IR 05000259/1988023

Insp Repts 50-259/88-23,50-260/88-23 & 50-296/88-23 on 880801-05.No Violations or Deviations Noted.Major Areas Inspected:Organization & Mgt Controls in Radiation Protection & Radwaste & Control of Radioactive Matls

ML20154L728
Person / Time
Site:	Browns Ferry
Issue date:	09/02/1988
From:	Collins T, Gloerson W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20154L718	List: IR 05000259/1988023 ML20154L714
References
50-259-88-23, 50-260-88-23, 50-296-88-23, NUDOCS 8809260272
Download: ML20154L728 (15)

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NUCLEAR REGULATORY COMMISSION REGION 11 f 101 MARIETTA ST., o% ,,,,,j ATLANTA GEORGIA 30323 k 4 l^[h Report Nos.: 50-259/88-23, 50-260/88-23, and 50-296/88-23 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Hos.: 50-259, 50-260 and 50-296 License Nos.: DPR-33, DPR-52, and DPR-68 Facility Name: Browns Ferry 1, 2, and 3 Inspection Conducted August 1-5, 1988 Inspectors: / 9 L/df WL\

T. R. C61 Tins M')h"'"

Date Signed Approved by: YL<. ,  ? / 2. //d C. M. Hosby? Secti4n Chief Date Signed Division of Radiati n Safety and Safeguards SUMMARY Scope: This routine, unannounced irspection was conducted in the areas of Organization and Management Controls in Radiation Protection and Radwaste; Radiation Safety Training and Qualifications; External Occupational Exposure Control; Internal Exposure Control and Assessment; Control of Radioactive Materials; Maintaining Occupational Exposures ALARA; Solid Wastes; Transportation; NRC Infonnation Notices; Operational Readiness Performance Evaluation; and Previously Identified Inspection Finding Results: The licensee's radiation protection program continues to be effective in protecting the health and safety of occupational workers. The licensee's ALARA measures appeared to be generally effective for reducing personnel exposure It was also apparent that there was high level corporate and station involvement in assuring an above-average quality assurance program in the area of whole-body countin !

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8809260272 SG0914 f PDR ADOCK 05000259 i Q PDC j

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REPORT DETAILS

, Persons Contacted Licensee Employees P. Byrd, Radeon Shift Supervisor

• H. Crowson, Radeon Field Operations Supervisor ,

• 0. Hixon, Radwaste Coordinator R. Howard, ALARA Supervisor E. Mastich, Radeon Supervisor

• R. McKeon Operations Superintendent R. Nite Health Physicist

• J. Savage, Compliance Supervisor

• A. Sorrell, Site Radcontrol Superintendent F. Tsakeres Radiological Health Supervisor '

• J. Walker, Plant Manager

• J. Wallace, Compliance Engineer

• R. Weedon, Supervisor, Water and Waste Group Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personne HRC Resident inspectors

• W. Bearden

• C Brooks

• D. Carpenter

• E. Christnot

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• Attended exit interview Audits (83724, 83725, 83726, 83728, 84722, 86721)

The inspector reviewed selected audits and appraisals of the Radiological '

Control Organization performed since January 198 The inspector ,

evaluated the quality of the audits with regards to their effectiveness in '

identifying programmatic weaknesses and assessing the quality of the program. The following audits were reviewed:

• Nuclear Quality Audit and Evaluation Branch Audit Report No. SSA88808, June 13-30, 1988

Condenser Tube Pullout - Radiological Material Storage (QBF-S-88-0058) January 28 - February 1, 1988

Radiological Control (QBF-S-88-0099) February 4-8, 1988

Contamination Control (QBF-S-88-0142) February 25-29, 1988

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Radiological Control Instrumentation (QBFS-88-0211) March 2-16,1988

• ALARA(QBF-S-88-0271) April 7-11,1988

• Radwaste Shipments (QBF-S-88-0522) May 23,1988

• Radiological Survey Program (QBF-S-88-0728) June 16-17, 1988 The inspector noted that the audits were generally complete and thoroug There were no major deficiencies identified in the audits. The inspector noted that a corporate appraisal of the Radiological Control Program (SSA-88808) identified four minor findings which were corrected by the licensee before the conclusion of the audi No violations or deviations were identifie . Organization and Management Controls (83722)

