determined to be appropriate.
(VIO 93-07-01) Closed. Inadequate Radiation Work Permit (RWP).
Licensee corrective actions included the following.
All Hydronuclear jobs are now assigned a planner to help avoid any possibility of
work scope miscommunication to Radiological Engineering or the ALARA Supervisor. There is a minor maintenance system used at OCNGS (Plant Engineering Procedure 125). Job orders (entry into GMS2) are not generated for this level of work. The Radiological Engineering Manager assured the inspector that programmatic controls were now in place to ensure that all radiologically challenging work was properly captured by the GMS2 system.
Hydrolasing activities are now captured by the General Maintenance System (GMS2).
- A new procedure called, " Radiological Work Process" (6630-ADM-4110.04), was
developed and replaced licensee Procedures 9300-ADM-4110.04, " Radiation Work Permit"; 9300-ADM-4110.15, "On Line Dose Assessment and Manual Operation of a Control Point"; and 9300-ADM-4300.01, "Use of Protective Clothing". The RWP request form was incorporated into this procedure. Previously, completion of this form was not procedurally required.
The RWP procedure was modified to change the definition of continuous monitoring
to uninterrupted or constant monitoring. This change in definition was subsequently captured by licensee procedure, " Radiological Work Process".
The ALARA review procedure (9300-ADM-4110.02) was revised and is now called
" Conduct of Radiological Engineering". The following change related to this violation was made.
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"7.1.2.5 Any work inside highly contaminated systerns per Rad. Eng.
7.1.2.5.1 A task which requires opening a highly contaminated system with potential to cause unacceptable contamination in a cleaner area meets this criteria.
7.1.2.5.2 A task which involves disturbing uncontained sludges or other solids which exceed or are expected to exceed 1 R/hr contact should be considered for applicability of this
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The Radiological Work Process Procedure has incorporated an example of a pre-job
briefing checklist.
These actions were verified by the inspector and were determined to be appropriat _ _ _ _ _ _ _ _ _ _
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(VIO 93-07-02) Closed. Failure to survey.
Licensee corrective actions for this violation are already described under VIO 93-07-01.
(VIO 93-07-03) Closed. Inadequate ALARA review procedure, j
Licensee corrective actions for this violation are largely described under VIO 93-07-01.
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Specifically, see licensee Procedure 9300-ADM-4110.02 step 7.1.2.5 noted above. Also, ALARA reviews are initiated upon an estimate of 2 person-rem of cumulative exposure (a change from 5 rem).
These actions were verified by the inspector and were determined to be appropriate.
(VIO 93-07-04) Closed. Exceeded respiratory protection factor.
Before the licensee's implementation of new 10 CFR 20, the licensee had modified its ALARA review procedure to prohibit risk balancing analyses when selecting respiratory protection devices. The Conduct of Radiological Engineering procedure has been modified to permit use of a respirator with a lower protection factor than the expected peak radionuclide concentration when an analysis shows potential TEDE savings by taking this action. This action requires formal documented Radiological Engineering review per licensee Procedure 6630-ADM-4010.02. The inspector assessed this change as being in accordance with new Part 20 requirements. Also, no violations of any licensee commitments made in regards to NRC Inspection 50-219/93-07 findings were noted by the inspector as a result of this change.
In order to address the concerns over a lack of proper HEPA usage, Radiological Engineering distributed additional guidance on proper HEPA usage to those work groups who use them.
These actions were verified by the inspector and were determined to be appropriate.
(VIO 93-07-05) Closed. Failure to conduct airborne sampling.
Licensee Procedure 6630-ADM-4110.04, " Radiological Work Process", was modified to require that if intake _> 0.4 DAC-hours is expected, each individual will be provided with a
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breathing zone air sampler. The inspector determined that this action satisfactorily addressed the violation.
(URI 93-027-02) Closed. Improper entry into area posted as LHRA.
This has been dispositioned as a non-cited violation. See Section 3.1.3 of this report.
(URI 93-024-02) Closed. Shipment of contaminated component as clean.
This has been dispositioned as a non-cited violation. See Section 3.2.2 of this report.
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6.0 Exit Meeting
The inspector met with licensee representatives at the end of the inspection, on March 4,
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1994. The inspector reviewed the purpose and scope of the inspection and discussed the
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findings. Licensee management acknowledged the inspection findings and stated that actions would be taken to evaluate the findings and, if appropriate, resolve them.
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