Technical Specification (TS) 6.1.B describes the licensee's plant organization. The inspector reviewed the organization and staffing of the licensee's radiological control (Radeon) grou The Radeon group was authorized a total of 229 technicians, engineers and supervisory personnel. 221 positions were currently filled. This total

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included a full complement of 94 ANSI-N18.1, dated March 8, 1971 F qualified health physics technicians. However, the inspector was informed

by a licensee management represertative that by March 1989, the Radeon j group would be reouced to a total of 122 personnel of which 82 of these

personnel would be health physics technicians. This reduction in force

' (RIF) was apparently related to only operating a one unit facility, rather

) than all three units. The inspector discussed this issue with the Radeon l Superintendent and the Plant Manager to determine if adequate health

physics coverage would be available when the RIF was completed as of March l 198 At present, the licensee had a ratio of health physics technicians to field operations personnel of 12.7 to The inspector detennined,

af ter discussion and review of the licensee's proposed staffing levels of

, all groups onsite as of March 1989, that a 20.0 to 1 ratio of health physics technicians to field operations personnel would be available.

l Licensee management informed the inspector that this issue would be i evaluated and indicated that a reduction in the Rad Con Group that would I adversly affect the health and safety of plant personnel would not occur, i The inspector informed licensee management that this issue would be

! reviewed again during a subsequent inspection and will be tracked by the l NRC as an Inspector Followup Item (IFI) (50-259/88-23-01).

No violations or deviations were identifie . Training and Qualification (83723)

TS 6.1.E requires that the qualification of the Browns Ferry Nuclear Plant Management and Operating staff meet the minimum acceptable levels as i

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described in ANSI-N18.1, dated March 8, 1971. The inspector reviewed with licensee representatives the qualifications and experience of selected personnel in the Radeon Group and determined that the qualifications were consistent with technical specification requirement The inspector discussed with licensee representatives proposals to fill senior positions within the licensee's Radeon Group. At the time of the inspection, specific personnel assignments to fill certain Radeon Group positions had not been mad No violations or deviations were identifie . External Occupational Exposure Control and Personnel Dosimetry (83724)

a4 Surveys 10 CFR 20.201(b) requires that each licensee shall 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 be presen During several tours of the facility, the inspector reviewed Radiological Work Permits (RWPs) posted at week areas. Current radiological survey informatier, was indicated on the RWP for Radiological survey information was also indicated on information boards at the controlled area access. During the tours of the facility, the inspector performed independent radiation surveys and noted no inconsistencies with licensee survey result During this inspection, there were no high-exposure jobs being performed. Most of the work activities were occurring ir the Unit 2 drywell. The inspector reviewed the following RWPs:

88-6101 Replace / Inspect Electrical Penctrations 88-6768 Paint Secondary Containment Blowout Panels (Steam Tunnel)

88-6118 Miscellaneous Conduit inspection and Rework The inspector verified that selected individuals who signed the above RWPs received the general employee training and respirator training and qualification (where applicable).

The inspector reviewed the licensee's computerized "watch list" which was generated twice daily and contained pertinent exposure and training data for all persone granted access to the sit These data included quarterly exposure limits, quarter-to-date exposure totals, maximum permissible concentration (MPC) hour totals, and complete training statu _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ . _ _ - _ _ _ - - _ _ _ __ _ _ _ _ _ _

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i b. High Radiation Area Control

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TS 6.3.0 requires that any individual or group of individuals permitted to enter a high radiation area shall be provided with or accompanied by one of more of the following: (1) a radiation i monitoring device which continuously indicates the radiation dose rate in the area; (2)a radiation monitoring device which *

continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received; or (3) an individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring devic From discussions with licensee representatives, the inspector determined that there were ten high radiation control areas in the plant (that is, areas with dose rates greater than 1000 mil 11 Roentgen per hour (mR/hr)). The following areas were identified: ,

(1) Units i, 2, and 3 Incore Probe Room; (2) Units 1, 2, and 3 "

i Cleanup Backwash Tank Room; (3) Cleanup Sludge Pump Room; (4) Evaporator Building (inside); (5) Evaporator Building outside door); and (6) Waste Phase Separators Valve Galler During tours of the facility, the inspector was made aware of the high radiation area control problem in the area of the Unit 1B Fuel Pool Heat Exchanger located at the 621 foot elevation. The licensee identified the high radiation area during a weekly routine radiation survey on June 30, 1988. The licensee was prepared for potential high radiation area problems associated with the heat exchanger since a similar problem occurred with the Unit 2 Fuel Pool Heat Exchangers

] during previous fuel reconstitutinn wor Part of the preparation i included placing three area radiation monitors with alarms around the i heat exchangers. The June 30, 1988 survey results indicated that the

! contact dose rate on the IB Fuel Pool Heat Exchanger was 4200 mR/hr i while the dose rate at 18 inches was 1500 mR/hr. The hi rates were 6000 mR/hr (contact) and 2500 mR/hr (18 inches)ghest doseon July i 198 On July 11, 1988, temporary shielding was placed around the heat exchanger. The shieloing reduced the radiation levels around

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the heat exchanger to belcw 1000 mR/hr. After the weekly radiation l survey performed on July 14, 1988, the radiation levels once again .

increased to greater than 1000 mR/hr. During the periods when the IB  !

Fuel Pool Heat Exchanger was greater than 1000 mR/hr, the high  :

radiation door watch procedure RCI-17 was implemented. The inspector reviewed the Locked High Radiation Area Door Access Control Log. The

"door v:atch" was in effect during the periods June 30 - July 11,1988 and July 14 - August 1, 1988. Additionally, the area surrounding the heat exchangers was conspicuously posted as a high radiation are !

Entrance to this area was controlled by Transit RWP 88-111 .

Specific RWPs were issued when work was performed on the heat  !

exchangers. The frequency of the radiation surveillance activities ,

was once per eight-hour shif t at the boundary and once per week l surveillance of the entire area. The inspector reviewed the weekly radiation surveillance records from June 30 - July 28,198 The

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i inspector and licensee representatives discussed long-term dose rate reduction plans for the fuel pool heat exchangers. The plan called

! for: (1) source term _ reduction by performing a high volume flush of

the heat exchanger, (2) permanent shield wall installation, and (3) locked fence around the heat exchanger. The inspector identified the long-tenn dose rate reduction plans as an IFl (50-259/88-23-02).

! Personal Dosimetry The inspector reviewed the _ license's methodology for thermoluminescent dosimeter (TLD) processing. All TLDs were processed onsite in the license's dosimetry laborator The licensee utilized a Panasonic Type 802 dosimeter which contains two elements of calcium sulfate and two elements of lithium borate. During the first half of 1988, there were 12 TLD/ Pocket Chamber (PC) Discrepancy Reports. The licensee used the following criteria to generate a Discrepancy Report:

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Type A: TLD greater than or equal to PC times and TLD greater than 250 mrem

) Typo B: PC greater than or equal to TLD times and PC greater than 250 mrem Of the 12 variances identified, one was a "Type A". As of this inspection, two variances have been resolved, including the Type A

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variance. Resolution of the remaining Type B discrepancies was still being pursued by the license Licentee representatives stated that the person-rem exposure total j through July 31, 1988, was approximately 644 person-rem which was

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approximately 46 percent of the goal for 1988. The maximum exposed e individual to 6 ate received 2438 mR. Additicnally, the inspector

) compared exposures due to routine RWPs with exposures dae to Special or Specific RWP Less than one percent of the year-to-date I exposures was attributable to routine RWD5 This low percentage indicated that the licensee had a more .ste program for i

tracking dose.

Records, Reports, and Notifications The inspector reviewed selected Radiation Incident Reports (RIRs)

generated since April 1988. A 1988 year-to-date total of 77 RIRs had

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been writte The licensee discussed three levels of RIRs:

l (1) Level 2 - letter of reprimand to parsonnel file; (2) Level 3 -

minimum three-day suspension; and (3) Level 4 - termination of l employe The RIRs reviewed were minor in terms of safety

significance and most of them were the Level 2 categor No violations or deviations were identified.

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6 Internal Exposure Control (83725)

The licensee is required by 10 CFR 20.103, 20.201(b), 20.401, and 20.403 to control intakes of radioactive materials, assess such intakes, and keep records of and make reports of such intakes. Chapter 12 of the Final Safety Analysis Report (FSAR) also includes comitments regarding internal exposure control and assessmen During tours of the facility, the inspector examined the licensee's respirator repair are The facility was used to dispatch and receive respirators from an offsite contractor laundry facility. The inspector observed respirators being inspected and tested in the facility. When the respirators are received from the INS,100 percent of the respirators are surveyed directly for contamination and approximately 10 percent are smeared for both alpha and beta contamination. After testing and makt n necessary repairs, the masks were heat sealed in plastic bags and taken to the issue areas. The inspector visited the respirator issue area and observed the use of the licensee's computerized equipment issue syste The equipment issue program was designed such that an individual was not issued a respirator if all the training, medical examination, and fit-testing prerequisites were not satisfied. The inspector observed that the licensee had purchased and had in service, four American Bristol SAC-25 air compressors to provide breathing air to supplied air respirators. The air compressors also had the capability of filling the compressed air bottles of the self-contained breathing apparatus (SCBA).

The inspector noted that 21 SCBAs were available in the Control Room for emergency us The inspector also observed the licensee's whole-body counting facilit The licensee had two counting systems in operation. The first system was a unique table top geometry designed by Nuclear Data which incorporated one intrinsic germanium detector with a nominal efficiency of 15 percen The second system was a Bionuclear Measurements chair geometry system which incorporated a two inch by two inch sodium iodide (2x2 Nal) detector for tne lung and gastrointestinal (Gi) regions and a 1x1 Nal detector for the thyroi Although the Nuclear Data System was mainly used for screening individuals to detennine if there was an uptake, the system was calibrated to quantify the amount of radioactive material in the lungs and lower GI tract. The chair geometry system was mainly used for quantification of radioactive material in the thyroid, however, it was also calibrated for both the lung and lower GI track geometries. The licensee participated in the Measurements Quality Assurance (MQA) Program organized by the Corporate Office. Once per quarter MQA comparison tests were performed using a Humanoids (trademark) phantom. The inspector reviewed the second quarter 1988 MQA results in which the phantom was loaded with I-131 in the thyroid and the following nuclides in the lungs:

Ce-144 Co-60, Cs-137, and Cs-13 The licensee's Bionuclear Measurements chair geometry system failed both the bias and precision criteria for Cs-137 and Cs-134. This was due to the inability of the Nal detector to resolve the interfering peaks of Cs-137 and Cs-13 It should be noted

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that the licensee had the capability to resolve and determine the amount of Cs-137 and Cs-134 by using the intrinsic germanium detector syste The inspector also reviewed tha daily quality assurance tests that were performed on both whole-body counting systems. The inspector also discussed changes to the whole-body counting program with the license The licensee indicated that two Canberra Stand-up Fastscans have been purchased as well as a Nuclear Data chair geometry system. The Nuclear Data System will incorporate two intrinsic germanium detectors for the lung and GI regions and a 1x1 Nal detector for the thyroid. The licensee expected the systems to be operational by November 1988. The licensee's Quality Assurance Program was more than adequate and demonstrated strong management involvement in assuring qualit The inspector also reviewed the licensee's Non-Rountine Whole Body Counting Second Quarter 1988 Report, dated August 3, 1988. During the second quarter 1988, a total of 2124 persons were counted and 114 were documented as non-routine whole-body counts (the total number of whole-body counts in 1987 was 8509). A non-routine count was defined as a whole body count other than an initial, annual, or termination count. Of the 114 non-routine counts, 17 were performed at the Radiolog'ical Control Department's discretion for medical treatments and 20 were perfonned upon randomly selected employees to test the respiratory protection progra Of the 77 remaining counts, 73 indicated a body burden of less than one percent maximum permissible organ burden (MPOB) and four indicated body burdens in excess of one percent. In each of these four casess a known body burden was detected prior to entering the licensee's facility, in no case was there a body burden greater than five percent MP0 The inspector also reviewed the licensee's urinalysis program which was described in the following procedures:

DSil-17. Invitro Bicassay Sampling, Revision 3, June 29, 1988

RCI-8, Bioassay Program, Revision 2, March 30, 1988 The licensee's Western Area Radiological Laboratory (WARL) was used for analyzing invitro bicassay samples. The WARL was equipped to analyre for Sr-89 Sr-90, H-3 and transuranics in bioassay samples. During the second quarter 1988, 20 urinalyses were performed. It should be noted that 20 urine samples corresponded to the 20 randomly selected individuals for verifying the effectiveness of the respirator protection program mentioned abov This verification program was recently implemented and was described in RCI- No violations or deviations were identifie . Control of Radioactive Paterial (83726)

10 CFR 20,201(b) states that each licensee shall make or cause to be made such surveys as (1) may be necessary for a licensee to comply with the

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regulations in this part, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be presen During the inspection, the inspector discussed with the licensee the number of personal contamination reports (PCRs) generated sir.ce January 198 As of June 30, 1988, the licensee generated 275 PCR There were 80 skin contaminations,172 clothing contaminations, and 23 involving both skin and clothing contaminations. The licensee's goal for the year was to have less tnan 270 personnel contamination. After an investigation into the source of the problem was initiated, it was detemined that some of the contamination zone clothing received from the contractor laundry facility had loose particles in the range of 100-4500 counts per minute. The contaminated C-Zone clothing was found after the licensee started a 100 percent contamination survey of both the inside and outside of each article of clothin The licensee later detemined that the contract laundry facility had placed a bag of C-Zone clothing reading approximately 100 mR/hr with a load of low contamination clothin Additionally, the laundry facility was not following a generally considered good practice of reducing the maximum allowable weight load per wash load ratio for more highly contaminated C-Zone clothing. Since the laundry problem has been identified, the rate of personnel contamination reports has been significantly reduce No violations or devietions were identifie . Maintaining Occupational Exposures ALARA (83728)

The inspector discussed with licensee representatives the program to maintain exposures as low as reasonably achievable (ALARA). The ALARA comittee consisted of the plant manager, site radcon manager, modifications manager, maintenance supervisor, and the ALARA superviso The ALARA committee met monthly and was chaired by the plant uanager. The ALARA comittee tracks and trends person-rem totals, PCRs, RWP entries, ALARA preplans, and ALARA suggestion ALARA reports are generated weekl Since January 1988, the licensee had 177 ALARA suggestions submitte The licensee's incentive program for ALARA suggestions appeared to be successful. The inspector also made note of an ALARA information besrd which was placed at the Turbine Building entrance to the controlled area. The board contained color-coded radiological information on plant diagrams and other ALARA and exposure control information. The licensee also had a series of informational pamphlets that TVA had prepared to keep workers informed on subjects such as radon, noble gas, whole-body counting, prenatal exposure, solar radiation, uses of radiation sources, radiation health effects, and invitro bicassa The inspector discussed ALARA preplanning involving radiological work with licensee representatives, including a comparison between the estimated and

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actual dose The following ALARA preplans were reviewed:  ;

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ALARA Preplan Job Estimate Actual Completion Report Number Description (man-rem) (man-rem Status- 88-012 Condenser tube 8 .9 70 replacement and  ;

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support work (88-021 Fuel 3 .8 80 [

Reconstitution (revised t from5.9) l 88-023 CRD Removal and 7 .2 98  :

Replacement l Additionally, the licensee indicated that other dose-intensive jobs that i were being planned included the cleaning of the Unit 1B Fuel Pool Heat  :

Exchanger and the rerouting of a drain line on the Unit 2 Reactor Water i Cleanup Heat Exchange l t

No violations or deviations were identifie . Solid Wastes (84722) l The inspector discussed with licensee representatives their waste stream I sampling program for developing 10 CFR Part 61 scaling factors. Licensee [-

representatives stated that all plant waste streams would be sampled prior to Unit 2 restart and the Unit 2 waste streams would be resampled after r startup and the system had stabilize j The inspector toured the resin dewatering process area. The current ,

process requires three 8-hour dewaterings separated by 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of ,

settling. The licensee was evaluating a new rapid dewatering system, r thereby decreasing the complete dewatering process to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This i process was planned to begin operation prior to Unit 2 startu l r

The inspector discussed with licensee representatives their current and f proposed radwaste organization and staffing levels. Under the proposed  ;

organization plan, the manager of this group will report directly to the  !

Operations Superintendent and will be responsible for water and wastewater !

processing, packaging and shipping of radioactive waste, and (

decontamination activities of plant facilities *,nd equipmen The r inspector determined by review that the proposed staffing levels and  !

organization entities for the processing and handling of radioactive waste !

was adequate. At present, the licensee has a dedicated decontamination j

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group of 48 decon personnel; however, as of March 1989, the decen staff will be reduced to 30 decon personnel. The inspector concluded that this  !

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reduction of personnel should not adversely affect safe plant operations for a single unit operating power reacto The inspector was informed that at the end of 1987, the total contaminated square feet of the facility was 6.4 percent of the total area which excluded drywells and fuel pools. However, at the time of the inspection 11.5 percent was being controlled as contaminated are Licensee representatives informed the inspector that this increase was primarily due to the reorganization of the decon group being reassigned from the chemistry group to the water and wastewater processing group. Efforts were underway to continue to reduce this percentag No violations or deviations were identifie . Transportation (86721)

The inspector discussed with licensee representatives radioactive material shipments performed in 1938, and reviewed the shipment log. The inspector reviewed the completed files for selected racioactive material shipments made during the first two quarters of 1938. The shipments reviewed were of dry active waste (OAW) and dewatered resin shipped to Chem Nuclear Systems, Inc. (CNSI) for buria The inspector determined that the shipments had been prepared consistent with NRC and Department of Transportation (DOT) requirement On August 1,1983, the licensee was preparing to transfer a shipment of radioactive material to CNSI for buria This shipment contained 170 cubic feet of dewatered condensate (powdex) resin in a high integrity container (HIC), cask identification number USA /9139/A, and contained 1.4 x 10' millicuries. After completion of loading the H1C liner in the shipping cask, the radiation levels were measured to be 11 mrem /hr at 2 meters and 80 mrem /hr on contact. Licensee management representatives were contacted because the the 11 mrem /hr measurement at 2 meters i.xceeded the legal limit of 10 mrem /hr at 2 meters as required by 49 CFR 173.44 Licensee management representative performed seven additional radiation survey measurements of the shipment in question using various types of survey instruments and determined that the highest radiation level measured was 9.0 mrem /hr which was below the legal limit of 10 mrem /hr. The inspector discussed this event with licensee representatives and reviewed the survey records performed by the licersee and determined that even though an initial reading of 11 mrem /hr was measured, follouwp surveys revealed that the radiation levels were within regulatory limits, The licensee's radiation surveys were performed at a distance of 2 meters from contact of the shipping cask, rather tha- from the vertical plane of the outer edges of the vehicle, which was in a conservative direction. The inspector concluded af ter review that the radiation levels of the radioactive waste shipment were within regulatory limit No violations or deviations were identifie _ - _ _ _ - _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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11. Operational Readiness Performance Evaluation (83722, 83723, 83724, 83725, 83726, 83727 and 83728)

The licensee had developed and completed an Operational Readiness Performance Evalaution Program (ORPEP) which was initially scheduled to be j completed by August 15, 1988, to assess the readiness of the Radeon Group to support Unit 2 startup and operational activitie ! Radcon operational readiness performance objectives included thirty-eight separate objectives in six general categories as described below:

• Organization and Administration Organizational understanding, management positions filled, technician

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authority, incident report system, performance indicators established, radcon training and qualification, procedure adequacy, internal communications, supervisory involvement, external interfaces and computerized information control * Radiation Exposure Controls

. Minimizing external exposure, minimizing beta exposure to skin and eyes, exposure reduction program planning, exposure reduction i (job-specific), exposure and other ALARA goals, self-analysis and

, industry wide comparison, diagnosis and response to unusual

situations and accidents.

j * Airborne Radioactivity Control i

Engineered airborne radioactivity controls - use of, plant controls to limit internal exposure, respiratory protection program, i minimizing respiratory protection areas, bicassasy program,

restrictions on eating, drinking, smoking and chewing.

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Instrumentation and Desimetry

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Survey equipment calioration and use, use of dosimetry devices, i selection and placement of dosimetry devices, extremity dosimetry

! devices, exposure records availability, and dosimetry QA progra i t

Contamination Control l Minimizing contamination of areas and equipment, minimizing

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contamination of personnel.

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Radcon Personnel Performance Standards

) Protection against ionizing radiation, Health Physics Information j System, hot particle program implementation, source term control l program, transuranic assessment and control.

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The inspector discussed this program with licensee representatives and was :

informed that this program, once completed, would be reviewed by upper !

level management. After final review and approval by plant management of l

< the ORPEP, corporate management would perfonn an assessment of their own t J to ascertain the operational readiness of the Radeon Group prior to Unit 2

! startup and operation. The inspector informed licensee management i

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representatives that this program would be reviewed again during a ;

subsequent inspectio No violations or deviations were identifie . NRCInformationNotices(ins)(92717) i

! The inspector determined that the following information notices had been

received by the licensee, reviewed for applicability, distributed to

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appropriate personnel and that action, as appropriate, was taken or '

j scheduled: IN 88-32: Prompt Reporting to NRC of Significant incidents involving Radioactive Material j IN 88-34: Nuclear Material Control and Accountability of Non-Fuel

! Special Nuclear Material at Power Reactors j 13. Action on Previous Inspection Findings (92701, 92702)

I l (Closed) Violation (50-259, 50-260, and 50-296/86-38-01.a,b, and d): l

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Failure to follow Written Material Control and Accounting Procedure T1-14, Special Nuclear Material Control. Failure to imediately Report the Loss of Five Dunking Chambers (fission counters) Containing Special Nuclear Material, and failure to Complete and Distribute a DOE /NRC Form 741 for the Transfer of Five Dunking Chambers (fission counters)

containing 10 grams) of Special Nuclear Material. The inspector reviewed the licensee's responses of February 11 and 19, and June 12, 1987, and verified that the the corrective action specified in the responses had been taken. This item is considered close (Closed) IFI (50-259, 50-260, 50-296/88-14-01): Clarification of Survey Requirements for Releasing Material, from a Contaminated Area. The inspector reviewed procedure TSIL-2, Contamination Surveys, Revistor,22 August 4, 1988, and determined that the procedure provided sufficient guidance on the types of surveys required to release material from a controlled area. Additionally, the procedure provided guidance on when the surveys were to be performed and the limits for release of the material to ensure that surveys were being performed in a consistent manner. This item is considered close (Closed) IFI (50-259, 50-260, and 50-296/88-14-02): 1) The licensee's skin dose assessment procedure from "Hot Particles" did not contain all dose factors from the hRC's computer code; 2) the skin dose assessment procedure did not contain any provisions to assess the effect of

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self-absorption on the calculated d0se; and 3) the skin dose assessment (

procedure did not contain dose assassments for contaminants that are not  :

readily removable that have been embedded in the skin. The inspector reviewed and verified that the licensee's procedure DSIL-30. Skin Do;e Assessment and Calculations, was revised on May 12, 1988, which incorporated the appropriate actions and changes necessary to evaluate l adequately skin doses from the hot particles. This item is considered close ;

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(Closed) IFl (50-259, 50-260, and 50-296/88-14-03): The licensee's dosimetry computer sof tware program did not reflect the correlation of l TLDs and pocket ion-chambers if there was greater than or equal to 50%  !

differences, and if the TLD or pocket ion-chambers was greater than or [

equal to 250 millire The inspector reviewed and verified that the licensee's procedure OSIL-7, Use of Direct Reading Dosimeters, dated June 21, 1988, was revised to incorporate investigation both in the ,

computer software and in their operating procedure to perform  ;

investigations of TL0s and pocket ion-chambers discrepancie This item is considered close (Closed) IFl (50-259, 50-260, 50-296/88-14-04): Revisiori of Procedure TSil-28, Hot Particle Control Program. The inspector reviewed TSil-28, ,

Hot Particle Control Program, Revision 2. August 4, 1988, and noted that l the following elements had been incorporated into the procedure:  !

Hot particle control areas were identified by an insert on the warning sig *

The procedure specified actions taken if contamination was detected *

on personnel in hot particle control area ;

The procedure specified that every person in the hot particle control f area be surveye *

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The procedure provided guidance on handling material, such as waste, by promptly containing and disposing the waste through the normal I plant processing to prevent the spread of hot particle [

f This item is considered close l 14. Exit Interview i The inspection scope and results were sumarized on August 5,1988, with l those persons indicated in Paragraph 1. The inspector described the areas  !

examined and discussed in detail the inspection results described in this i repor The licensee did not identify as proprietary any of the material l provided to or reviewed by the inspector during this inspection. Two inspector follewup items were identified in the aree; of organization and management controls (Paragraph 3) and high radiation area control (Paragraph 5.b). The inspector discussed the licensee's proposed Health 7 Physics staffing levels after the proposed reduction-in-force and whether

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or not the licensee could maintain an adequate health physics staff to i support field operations. The plant manager acknowledged the inspectors' l comments and stated that adequate Radeon staff would be available after  ;

the RIF is complete item Number Description and Reference

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50-259/88-23-01 IFI - Adequacy of Radeon staffing ,

following reduction-in-forc /88-23-02 IFl - Long-term dose rata reduction plans for the f ael pool j heat exchangers,

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